American Canyon City Council
April 15, 2025

423
Notice of Preparation
City of American Canyon General Plan Update
• Open Space and Recreation Element. This element will address the wide variety of parks, trails, and open spaces serving the diverse recreation needs of American Canyon residents, particularly youth, and emphasize the unique features of the City's natural environment-from the Newell Open Space to the east to the wetlands and trails to the west.
• Conservation Element. This element will consider the effects of existing and planned development on natural resources located on public lands, including military installations, consistent with Government Code Section 65302(d). This Element will address 5tate law requirements, including air quality, greenhouse gas emissions, and climate change adaptation. • Safety Element. This element will cover seismic activity, other geologic hazards,fire hazards,hazardous materials, flooding, and other potential hazards,consistent with Government Code Section 65302(g). It will also address resiliency and risks from natural hazards in American Canyon, pursuant to Senate Bill (SB) 379. This element update will require a vulnerability analysis to comply with State law. • Noise Element. This element will require, consistent with Government Code Section 65302(f), the inclusion of new existing noise contours as well as projected noise contours based on future traffic volumes projected to arise from improvements planned for in the Circulation Element. • Housing Element. This element will be an update for the 2023-2031RHNA cycle to adequately plan to meet the housing needs of everyone in the community, consistent with Government Code Section 65S83.

Due to State-Mandated deadlines, the Housing Element update is anticipated to be completed earlier than the rest of the comprehensive technical General Plan update. • Implementation. This chapter will be a comprehensive implementation strategy with discrete,tangible actions that the City will undertake to carry out all the Plan's goals, policies, and objectives. It will also highlight goals, policies, and programs related to administration of the General Plan. The chapter will detail timing, potential funding sources, and the responsible parties for each implementation measure.

Project Alternatives:The EIR will evaluate a reasonable range of proposed project alternatives that, consistent with CEQA,meet most of the proposed project objectives and reduce or avoid potential environmental effects, including a required No Project Alternative.

Potential Environmental Effect Areas: The EIR will describe the reasonably foreseeable and potentially significant adverse effects of the proposed project (both direct and indirect). The EIR also will evaluate the cumulative impacts of the proposed project when considered in conjunction with other related past, present, and reasonably foreseeable future projects. The City preliminarily anticipates that the proposed project could result in potentially significant environmental impacts in the following topic areas, which will be further evaluated in the EIR.

424
Notice of Preparation
City of American Canyon General Plan Update
Aesthetics Population and Housing
Public Services and Recreation
Transportation
Tribal Cultural Resources
Utilities and Service Systems
Wildfire
Cumulative Effects
Growth Inducing Effects
When the Draft EIR is completed,it will be available for review at the City's offices located at 4381Broadway Street,Suite 201, American Canyon, California 94503 and online at:
https://www.citvofamericancanvon.org/government/communitv-development/planning-zoning/general-planupdate. The City will issue a Notice of Availability of a Draft EIR at that time to inform the public and interested agencies, groups, and individuals of how to access the Draft EIR and provide comments.

Agriculture and Forestry Resources
Air Quality
Biological Resources
Cultural Resources
Greenhouse Gas Emissions
Land Use and Planning
Noise
If you have questions regarding this NOP or the scoping meeting, please contact Brent Cooper at (707) 647-4335 or via email at [email protected]
Brent Cooper, Community Development Director

425
Notice of Preparation
City of American Canyon General Plan Update
Figure 1 Regional Location
Basemap provided by Microsoft Bing, Esri and their licensors © 2022.

Additional data provided by the City of American Canyon, 2022.

I
City of American Canyon
Boundary
]General Plan Area
Y / } 2030 Urban Limit
FldoiacJo
National
Forest
N
A Roseville
Sacramento
Project Location Santa Rosa
@
Elk Grove Vacaville
^
Fairfield
VaTleio
Stockton
Antioch
S3
^
an Livermorem
Francisco Modesto
Fremont
San Jose

426
Notice of Preparation
City of American Canyon General Plan Update
Figure 2 Project Location
Additional data provided by the City of American Canyon, 2022.

Notice of Preparation
City of American Canyon General Plan Update
Figure 3 Area of Proposed Land Use Element Amendments
428
Notice of Preparation
City of American Canyon General Plan Update
Figure 4 Proposed Urban Limit Line
Basemap provided by Microsoft Bing, Bsri and their '
licensors © 2022.

Additional dota provided by the City of American Canyon, 2021; Hess/Laird Property digitizedfrom the Proposed Urban Limit LineAddition,2022

429
Notice of Preparation
City of American Canyon General Plan Update
Figure 5 Proposed Circulation Element Amendments

430
431
432
433
434
435
436
437
438
439
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 4

OFFICE OF TRANSIT AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
August 4, 2022 SCH #: 2022070038
GTS #: 04-NAP-2022-00282
GTS ID: 26948
Co/Rt/Pm: NAP/29/VAR
Brent Cooper, Community Development Director
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
Re: City of American Canyon General Plan Update – Notice of Preparation (NOP) of a Draft Environmental Impact Report (DEIR)
Dear Brent Cooper:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the City of American Canyon General Plan Update 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 following comments are based on our review of the July 2022 NOP.

Project Understanding
The proposed project consists of an update to the City’s General Plan which will serve as a long-term framework for future growth and development. State Route (SR)-29 runs through the City of American Canyon.

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).
440
Brent Cooper, Community Development Director
August 4, 2022

“Provide a safe and reliable transportation network that serves all people and respects the environment” Caltrans looks forward to reviewing the VMT analysis in the DEIR, which should include the following:
● VMT analysis pursuant to the City’s guidelines. Projects that result in automobile VMT per capita above the threshold of significance for existing (i.e. baseline) city-wide or regional values for similar land use types may indicate a significant impact. If necessary, mitigation for increasing VMT should be identified. Mitigation should support the use of transit and active transportation modes. Potential mitigation measures that include the requirements of other agencies such as Caltrans are fully enforceable through permit conditions, agreements, or other legally-binding instruments under the control of the City.
● A schematic illustration of walking, biking and auto conditions at the project site and study area roadways. Potential traffic safety issues to the State Transportation Network (STN) may be assessed by Caltrans via the Interim Safety Guidance (link). ● The project’s primary and secondary effects on pedestrians, bicycles, travelers with disabilities and transit performance should be evaluated, including countermeasures and trade-offs resulting from mitigating VMT increases. Access to pedestrians, bicycle, and transit facilities must be maintained.

Lead Agency
As the Lead Agency, the Cit of American Canyon is responsible for all project mitigation, including any needed improvements to the STN. The project’s fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures.

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, or for future notifications and requests for review of new projects, please email [email protected].

Sincerely,

MARK LEONG
District Branch Chief
Local Development Review
c: State Clearinghouse
441
STATE OF CALIFORNIA Gavin Newsom, Governor

NATIVE AMERICAN HERITAGE COMMISSION

July 8, 2022
Brent Cooper
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
Re: 2022070038, City of American Canyon General Plan Update Project, Napa County Dear Mr. Cooper:

The Native American Heritage Commission (NAHC) has received the Notice of Preparation (NOP), Draft Environmental Impact Report (DEIR) or Early Consultation for the project referenced above. The California Environmental Quality Act (CEQA) (Pub. Resources Code §21000 et seq.), specifically Public Resources Code §21084.1, states that a project that may cause a substantial adverse change in the significance of a historical resource, is a project that may have a significant effect on the environment. (Pub. Resources Code § 21084.1; Cal. Code Regs., tit.14, §15064.5 (b) (CEQA Guidelines §15064.5 (b)). If there is substantial evidence, in light of the whole record before a lead agency, that a project may have a significant effect on the environment, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)(1) (CEQA Guidelines §15064 (a)(1)).

In order to determine whether a project will cause a substantial adverse change in the significance of a historical resource, a lead agency will need to determine whether there are historical resources within the area of potential effect (APE).

CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of 2014) (AB 52) amended CEQA to create a separate category of cultural resources, “tribal cultural resources” (Pub. Resources Code §21074) and provides that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment. (Pub. Resources Code §21084.2). Public agencies shall, when feasible, avoid damaging effects to any tribal cultural resource. (Pub. Resources Code §21084.3 (a)). AB 52 applies to any project for which a notice of preparation, a notice of negative declaration, or a mitigated negative declaration is filed on or after July 1, 2015. If your project involves the adoption of or amendment to a general plan or a specific plan, or the designation or proposed designation of open space, on or after March 1, 2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).

Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal consultation requirements of Section 106 of the National Historic Preservation Act of 1966 (154 U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.

The NAHC recommends consultation with California Native American tribes that are traditionally and culturally affiliated with the geographic area of your proposed project as early as possible in order to avoid inadvertent discoveries of Native American human remains and best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as well as the NAHC’s recommendations for conducting cultural resources assessments.

Consult your legal counsel about compliance with AB 52 and SB 18 as well as compliance with any other applicable laws.

AB 52

CHAIRPERSON
Laura Miranda
Luiseño

VICE CHAIRPERSON
Reginald Pagaling
Chumash

PARLIAMENTARIAN
Russell Attebery
Karuk

SECRETARY
Sara Dutschke
Miwok

COMMISSIONER
William Mungary
Paiute/White Mountain
Apache

COMMISSIONER
Isaac Bojorquez
Ohlone-Costanoan

COMMISSIONER
Buffy McQuillen
Yokayo Pomo, Yuki,
Nomlaki

COMMISSIONER
Wayne Nelson
Luiseño

COMMISSIONER
Stanley Rodriguez
Kumeyaay

EXECUTIVE SECRETARY
Raymond C.

Hitchcock
Miwok/Nisenan

NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 95691
(916) 373-3710
[email protected]
NAHC.ca.gov
442

AB 52 has added to CEQA the additional requirements listed below, along with many other requirements:

1. Fourteen Day Period to Provide Notice of Completion of an Application/Decision to Undertake a Project:

Within fourteen (14) days of determining that an application for a project is complete or of a decision by a public agency to undertake a project, a lead agency shall provide formal notification to a designated contact of, or tribal representative of, traditionally and culturally affiliated California Native American tribes that have requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.

Resources Code §21080.3.1 (d)).
d. A “California Native American tribe” is defined as a Native American tribe located in California that is on the contact list maintained by the NAHC for the purposes of Chapter 905 of Statutes of 2004 (SB 18). (Pub. Resources Code §21073).

2. Begin Consultation Within 30 Days of Receiving a Tribe’s Request for Consultation and Before Releasing a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report: A lead agency shall begin the consultation process within 30 days of receiving a request for consultation from a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project. (Pub. Resources Code §21080.3.1, subds. (d) and (e)) and prior to the release of a negative declaration, mitigated negative declaration or Environmental Impact Report. (Pub. Resources Code §21080.3.1(b)). a. For purposes of AB 52, “consultation shall have the same meaning as provided in Gov. Code §65352.4 (SB 18). (Pub. Resources Code §21080.3.1 (b)).

3. Mandatory Topics of Consultation If Requested by a Tribe: The following topics of consultation, if a tribe requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
c. Significant effects. (Pub. Resources Code §21080.3.2 (a)).

4. Discretionary Topics of Consultation: The following topics are discretionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project’s impacts on tribal cultural resources. d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).

5. Confidentiality of Information Submitted by a Tribe During the Environmental Review Process: With some exceptions, any information, including but not limited to, the location, description, and use of tribal cultural resources submitted by a California Native American tribe during the environmental review process shall not be included in the environmental document or otherwise disclosed by the lead agency or any other public agency to the public, consistent with Government Code §6254 (r) and §6254.10. Any information submitted by a California Native American tribe during the consultation or environmental review process shall be published in a confidential appendix to the environmental document unless the tribe that provided the information consents, in writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3 (c)(1)).

6. Discussion of Impacts to Tribal Cultural Resources in the Environmental Document: If a project may have a significant impact on a tribal cultural resource, the lead agency’s environmental document shall discuss both of the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource. b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed to pursuant to Public Resources Code §21082.3, subdivision (a), avoid or substantially lessen the impact on the identified tribal cultural resource. (Pub. Resources Code §21082.3 (b)). 443

7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on a tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. (Pub. Resources Code §21080.3.2 (b)).

8. Recommending Mitigation Measures Agreed Upon in Consultation in the Environmental Document: Any mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code §21080.3.2 shall be recommended for inclusion in the environmental document and in an adopted mitigation monitoring and reporting program, if determined to avoid or lessen the impact pursuant to Public Resources Code §21082.3, subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §21082.3 (a)).

9. Required Consideration of Feasible Mitigation: If mitigation measures recommended by the staff of the lead agency as a result of the consultation process are not included in the environmental document or if there are no agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if substantial evidence demonstrates that a project will cause a significant effect to a tribal cultural resource, the lead agency shall consider feasible mitigation pursuant to Public Resources Code §21084.3 (b). (Pub. Resources Code §21082.3 (e)).

10. Examples of Mitigation Measures That, If Feasible, May Be Considered to Avoid or Minimize Significant Adverse Impacts to Tribal Cultural Resources:
a. Avoidance and preservation of the resources in place, including, but not limited to:
i. Planning and construction to avoid the resources and protect the cultural and natural context.
ii. Planning greenspace, parks, or other open space, to incorporate the resources with culturally appropriate protection and management criteria.
b. Treating the resource with culturally appropriate dignity, taking into account the tribal cultural values and meaning of the resource, including, but not limited to, the following:
i. Protecting the cultural character and integrity of the resource. ii. Protecting the traditional use of the resource.
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easements or other interests in real property, with culturally appropriate management criteria for the purposes of preserving or utilizing the resources or places. d. Protecting the resource. (Pub. Resource Code §21084.3 (b)). e. Please note that a federally recognized California Native American tribe or a non-federally recognized California Native American tribe that is on the contact list maintained by the NAHC to protect a California prehistoric, archaeological, cultural, spiritual, or ceremonial place may acquire and hold conservation easements if the conservation easement is voluntarily conveyed. (Civ. Code §815.3 (c)). f. Please note that it is the policy of the state that Native American remains and associated grave artifacts shall be repatriated. (Pub. Resources Code §5097.991).

11. Prerequisites for Certifying an Environmental Impact Report or Adopting a Mitigated Negative Declaration or Negative Declaration with a Significant Impact on an Identified Tribal Cultural Resource: An Environmental Impact Report may not be certified, nor may a mitigated negative declaration or a negative declaration be adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public Resources Code §21080.3.1 and §21080.3.2 and concluded pursuant to Public Resources Code §21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise failed to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources Code §21080.3.1 (d) and the tribe failed to request consultation within 30 days. (Pub. Resources Code §21082.3 (d)).

The NAHC’s PowerPoint presentation titled, “Tribal Consultation Under AB 52: Requirements and Best Practices” may be found online at: http://nahc.ca.gov/wp-content/uploads/2015/10/AB52TribalConsultation_CalEPAPDF.pdf 444

SB 18
SB 18 applies to local governments and requires local governments to contact, provide notice to, refer plans to, and consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of open space. (Gov. Code §65352.3). Local governments should consult the Governor’s Office of Planning and Research’s “Tribal Consultation Guidelines,” which can be found online at:
https://www.opr.ca.gov/docs/09_14_05_Updated_Guidelines_922.pdf.

Some of SB 18’s provisions include:

1. Tribal Consultation: If a local government considers a proposal to adopt or amend a general plan or a specific plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC by requesting a “Tribal Consultation List.” If a tribe, once contacted, requests consultation the local government must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification to request consultation unless a shorter timeframe has been agreed to by the tribe. (Gov. Code §65352.3 (a)(2)).

2. No Statutory Time Limit on SB 18 Tribal Consultation. There is no statutory time limit on SB 18 tribal consultation.

3. Confidentiality: Consistent with the guidelines developed and adopted by the Office of Planning and Research pursuant to Gov. Code §65040.2, the city or county shall protect the confidentiality of the information concerning the specific identity, location, character, and use of places, features and objects described in Public Resources Code §5097.9 and §5097.993 that are within the city’s or county’s jurisdiction. (Gov. Code §65352.3 (b)).

4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures for preservation or mitigation; or
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached concerning the appropriate measures of preservation or mitigation. (Tribal Consultation Guidelines, Governor’s Office of Planning and Research (2005) at p. 18).

Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initiating tribal consultation with tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in AB 52 and SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and “Sacred Lands File” searches from the NAHC. The request forms can be found online at: http://nahc.ca.gov/resources/forms/.

NAHC Recommendations for Cultural Resources Assessments To adequately assess the existence and significance of tribal cultural resources and plan for avoidance, preservation in place, or barring both, mitigation of project-related impacts to tribal cultural resources, the NAHC recommends the following actions:

1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center (https://ohp.parks.ca.gov/?page_id=30331) for an archaeological records search. The records search will determine:
a. If part or all of the APE has been previously surveyed for cultural resources. b. If any known cultural resources have already been recorded on or adjacent to the APE. c. If the probability is low, moderate, or high that cultural resources are located in the APE. d. If a survey is required to determine whether previously unrecorded cultural resources are present.

2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey. a. The final report containing site forms, site significance, and mitigation measures should be submitted immediately to the planning department. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum and not be made available for public disclosure.
b. The final written report should be submitted within 3 months after work has been completed to the appropriate regional CHRIS center.
445

3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the Sacred Lands File, nor are they required to do so. A Sacred Lands File search is not a substitute for consultation with tribes that are traditionally and culturally affiliated with the geographic area of the project’s APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the project site and to assist in planning for avoidance, preservation in place, or, failing both, mitigation measures.

4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources) does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code Regs., tit. 14, §15064.5(f) (CEQA Guidelines §15064.5(f)). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American with knowledge of cultural resources should monitor all ground-disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions for the disposition of recovered cultural items that are not burial associated in consultation with culturally affiliated Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions for the treatment and disposition of inadvertently discovered Native American human remains. Health and Safety Code §7050.5, Public Resources Code §5097.98, and Cal. Code Regs., tit. 14, §15064.5, subdivisions (d) and (e) (CEQA Guidelines §15064.5, subds. (d) and (e)) address the processes to be followed in the event of an inadvertent discovery of any Native American human remains and associated grave goods in a location other than a dedicated cemetery.

If you have any questions or need additional information, please contact me at my email address:

[email protected].

Sincerely,
Cameron Vela
Cultural Resources Analyst
cc: State Clearinghouse
446
Appendix B
Supporting Biological Resources Information
447
Scientific Name
Common Name Status Habitat Requirements
Allium peninsulare var.
franciscanum
Franciscan onion
None/None
G5T2/S2
1B.2
Perennial bulbiferous herb. Cismontane woodland,
valley and foothill grassland. Clay, Serpentinite
(often), volcanic. Elevations: 170-1000ft. (52-305m.)
Blooms (Apr)May-Jun.

Amorpha californica var.
napensis
Napa false indigo
None/None
G4T2/S2
1B.2
Perennial deciduous shrub. Broadleafed upland
forest, chaparral, cismontane woodland. Openings in
forest or woodland or in chaparral. 30-735 m.

Elevations: 165-6560ft. (50-2000m.) Blooms Apr-Jul.

Astragalus tener var. tener
alkali milk-vetch
None/None
G2T1/S1
1B.2
Annual herb. Playas, valley and foothill grassland,
vernal pools. Alkaline. Elevations: 5-195ft. (1-60m.)
Blooms Mar-Jun.

Atriplex persistens
vernal pool smallscale
None/None
G2/S2
1B.2
Annual herb. Vernal pools. Alkaline vernal pools.

Elevations: 35-375ft. (10-115m.) Blooms Jun-Oct.

Balsamorhiza macrolepis
big-scale balsamroot
None/None
G2/S2
1B.2
Perennial herb. Chaparral, cismontane woodland,
valley and foothill grassland. Serpentinite
(sometimes). Elevations: 150-5100ft. (45-1555m.)
Blooms Mar-Jun.

Blennosperma bakeri
Sonoma sunshine
FE/SCE
G1/S1
1B.1
Annual herb. Valley and foothill grassland, vernal
pools. Vernal pools and swales. Elevations: 35-360ft.
(10-110m.) Blooms Mar-May.

Blepharizonia plumosa
big tarplant
None/None
G1G2/S1S2
1B.1
Annual herb. Valley and foothill grassland. Clay
(usually). Elevations: 100-1655ft. (30-505m.) Blooms
Jul-Oct.

Brodiaea leptandra
narrow-anthered brodiaea
None/None
G3?/S3?
1B.2
Perennial bulbiferous herb. Broadleafed upland
forest, chaparral, cismontane woodland, lower
montane coniferous forest, valley and foothill
grassland. Volcanic. Elevations: 360-3000ft. (110-
915m.) Blooms May-Jul.
19-08673: American Canyon
Plants and Lichens
448
Calochortus pulchellus
Mt. Diablo fairy-lantern
None/None
G2/S2
1B.2
Perennial bulbiferous herb. Chaparral, cismontane
woodland, riparian woodland, valley and foothill
grassland. On wooded and brushy slopes. Elevations:
100-2755ft. (30-840m.) Blooms Apr-Jun.

Carex lyngbyei
Lyngbye's sedge
None/None
G5/S3
2B.2
Perennial rhizomatous herb. Marshes and swamps.

Elevations: 0-35ft. (0-10m.) Blooms Apr-Aug.

Castilleja affinis var. neglecta
Tiburon paintbrush
FE/SCT
G4G5T1T2/S1S2
1B.2
Perennial herb (hemiparasitic). Valley and foothill
grassland. Rocky serpentine sites. Elevations: 195-
1310ft. (60-400m.) Blooms Apr-Jun.

Ceanothus confusus
Rincon Ridge ceanothus
None/None
G1/S1
1B.1
Perennial evergreen shrub. Chaparral, cismontane
woodland, closed-cone coniferous forest.

Serpentinite (sometimes), volcanic (sometimes).

Elevations: 245-3495ft. (75-1065m.) Blooms Feb-Jun.

Ceanothus purpureus
holly-leaved ceanothus
None/None
G2/S2
1B.2
Perennial evergreen shrub. Chaparral, cismontane
woodland. Rocky, volcanic. Elevations: 395-2100ft.
(120-640m.) Blooms Feb-Jun.

Ceanothus sonomensis
Sonoma ceanothus
None/None
G2/S2
1B.2
Perennial evergreen shrub. Chaparral. Sandy,
serpentine or volcanic soils. Elevations: 705-2625ft.
(215-800m.) Blooms Feb-Apr.

Centromadia parryi ssp.
congdonii
Congdon's tarplant
None/None
G3T1T2/S1S2
1B.1
Annual herb. Valley and foothill grassland. Alkaline
soils, sometimes described as heavy white clay.

Elevations: 0-755ft. (0-230m.) Blooms May-Oct(Nov).

Centromadia parryi ssp. parryi
pappose tarplant
None/None
G3T2/S2
1B.2
Annual herb. Chaparral, coastal prairie, marshes and
swamps, meadows and seeps, valley and foothill
grassland. Alkaline (often). Elevations: 0-1380ft. (0-
420m.) Blooms May-Nov.

Chloropyron molle ssp. molle
soft salty bird's-beak
FE/SCR
G2T1/S1
1B.2
Annual herb (hemiparasitic). Marshes and swamps. In
coastal salt marsh with Distichlis, Salicornia,
Frankenia, etc. Elevations: 0-10ft. (0-3m.) Blooms JunNov. 449
Cicuta maculata var. bolanderi
Bolander's water-hemlock
None/None
G5T4T5/S2?
2B.1
Perennial herb. Marshes and swamps. In fresh or
brackish water. Elevations: 0-655ft. (0-200m.) Blooms
Jul-Sep.

Cirsium hydrophilum var.
hydrophilum
Suisun thistle
FE/None
G2T1/S1
1B.1
Perennial herb. Marshes and swamps. Grows with
Scirpus, Distichlis near small watercourses within
saltmarsh. Elevations: 0-5ft. (0-1m.) Blooms Jun-Sep.

Dirca occidentalis
western leatherwood
None/None
G2/S2
1B.2
Perennial deciduous shrub. Broadleafed upland
forest, chaparral, cismontane woodland, closed-cone
coniferous forest, north coast coniferous forest,
riparian forest, riparian woodland. On brushy slopes,
mesic sites; mostly in mixed evergreen and foothill
woodland communities. Elevations: 80-1395ft. (25-
425m.) Blooms Jan-Mar(Apr).

Downingia pusilla
dwarf downingia
None/None
GU/S2
2B.2
Annual herb. Valley and foothill grassland, vernal
pools. Vernal lake and pool margins with a variety of
associates. In several types of vernal pools.

Elevations: 5-1460ft. (1-445m.) Blooms Mar-May.

Erigeron greenei
Greene's narrow-leaved daisy
None/None
G3/S3
1B.2
Perennial herb. Chaparral. Serpentine and volcanic
substrates, generally in shrubby vegetation.

Elevations: 260-3295ft. (80-1005m.) Blooms May-Sep.

Eriogonum truncatum
Mt. Diablo buckwheat
None/None
G1/S1
1B.1
Annual herb. Chaparral, coastal scrub, valley and
foothill grassland. Dry, exposed clay or sandy
substrates. Elevations: 10-1150ft. (3-350m.) Blooms
Apr-Sep(Nov-Dec).

Eryngium jepsonii
Jepson's coyote-thistle
None/None
G2/S2
1B.2
Perennial herb. Valley and foothill grassland, vernal
pools. Clay. Elevations: 10-985ft. (3-300m.) Blooms
Apr-Aug.

Extriplex joaquinana
San Joaquin spearscale
None/None
G2/S2
1B.2
Annual herb. Chenopod scrub, meadows and seeps,
playas, valley and foothill grassland. In seasonal alkali wetlands or alkali sink scrub with Distichlis spicata,
Frankenia, etc. Elevations: 5-2740ft. (1-835m.) Blooms
Apr-Oct.

Fritillaria liliacea
fragrant fritillary
None/None
G2/S2
1B.2
Perennial bulbiferous herb. Cismontane woodland,
coastal prairie, coastal scrub, valley and foothill
grassland. Often on serpentine; various soils reported
though usually on clay, in grassland. Elevations: 10-
1345ft. (3-410m.) Blooms Feb-Apr.
450
Helianthella castanea
Diablo helianthella
None/None
G2/S2
1B.2
Perennial herb. Broadleafed upland forest, chaparral,
cismontane woodland, coastal scrub, riparian
woodland, valley and foothill grassland. Azonal soils,
Partial shade (often), rocky (usually). Elevations: 195- 4265ft. (60-1300m.) Blooms Mar-Jun.

Hemizonia congesta ssp.
congesta
congested-headed hayfield
tarplant
None/None
G5T2/S2
1B.2
Annual herb. Valley and foothill grassland. Grassy
valleys and hills, often in fallow fields; sometimes
along roadsides. Elevations: 65-1835ft. (20-560m.)
Blooms Apr-Nov.

Hesperolinon bicarpellatum
two-carpellate western flax
None/None
G2/S2
1B.2
Annual herb. Chaparral. Serpentine barrens at edge of
chaparral. Elevations: 195-3295ft. (60-1005m.)
Blooms (Apr)May-Jul.

Hesperolinon breweri
Brewer's western flax
None/None
G2/S2
1B.2
Annual herb. Chaparral, cismontane woodland, valley
and foothill grassland. Often in rocky serpentine soil
in serpentine chaparral and serpentine grassland.

Elevations: 100-3100ft. (30-945m.) Blooms May-Jul.

Horkelia tenuiloba
thin-lobed horkelia
None/None
G2/S2
1B.2
Perennial herb. Broadleafed upland forest, chaparral,
valley and foothill grassland. Sandy soils; mesic
openings. Elevations: 165-1640ft. (50-500m.) Blooms
May-Jul(Aug).

Isocoma arguta
Carquinez goldenbush
None/None
G1/S1
1B.1
Perennial shrub. Valley and foothill grassland. Alkaline soils, flats, lower hills. On low benches near drainages and on tops and sides of mounds in swale habitat.

Elevations: 5-65ft. (1-20m.) Blooms Aug-Dec.

Lasthenia conjugens
Contra Costa goldfields
FE/None
G1/S1
1B.1
Annual herb. Cismontane woodland, playas, valley
and foothill grassland, vernal pools. Vernal pools,
swales, low depressions, in open grassy areas.

Elevations: 0-1540ft. (0-470m.) Blooms Mar-Jun.

Lathyrus jepsonii var. jepsonii
Delta tule pea
None/None
G5T2/S2
1B.2
Perennial herb. Marshes and swamps. In freshwater
and brackish marshes. Often found with Typha, Aster
lentus, Rosa californica, Juncus spp., Scirpus, etc.

Usually on marsh and slough edges. Elevations: 0-
15ft. (0-5m.) Blooms May-Jul(Aug-Sep).

Legenere limosa
legenere
None/None
G2/S2
1B.1
Annual herb. Vernal pools. In beds of vernal pools. 1-.

Elevations: 5-2885ft. (1-880m.) Blooms Apr-Jun.
451
Leptosiphon jepsonii
Jepson's leptosiphon
None/None
G2G3/S2S3
1B.2
Annual herb. Chaparral, cismontane woodland, valley
and foothill grassland. Open to partially shaded grassy slopes. On volcanics or the periphery of serpentine
substrates. Elevations: 330-1640ft. (100-500m.)
Blooms Mar-May.

Lilaeopsis masonii
Mason's lilaeopsis
None/SCR
G2/S2
1B.1
Perennial rhizomatous herb. Marshes and swamps,
riparian scrub. Tidal zones, in muddy or silty soil
formed through river deposition or river bank
erosion. In brackish or freshwater. Elevations: 0-35ft. (0-10m.) Blooms Apr-Nov.

Limosella australis
Delta mudwort
None/None
G4G5/S2
2B.1
Perennial stoloniferous herb. Marshes and swamps,
riparian scrub. Usually on mud banks of the Delta in
marshy or scrubby riparian associations; often with
Lilaeopsis masonii. Elevations: 0-10ft. (0-3m.) Blooms
May-Aug.

Lomatium repostum
Napa lomatium
None/None
G2G3/S2S3
1B.2
Perennial herb. Chaparral, cismontane woodland.

Rocky areas in volcanic and serpentine soils with
mixed chaparral and black oak woodland
communities. Elevations: 295-3380ft. (90-1030m.)
Blooms Mar-Jun.

Lupinus sericatus
Cobb Mountain lupine
None/None
G2?/S2?
1B.2
Perennial herb. Broadleafed upland forest, chaparral,
cismontane woodland, lower montane coniferous
forest. In stands of knobcone pine-oak woodland, on
open wooded slopes in gravelly soils; sometimes on
serpentine. Elevations: 900-5005ft. (275-1525m.)
Blooms Mar-Jun.

Navarretia leucocephala ssp.
bakeri
Baker's navarretia
None/None
G4T2/S2
1B.1
Annual herb. Cismontane woodland, lower montane
coniferous forest, meadows and seeps, valley and
foothill grassland, vernal pools. Vernal pools and
swales; adobe or alkaline soils. Elevations: 15-5710ft. (5-1740m.) Blooms Apr-Jul.

Puccinellia simplex
California alkali grass
None/None
G3/S2
1B.2
Annual herb. Chenopod scrub, meadows and seeps,
valley and foothill grassland, vernal pools. Alkaline,
vernally mesic. Sinks, flats, and lake margins.

Elevations: 5-3050ft. (2-930m.) Blooms Mar-May.

Rhynchospora californica
California beaked-rush
None/None
G1/S1
1B.1
Perennial rhizomatous herb. Bogs and fens, lower
montane coniferous forest, marshes and swamps,
meadows and seeps. Freshwater seeps and open
marshy areas. Elevations: 150-3315ft. (45-1010m.)
Blooms May-Jul.

Senecio aphanactis
chaparral ragwort
None/None
G3/S2
2B.2
Annual herb. Chaparral, cismontane woodland,
coastal scrub. Drying alkaline flats. Elevations: 50-
2625ft. (15-800m.) Blooms Jan-Apr(May).
452
Sidalcea hickmanii ssp. napensis
Napa checkerbloom
None/None
G3T1/S1
1B.1
Perennial herb. Chaparral. Rhyolitic substrates.

Elevations: 1360-2000ft. (415-610m.) Blooms Apr-Jun.

Spergularia macrotheca var.
longistyla
long-styled sand-spurrey
None/None
G5T2/S2
1B.2
Perennial herb. Marshes and swamps, meadows and
seeps. Alkaline. Elevations: 0-835ft. (0-255m.) Blooms
Feb-May.

Stuckenia filiformis ssp. alpina
northern slender pondweed
None/None
G5T5/S2S3
2B.2
Perennial rhizomatous herb (aquatic). Marshes and
swamps. Shallow, clear water of lakes and drainage
channels. Elevations: 985-7055ft. (300-2150m.)
Blooms May-Jul.

Symphyotrichum lentum
Suisun Marsh aster
None/None
G2/S2
1B.2
Perennial rhizomatous herb. Marshes and swamps.

Most often seen along sloughs with Phragmites,
Scirpus, blackberry, Typha, etc. Elevations: 0-10ft. (0- 3m.) Blooms (Apr)May-Nov.

Trichostema ruygtii
Napa bluecurls
None/None
G1G2/S1S2
1B.2
Annual herb. Chaparral, cismontane woodland, lower
montane coniferous forest, valley and foothill
grassland, vernal pools. Often in open, sunny areas.

Also has been found in vernal pools. Elevations: 100-
2230ft. (30-680m.) Blooms Jun-Oct.

Trifolium amoenum
two-fork clover
FE/None
G1/S1
1B.1
Annual herb. Coastal bluff scrub, valley and foothill
grassland. Sometimes on serpentine soil, open sunny
sites, swales. Most recently cited on roadside and
eroding cliff face. Elevations: 15-1360ft. (5-415m.)
Blooms Apr-Jun.

Trifolium hydrophilum
saline clover
None/None
G2/S2
1B.2
Annual herb. Marshes and swamps, valley and foothill
grassland, vernal pools. Mesic, alkaline sites.

Elevations: 0-985ft. (0-300m.) Blooms Apr-Jun.

Viburnum ellipticum
oval-leaved viburnum
None/None
G4G5/S3?
2B.3
Perennial deciduous shrub. Chaparral, cismontane
woodland, lower montane coniferous forest.

Elevations: 705-4595ft. (215-1400m.) Blooms MayJun.

Bombus crotchii
Crotch bumble bee
None/None
G2/S1S2
Coastal California east to the Sierra-Cascade crest and south into Mexico. Food plant genera include
Antirrhinum, Phacelia, Clarkia, Dendromecon,
Eschscholzia, and Eriogonum.

Invertebrates
453
Bombus occidentalis
western bumble bee
None/None
G2G3/S1
Once common and widespread, species has declined
precipitously from central CA to southern B.C.,
perhaps from disease.

Branchinecta lynchi
vernal pool fairy shrimp
FT/None
G3/S3
Endemic to the grasslands of the Central Valley,
Central Coast mountains, and South Coast mountains,
in astatic rain-filled pools. Inhabit small, clear-water sandstone-depression pools and grassed swale, earth
slump, or basalt-flow depression pools.

Desmocerus californicus
dimorphus
valley elderberry longhorn beetle
FT/None
G3T2T3/S3
Occurs only in the Central Valley of California, in
association with blue elderberry (Sambucus
mexicana). Prefers to lay eggs in elderberries 2-8
inches in diameter; some preference shown for
"stressed" elderberries.

Speyeria callippe callippe
callippe silverspot butterfly
FE/None
G5T1/S1
Restricted to the northern coastal scrub of the San
Francisco peninsula. Hostplant is Viola pedunculata.

Most adults found on E-facing slopes; males
congregate on hilltops in search of females.

Syncaris pacifica
California freshwater shrimp
FE/SE
G2/S2
Endemic to Marin, Napa, and Sonoma counties.

Found in low elevation, low gradient streams where
riparian cover is moderate to heavy. Shallow pools
away from main streamflow. Winter: undercut banks
with exposed roots. Summer: leafy branches touching
water.

Acipenser medirostris pop. 1
green sturgeon - southern DPS
FT/None
G3T1/S1
Spawning site fidelity. Spawns in the Sacramento,
Feather and Yuba Rivers. Presence in upper Stanislaus
and San Joaquin Rivers may indicate spawning. Nonspawning adults occupy marine/estuarine waters.

Delta Estuary is important for rearing juveniles.

Spawning occurs primarily in cool (11-15 C) sections
of mainstem rivers in deep pools (8-9 meters) with
substrate containing small to medium sized sand,
gravel, cobble, or boulder.

Hypomesus transpacificus
Delta smelt
FT/SE
G1/S1
Sacramento-San Joaquin Delta. Seasonally in Suisun
Bay, Carquinez Strait and San Pablo Bay. Seldom
found at salinities > 10 ppt. Most often at salinities < 2ppt.

Fish
454
Oncorhynchus mykiss irideus
pop. 8
steelhead - central California
coast DPS
FT/None
G5T2T3Q/S2S3
DPS includes all naturally spawned populations of
steelhead (and their progeny) in streams from the
Russian River to Aptos Creek, Santa Cruz County,
California (inclusive). Also includes the drainages of
San Francisco and San Pablo Bays.

Pogonichthys macrolepidotus
Sacramento splittail
None/None
GNR/S3
SSC
Endemic to the lakes and rivers of the Central Valley,
but now confined to the Delta, Suisun Bay and
associated marshes. Slow moving river sections, dead
end sloughs. Requires flooded vegetation for
spawning and foraging for young.

Spirinchus thaleichthys
longfin smelt
FC/ST
G5/S1
Euryhaline, nektonic and anadromous. Found in open
waters of estuaries, mostly in middle or bottom of
water column. Prefer salinities of 15-30 ppt, but can
be found in completely freshwater to almost pure
seawater.

Dicamptodon ensatus
California giant salamander
None/None
G3/S2S3
SSC
Known from wet coastal forests near streams and
seeps from Mendocino County south to Monterey
County, and east to Napa County. Aquatic larvae
found in cold, clear streams, occasionally in lakes and ponds. Adults known from wet forests under rocks
and logs near streams and lakes.

Rana boylii pop. 1
foothill yellow-legged frog -
north coast DPS
None/None
G3TNRQ/S3
SSC
Northern Coast Ranges north of San Francisco Bay
Estuary, Klamath Mountains, and Cascade Range
including watershed subbasins (HU 8) Lower Pit,
Battle Creek, Thomes Creek, and Big Chico Creek in
Lassen, Shasta, Tehama, and Butte Counties. Partly
shaded shallow streams and riffles with a rocky
substrate in a variety of habitats. Needs at least some cobble-sized substrate for egg-laying and at least 15
weeks to attain metamorphosis.

Rana draytonii
California red-legged frog
FT/None
G2G3/S2S3
SSC
Lowlands and foothills in or near permanent sources
of deep water with dense, shrubby or emergent
riparian vegetation. Requires 11-20 weeks of
permanent water for larval development. Must have
access to estivation habitat.

Amphibians
455
Taricha rivularis
red-bellied newt
None/None
G2/S2
SSC
Coastal drainages from Humboldt County south to
Sonoma County, inland to Lake County. Isolated
population of uncertain origin in Santa Clara County.

Lives in terrestrial habitats, juveniles generally
underground, adults active at surface in moist
environments. Will migrate over 1 km to breed,
typically in streams with moderate flow and clean,
rocky substrate.

Emys marmorata
western pond turtle
None/None
G3G4/S3
SSC
A thoroughly aquatic turtle of ponds, marshes, rivers,
streams and irrigation ditches, usually with aquatic
vegetation, below 6000 ft elevation. Needs basking
sites and suitable (sandy banks or grassy open fields)
upland habitat up to 0.5 km from water for egglaying.

Masticophis lateralis
euryxanthus
Alameda whipsnake
FT/ST
G4T2/S2
Typically found in chaparral and scrub habitats but
will also use adjacent grassland, oak savanna and
woodland habitats. Mostly south-facing slopes and
ravines, with rock outcrops, deep crevices or
abundant rodent burrows, where shrubs form a
vegetative mosaic with oak trees and grasses.

Accipiter cooperii
Cooper's hawk
None/None
G5/S4
WL
Woodland, chiefly of open, interrupted or marginal
type. Nest sites mainly in riparian growths of
deciduous trees, as in canyon bottoms on river floodplains; also, live oaks.

Agelaius tricolor
tricolored blackbird
None/ST
G1G2/S1S2
SSC
Highly colonial species, most numerous in Central
Valley and vicinity. Largely endemic to California.

Requires open water, protected nesting substrate,
and foraging area with insect prey within a few km of
the colony.

Aquila chrysaetos
golden eagle
None/None
G5/S3
FP
WL
Rolling foothills, mountain areas, sage-juniper flats,
and desert. Cliff-walled canyons provide nesting
habitat in most parts of range; also, large trees in
open areas.

Reptiles
Birds
456
Asio flammeus
short-eared owl
None/None
G5/S3
SSC
Found in swamp lands, both fresh and salt; lowland
meadows; irrigated alfalfa fields. Tule patches/tall
grass needed for nesting/daytime seclusion. Nests on
dry ground in depression concealed in vegetation.

Athene cunicularia
burrowing owl
None/None
G4/S3
SSC
Open, dry annual or perennial grasslands, deserts,
and scrublands characterized by low-growing
vegetation. Subterranean nester, dependent upon
burrowing mammals, most notably, the California
ground squirrel.

Buteo regalis
ferruginous hawk
None/None
G4/S3S4
WL
Open grasslands, sagebrush flats, desert scrub, low
foothills and fringes of pinyon and juniper habitats.

Eats mostly lagomorphs, ground squirrels, and mice.

Population trends may follow lagomorph population
cycles.

Buteo swainsoni
Swainson's hawk
None/ST
G5/S3
Breeds in grasslands with scattered trees, junipersage flats, riparian areas, savannahs, and agricultural or ranch lands with groves or lines of trees. Requires
adjacent suitable foraging areas such as grasslands, or alfalfa or grain fields supporting rodent populations.

Charadrius nivosus nivosus
western snowy plover
FT/None
G3T3/S2
SSC
Sandy beaches, salt pond levees and shores of large
alkali lakes. Needs sandy, gravelly or friable soils for nesting.

Circus hudsonius
northern harrier
None/None
G5/S3
SSC
Coastal salt and freshwater marsh. Nest and forage in
grasslands, from salt grass in desert sink to mountain
cienagas. Nests on ground in shrubby vegetation,
usually at marsh edge; nest built of a large mound of
sticks in wet areas.

Coturnicops noveboracensis
yellow rail
None/None
G4/S1S2
SSC
Summer resident in eastern Sierra Nevada in Mono
County. Freshwater marshlands.

Cypseloides niger
black swift
None/None
G4/S2
SSC
Coastal belt of Santa Cruz and Monterey counties;
central and southern Sierra Nevada; San Bernardino
and San Jacinto mountains. Breeds in small colonies
on cliffs behind or adjacent to waterfalls in deep
canyons and sea-bluffs above the surf; forages widely.
457
Elanus leucurus
white-tailed kite
None/None
G5/S3S4
FP
Rolling foothills and valley margins with scattered
oaks and river bottomlands or marshes next to
deciduous woodland. Open grasslands, meadows, or
marshes for foraging close to isolated, dense-topped
trees for nesting and perching.

Falco peregrinus anatum
American peregrine falcon
FD/SD
G4T4/S3S4
FP
Near wetlands, lakes, rivers, or other water; on cliffs, banks, dunes, mounds; also, human-made structures.

Nest consists of a scrape or a depression or ledge in
an open site.

Geothlypis trichas sinuosa
saltmarsh common yellowthroat
None/None
G5T3/S3
SSC
Resident of the San Francisco Bay region, in fresh and
salt water marshes. Requires thick, continuous cover
down to water surface for foraging; tall grasses, tule
patches, willows for nesting.

Laterallus jamaicensis
coturniculus
California black rail
None/ST
G3T1/S1
FP
Inhabits freshwater marshes, wet meadows and
shallow margins of saltwater marshes bordering
larger bays. Needs water depths of about 1 inch that
do not fluctuate during the year and dense vegetation
for nesting habitat.

Melospiza melodia maxillaris
Suisun song sparrow
None/None
G5T3/S3
SSC
Resident of brackish-water marshes surrounding
Suisun Bay. Inhabits cattails, tules and other sedges,
and Salicornia; also known to frequent tangles
bordering sloughs.

Melospiza melodia samuelis
San Pablo song sparrow
None/None
G5T2/S2
SSC
Resident of salt marshes along the north side of San
Francisco and San Pablo bays. Inhabits tidal sloughs in the Salicornia marshes; nests in Grindelia bordering
slough channels.

Pandion haliaetus
osprey
None/None
G5/S4
WL
Ocean shore, bays, freshwater lakes, and larger
streams. Large nests built in tree-tops within 15 miles of a good fish-producing body of water.

Rallus obsoletus obsoletus
California Ridgway's rail
FE/SE
G3T1/S1
FP
Salt water and brackish marshes traversed by tidal
sloughs in the vicinity of San Francisco Bay.

Associated with abundant growths of pickleweed, but
feeds away from cover on invertebrates from mudbottomed sloughs.

Riparia riparia
bank swallow
None/ST
G5/S2
Colonial nester; nests primarily in riparian and other
lowland habitats west of the desert. Requires vertical
banks/cliffs with fine-textured/sandy soils near
streams, rivers, lakes, ocean to dig nesting hole.
458
Xanthocephalus xanthocephalus
yellow-headed blackbird
None/None
G5/S3
SSC
Nests in freshwater emergent wetlands with dense
vegetation and deep water. Often along borders of
lakes or ponds. Nests only where large insects such as
Odonata are abundant, nesting timed with maximum
emergence of aquatic insects.

Antrozous pallidus
pallid bat
None/None
G4/S3
SSC
Found in a variety of habitats including deserts,
grasslands, shrublands, woodlands, and forests. Most
common in open, dry habitats with rocky areas for
roosting. Roosts in crevices of rock outcrops, caves,
mine tunnels, buildings, bridges, and hollows of live
and dead trees which must protect bats from high
temperatures. Very sensitive to disturbance of
roosting sites.

Corynorhinus townsendii
Townsend's big-eared bat
None/None
G4/S2
SSC
Occurs throughout California in a wide variety of
habitats. Most common in mesic sites, typically
coniferous or deciduous forests. Roosts in the open,
hanging from walls &amp; ceilings in caves, lava
tubes, bridges, and buildings. This species is
extremely sensitive to human disturbance.

Nyctinomops macrotis
big free-tailed bat
None/None
G5/S3
SSC
Low-lying arid areas in Southern California. Need high
cliffs or rocky outcrops for roosting sites. Feeds
principally on large moths.

Reithrodontomys raviventris
salt-marsh harvest mouse
FE/SE
G1G2/S1S2
FP
Only in the saline emergent wetlands of San Francisco
Bay and its tributaries. Pickleweed is primary habitat, but may occur in other marsh vegetation types and in
adjacent upland areas. Does not burrow; builds
loosely organized nests. Requires higher areas for
flood escape.

Sorex ornatus sinuosus
Suisun shrew
None/None
G5T1T2Q/S1S2
SSC
Tidal marshes of the northern shores of San Pablo and
Suisun bays. Require dense low-lying cover and
driftweed and other litter above the mean hightide
line for nesting and foraging.

Mammals
459
Taxidea taxus
American badger
None/None
G5/S3
SSC
Most abundant in drier open stages of most shrub,
forest, and herbaceous habitats, with friable soils.

Needs sufficient food, friable soils and open,
uncultivated ground. Preys on burrowing rodents.

Digs burrows.

Coastal Brackish Marsh None/None
G2/S2.1
Northern Claypan Vernal Pool None/None
G1/S1.1
Northern Coastal Salt Marsh None/None
G3/S3.2
Coastal salt marshes, alkaline flats. The USFWS
Wetland Inventory (1996 national list) recognizes
Sarcocornia pacifica as an OBL plant.

Northern Vernal Pool None/None
G2/S2.1
Serpentine Bunchgrass None/None
G2/S2.2
All topographic locations. Soils may be deep with high
clay content, loamy, sandy, or silty derived from
mudstone, sandstone, or serpentine substrates.

Sensitive Natural Communities
460
Appendix C
Supporting Noise Information
461
Roadway Location Facility Type
Number
of Lanes
Speed
Limit
Existing
2022 Count Facility Type
Number of
Lanes
Speed
Limit
Future
2040
Forecast
Interstate 80 s/o SR 37 Nine-Lane Freeway 9 65 110,006 Nine-Lane Freeway 9 65 117,514 s/o American Canyon Road Nine-Lane Freeway 9 65 109,042 Nine-Lane Freeway 9 65 121,991 s/o Red Top Road Eight-Lane Freeway 8 65 112,650 Nine-Lane Freeway 8 65 128,806 s/o SR 12 Eight-Lane Freeway 8 65 97,782 Eight-Lane Freeway 8 65 113,977 n/o SR 12 Eight-Lane Freeway 8 65 136,706 Eight-Lane Freeway 8 65 155,682 State Route 29 s/o SR 37 Four-Lane Arterial 4 50 to 55 24,051 Four-Lane Arterial 4 50 to 55 26,059 n/o SR 37 Four-Lane Arterial 4 50 to 55 43,483 Six-Lane Arterial 4 50 to 55 40,444 s/o Mini Drive Four-Lane Arterial 4 50 to 55 37,492 Six-Lane Arterial 4 50 to 55 37,666 n/o Mini Drive Four-Lane Arterial 4 50 to 55 43,469 Six-Lane Arterial 4 50 to 55 43,575 n/o American Canyon Road Four-Lane Arterial 4 50 to 55 49,579 Six-Lane Arterial 4 50 to 55 51,132 s/o Napa Junction Road Six-Lane Arterial 6 50 to 55 40,762 Six-Lane Arterial 6 50 to 55 36,053 n/o Napa Junction Road Four-Lane Highway 4 50 to 55 59,044 Six-Lane Highway 4 50 to 55 60,310 n/o Green Island Road Four-Lane Highway 4 50 to 55 60,263 Four-Lane Highway 4 50 to 55 62,189 s/o SR 12 Six-Lane Highway 6 50 to 55 59,200 Six-Lane Highway 6 50 to 55 62,560 n/o SR 12 Six-Lane Highway 6 50 to 55 88,600 Six-Lane Highway 6 50 to 55 106,300 Airport Blvd. w/o SR 29 Four-Lane Collector 4 45 10,500 Four-Lane Collector 4 45 10,341 State Route 12 e/o N. Kelly Road Four-Lane Highway 3 55 35,033 Four-Lane Highway 3 55 36,038 w/o Red Top Road Two-Lane Highway 2 55 37,179 Four-Lane Highway 2 55 38,106 State Route 37 w/o SR 29 Four-Lane Freeway 4 50 to 55 39,980 Four-Lane Freeway 4 50 to 55 39,074 e/o SR 29 Four-Lane Freeway 4 50 to 55 62,495 Four-Lane Freeway 4 50 to 55 63,592 e/o Fairgrounds Road Four-Lane Freeway 4 50 to 55 69,800 Four-Lane Freeway 0 50 to 55 69,800 e/o I-80 Six-Lane Freeway 6 50 to 55 42,000 Six-Lane Freeway 6 50 to 55 47,776 American Cyn Rd. w/o SR 29 Four-Lane Arterial 4 45 15,330 Four-Lane Arterial 4 45 10,935 e/o Flosden Road Two-Lane Arterial 2 45 10,771 Two-Lane Arterial 2 45 14,194 w/o I-80 Two-Lane Arterial 2 45 4,076 Two-Lane Arterial 2 45 7,610 Hiddenbrook Pkwy e/o I-80 Two-Lane Collector 2 40 6,023 Two-Lane Collector 2 40 6,943 Flosden Road s/o American Canyon Road Four-Lane Arterial 4 45 21,510 Four-Lane Arterial 4 45 29,362 Newell Drive n/o American Canyon Road Four-Lane Arterial 4 35 9,685 Four-Lane Arterial 4 35 28,072 s/o Napa Junction Road - - - - Four-Lane Arterial 4 35 21,790 South Kelly Road s/o SR 12 Two-Lane Collector 2 50 1,602 Two-Lane Collector 2 50 11,310 Devlin Road n/o Green Island Road Two-Lane Collector - - - Two-Lane Collector 2 40 5,224 Existing and Forecast Volumes
Existing Network Build-Out Network
462
Roadway Location Auto
Medium
Duty
Heavy
Duty
Existing
2022
Count Auto
Medium
Duty
Heavy
Duty
Future
2040
Forecast
Interstate 80 s/o SR 37 103,087 3,460 3,460 110,006 110,122 3,696 3,696 117,514 s/o American Canyon Road 102,881 3,080 3,080 109,042 115,099 3,446 3,446 121,991 s/o Red Top Road 106,037 3,306 3,306 112,650 121,245 3,780 3,780 128,806 s/o SR 12 92,042 2,870 2,870 97,782 107,287 3,345 3,345 113,977 n/o SR 12 125,441 5,632 5,632 136,706 142,854 6,414 6,414 155,682 State Route 29 s/o SR 37 23,544 254 254 24,051 25,509 275 275 26,059 n/o SR 37 41,357 1,063 1,063 43,483 38,466 989 989 40,444 s/o Mini Drive 35,689 902 902 37,492 35,854 906 906 37,666 n/o Mini Drive 41,448 1,011 1,011 43,469 41,549 1,013 1,013 43,575 n/o American Canyon Road 47,402 1,088 1,088 49,579 48,887 1,122 1,122 51,132 s/o Napa Junction Road 37,966 1,398 1,398 40,762 33,580 1,237 1,237 36,053 n/o Napa Junction Road 54,415 2,315 2,315 59,044 55,582 2,364 2,364 60,310 n/o Green Island Road 54,176 3,043 3,043 60,263 55,908 3,141 3,141 62,189 s/o SR 12 54,553 2,324 2,324 59,200 57,649 2,455 2,455 62,560 n/o SR 12 82,761 2,919 2,919 88,600 99,295 3,503 3,503 106,300 Airport Blvd. w/o SR 29 9,899 300 300 10,500 9,749 296 296 10,341 State Route 12 e/o N. Kelly Road 31,284 1,874 1,874 35,033 32,182 1,928 1,928 36,038 w/o Red Top Road 33,312 1,933 1,933 37,179 34,143 1,982 1,982 38,106 State Route 37 w/o SR 29 37,861 1,059 1,059 39,980 37,003 1,035 1,035 39,074 e/o SR 29 59,370 1,562 1,562 62,495 60,412 1,590 1,590 63,592 e/o Fairgrounds Road 66,108 1,846 1,846 69,800 66,108 1,846 1,846 69,800 e/o I-80 41,013 494 494 42,000 46,653 561 561 47,776
American Cyn Rd. w/o SR 29 14,930 200 200 15,330 10,650 143 143 10,935 e/o Flosden Road 10,684 44 44 10,771 14,079 57 57 14,194 w/o I-80 3,648 214 214 4,076 6,811 400 400 7,610
Hiddenbrook Pkwy e/o I-80 5,858 83 83 6,023 6,753 95 95 6,943 Flosden Road s/o American Canyon Road 20,884 313 313 21,510 28,508 427 427 29,362 Newell Drive n/o American Canyon Road 9,485 100 100 9,685 27,491 291 291 28,072 s/o Napa Junction Road - - - - 21,339 226 226 21,790
South Kelly Road s/o SR 12 1,586 8 8 1,602 11,197 57 57 11,310 Devlin Road n/o Green Island Road - - - - 261 2,481 2,481 5,224 Vehicle Mix: Existing and Forecast Volumes
Existing 2022 Future 2040
463
Roadway Location
7 a.m.-7
p.m.
7 p.m. - 10
p.m.
10 p.m. - 7
a.m.

Existing
2022
Count
7 a.m.-7
p.m.
7 p.m. - 10
p.m.
10 p.m. - 7
a.m.

Future
2040
Forecast
Interstate 80 s/o SR 37 85,166 14,686 10,154 110,006 90,979 15,688 10,847 117,514 s/o American Canyon Road 84,420 14,557 10,065 109,042 94,445 16,286 11,261 121,991 s/o Red Top Road 87,213 15,039 10,398 112,650 99,721 17,196 11,890 128,806 s/o SR 12 75,702 13,054 9,026 97,782 88,240 15,216 10,521 113,977 n/o SR 12 105,837 18,250 12,619 136,706 120,528 20,784 14,371 155,682 State Route 29 s/o SR 37 19,692 3,110 1,249 24,051 21,336 3,369 1,353 26,059 n/o SR 37 34,302 5,783 3,398 43,483 31,904 5,379 3,161 40,444 s/o Mini Drive 29,794 4,881 2,816 37,492 29,932 4,904 2,829 37,666 n/o Mini Drive 35,449 5,512 2,508 43,469 35,535 5,525 2,514 43,575 n/o American Canyon Road 40,432 6,287 2,861 49,579 41,698 6,484 2,950 51,132 s/o Napa Junction Road 33,241 5,169 2,352 40,762 29,401 4,572 2,080 36,053 n/o Napa Junction Road 48,150 7,487 3,407 59,044 49,183 7,647 3,480 60,310 n/o Green Island Road 49,144 7,641 3,477 60,263 50,715 7,886 3,588 62,189 s/o SR 12 48,278 7,507 3,416 59,200 51,018 7,933 3,610 62,560 n/o SR 12 72,253 11,234 5,112 88,600 86,688 13,479 6,134 106,300 Airport Blvd. w/o SR 29 8,831 462 1,207 10,500 8,697 455 1,189 10,341 State Route 12 e/o N. Kelly Road 25,912 2,831 6,291 35,033 26,655 2,912 6,471 36,038 w/o Red Top Road 27,499 3,004 6,676 37,179 28,185 3,079 6,842 38,106 State Route 37 w/o SR 29 31,180 5,397 3,402 39,980 30,474 5,275 3,325 39,074 e/o SR 29 48,740 8,437 5,318 62,495 49,595 8,585 5,412 63,592 e/o Fairgrounds Road 54,437 9,423 5,940 69,800 54,437 9,423 5,940 69,800 e/o I-80 32,756 5,670 3,574 42,000 37,261 6,450 4,066 47,776 American Cyn Rd. w/o SR 29 12,528 1,722 1,080 15,330 8,937 1,228 770 10,935 e/o Flosden Road 8,803 1,210 759 10,771 11,600 1,594 1,000 14,194 w/o I-80 3,331 458 287 4,076 6,219 855 536 7,610
Hiddenbrook Pkwy e/o I-80 4,757 771 495 6,023 5,484 888 571 6,943 Flosden Road s/o American Canyon Road 17,605 2,381 1,524 21,510 24,032 3,250 2,080 29,362 Newell Drive n/o American Canyon Road 8,220 1,045 420 9,685 23,825 3,029 1,218 28,072 s/o Napa Junction Road - - - - 18,494 2,351 945 21,790
South Kelly Road s/o SR 12 1,417 123 62 1,602 10,004 871 435 11,310 Devlin Road n/o Green Island Road - - - - 5,133 0 91 5,224 Time of Day Distribution
Existing 2022 Future 2040
464
ID Leq-24hr Ldn CNEL 70 dBA 65 dBA 60 dBA Roadway Segment ADT Posted Speed Limit Grade % Autos % Med Trucks
% Heavy
Trucks
%
Daytime % Evening % Night Number of Lanes
Site
Condition
Distance to
Reciever
Ground
Absorption
Lane
Distance
1 80.3 83.0 83.6 404 870 1874 Interstate 80 s/o SR 37 110,006 65 0.0% 93.7% 3.1% 3.1% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 2 80.2 82.8 83.4 394 849 1829 Interstate 80 s/o American Canyon Road109,042 65 0.0% 94.4% 2.8% 2.8% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 3 80.4 83.0 83.6 405 873 1881 Interstate 80 s/o Red Top Road 112,650 65 0.0% 94.1% 2.9% 2.9% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 4 79.8 82.4 83.0 369 795 1712 Interstate 80 s/o SR 12 97,782 65 0.0% 94.1% 2.9% 2.9% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 5 81.6 84.3 84.9 492 1059 2282 Interstate 80 n/o SR 12 136,706 65 0.0% 91.8% 4.1% 4.1% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 6 70.8 72.4 73.2 82 176 378 State Route 29 s/o SR 37 24,051 55 0.0% 97.9% 1.1% 1.1% 81.9% 12.9% 5.2% 4 Soft 50 0.5 44 7 74.1 76.4 77.1 148 319 688 State Route 29 n/o SR 37 43,483 55 0.0% 95.1% 2.4% 2.4% 78.9% 13.3% 7.8% 4 Soft 50 0.5 44 8 73.4 75.7 76.3 132 285 614 State Route 29 s/o Mini Drive 37,492 55 0.0% 95.2% 2.4% 2.4% 79.5% 13.0% 7.5% 4 Soft 50 0.5 44 9 74.0 75.8 76.6 137 295 636 State Route 29 n/o Mini Drive 43,469 55 0.0% 95.4% 2.3% 2.3% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 10 74.5 76.3 77.1 148 319 687 State Route 29n/o American Canyon Road49,579 55 0.0% 95.6% 2.2% 2.2% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 11 74.5 76.3 77.1 148 318 685 State Route 29 s/o Napa Junction Road40,762 55 0.0% 93.1% 3.4% 3.4% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 12 76.1 77.9 78.6 188 405 874 State Route 29 n/o Napa Junction Road59,044 55 0.0% 92.2% 3.9% 3.9% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 13 76.6 78.5 79.2 205 441 950 State Route 29 n/o Green Island Road 60,263 55 0.0% 89.9% 5.1% 5.1% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 14 76.4 78.2 78.9 196 421 908 State Route 29 s/o SR 12 59,200 55 0.0% 92.2% 3.9% 3.9% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 15 77.8 79.6 80.4 245 528 1139 State Route 29 n/o SR 12 88,600 55 0.0% 93.4% 3.3% 3.3% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 16 66.2 69.3 69.5 46 100 215 Airport Blvd w/o SR 29 10,500 45 0.0% 94.3% 2.9% 2.9% 84.1% 4.4% 11.5% 4 Soft 50 0.5 44 17 74.3 78.5 78.8 193 415 894 State Route 12 e/o N. Kelly Road 35,033 55 0.0% 89.3% 5.4% 5.4% 74.0% 8.1% 18.0% 3 Soft 50 0.5 32 18 74.5 78.7 78.9 197 424 914 State Route 12 w/o Red Top Road 37,179 55 0.0% 89.6% 5.2% 5.2% 74.0% 8.1% 18.0% 2 Soft 50 0.5 20 19 73.8 76.3 77.0 146 314 675 State Route 37 w/o SR 29 39,980 55 0.0% 94.7% 2.7% 2.7% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 20 75.7 78.2 78.8 194 418 900 State Route 37 e/o SR 29 62,495 55 0.0% 95.0% 2.5% 2.5% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 21 76.2 78.7 79.4 211 454 979 State Route 37 e/o Fairgrounds Road 69,800 55 0.0% 94.7% 2.6% 2.6% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 22 73.5 76.0 76.6 138 298 642 State Route 37 e/o I-80 42,000 55 0.0% 97.7% 1.2% 1.2% 78.0% 13.5% 8.5% 6 Soft 50 0.5 68 23 66.8 68.9 69.5 46 100 216 American Canyon Rd w/o SR 29 15,330 45 0.0% 97.4% 1.3% 1.3% 81.7% 11.2% 7.0% 4 Soft 50 0.5 44 24 64.4 66.5 67.1 32 69 148 American Canyon Rd e/o Flosden Road 10,771 45 0.0% 99.2% 0.4% 0.4% 81.7% 11.2% 7.0% 2 Soft 50 0.5 20 25 63.3 65.4 66.0 27 58 125 American Canyon Rd w/o I-80 4,076 45 0.0% 89.5% 5.3% 5.3% 81.7% 11.2% 7.0% 2 Soft 50 0.5 20 26 61.4 63.9 64.5 21 46 100 Hiddenbrook Pkwy e/o I-80 6,023 40 0.0% 97.3% 1.4% 1.4% 79.0% 12.8% 8.2% 2 Soft 50 0.5 20 27 68.4 70.5 71.1 59 128 275 Flosden Road s/o American Canyon Road 21,510 45 0.0% 97.1% 1.5% 1.5% 81.8% 11.1% 7.1% 4 Soft 50 0.5 44 28 61.9 63.4 64.0 20 43 93 Newell Drive n/o American Canyon Road 9,685 35 0.0% 97.9% 1.0% 1.0% 84.9% 10.8% 4.3% 4 Soft 50 0.5 44 29 57.4 58.7 59.2 10 21 44 South Kelly Road s/o SR 12 1,602 50 0.0% 99.0% 0.5% 0.5% 88.5% 7.7% 3.9% 2 Soft 50 0.5 20 Auto Inputs
Traffic Noise Calculator: FHWA 77-108 Project Title: 19-08673 American Canyon General Plan EIR - Existing 2022 dBA at 50 feet Distance to CNEL Contour
Output Inputs
465
ID Leq-24hr Ldn CNEL 70 dBA 65 dBA 60 dBA Roadway Segment ADT Posted Speed Limit Grade % Autos % Med Trucks
% Heavy
Trucks
%
Daytime % Evening % Night Number of Lanes
Site
Condition
Distance to
Reciever
Ground
Absorption
Lane
Distance
1 80.6 83.3 83.9 422 909 1958 Interstate 80 s/o SR 37 117,514 65 0.0% 93.7% 3.1% 3.1% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 2 80.7 83.3 83.9 425 915 1971 Interstate 80 s/o American Canyon Road121,991 65 0.0% 94.4% 2.8% 2.8% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 3 81.0 83.6 84.2 443 955 2057 Interstate 80 s/o Red Top Road 128,806 65 0.0% 94.1% 2.9% 2.9% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 4 80.4 83.0 83.7 408 880 1896 Interstate 80 s/o SR 12 113,977 65 0.0% 94.1% 2.9% 2.9% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 5 82.2 84.8 85.5 536 1155 2489 Interstate 80 n/o SR 12 155,682 65 0.0% 91.8% 4.1% 4.1% 77.4% 13.4% 9.2% 6 Soft 50 0.5 68 6 71.1 72.8 73.5 86 185 399 State Route 29 s/o SR 37 26,059 55 0.0% 97.9% 1.1% 1.1% 81.9% 12.9% 5.2% 4 Soft 50 0.5 44 7 73.8 76.1 76.8 141 304 656 State Route 29 n/o SR 37 40,444 55 0.0% 95.1% 2.4% 2.4% 78.9% 13.3% 7.8% 4 Soft 50 0.5 44 8 73.4 75.7 76.4 133 286 616 State Route 29 s/o Mini Drive 37,666 55 0.0% 95.2% 2.4% 2.4% 79.5% 13.0% 7.5% 4 Soft 50 0.5 44 9 74.0 75.9 76.6 137 296 637 State Route 29 n/o Mini Drive 43,575 55 0.0% 95.4% 2.3% 2.3% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 10 74.7 76.5 77.2 151 325 701 State Route 29n/o American Canyon Road51,132 55 0.0% 95.6% 2.2% 2.2% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 11 74.0 75.8 76.5 136 293 631 State Route 29 s/o Napa Junction Road36,053 55 0.0% 93.1% 3.4% 3.4% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 12 76.2 78.0 78.7 191 411 886 State Route 29 n/o Napa Junction Road60,310 55 0.0% 92.2% 3.9% 3.9% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 13 76.8 78.6 79.3 209 450 970 State Route 29 n/o Green Island Road 62,189 55 0.0% 89.9% 5.1% 5.1% 81.6% 12.7% 5.8% 4 Soft 50 0.5 44 14 76.6 78.4 79.1 203 437 942 State Route 29 s/o SR 12 62,560 55 0.0% 92.2% 3.9% 3.9% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 15 78.6 80.4 81.2 277 597 1286 State Route 29 n/o SR 12 106,300 55 0.0% 93.4% 3.3% 3.3% 81.6% 12.7% 5.8% 6 Soft 50 0.5 68 16 66.2 69.2 69.4 46 99 213 Airport Blvd w/o SR 29 10,341 45 0.0% 94.3% 2.9% 2.9% 84.1% 4.4% 11.5% 4 Soft 50 0.5 44 17 74.4 78.6 78.9 196 423 911 State Route 12 e/o N. Kelly Road 36,038 55 0.0% 89.3% 5.4% 5.4% 74.0% 8.1% 18.0% 3 Soft 50 0.5 32 18 74.6 78.8 79.0 200 431 930 State Route 12 w/o Red Top Road 38,106 55 0.0% 89.6% 5.2% 5.2% 74.0% 8.1% 18.0% 2 Soft 50 0.5 20 19 73.7 76.2 76.9 143 309 665 State Route 37 w/o SR 29 39,074 55 0.0% 94.7% 2.7% 2.7% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 20 75.8 78.2 78.9 196 422 910 State Route 37 e/o SR 29 63,592 55 0.0% 95.0% 2.5% 2.5% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 21 76.2 78.7 79.4 211 454 979 State Route 37 e/o Fairgrounds Road 69,800 55 0.0% 94.7% 2.6% 2.6% 78.0% 13.5% 8.5% 4 Soft 50 0.5 44 22 74.1 76.5 77.2 151 325 699 State Route 37 e/o I-80 47,776 55 0.0% 97.7% 1.2% 1.2% 78.0% 13.5% 8.5% 6 Soft 50 0.5 68 23 65.3 67.5 68.1 37 80 172 American Canyon Rd w/o SR 29 10,935 45 0.0% 97.4% 1.3% 1.3% 81.7% 11.2% 7.0% 4 Soft 50 0.5 44 24 65.6 67.7 68.3 38 83 178 American Canyon Rd e/o Flosden Road 14,194 45 0.0% 99.2% 0.4% 0.4% 81.7% 11.2% 7.0% 2 Soft 50 0.5 20 25 66.0 68.1 68.7 41 88 190 American Canyon Rd w/o I-80 7,610 45 0.0% 89.5% 5.3% 5.3% 81.7% 11.2% 7.0% 2 Soft 50 0.5 20 26 62.1 64.5 65.1 24 51 110 Hiddenbrook Pkwy e/o I-80 6,943 40 0.0% 97.3% 1.4% 1.4% 79.0% 12.8% 8.2% 2 Soft 50 0.5 20 27 69.7 71.9 72.5 73 157 339 Flosden Road s/o American Canyon Road 29,362 45 0.0% 97.1% 1.5% 1.5% 81.8% 11.1% 7.1% 4 Soft 50 0.5 44 28 66.6 68.0 68.7 41 88 189 Newell Drive n/o American Canyon Road 28,072 35 0.0% 97.9% 1.0% 1.0% 84.9% 10.8% 4.3% 4 Soft 50 0.5 44 29 65.5 66.9 67.6 34 74 160 Newell Drive s/o Napa Junction Road21,790 35 0.0% 97.9% 1.0% 1.0% 84.9% 10.8% 4.3% 4 Soft 50 0.5 44 30 65.9 67.2 67.7 35 75 163 South Kelly Road s/o SR 12 11,310 50 0.0% 99.0% 0.5% 0.5% 88.5% 7.7% 3.9% 2 Soft 50 0.5 20 31 71.2 71.7 71.8 65 141 304 Devlin Road n/o Green Island Road 5,224 40 0.0% 5.0% 47.5% 47.5% 98.3% 0.1% 1.6% 2 Soft 50 0.5 20 Auto Inputs
Traffic Noise Calculator: FHWA 77-108 Project Title: 19-08673 American Canyon General Plan - Future 2040 dBA at 50 feet Distance to CNEL Contour
Output Inputs
466
Roadway Segment Existing ADT 2040 Buildout ADT Existing Traffic Noise Level at 50 feet (dBA CNEL)
2040 Traffic Noise Level
at 50 feet (dBA CNEL)
Traffic Noise
Increase (dBA
CNEL)
Significant?
(Y/N)
I-80 South of SR 37 110,006 117,514 83.6 83.9 0.3 N
I-80 South of American Canyon Road 109,042 121,991 83.4 83.9 0.5 N I-80 South of Red Top Road 112,650 128,806 83.6 84.2 0.6 N I-80 South of SR 12 97,782 113,977 83.0 83.7 0.7 N
I-80 North of SR 12 136,706 155,682 84.9 85.5 0.6 N
SR 29 South of SR 37 24,051 26,059 73.2 73.5 0.3 N
SR 29 North of SR 37 43,483 40,444 77.1 76.8 -0.3 N
SR 29 South of Mini Drive 37,492 37,666 76.3 76.4 0.0 N SR 29 North of Mini Drive 43,469 43,575 76.6 76.6 0.0 N SR 29 North of American Canyon Road 49,579 51,132 77.1 77.2 0.1 N SR 29 South of Napa Junction Road 40,762 36,053 77.1 76.5 -0.5 N SR 29 North of Napa Junction Road 59,044 60,310 78.6 78.7 0.1 N SR 29 North of Green Island Road 60,263 62,189 79.2 79.3 0.1 N SR 29 South of SR 12 59,200 62,560 78.9 79.1 0.2 N
SR 29 North of SR 12 88,600 106,300 80.4 81.2 0.8 N
Airport Boulevard West of SR 29 10,500 10,341 69.5 69.4 -0.1 N SR 12 East of North Kelly Road 35,033 36,038 78.8 78.9 0.1 N SR 12 West of Red Top Road 37,179 38,106 78.9 79.0 0.1 N SR 37 West of SR 29 39,980 39,074 77.0 76.9 -0.1 N
SR 37 East of SR 29 62,495 63,592 78.8 78.9 0.1 N
SR 37 East of Fairgrounds Road 69,800 69,800 79.4 79.4 0.0 N SR 37 East of I-80 42,000 47,776 76.6 77.2 0.6 N
American Canyon Road West of SR 29 15,330 10,935 69.5 68.1 -1.5 N American Canyon Road East of Flosden Road 10,771 14,194 67.1 68.3 1.2 N American Canyon Road West of I-80 4,076 7,610 66.0 68.7 2.7 Y Hiddenbrook Parkway East of I-80 6,023 6,943 64.5 65.1 0.6 N Flosden Road South of American Canyon Road 21,510 29,362 71.1 72.5 1.4 N Newell Drive North of American Canyon Road 9,685 28,072 64.0 68.7 4.6 Y Newell Drive South of Napa Junction Road - 21,790 - 67.6 - N South Kelly Road South of SR 12 1,602 11,310 59.2 67.7 8.5 Y Devlin Road North of Green Island Road - 5,224 - 71.8 - N 467
Noise Model
Noise Model Based on Federal Transit Adminstration General Transit Noise Assessment Developed for Chicago Create Project
Copyright 2006, HMMH Inc.

Case:

Noise Source
All Sources
Source 1
Source 2
Source 3
Source 4
Source 5
Source 6
Source 7
Source 8
Enter noise receiver land use category below.
2 Enter data for up to 8 noise sources below - see reference list for source numbers.

NOISE SOURCE PARAMETERS
Parameter
Source Num. Freight Locomotive 9 Freight Cars 10
Distance (source to receiver) distance (ft) 35 distance (ft) 35 Daytime Hours speed (mph) speed (mph)
(7 AM - 10 PM) trains/hour trains/hour
locos/train length of cars (ft) / train
Nighttime Hours speed (mph) 10 speed (mph) 10
(10 PM - 7 AM) trains/hour 0.45 trains/hour 0.45
locos/train 1 length of cars (ft) / train 900
Wheel Flats? % of cars w/ wheel flats 0.00%
Jointed Track? Y/N n Y/N n
Embedded Track? Y/N n Y/N n
Aerial Structure? Y/N n Y/N n
Barrier Present? Y/N n Y/N n
Intervening Rows of of Buildings number of rows number of rows Source Number
Commuter Electric Locomotive 1
Commuter Diesel Locomotive 2
Commuter Rail Cars 3
RRT/LRT 4
AGT, Steel Wheel 5
AGT, Rubber Tire 6
Monorail 7
Maglev 8
Freight Locomotive 9
Freight Cars 10
Hopper Cars (empty) 11
Hopper Cars (full) 12
Crossover 13
Automobiles 14
City Buses 15
Commuter Buses 16
Rail Yard or Shop 17
Layover Tracks 18
Bus Storage Yard 19
Bus Op. Facility 20
Bus Transit Center 21
Parking Garage 22
Park & Ride Lot 23

RESULTS
Source 1 Source 2 Source 3
54 57
59 Leq - nighttime (dB)

LAND USE CATEGORY
Noise receiver land use category (1, 2 or 3)
0 0
Leq - daytime (dB)
41 41
24 0
0 0
0 0
0 0
0 0
0 0
0 CFNR - Calistoga to Vallejo
0 SOURCE REFERENCE LIST
Ldn (dB)
65 63
60 0
0 0

468
Noise Model
Noise Model Based on Federal Transit Adminstration General Transit Noise Assessment Developed for Chicago Create Project
Copyright 2006, HMMH Inc.

Case:

Noise Source
All Sources
Source 1
Source 2
Source 3
Source 4
Source 5
Source 6
Source 7
Source 8
Enter noise receiver land use category below.
2 Enter data for up to 8 noise sources below - see reference list for source numbers.

NOISE SOURCE PARAMETERS
Parameter
Source Num. Freight Locomotive 9 Freight Cars 10
Distance (source to receiver) distance (ft) 50 distance (ft) 50 Daytime Hours speed (mph) speed (mph)
(7 AM - 10 PM) trains/hour trains/hour
locos/train length of cars (ft) / train
Nighttime Hours speed (mph) 25 speed (mph) 25
(10 PM - 7 AM) trains/hour 0.6 trains/hour 0.6
locos/train 1 length of cars (ft) / train 900
Wheel Flats? % of cars w/ wheel flats 0.00%
Jointed Track? Y/N n Y/N n
Embedded Track? Y/N n Y/N n
Aerial Structure? Y/N n Y/N n
Barrier Present? Y/N n Y/N n
Intervening Rows of of Buildings number of rows number of rows Source Number
Commuter Electric Locomotive 1
Commuter Diesel Locomotive 2
Commuter Rail Cars 3
RRT/LRT 4
AGT, Steel Wheel 5
AGT, Rubber Tire 6
Monorail 7
Maglev 8
Freight Locomotive 9
Freight Cars 10
Hopper Cars (empty) 11
Hopper Cars (full) 12
Crossover 13
Automobiles 14
City Buses 15
Commuter Buses 16
Rail Yard or Shop 17
Layover Tracks 18
Bus Storage Yard 19
Bus Op. Facility 20
Bus Transit Center 21
Parking Garage 22
Park & Ride Lot 23
CFNR - Ignacio to Fairfield/Suisun
0 SOURCE REFERENCE LIST
Ldn (dB)
65 63
60 0
0 0
0 0
0 0
0 0
0 0
0 0 0
Leq - daytime (dB)
38 38
21 0
0 0

RESULTS
Source 1 Source 2 Source 3
55 57
59 Leq - nighttime (dB)

LAND USE CATEGORY
Noise receiver land use category (1, 2 or 3)

469
User Input Noise Situation Shielding Ldn 65 Contours Numeric Output (in feet) Noise Situation (Pick from List) 1 Horns Existing and Future 1 Dense Urban 1 Existing 65 Ldn Contour at X-ing 199 Horn Lmax (dBA) @ 100 feet 104 Horns in Future Only 2 Light Urban 2 Future 65 Ldn Contour at X-ing 199 Horn Location on Locomotive(Pick from List) 1 No Horns Existing and Future 3 Dense Suburban 3 Existing 65 Ldn Contour at 1/2 zone length 149 Non Train Noise Environment (pick from list) 2 Light Suburban 4 Future 65 Ldn Contour at 1/2 zone length 149 Shielding (Pick from List) 3 Horn Location on Locomotive Rural 5 Zone Length 1320 Length of Impact Area (pick from list) 1 National Average (50% front, 50% middle) 1 No Shielding 6 1/2 Zone Length 660 Existing Train Speed (mph) 10 All Front Mounted 2
Future Train Speed (mph) 10 All Middle Mounted 3 Length of Impact Area Impact Zones Numeric Output (in feet) Number of Existing Trains in one Direction 2 User Defined 80 % front mounted horns 4 1/4 mile 1 Impact Distance at X-ing 0 Number of Future Trains in one Direction 2 20 seconds 2 Severe Impact Distance at X-ing 0 Existing Number of Day Trains (7 am to 10 p.m.) 1.25 Non Train Noise Environment 15 seconds 3 Impact Distance at 1/2 zone length 0 Future Number of Day Trains (7 am to 10 p.m.) 1.25 Urban 1 Severe Impact Distance at 1/2 zone length 0 Existing Number of Night Trains (10 p.m. to 7 am) 0.75 Suburban 2 Zone Length 1320 Future Number of Night Trains (10 p.m. to 7 am) 0.75 Rural 3 1/2 Zone Length 660 Existing Average Number of Cars 15 User Defined Ldn = 50 dBA 4 Future Average Number of Cars 15
Existing Average Number of Locomotives 1
Future Average Number of Locomotives 1
FRA Grade Crossing Noise Model
-2000
-1500
-1000
-500
0 500
1000
1500
2000
1320
660
0 660
Distance (ft)
1320
Distance (ft)
Ldn 65 Contours
-2000
-1500
-1000
-500
0 500
1000
1500
2000
1320
660
0 660
Distance (ft)
1320
Distance (ft)
Impact Zones
470
User Input Noise Situation Shielding Ldn 65 Contours Numeric Output (in feet) Noise Situation (Pick from List) 1 Horns Existing and Future 1 Dense Urban 1 Existing 65 Ldn Contour at X-ing 218 Horn Lmax (dBA) @ 100 feet 104 Horns in Future Only 2 Light Urban 2 Future 65 Ldn Contour at X-ing 218 Horn Location on Locomotive(Pick from List) 1 No Horns Existing and Future 3 Dense Suburban 3 Existing 65 Ldn Contour at 1/2 zone length 163 Non Train Noise Environment (pick from list) 2 Light Suburban 4 Future 65 Ldn Contour at 1/2 zone length 163 Shielding (Pick from List) 3 Horn Location on Locomotive Rural 5 Zone Length 1320 Length of Impact Area (pick from list) 1 National Average (50% front, 50% middle) 1 No Shielding 6 1/2 Zone Length 660 Existing Train Speed (mph) 25 All Front Mounted 2
Future Train Speed (mph) 25 All Middle Mounted 3 Length of Impact Area Impact Zones Numeric Output (in feet) Number of Existing Trains in one Direction 2.5 User Defined 80 % front mounted horns 4 1/4 mile 1 Impact Distance at X-ing 0 Number of Future Trains in one Direction 2.5 20 seconds 2 Severe Impact Distance at X-ing 0 Existing Number of Day Trains (7 am to 10 p.m.) 1.5625 Non Train Noise Environment 15 seconds 3 Impact Distance at 1/2 zone length 0 Future Number of Day Trains (7 am to 10 p.m.) 1.5625 Urban 1 Severe Impact Distance at 1/2 zone length 0 Existing Number of Night Trains (10 p.m. to 7 am) 0.9375 Suburban 2 Zone Length 1320 Future Number of Night Trains (10 p.m. to 7 am) 0.9375 Rural 3 1/2 Zone Length 660 Existing Average Number of Cars 15 User Defined Ldn = 50 dBA 4 Future Average Number of Cars 15
Existing Average Number of Locomotives 1
Future Average Number of Locomotives 1
FRA Grade Crossing Noise Model
-2000
-1500
-1000
-500
0 500
1000
1500
2000
1320
660
0 660
Distance (ft)
1320
Distance (ft)
Ldn 65 Contours
-2000
-1500
-1000
-500
0 500
1000
1500
2000
1320
660
0 660
Distance (ft)
1320
Distance (ft)
Impact Zones
471
American Canyon
2040 General Plan Update
Final Environmental Impact Report
SCH# 2022070038
prepared by
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, California 94503
Contact: Brent Cooper, AICP, Community Development Director prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
March 2025
ATTACHMENT 1, EXHIBIT C
472
Table of Contents
Final Environmental Impact Report i
Table of Contents
1 Introduction................................................................................................................................1-1

1.1 Final EIR Contents...........................................................................................................1-1

1.2 Draft EIR Public Review Process......................................................................................1-1

1.3 EIR Certification Process and Project Approval ..............................................................1-2 2 Responses to Comments on the Draft EIR..................................................................................2-1

2.1 Comment Letters and Responses...................................................................................2-1 3 Minor Revisions to the Draft EIR ................................................................................................3-1

3.1 Revisions to the Draft EIR................................................................................................3-1 4 Recirculation Not Warranted......................................................................................................4-1 Appendices
Revised Appendix B Special Status Species
473
City of American Canyon
American Canyon 2040 General Plan Update
ii
This page intentionally left blank.
474
Introduction
Final Environmental Impact Report 1-1
Introduction

1.1 Final EIR Contents
This Final Environmental Impact Report (EIR) has been prepared by the City of American Canyon (City) to evaluate the potential environmental impacts of the proposed 2040 General Plan Update Project (hereafter also referred to as “project”).

Pursuant to California Environmental Quality Act (CEQA) Guidelines Sections 15088 and 15132, the City of American Canyon, as the lead agency, is required to evaluate comments on environmental issues received from persons who have reviewed the Draft EIR and to prepare written responses to those comments. This document together with the Draft EIR (incorporated by reference) comprise the Final EIR for the project. This Final EIR includes individual responses to each letter received during the public review period for the Draft EIR. In accordance with CEQA Guidelines Section 15088(c), the written responses describe the disposition of significant environmental issues raised.

The City has provided a good faith effort to respond to all significant environmental issues raised by the comments. The Final EIR also includes minor clarifications, corrections, or revisions to the Draft EIR suggested by certain comments. The Final EIR includes the following contents:
 Section 1: Introduction
 Section 2: Responses to Comments on the Draft EIR
 Section 3: Minor Revisions to the Draft EIR
 Section 4: Recirculation Not Warranted

1.2 Draft EIR Public Review Process
Pursuant to CEQA, lead agencies are required to consult with public agencies with jurisdiction over a proposed project and to provide the general public with an opportunity to comment on the Draft EIR.

The City of American Canyon filed a notice of completion (NOC) with the Governor’s Office of Planning and Research to begin a minimum of a 45-day public review period (Public Resources Code [PRC] Section 21161), which began on September 27, 2024, and ended on December 27, 2024. The Draft EIR was made available on the City’s website.1 In addition, the Draft EIR was made available for review at the City’s offices at 4381 Broadway Street, Suite 201; the City Library at 300 Crawford Way; and the Active Adults Center at 2185 Elliot Drive. A Notice of Availability (NOA) of the Draft EIR was published on September 27, 2024. As a result of these notification efforts, the City received eight written comments on the content of the Draft EIR. Section 2, “Responses to Comments on the Draft EIR,” identifies these commenting parties, their respective comments, and responses to these comments. None of the comments received, or the responses provided, constitute “significant new information” by CEQA standards (CEQA Guidelines Section 15088.5). 1 Draft EIR for the project is available here: https://portal.laserfiche.com/Portal/DocView.aspx?id=232476&repo=r-f53bdda4 475
City of American Canyon
American Canyon 2040 General Plan Update
1-2

1.3 EIR Certification Process and Project Approval
Before adopting the project, the lead agency is required to certify that the EIR has been completed in compliance with CEQA, that the decision-making body reviewed and considered the information in the EIR, and that the EIR reflects the independent judgment of the lead agency.

Upon certification of an EIR, the lead agency makes a decision on the project analyzed in the EIR. A lead agency may: (a) disapprove a project because of its significant environmental effects; (b) require changes to a project to reduce or avoid significant environmental effects; or (c) approve a project despite its significant environmental effects, if the proper findings and statement of overriding considerations are adopted (CEQA Guidelines Sections 15042 and 15043).

In approving a project, for each significant impact of the project identified in the EIR, the lead or responsible agency must find, based on substantial evidence, that either: (a) the project has been changed to avoid or substantially reduce the magnitude of the impact; (b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or (c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (CEQA Guidelines Section 15091). Pursuant to PRC Section 21061.1, feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account, economic, environmental, legal, social, and technological factors.

While the information in the EIR does not constrain the City’s ultimate decision under its land use authority, the City must respond to each significant effect and mitigation measure identified in the EIR as required by CEQA by making findings supporting its decision. If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision and explains why the project’s benefits outweigh the significant environmental effects (CEQA Guidelines Section 15093).

When an agency makes findings on significant effects identified in the EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects (CEQA Guidelines Section 15091[d]). 476
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Responses to Comments on the Draft EIR
This section includes comments received during public circulation of the Draft Environmental Impact Report (EIR) prepared for the City of American Canyon 2040 General Plan Update project. The comment letters included herein were submitted to the City of American Canyon by public agencies, an organization, and individuals. The City prepared these responses to written comments received to address the environmental concerns raised by the commenters and to indicate where and how the Draft EIR addresses pertinent environmental issues. The Draft EIR was circulated for a 111-day public review period that began on September 27, 2024, and ended on December 27, 2024. The City of American Canyon received nine comment letters on the Draft EIR. The commenters and the page number on which each commenter’s letter appear are listed below.

Letter No. and Commenter Page No.
1 Napa Climate NOW! 2-2
2 Maia Medalle 2-10
3 Jodi Cruz 2-12
4 Caltrans 2-14
5 Yvonne Baginski 2-22
6 California Department of Fish and Wildlife 2-38
7 Napa County Bicycle Coalition 2-67
8 Clark Morrison 2-77
9 Napa Valley Transportation Authority 2-79

2.1 Comment Letters and Responses
Written responses to each comment letter received on the Draft EIR are provided in this section. All letters received on the Draft EIR are provided in their entirety. The comment letters have been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1-1, for example, indicates that the response is for the first issue raised in comment Letter 1).

Revisions made to the text of the Draft EIR are provided in Section 3, Minor Revisions to the Draft EIR, including corrected information, data, or intent. Where a comment results in a revision to the Draft EIR text, a notation is made in the response indicating that the text is revised. Within the Minor Revisions to the Draft EIR, revisions in text are signified by strikeouts (strikeouts) where text is removed and by underlined font (underlined font) where text is added.

Following public review of an EIR, lead agencies are directed to “evaluate comments on environmental issues received from persons who reviewed the draft EIR and prepare a written response” (CEQA Guidelines Section 15088(a)). Some of the comments that were received on the Draft EIR did not address specific environmental issues or effects associated with the project or the adequacy of the analysis contained in the Draft EIR. No additional analysis or response is required for these types of comments. All comments, however, will be noted and made available to applicable decision-makers as they consider the project. 2-1
477
2 Dear Planning Commissioners,
The website eComment portal can accommodate part of our comment Please accept our complete comment, including reference materials, below.

Thank you for all you are doing to develop a General Plan to guide the development of American Canyon through 2040.

The goals and policies you adopt are crucial to safeguarding the lives and livelihoods of American Canyon residents and, in the process, helping all of Napa County and beyond in becoming more climate resilient.

We are writing this letter today to weigh in on this important General Plan workshop discussion; namely, whether American Canyon should retain its 2030 net-zero focus as a firm commitment. Current drafts of the General Plan Policy Document and Draft EIR do not specify this goal. On behalf of residents throughout Napa County, we urge you to stand strong in support of the 2030 goal, along with each of the other jurisdictions in Napa County, Napa Valley Unified School District, Napa RCD, and surrounding communities.

American Canyon has been a leader in the county, inspiring other jurisdictions with its climate-positive initiatives – water savings, residential energy efficiency scoring requirements above minimum building code levels, solar installations, no new gas stations, open space commitments, new bike lanes, and more. These initiatives are serving the vital interests of American Canyon residents and are important building blocks toward climate resilience. They are also in line with the 2030 net zero climate pollution goal.

Pulling back from a firm 2030 commitment could easily undermine these initiatives in the coming years, which face recurring challenges from interested parties. Pulling back could also delay or prevent the adoption of additional measures needed to protect city residents and environs, and discourage collective Countywide Climate Action Committee efforts. As guardians of the public trust, elected government officials and agencies, and committees and commissions established in the public interest, such as the Planning Commission, are in a unique position to weigh the benefits and costs of development from a holistic community perspective. And now, more than ever, there is a need for this kind of leadership as climate change continues to accelerate unabated.

The science is clearly on the side of 2030. In the latest intergovernmental consensus report (IPCC AR6), the world’s climate scientists agreed that the earth is very likely to exceed the dangerous threshold of 1.5°C above normal on a sustained basis by the early 2030s, and as early as 2030. (The planet has already surpassed this threshold, first in 2015 and again this year.) As you know, record heat waves, hurricanes, flooding, and wildfires have put communities across the country at extreme risk, along with whole ecosystems vital to our environment and economy. Smoke blanketing large parts of the county are another stark reminder of what we have lived through in recent years, with clear respiratory and other health consequences for American Canyon residents.

Community resources, such as Napa County Resource Conservation District, are committed to 2030 and stand ready to support cities in making the transition to net zero by 2030 through innovative farm, forest, urban and wild lands management. Our schools are committed to 2030. And state and federal resources, including millions in infrastructure and other climate funds made available through the 2022 Inflation Reduction Act, are now available to help American Canyon meet its 2030 goal.

In short, the 2030 goal post is not an artificial date established for aspirational or political purposes, but rather is grounded in unfortunate changes in climate that we simply cannot afford to ignore. Decisions and delays of the past several decades have put today’s elected officials, residents, corporations, and youth in the untenable position of having to make extremely hard choices. And every single year we delay taking decisive action to make our home more climate resilient, climate scientists remind us that our opportunity to do so diminishes. That’s because as the globe warms, devastating feedback loops are being set into motion that are accelerating the change.

At the same time, it is helpful to consider that the changes we make now can still make a difference, and indeed, support a thriving economy. In addition, it is crucial to recognize that the cost of working to achieve net zero will ultimately pay off, while the cost of inaction or delay will be much, much greater — not only in dollars and cents, but in the devastating impacts on people’s lives.

Please support the retention of 2030 as a firm net zero goal in all planning and development, for our children’s sake. 1-1
1-2
1-3
1-4
1-5
1-6
1-7
1-8
1-9
Letter 1
2-2
478
3 Sincerely,
Napa Climate NOW! Steering Committee:

Lynne Baker – nurse, grandmother
Chris Benz – retired winemaker, grandmother
Linda Brown – environmental standards and climate accounting professional, mother Marilyn Knight-Mendelson – retired educator, grandmother Jim Wilson – retired quality assurance professional, grandfather Addendum - References to commitment to a goal of net zero climate pollution by or before 2030 The City of American Canyon website, Climate & Sustainability, states in its Overview:

The City of American Canyon prides itself on being leaders in environmental action, responsible growth and a sustainable future.

It refers to the RCAAP Project Website
In 2021, each local government adopted Resolutions or Proclamations regarding the "Countywide Commitment to Address Climate Change." The resolutions include efforts to:
 A climate emergency exists and threatens our region, state, country, and world.  Each jurisdiction commits to a goal of net zero climate pollution by or before 2030 and to implement both immediate and sustained actions to achieve the goal.
 Each jurisdiction recognizes the need to work with community organizations, businesses, schools, regional partners, and jurisdictions to support comprehensive, immediate, and sustained action to achieve collaboratively with each other and alongside community organizations, businesses, schools, and regional partners goals of net zero climate pollution by or before 2030.

Napa County's Procurement Website outlines the specific requirements for the Regional Climate Action and Adaptation Plan (RCAAP), and stipulates the shared goal of the regional GHG reduction effort is to achieve net zero GHG emissions by 2030.

Napa County RFP - Regional Climate Action and Adaptation Plan ConsultantRFP No. PBES092301 The purpose of the RCAAP is to prepare a comprehensive plan for the Cities of American Canyon, Calistoga, Napa, and St. Helena, the Town of Yountville, and the County of Napa to achieve the goal of carbon neutrality (net zero greenhouse gas (GHG) emissions) by the year 2030.

It also notes the date that each of the cities adopted climate emergency resolutions with 2030 net zero emissions commitments, including American Canyon’s:

City of American Canyon adopted Resolution No. 2022-07 on February 1, 2022, which set a goal of net zero climate pollution by or before 2030.

The City of Napa, a partner in the Regional Climate Action and Adaptation Plan (RCAAP), has a newly adopted General Plan that incorporates a Climate Change and Sustainability Element. It establishes goals and policies consistent with its Climate Emergency Resolution's 2030 net zero goal:

Policy CCS 1-1 which seeks to achieve net zero climate pollutants from public and private operations within the City by 2030. It references its April 5, 2022 Climate Emergency Resolution R2022-030, and lists 57 climate actions in support of the 2030 goal.

During preparation of the Draft General Plan, on April 5, 2022, the City Council adopted Resolution R2022-030,
a resolution declaring a climate emergency, furthering
the City’s commitment to combating Climate Change. This 1-9
1-10
2-3
479
4 resolution added the City of Napa to a growing list of communities committed to a goal of Net Zero Climate pollution by 2030 and demonstrates the City’s commitment to implementing goals and policies in the General Plan
through actionable tasks and projects. Additionally, the resolution calls upon the City to evaluate all planning and policy decisions with the lens of this commitment to climate change initiatives.

Allison Bencsik, American Canyon High School student and Co-President, Napa Schools for Climate Action, presents during a hearing on Napa's proposed General Plan:

On behalf of Napa Schools for Climate Action, we wanted to thank you for listening to our concerns and for proceeding with the Climate Emergency Resolution! It has been incredible to see all the other cities and the county pass a Climate Emergency Resolution and, most importantly, commit to achieving net zero climate pollution by or before 2030. It would be amazing to see the Napa City Council make this same level of commitment in its General Plan. You, along with our schools and cities who have set the same goal, would send the message that we are in a true emergency and that you take your responsibility to our younger generation seriously.

American Canyon City Council:
 made a Climate Emergency Proclamation on 11/16/21
 passed a Climate Emergency Resolution on 2/1/22, resolving that o NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of American Canyon hereby declares the following:

1. That a Climate Emergency exists, and that it threatens our city, state, country, and the planet;

2. That the City of American Canyon joins a growing list of communities committed to a goal of Net Zero Climate Pollution, measured in terms of net contribution to excess trapped heat, by or before 2030, and further commits to evaluate all planning and policy decisions through the lens of this pledge, and to implement both immediate and sustained actions in support of its achievement; and

3. That the City Council recognizing the need for full community participation and support, commits to providing leadership and services in working with community organizations, businesses, schools, and regional partners and jurisdictions to educate, mobilize, expand, and accelerate local, regional and statewide support for comprehensive, immediate, and sustained action to achieve its goal of net zero climate pollution by or before 2030; and

4. That the City Council will consider amendments to its General Plan and its 2012 Energy Efficiency/Climate Action Plan, consistent with its commitment to net zero climate pollution by or before 2030. 1-10
2-4
480
5 o BE IT FURTHER RESOLVED that the City Council directs its Ad Hoc Climate Action Committee to complete the following:

1. Develop specific recommendations and measurable outcomes to achieve the goal of Net Zero Climate Pollutants by 2030 in the following areas:
a. Transportation
b. Buildings
c. Renewable Energy and Storage
d. Other Environmental issues, including but not limited to, water conservation, urban agriculture and food composting, and recycling
e. Carbon Sequestration
f. Public Awareness and Education regarding individual actions, including individual lifestyles and business operations
g. Climate Resiliency Efforts

2. Work with City staff, stakeholders and community leaders and organizations and the public at large.

3. Identify funding sources and grant opportunities.

4. Present its findings and recommendations within six months.

Napa Valley Register Top Story, 2/6/22: American Canyon declares climate emergency American Canyon has declared a climate change emergency and set the goal of net-zero climate pollution by 2030. “Our work has just begun,” Mayor Leon Garcia said after the City Council took action on Feb. 1.

American Canyon City Council Ad Hoc Climate Action Committee was commissioned in response to the Climate Emergency Resolution. Two student members from Schools for Climate Action served on the committee.

Interim CAP report was received by the City Council on 9/6/22, including:

Develop specific recommendations and measurable outcomes to achieve the goal of Net Zero Climate Pollutants by 2030 in the following areas: a. Transportation; b. Buildings; c.

Renewable Energy and Storage; d. Other Environmental issues, including but not limited to, water conservation, urban agriculture and food compos0ng, and recycling; e. Carbon Sequestration; f. Public Awareness and Education regarding individual ac0ons, including individual lifestyles and business operations; and g. Climate Resiliency Efforts Napa Valley Unified School District adopted a Climate Emergency Resolution on 5/23/19 that states, in part:

BE IT FURTHER RESOLVED, that Napa Valley Unified School District Board of Education support local climate mobilization efforts to reduce the sources of excess trapped heat that are responsible for climate change, and to increase resiliency for all residents, with special attention to the needs of marginalized and vulnerable communities, in order to achieve the goal of net zero climate pollution by or before 2030 The City of American Canyon partnered with NVUSD/American Canyon High School to initiate public outreach. 864 students participated in the Climate Challenge.

Climate Challenge Rally was attended by NVUSD and City of American Canyon officials on 2/8/23 when climate goals were presented:

NVUSD commitment to achieve the goal of net zero climate pollution by or before 2030.

City of American Canyon commitment to achieve its goal of net zero climate pollution by or before 2030.

All jurisdictions acknowledged a Climate Emergency and committed to achieving net zero climate pollutants by 2030 Open Space, Alternative Transportation and Sustainability Commission:

Hand-off of the Ad Hoc Climate Action Committee's Draft CAP to OSATS on 4/5/23, with 34 actions to support the goal as presented by Ad Hoc Climate Action Committee members Mark Joseph and Pierre Washington:

1. Net Zero Climate Pollutants by 2030

2. Evaluate Planning and Policy decisions
through the lens of this pledge; and

3. Established an Ad Hoc Climate Action
Committee to develop an action plan
1-10
2-5
481
6 Allison Bencsik served as OSATS Youth Commissioner. She spoke repeatedly during her tenure in support of emergencylevel climate action, consistent with American Canyon's Climate Emergency Resolution and Draft CAP. 1-10 2-6
482
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 1
COMMENTER: Napa Climate NOW!
DATE: October 23, 2024
Response 1-1
The commenter requests that attached reference material be included as part of the comment and expresses appreciation for the development of an updated General Plan.

This comment is noted and does not require revisions to the Draft EIR.

Response 1-2
The commenter states that current drafts of the General Plan Policy Document and Draft EIR do not retain a 2030 net-zero focus as a firm commitment. The commenter states that the City should stand in support of the 2030 goal, along with the jurisdictions in Napa County, Napa Valley Unified School District, Napa RCD, and surrounding communities.

The commenter expresses support for the City Council’s approved Climate Emergency Resolution (Resolution 2022-07) which recognizes the need to provide leadership and services in working with community organizations, businesses, schools, and regional partners and jurisdictions to educate, mobilize, expand, and accelerate local, regional, and statewide support for comprehensive, immediate, and sustained action to achieve its goal of net zero climate pollution by or before 2030.

The Climate Emergency Resolution serves as a guiding framework and a statement of intent on future actions, but it does not have the legal authority to mandate compliance within the Draft EIR.

The threshold for evaluating greenhouse gas emissions under CEQA assesses whether the project would conflict with any applicable plans, policies, or regulations aimed at reducing greenhouse gas emissions. As discussed on Page 4.5-22 of the Draft EIR, Mitigation Measure GHG-3 requires that the City draft and adopt the American Canyon qualified Climate Action Plan (CAP) by the end of 2025.

This plan will outline how American Canyon will meet the State’s 2030 goal of 40 percent below 1990 emissions levels and 2045 goal of carbon neutrality. As discussed on Page 4.5-23 of the Draft EIR, individual projects that may occur prior to adoption and implementation of the CAP may not be consistent with State emissions goals, nor are exact emissions reductions known at the time of adoption of the 2040 General Plan. Until the CEQA greenhouse gas (GHG) thresholds are adopted and the CAP is updated, implementation of the project during this interim period would not be consistent with State GHG reduction plans and impacts related to GHG emissions would be significant and unavoidable.

No additional revisions to the Draft EIR are required in response to this comment.

Response 1-3
The commenter notes American Canyon's various climate-positive initiatives, including water savings, enhanced residential energy efficiency, solar installations, a ban on new gas stations, commitments to open space, and new bike lanes. These efforts contribute to the community's climate resilience and align with the 2030 net zero climate pollution goal.

This comment does not pertain to the Draft EIR or CEQA. Therefore, no additional revisions to the Draft EIR are required in response to this comment.
2-7
483
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 1-4
The commenter states that retreating from a firm 2030 commitment could undermine current initiatives, delay or prevent new protective measures, and discourage collective climate action efforts.

The commenter supports the City Council’s approved Climate Emergency Resolution (Resolution 2022-07). As discussed under Response 1-3, above, CEQA assesses whether a project conflicts with existing plans, policies, or regulations to reduce greenhouse gas emissions. The 2030 Net Zero goal is a policy decision, not the CEQA standard. As discussed under Response 1-3, Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025.

Because this interim period would not be consistent with State GHG reduction plans, impacts related to GHG emissions would be significant and unavoidable. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 1-5
The commenter highlights that elected officials and public interest committees, like the Planning Commission, are uniquely positioned to evaluate development holistically, especially as climate change accelerates.

This comment does not pertain to the Draft EIR or CEQA. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 1-6
The commenter states that scientific consensus supports the 2030 climate goal, warning that the earth is likely to exceed the 1.5°C threshold by the early 2030s. They highlight recent extreme weather events and their health impacts on American Canyon residents as evidence of the urgent need for action.

This comment does not pertain to the Draft EIR or CEQA. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 1-7
The commenter notes that community resources, like the Napa County Resource Conservation District, and schools are committed to the 2030 net zero goal. They also mention that state and federal funds from the 2022 Inflation Reduction Act are available to support American Canyon in achieving this goal.

The threshold for evaluating greenhouse gas emissions under CEQA involves assessing whether the project would conflict with any applicable plans, policies, or regulations aimed at reducing greenhouse gas emissions. It is important to note that the 2030 Net Zero goal is a policy decision and not the standard used for CEQA evaluations. Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025. Because this interim period would not be consistent with State GHG reduction plans, impacts related to GHG emissions would be significant and unavoidable. Therefore, no revisions to the Draft EIR are required in response to this comment.
2-8
484
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 1-8
The commenter argues that the 2030 goal is essential due to unavoidable climate changes. They stress that past delays have forced difficult decisions on current officials and residents and that each year of inaction reduces the chance to enhance climate resilience, as warming triggers accelerating feedback loops. They also note that proactive changes can support a thriving economy and that the cost of achieving net zero will be less than the cost of inaction.

The threshold for evaluating greenhouse gas emissions under CEQA involves assessing whether the project would conflict with any applicable plans, policies, or regulations aimed at reducing greenhouse gas emissions or if the project would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. As discussed under Response 1-7, above, the 2030 Net Zero goal is a policy decision and does not serve as the standard for CEQA evaluations. Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025. Because this interim period would not be consistent with State GHG reduction plans, impacts related to GHG emissions would be significant and unavoidable.

Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 1-9
The commenter urges support for maintaining the 2030 net zero goal in all planning and development, emphasizing its importance for future generations.

As discussed under Response 1-7, above, CEQA assesses if a project conflicts with existing plans, policies, or regulations to reduce greenhouse gas emissions. The 2030 Net Zero goal is a policy decision, not the CEQA standard. Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025. Because this interim period would not be consistent with State GHG reduction plans, impacts related to GHG emissions would be significant and unavoidable. Therefore, no revisions to the Draft EIR are needed in response to this comment.

Response 1-10
The commenter provides an addendum which references mentions of Net Zero 2030 by the City of American Canyon website and City Council resolutions and proclamations, Napa County Procurement website, the City of Napa Regional Climate Action and Adaptation Plan, American Canyon City Council Ad Hoc Climate Action Committee, Napa Valley Unified School District (NVUSD), Open Space, and Alternative Transportation and Sustainability Commission.

As discussed in Responses 1-7 through 1-9, the threshold for evaluating greenhouse gas emissions under CEQA involves assessing whether the project would conflict with any applicable plans, policies, or regulations aimed at reducing greenhouse gas emissions. Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025.

Because this interim period would not be consistent with State GHG reduction plans, impacts related to GHG emissions would be significant and unavoidable. Therefore, no revisions to the Draft EIR are required in response to this comment.
2-9
485
1 New eComment for Planning Commission
Maia Medalle submitted a new eComment.

Meeting: Planning Commission
Item: 3.) General Plan Technical Update Draft Environmental Impact Report (DEIR) Public Review Workshop
eComment: Good evening American Canyon Planning Commissioners, My name is Maia Medalle, I am a Junior at American Canyon High School, and alongside other high school students, I have worked tirelessly as a representative of Napa Schools 4 Climate Action. Napa Schools for Climate Action is a group composed of passionate students, teachers, staff, local government officials, and citizens all across Napa County & the NVUSD. Our motto is that no Letter 2
2-1
a 2030 net-zero focus in our General Plan. In the past year, Napa Schools 4 Climate Action has put endless amounts of energy into drafting and fighting for the adoption of our “ Call To Climate Restoration Action” within NVUSD and successfully were able to have it adopted this past April.

This resolution acknowledges the importance of restoring atmospheric carbon levels to preindustrial levels and aiming for net-zero climate pollution, by or before the decisive year of 2030.

The adoption of our resolution in our school district solidified the commitment of our community to our future, the youth’s future. I recognize this same commitment made by the leaders of our town, my hometown. Your dedication to the future of our earth has been seen through the declaration of a climate emergency and the ban on new and expanding gas stations, yet past actions aren’t enough to guarantee our future. We must continue to work toward progress, and this is why I urge you to consider the 2030 net-zero focus as a commitment, instead of just a goal. As the bearers of my generation’s future, I strongly compel you to recognize the urgency of including this commitment in the draft of your General Plan. Our future is in your hands, and my generation looks to you, trusting you will make the right decisions. I thank you for your time and consideration, Maia Medalle Napa Schools 4 Climate Action 2-3
2-4
school should be a silent witness to climate injustice. I write to you to acknowledge the need for 2-2 2-10
486
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 2
COMMENTER: Maia Medalle
DATE: October 24, 2024
Response 2-1
The commenter introduces themselves as a Junior at American Canyon High School, and mentions their work with Napa Schools 4 Climate Action, a group of students, teachers, staff, local government officials, and citizens from across Napa County and NVUSD.

This comment does not pertain to the Draft EIR or CEQA. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 2-2
The commenter states the need for a 2030 net zero focus within the General Plan.

Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 2-3
The commenter describes how Napa Schools 4 Climate Action worked to draft and advocate for the "Call To Climate Restoration Action" resolution, which was adopted by NVUSD in April. This resolution aims to restore atmospheric carbon levels to pre-industrial levels and achieve net-zero climate pollution by 2030, solidifying the community's commitment to the future.

The approved Climate Emergency Resolution (Resolution 2022-07). Consistent with this resolution, Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 2-4
The commenter acknowledges the town leaders' commitment to climate action, citing the declaration of a climate emergency and the ban on new gas stations. They urge the leaders to treat the 2030 net-zero focus as a firm commitment rather than just a goal, emphasizing the urgency of including this in the General Plan for the sake of future generations.

As discussed under Response 1-7, above, CEQA assesses if a project conflicts with existing plans, policies, or regulations to reduce greenhouse gas emissions. The 2030 Net Zero goal is a policy decision, not the CEQA standard. However, Mitigation Measure GHG-3 seeks to bring the City into compliance with State carbon neutrality goals by the end of 2025.. Therefore, no revisions to the Draft EIR are required in response to this comment.
2-11
487
1 New eComment for Planning Commission
Jodl Cruz submitted a new eComment.

Meeting: Planning Commission
Item: PUBLIC COMMENT
eComment: Good morning, We know that there will be a Planning Commission meeting tonight and as a representative and President of FilAm we are asking for help to request that the planning commission absolutely include Green Island as a study area. And we know that project is almost ready to proceed with the appropriate applications with the new city council, and will Letter 3
3-1
definitely improve and contribute to our city. Thank you very much 뛴뛵뛶뜌뛸뛹뜎뜍뛻뛼뛽뛾뛿뜀뜁뜂뜃뜄뜅뜏뛴뛵뛶뜌뛸뛹뜎뜍뛻뛼뛽뛾뛿뜀뜁뜂뜃뜄뜅뜏 Respectfully yours, Jod’l Cruz FilAm President
2-12
488
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 3
COMMENTER: Jodi Cruz
DATE: October 24, 2024
Response 2-1
The commenter introduces themselves as the President of FilAm and requests that the Planning Commission include the Green Island Vineyard property as a study area in their meeting. They mention that the project is nearly ready to proceed with the new City Council and will benefit the city.

The General Plan update scope of work which was evaluated by the Environmental Impact Report was described in the Notice of Preparation. The Notice of Preparation did not include consideration of adding the Green Island Vineyard property into the City’s urban limit line. Adding the Green Island Vineyard property into the City’s urban limit line may be considered in the future, but it is not part of the proposed General Plan project and therefore does not pertain to the Draft EIR or CEQA.

Therefore, no revisions to the Draft EIR are required in response to this comment. 2-13
489
“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 6, 2024 SCH #: 2022070038
GTS #: 04-NAP-2022-00452
GTS ID: 26948
Co/Rt/Pm: NAP/VAR/VAR
Brent Cooper, Community Development Director
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
Re: City of American Canyon General Plan Update ─ Draft Environmental Impact Report (DEIR)
Dear Brent Cooper:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the City of American Canyon General Plan Update.

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 September 2024 DEIR.

Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only.

Project Understanding
The proposed project consists of an update to the City's General Plan which will serve as a long-term framework for future growth and development.

Travel Demand Analysis
The project’s vehicle miles traveled (VMT) analysis and significance determination are undertaken in a manner consistent with the City’s adopted VMT policy. Per the DEIR, this project is found to have significant and unavoidable VMT impact. Caltrans commends the City for implementing policies in the General Plan to increase multimodal transportation and reduce VMT. We encourage the City to document progress with annual monitoring reports to demonstrate effectiveness.

Letter 4
4-1
4-2
2-14
490
Brent Cooper, Community Development Director
November 6, 2024

“Provide a safe and reliable transportation network that serves all people and respects the environment.” Please also consider the measures listed below that are quantified by the California Air Pollution Control Officers Association (CAPCOA) and shown to have different efficiencies reducing regional VMT:
• Increase Residential Density
• Increase Job Density
• Provide Transit-Oriented Development
• Integrate Affordable and Below Market Rate Housing
• Locate Project/Developments in Area with High Destination Accessibility • Improve Destination Accessibility in Underserved Areas • Implement Shared Vehicle Program (car/bike/E-bike/scooter) • Create Urban Non-motorized zones
• Extend Transit Network Coverage or Hours
• Increase Transit Service Frequency
• Implement Transit-Supportive Roadway Treatments
• Provide Bus Rapid Transit
• Reduce Transit Fares
• Improve Transit Access, Safety, and Comfort
• Provide Bike Parking Near Transit
• Provide Electric Vehicle Charging Infrastructure
• Limit Residential Parking Supply
• Implement Market Price Public Parking (On-Street)
• Implement Area or Cordon Pricing
• Replace Traffic Controls with Roundabout
• Required Project Contributions to Transportation Infrastructure Improvement • Install Park-and-Ride Lots
Please consider exploring the following options to help further reduce the VMT impact if the implementation of applicable TDM measures is insufficient to mitigate the project VMT impact to a less-than-significant level: VMT based Transportation Impact Fee program, VMT Mitigation Exchange and VMT Mitigation Bank. Please note that Caltrans has funded several local/regional agencies to study the feasibility of a variety of VMT mitigation programs through the Sustainable Transportation Planning Grant program (link). Caltrans welcomes the potential opportunities to work with the City.

The City may also consider encouraging fair share contributions from future development projects to multimodal projects that promote mode shift and reduce single-occupancy vehicle travel to mitigate VMT impacts. Caltrans suggest the following Regional Transportation Plan (Plan Bay Area 2050) projects for future fair share contribution considerations:
4-3
4-4
4-5
2-15
491
Brent Cooper, Community Development Director
November 6, 2024

“Provide a safe and reliable transportation network that serves all people and respects the environment.” RTP ID Project Description
21-T06-049
511 Bay Area Program includes funding to support the 511Bay Area Program, which provides multi-modal traveler
information.
21-T07-052
Carpool/Vanpool Program includes funding to provide
carpool-matching tools and encourage carpool behavior
through outreach, education, rewards, incentives, and new technology.
21-T07-056
This program generally implements projects exempt from
regional air quality conformity, but it does include nonexempt local roadway widenings or extensions.

Improvements include local road extensions or new lanes, and intersection improvements such as channelization and signalization.
21-T10-067
This program includes funding to implement improvements to existing Napa VINE regional/local bus service. Improvements include frequency upgrades (30-minute peak headways);
expanded service hours (from 4am- 12am); and Sunday
service.
21-T10-070
This program includes funding to implement improvements to existing bus service in Priority Development Areas (PDAs) without existing high-frequency rail, ferry, or bus service.

Improvements include frequency upgrades (30-minute peak headways) and reorganization and/or expansion of bus
routes.
21-T12-118
This program includes funding to implement express bus
enhancements between Napa (Redwood Park-and-Ride)
and the Vallejo Ferry Terminal. Improvements include bus-onshoulder facilities.

Multimodal Transportation Planning
Please review and include the reference to the Caltrans District 4 Pedestrian Plan (2021) and the Caltrans District 4 Bike Plan (2018) in the DEIR. These two plans studied existing conditions for walking and biking along and across the State Transportation Network (STN) in the nine-county Bay Area and developed a list of location-based and prioritized needs.

Please note that any Complete Streets reference should be updated to reflect Caltrans Director’s Policy 37 (link) that highlights the importance of addressing the needs of non-motorists and prioritizing space-efficient forms of mobility, while also 4-5
cont.
4-6
4-7
2-16
492
Brent Cooper, Community Development Director
November 6, 2024

“Provide a safe and reliable transportation network that serves all people and respects the environment.” facilitating goods movement in a manner with the least environmental and social impacts. This supersedes Deputy Directive 64-R1, and further builds upon its goals of focusing on the movement of people and goods.

Equity and Public Engagement
We will achieve equity when everyone has access to what they need to thrive no matter their race, socioeconomic status, identity, where they live, or how they travel.

Caltrans is committed to advancing equity and livability in all communities. We look forward to collaborating with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Llisel Ayon, Associate Transportation Planner, via [email protected].

For future early coordination opportunities or project referrals, please visit Caltrans LDR website (link) or contact [email protected].

Sincerely,

YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
4-7
cont.
4-8
2-17
493
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 4
COMMENTER: Yunsheng Luo, Branch Chief – Local Development Review Office of Regional and Community Planning, California Department of Transportation (Caltrans) DATE: November 6, 2024
Response 4-1
The commenter thanks the City of American Canyon for involving Caltrans in the environmental review of the General Plan Update. They clarify that their comments are for informational purposes and do not represent an official Caltrans position. The commenter provides a summary of their understanding of the project which involves updating the City's General Plan to guide future growth and development.

This comment provides informational comments. No revisions to the Draft EIR are required in response to this comment.

Response 4-2
The commenter notes that the project's vehicle miles traveled (VMT) analysis aligns with the City's adopted VMT policy and acknowledges the significant and unavoidable VMT impact identified in the DEIR. Caltrans commends the City for its policies to enhance multimodal transportation and reduce VMT, and encourages annual monitoring reports to track progress.

No revisions to the Draft EIR are required in response to this comment.

Response 4-3
The commenter suggests considering various measures quantified by the California Air Pollution Control Officers Association (CAPCOA) to reduce regional vehicle miles traveled (VMT).

As discussed on pages 4.11-9 through 4.11-11 of the Draft EIR, the proposed General Plan would result in significant and unavoidable impacts on VMT. As included therein, the General Plan includes potentially self-mitigating policies which align with the CAPCOA measures provided by the commenter. These are outlined as follows:

Increasing residential and job density is a key strategy to reduce VMT by bringing people closer to their workplaces and amenities. The General Plan's MOB-1.1: Complete Streets policy supports this by ensuring streets are designed to accommodate all users, promoting higher density and mixed-use developments that reduce the need for long commutes. Additionally, Policy MOB-1.23: Pedestrian Connections to Employment Destinations, encourages 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.

Providing transit-oriented development (TOD) and integrating affordable and below-market rate housing are crucial for creating accessible and inclusive communities. Policy MOB-1.4: Development Review, ensures that new developments prioritize the safety and convenience of pedestrians, bicyclists, and transit users, which is essential for successful TOD and affordable housing projects.

Additionally, Policy MOB-1.6: Transportation Facility Construction and Modification, strives to provide for the movement of vehicles, commercial trucks, alternative and low energy vehicles, transit, bicyclists, and pedestrians appropriate for the road classification and adjacent land use 2-18
494
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Locating projects in areas with high destination accessibility and improving destination accessibility in underserved areas are strategies that align with MOB-1.7: Promote Walking and Bicycling. By enhancing accessibility, more people are encouraged to walk or bike, reducing reliance on cars.

Implementing shared vehicle programs and creating urban non-motorized zones can significantly reduce VMT by offering alternatives to private car ownership. Policy MOB-1.17: Reduce Vehicle Miles Traveled aims to achieve this by improving alternate travel modes and providing more direct routes.

Providing bike parking near transit and electric vehicle charging infrastructure are essential for supporting sustainable transportation modes. Policy MOB-1.20: Bicycle Plan Funding supports this by ensuring that bikeway improvements are well-funded and integrated with the transit network Lastly, the General Plan is a guiding document which will allow the City to work closely with Caltrans on future development projects that impact roadways, ensuring that all changes are beneficial and well-coordinated. Additionally, policies such as Policy MOB-1.9: SR 29 Mobility and Policy MOB-1.28:

Coordination with Adjacent Jurisdictions ensure that transportation strategies are aligned with those of neighboring areas, creating a cohesive regional approach. This collaboration will help to streamline efforts, reduce redundancy, and promote a more efficient and effective transportation network for the entire region.

However, as discussed on page 4.11-11 of the Draft EIR, measures to reduce specific VMT per resident are challenging to implement and monitor in a meaningful way. Other than the selfmitigating measures and policies outlined above, it is infeasible that additional mitigation is likely to further reduce the citywide rate of VMT per resident. Further, because General Plan policies cannot realistically enforce mitigation programs or policies that might reduce VMT below the threshold, impacts would remain significant and unavoidable.

No additional revisions to the Draft EIR are required in response to this comment.

Response 4-4
The commenter suggests exploring additional options to reduce VMT impact if current TDM measures are insufficient. These options include a VMT-based Transportation Impact Fee program, VMT Mitigation Exchange, and VMT Mitigation Bank. They note that Caltrans has funded studies on VMT mitigation programs and welcomes opportunities to collaborate with the City.

The feasibility of additional mitigation strategies are discussed above in Response 4-3. The suggested VMT mitigation programs, such as a VMT-based Transportation Impact Fee program, VMT Mitigation Exchange, and VMT Mitigation Bank, are infeasible due to the programmatic nature of the project and staffing and financial limitations to coordinate and fund Furthermore, this comment represents an opinion, and not the policy of Caltrans. No additional revisions to the Draft EIR are required in response to this comment.

Response 4-5
The commenter suggests that the City encourage fair share contributions from future development projects to support multimodal projects, suggesting that this would promote mode shifts and reduce single-occupancy vehicle travel, helping to mitigate VMT impacts. The commenter provides Regional Transportation Plan (Plan Bay Area 2050) projects for future fair share contribution considerations.

As discussed on page 4.11-4 of the Draft EIR, the proposed project is within the jurisdiction of Plan Bay Area 2050 and could be subject to consideration of potential fair share contributions. While the 2-19
495
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
City will consider these recommendations for future collaboration with Caltrans and for future projects, it is important to note that certain projects may face feasibility challenges at this time. For example, the 511 Bay Area Program (RTP ID 21-T06-049) involves extensive funding and coordination to provide comprehensive multi-modal traveler information, which may not be immediately feasible for all future developments. Similarly, the Carpool/Vanpool Program (RTP ID 21-T07-052) requires significant outreach, education, and incentives to encourage carpool behavior, which may not be practical for every project proposed under the General Plan. Additionally, projects like the express bus enhancements between Napa and the Vallejo Ferry Terminal (RTP ID 21-T12- 118) involve specific infrastructure improvements such as bus-on-shoulder facilities, which may not be applicable to all development areas. However, the City values the opportunity to collaborate with Caltrans and ABAG on future fair share contribution opportunities. No additional revisions to the Draft EIR are required in response to this comment.

Response 4-6
The commenter suggests including references to the Caltrans District 4 Pedestrian Plan and Bike Plan in the Draft EIR.

In response to this comment, the following revisions have been made to the Draft EIR Section 4.11, Transportation, Sub-Section 4.11.2, Regulatory Framework. The revision would not alter the impact analysis or findings of Section 4.11 and, as such, would not warrant recirculation of the Draft EIR.

Caltrans District 4 Pedestrian Plan
The Caltrans District 4 Pedestrian Plan, released in 2021, is a comprehensive guide aimed at improving pedestrian infrastructure across the nine-county Bay Area. This plan identifies existing conditions and prioritizes location-based needs to enhance pedestrian safety and accessibility. Developed in collaboration with local agencies, advocates, and the public, the plan serves as a crucial reference for planners and project designers. It promotes alternatives to driving, aiming to reduce congestion, lower greenhouse gas emissions, and encourage healthier lifestyles. The plan is part of the broader Bay Area Active Transportation Plan, which integrates pedestrian and bicycle needs into a cohesive strategy.

Caltrans District 4 Bike Plan
The Caltrans District 4 Bike Plan, finalized in 2018, evaluates the bicycling needs across the Bay Area's state transportation network. This plan identifies and prioritizes infrastructure improvements to enhance bicycle safety, mobility, and accessibility. It builds on the 2017 California State Bicycle and Pedestrian Plan and aims to create an integrated bicycle network that supports safe and convenient cycling for all ages and abilities. The plan was developed with input from the public and collaboration with local and regional partners, ensuring that proposed improvements align with local networks and address barriers to cycling.

Response 4-7
The commenter suggests updating Complete Streets references to reflect Caltrans Director’s Policy 37, which supersedes Deputy Directive 64-R1.

In response to this comment, the following revisions have been made to the Draft EIR Section 4.11, Transportation, Sub-Section 4.11.2, Regulatory Framework, Page 4.11-3. The revision would not 2-20
496
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
alter the impact analysis or findings of Section 4.11 and, as such, would not warrant recirculation of the Draft EIR.

Complete Streets Act
The California Complete Streets Act (AB 1358) adopted in 2008, requires that cities and other public agencies incorporate “Complete Street” policies when updating their General Plan Circulation Element. The term “Complete Streets” refers to a balanced, multimodal transportation network that meets the needs of all users of streets, including bicyclists, children, persons with disabilities, motorists, movers of commercial goods, pedestrians, public transportation, and seniors. A “Complete Street” is one that provides safe and convenient travel in a manner that is suitable to the local context. Complete Streets make travel safe for all users, including bicyclists, pedestrians, motorists, transit vehicles, and people of all ages and abilities.

Each street does not need to provide dedicated space to all users, but the network must accommodate the needs of all users.

In 2021, Caltrans adopted Director’s Policy 37, a policy directive related to non-motorized travel throughout the State. Director’s Policy 37 states:

The California Department of Transportation (Caltrans) recognizes that walking, biking, transit, and passenger rail are integral to our vision of delivering a brighter future for all through a world-class transportation network. Additionally, Caltrans recognizes that streets are not only used for transportation but are also valuable community spaces. Accordingly, in locations with current and/or future pedestrian, bicycle, or transit needs, all transportation projects funded or overseen by Caltrans will provide comfortable, convenient, and connected complete streets facilities for people walking, biking, and taking transit or passenger rail unless an exception is documented and approved. When decisions are made not to include complete streets elements in capital and maintenance projects, the justification will be documented with final approval by the responsible District Director. Opportunities for complete streets exist in all phases of project development from planning and design to construction, operations, and maintenance.

Complete streets projects should prioritize underserved communities that have been historically harmed and segmented by the transportation network and should serve people of all ages and abilities. Furthermore, Caltrans commits to removing unnecessary policy and procedural barriers and partnering with communities and agencies to ensure projects on local and state transportation systems improve the connectivity to existing and planned pedestrian, bicycle, and transit facilities, and accessibility to existing and planned destinations, where possible.

Response 4-8
The commenter emphasizes Caltrans' commitment to achieving equity by ensuring everyone has access to what they need to thrive, regardless of race, socioeconomic status, identity, location, or mode of travel. They express eagerness to work with the City on projects that benefit historically underserved communities. They also thank the City for involving Caltrans in the environmental review process and provide contact information for further inquiries and future coordination.

This comment is noted and no additional revisions to the Draft EIR are required in response to this comment.
2-21
497
Memo to William He, Planner, City of American Canyon
November 10, 2024
Comments on EIR for General Plan
Thank you for the opportunity to comment. I am a member of the Napa Solano Audubon Society, the Napa County Sierra Club, Napa Climate NOW! and have graduated from the iNaturalist program as a certified California Naturalist. I also represent Napa and Solano as the Senior Senator for the California Senior Legislature.

I have tracked and researched land use, environmental decline, and widespread loss of wildlife in the American Canyon Region for several years. As the lead for the Committee to Stop Measure J, and the writer of the oppositional narrative for the ballot, I also have become somewhat aware of the politics of this community. In 2022, I received the Climate Champion of Napa County, specifically for the work done to defeat Measure J.

There’s still so much left for us to consider. With projected economic growth and plans for this city, I see American Canyon’s west side growing into a diesel fume death zone.

Watching one of California’s most biologically diverse areas disappear, with the land being smothered with a blanket of cement, is devasting. It continues, unabated, no matter the concerns voiced by residents, environmental groups, and the California Department of Fish and Wildlife. No entity in American Canyon protects and speaks for the wildlife. There is no voice.

At the same time the land is being graded, vegetation stripped and trees cut down, the wine industry is facing a challenge. Interest in wine is dropping in the aging consumer base and changing preferences are reshaping the market. Reductions in wine consumption are most drastic with baby boomers, the largest population drinking wine. Predictions are that the wine industry is looking at a decades-long decline.

So, why continue to build more wine warehouses?
As the wine industry struggles with reduced demand, it also faces the struggles of a shrinking workforce.

Letter 5
5-1
5-2
5-3
5-4
2-22
498
We are also in a climate crisis changing how we live. Heat domes, heavier rains, changing weather patterns, and rising seas are now our reality. American Canyon is affected.

Everything planned in EIR for this General Plan should be decided through the lens of the Climate Crisis.

American Canyon is not going to stop all economic growth. But, perhaps, it’s time to consider doing things differently, with consideration to the environment, wildlife, and future of our children. Back, 30 years ago, when many of the land decisions were made between politicians and investors, the times were much different. The climate crisis was a speck in the distant future, the wineries were beginning to boom and American Canyon was incorporated to become a city and the development hub of Napa County. The stability of status quo reigned.

Now we’re in 2025 and it’s a different world. We cannot rely on agreements or plans made thirty years ago without acquiescing to the new reality. How will the city accommodate growth while conserving open space, wildlife, and natural resources? That is the real question of a General Plan.

Before land is permanently destroyed, the question thoroughly investigated should be the consequences of this action to all life. And, how can it be done with the least harm and highest good?
This General Plan should call for action in creating a baseline compilation and assessment of all private and public lands. There are at least 51 threatened/endangered/special plant species and 44 animal species with the potential to occur in American Canyon. The General Plan needs to create a database of baseline information to include detailed land cover maps, species accounts, species distribution models, land use data and estimates of what is located there and what is the activity. The goal is to find out what potential land needs to be set aside so there will be an open space, conserved area for wildlife. Where are the red-legged frogs, the Swainson Hawks, the Bald Eagles and White-Tailed Kites (to name a few), living? Should land be preserved for them? Who owns the land where critical habitats are located? Can conservation easements be considered and encouraged? Should American Canyon make plans to strategically purchase land and/or increase and promote voluntary conservation easements? Please consider adding these elements to the General Plan.

Also, consider the following suggestions:

Recognizing that people and wildlife don’t mix, access areas should be limited in riparian corridors, or where damage to habitat will occur.
5-5
5-6
5-7
5-8
5-9
5-10
5-11
5-12
5-13
2-23
499
Habitat connectivity needs to be a priority. Grading/cutting down trees and destroying soil by discing should be avoided until a biological assessment is completed on any land. All these activities should be especially prohibited in biologically diverse and riparian habitat.

Because so much land has already been destroyed, the city could look at reparations and restoration. All nonfunctional space, for example, and landscaping could be reverted to natural native plantings and trees. A native plant ordinance can be adopted by the city mandating that all residential planting contains at least 70% native plants.

Increase buffer zones around nests and wildlife use areas to .5 mile (as recommended by CDFW).

Increase mitigation for tree replacement from 1:1 to 5:1. This reflects a truer survival rate of 20% of new tree plantings. Also, require all trees/vegetation replacement to be watered and cared for at least one year after planting. Failed mitigations are to be replaced.

Require a one-year survival review, with failed plantings replaced as needed beforehand the year ends.

Develop a mitigation enforcement statute with accountability standards. Include consequences for failure to comply with mitigation. Require city review and final approval signoff on all mitigation efforts at completion.

Define vague statements such as “large” by actual numbers. One example: “If a qualified biologist determines a roost is used by a “large” number of bats. This is a subjective statement, and needs further clarification. Any development activity removing habitat need such as roosting treets, nesting trees, etc., needs to replace as close to the original site as possible.

Ban discing for weed control. It destroys habitat for animals living in the ground, including burrowing owls, lizards and snakes. (Yes, there have been sightings of burrowing owls in the American Canyon wetlands area.)
Prohibit capturing, killing or relocating animals without expressly written authorization from the CDFW or USFWS. Ban all killing of wildlife in construction zones. Place large signs at all the sites for wildlife injuries to be taken immediately to the Napa Wildlife Rescue Center.

Include a map with a phone number.

Ban pesticides and bait stations on property within 500 feet of wildlife habitat creeks, sloughs, watering sites. . No overnight lighting on buildings within 500 feet of a wildlife area.
5-16
5-17
5-18
5-19
5-20
5-21
5-22
5-23
5-24
5-25
5-26
5-15
5-14
2-24
500
Require mitigation measures for warehouse/urban park developers to include an expansion of the urban forest, including participating in soil or compost application to sequester carbon and incentivizing rooftop gardens.

Support a regional plan, with Napa and Solano Counties for open space and wildlife protection.

Ban plastic grass in schools, residential, and in industrial development lands.

When planners require EIR’s and Biological reviews, include data and information. from local environmental groups, i.e. the Audubon Society, Napa Plant Society, Beekeepers, ICare, etc.) Also include other recognized verification apps, including iNaturalist and ebird.org. Local bird watchers and regular walkers know more about what plants/animals are in an environment than outdated data in many other sites. Encourage the participation of local environmental groups in land use planning, especially in protecting critical habitat for special status species.

Ban diesel truck idling in the warehouse districts. Impose fines for any idling over 3 minutes.

American Canyon hire or assign dedicated staff to protect wildlife and preserve land for habitat.

Ban black asphalt in all new roads, developments, parking lots, and replace with permeable concrete.

And, finally, the 203 acres of what is currently Green Island Vineyard should be set aside as an area of study for a conservation easement.

Thank you for this opportunity for public comments. I hope these will considered and incorporated in the FEIR.

Yvonne Baginski
5-30
5-31
5-32
5-33
5-34
5-35
5-36
5-27
5-28
5-29
2-25
501
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 5
COMMENTER: Yvonne Baginski
DATE: November 10, 2024
Response 5-1
The commenter introduces themselves as a member of several environmental organizations and a certified California Naturalist, citing that they have tracked land use and environmental decline in the American Canyon Region for years.

No additional revisions to the Draft EIR are required in response to this comment.

Response 5-2
The commenter expresses concern that projected economic growth and city plans could turn American Canyon's west side into a heavily polluted area. They lament the potential loss of one of California's most biologically diverse regions to urban development.

The General Plan accommodates thoughtful growth within the city while preserving areas of biological significance. Section 4.3, Biological Resources, of the Draft EIR describes various biologically sensitive areas that occur or may occur in the planning area. While proposed General Plan and associated land use changes may result in impacts on biological resources, overall impacts to biological resources would be less than significant with implementation of Mitigation Measure BIO-1 through BIO-9. Mitigation efforts implemented through federal, state, and local policies minimize environmental impacts and protect public health.

Development within the western portion of American Canyon was evaluated in the Draft EIR and will be subject to adopted mitigation measures. No revisions to the Draft EIR are required in response to this comment.

Response 5-3
The commenter notes that despite concerns from residents, environmental groups, and the California Department of Fish and Wildlife, there is no entity in American Canyon advocating for wildlife protection.

The Draft EIR evaluates potential environmental impacts of future development proposed by the General Plan, as required by CEQA. Wildlife protection is addressed through implementation of applicable laws and standards. As discussed on page 4.3-12 of the Draft EIR, the proposed General Plan includes policies ENV-1.2 and ENV-1.3 which require new development and redevelopment located within sensitive habitats to provide a detailed assessment of the potential for impacts on these resources and supports habitat conservation efforts to set aside and preserve suitable habitats (with priority given for rare and endangered species) in accordance with state and federal resource agency requirements, respectively. Additionally, as discussed on page 4.3-21 of the Draft EIR, the proposed General Plan includes policy ENV-2.1 and ENV-2.2 which maintains American Canyon Creek within its natural waterway and requires new development to incorporate existing streams and creeks into proposed development plans in their natural state to prevent degradation, erosion, or sedimentation and help impart a unique character to the city. No revisions to the Draft EIR are required in response to this comment.
2-26
502
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-4
The commenter highlights that while land is being developed and natural habitats are being destroyed, the wine industry is facing declining interest and a shrinking workforce. They question the rationale behind building more wine warehouses amid these challenges.

The proposed General Plan identifies a balance of land uses throughout the planning area. The Draft EIR evaluates proposed land uses, and provides programmatic mitigation measures to evaluate subsequent development projects, including wine warehouses. No revisions to the Draft EIR are required in response to this comment.

Response 5-5
The commenter emphasizes that the climate crisis, with its heat domes, heavier rains, changing weather patterns, and rising seas, is affecting American Canyon. They argue that the General Plan should consider the climate crisis.

Pages 4.5-1 through 4.5-5 of the Draft EIR discuss the existing setting with regards to climate change in American Canyon, with specific attention to effects on the water supply, ecosystems, hydrology and sea level rise. As discussed on page 4.5-22 of the Draft EIR, implementation of Mitigation Measures GHG-2 and GHG-3 would ensure that development facilitated by the project would be consistent with State emissions goals. However, individual projects that may occur prior to adoption of a City Climate Action Plan (CAP) would not be guaranteed to be consistent with State emissions goals, nor are exact emissions reductions known at the time of adoption of the 2040 General Plan.

Until the CEQA GHG thresholds are adopted and the CAP is updated, implementation of the project during this interim period would not be consistent with BAAQMD GHG thresholds nor would it be consistent with State GHG reduction plans. Therefore, the project’s impacts related to GHG emissions would be significant and unavoidable. No revisions to the Draft EIR are required in response to this comment.

Response 5-6
The commenter suggests that while economic growth in American Canyon will continue, it might be time to adopt new approaches that consider the environment, wildlife, and the future of children.

The General Plan is a comprehensive, programmatic document designed to guide the future development of American Canyon. It considers various factors, including the environment, wildlife, economic growth, and the overall future growth of the city. The Draft EIR thoroughly evaluates the objectives, goals, policies, and programs outlined in the General Plan. No revisions to the Draft EIR are required in response to this comment.

Response 5-7
The commenter reflects on how, previously, land decisions were made in a different context, with American Canyon becoming a development hub.

As discussed above within Response 5-6, the General Plan is a comprehensive, programmatic document designed to guide the future development of American Canyon. The Draft EIR thoroughly evaluates the objectives, goals, policies, and programs outlined in the General Plan. No revisions to the Draft EIR are required in response to this comment. 2-27
503
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-8
The commenter questions how the city will balance growth with the conservation of open space, wildlife, and natural resources, emphasizing that this is the core issue for the General Plan.

As discussed above within Response 5-6, the General Plan is a comprehensive, programmatic document designed to guide the future development of American Canyon. The Draft EIR thoroughly evaluates the objectives, goals, policies, and programs outlined in the General Plan. No revisions to the Draft EIR are required in response to this comment.

Response 5-9
The commenter urges that before any land is permanently altered, the consequences for all life should be thoroughly investigated. They ask how development can be done with the least harm and the greatest benefit.

The primary purpose of the Draft EIR is to ensure that the potential consequences of future development under the proposed General Plan are thoroughly considered in accordance with the CEQA. The Draft EIR identifies significant impacts and proposes mitigation measures to minimize these impacts. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 5-10
The commenter suggests that the General Plan should include a baseline assessment of all private and public lands. They note the presence of at least 51 threatened or special plant species and 44 animal species in American Canyon. They recommend creating a database with detailed land cover maps, species accounts, distribution models, land use data, and activity estimates, with the goal of determining what potential land needs to be set aside so there will be an open space, conserved area for wildlife.

The Draft EIR includes the USFWS’s IPaC, California Natural Diversity Database CNDDB, and CNPS’s online Inventory of Rare and Endangered Plants of California (see Appendix B). As discussed within Response 6-34, an updated query was conducted in February 2025. Therein, it discusses that there are 52 plant species and 45 animal species with potential to occur within the planning area which meet at least one of the criteria for a special status species (see Revised Appendix B to this Final EIR). As discussed on pages 4.3-11 through 4.3-19 of the Draft EIR, the project could have the potential to have an adverse impact on special status species. However, implementation of federal, state, and local regulations and policies, as well as Mitigation Measures BIO-1 through BIO-9, would ensure development facilitated by the project would not have a substantial adverse effect on candidate, sensitive, or special status species by requiring Biological Resources Screening and Assessments, avoidance and minimization, habitat restoration, and preconstruction surveys.

In response to this comment, Impact BIO-1 on page 4.3-11 of the Draft EIR is revised as follows:
2-28
504
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Impact BIO-1 THE PROJECT COULD HAVE THE POTENTIAL TO HAVE AN ADVERSE IMPACT ON SPECIAL STATUS SPECIES. IMPLEMENTATION OF FEDERAL, STATE, AND LOCAL REGULATIONS AND POLICIES, AS WELL AS MITIGATION MEASURES BIO-1 AND BIO-2 THROUGH BIO-9, WOULD ENSURE DEVELOPMENT

FACILITATED BY THE PROJECT WOULD NOT HAVE A SUBSTANTIAL ADVERSE EFFECT ON CANDIDATE, SENSITIVE, OR SPECIAL STATUS SPECIES. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

CEQA does not require a lead agency to prepare a baseline assessment of all private and public lands and create a detailed database for land conservation. No additional revisions to the Draft EIR are required in response to this comment.

Response 5-11
The commenter questions the locations of critical habitats for species like red-legged frogs, Swainson Hawks, Bald Eagles, and White-Tailed Kites. They ask whether land should be preserved for these species and who owns the land where these habitats are found.

Appendix B to the Draft EIR includes supporting details regarding species found within the plan area, including their listed status and habitat requirements. This appendix item has been updated and is included as Revised Appendix B to this Final EIR. Therein, it includes the details of the status of redlegged frogs, Swainson Hawks, Bald Eagles, and White-Tailed Kites. The City, through the General Plan, aims to protect and preserve habitats through policy and implementation of feasible mitigation measures. For example, as discussed on page 4.3-12 of the Draft EIR, the 2040 General Plan would include the following proposed policies that would help protect habitats:
 Policy ENV-1.2: Sensitive Habitat Assessment and Impact Mitigation. Require new development and redevelopment located within sensitive habitats, including coastal saltmarsh, mixed hardwood forest, oak savannah, vernal pools, and riparian habitats to provide a detailed assessment of the potential for impacts on these resources, and include measures to reduce any identifiable impacts.
 Policy ENV-1.3: Habitat Conservation. Support habitat conservation efforts to set aside and preserve suitable habitats, with priority given to habitats for rare and endangered species in American Canyon in accordance with state and federal resource agency requirements.

Compliance with the American Canyon Municipal Code and implementation of proposed policies in the 2040 General Plan would help ensure habitats are identified prior to project-specific siting and habitat areas are protected where applicable. Further, as noted in Response 5.2 above, Mitigation Measures BIO-1 through BIO-9 would also reduce impacts to biological resources. The policies noted above and mitigation measures identified in the Draft EIR are intended to avoid impacts to habitats and sensitive species within American Canyon and in certain instances would result in preservation of land that contains sensitive species or suggests methods to reduce or avoid an impact. No revisions to the Draft EIR are required in response to this comment.

Response 5-12
The commenter asks if conservation easements can be considered and encouraged. They suggest that American Canyon should plan to strategically purchase land and promote voluntary conservation easements, recommending these elements be added to the General Plan.

As discussed on page 4.3-12 of the Draft EIR, the proposed General Plan includes Policy ENV-1.3 which supports habitat conservation efforts to set aside and preserve suitable habitats, with priority given to habitats for rare and endangered species in American Canyon in accordance with state and 2-29
505
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
federal resource agency requirements. No revisions to the Draft EIR are required in response to this comment.

Response 5-13
The commenter suggests that access to riparian corridors should be restricted to prevent habitat damage, acknowledging that human presence can negatively impact wildlife.

Riparian corridors are protected areas which serve as habitats for a variety of wildlife within the city, as shown within Figure 4.3-1 of the Draft EIR which shows mapped riparian areas within the planning area. As discussed on page 4.3-20 of the Draft EIR, development and mobility improvements facilitated by the project would be subject to adopted City regulations to minimize impacts to riparian habitat, sensitive natural communities, and wetlands. Specifically, Section

19.24.050 of the American Canyon Municipal Code requires new development to be sited to preserve wetlands, including the retention of sufficient natural space and Section 19.24.040 restricts residential, commercial, and industrial uses in riparian corridors, limiting the potential for new development to substantially affect these areas. Further, as discussed under Impact BIO-1 and on page 4.3-21 of the Draft EIR, compliance with the NPDES Construction General Permit and MS4 Storm Water Permit would ensure that potential impacts to riparian habitat, sensitive natural communities, and wetlands would be less than significant.

To the commenter’s second point regarding the impact of human presence in riparian corridors, it is important to note that while protecting these areas is crucial, the City cannot fully restrict human access to them, nor is that the purpose of the Draft EIR. No revisions to the Draft EIR are required in response to this comment.

Response 5-14
The commenter emphasizes the importance of prioritizing habitat connectivity. They argue that activities like grading, cutting down trees, and soil discing should be avoided until a biological assessment is conducted. These actions should be particularly prohibited in areas with high biological diversity and riparian habitats.

As discussed on pages 4.3-11 and 4.-3-12 of the Draft EIR, Section 19.24.060 of the American Canyon Municipal Code requires development in areas that encompass oak savannah, mixed hardwood forest, and coastal saltmarsh to maintain buffers from these habitats as recommended by the biological assessment report, maintain connectivity to surrounding habitats, and limit public access in areas where habitat damage may occur. In addition, the 2040 General Plan would include the following proposed policies that would help protect habitats:
 Policy ENV-1.2: Sensitive Habitat Assessment and Impact Mitigation. Require new development and redevelopment located within sensitive habitats, including coastal saltmarsh, mixed hardwood forest, oak savannah, vernal pools, and riparian habitats to provide a detailed assessment of the potential for impacts on these resources, and include measures to reduce any identifiable impacts.
 Policy ENV-1.3: Habitat Conservation. Support habitat conservation efforts to set aside and preserve suitable habitats, with priority given to habitats for rare and endangered species in American Canyon in accordance with state and federal resource agency requirements.

However, as discussed on page 4.3-12 of the Draft EIR, the Municipal Code is only applicable to “significant biological habitats” defined as riparian corridors, coastal saltmarsh, mixed hardwood 2-30
506
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
forest, oak savannah, vernal pools and wetlands (as defined by USFWS), and special-status species may occur in other habitats such as grasslands and eucalyptus stands, or less suitable habitats within the planning area. Given the City does not have substantial contiguous, high-quality habitat to support special status species in previously developed and disturbed areas of the City and existing American Canyon Municipal Code requirements designed to limit the disturbance of habitat, including critical habitat, development facilitated by the project would not result in significant direct impacts to special status species due to habitat loss, but may impact special status-species if individuals are present during vegetation removal or construction. Accordingly, the Draft EIR includes Mitigation Measure BIO-1 which requires projects on undeveloped parcels to perform a baseline Biological Resources Screening and Assessment. If the project would have the potential to impact biological resources, Mitigation Measures BIO-2 through BIO-9 would be required, as applicable, to reduce impacts to a less than significant level. Pending the results of the projectspecific biological analysis, design alterations, further technical studies (e.g., protocol surveys) and consultations with the USFWS, CDFW, and/or other local, state, and federal agencies may be required. No revisions to the Draft EIR are required in response to this comment.

Response 5-15
The commenter suggests that the city should consider reparations and restoration efforts through converting nonfunctional spaces and landscaping back to natural native plantings and trees.

Additionally, they recommend adopting a native plant ordinance requiring that at least 70 percent of residential plantings consist of native species.

The City Council has expressed interest in furthering the use of native plants in public and private landscaping. However, this would be a subsequent action to the General Plan and EIR. Therefore, this comment does not pertain to the Draft EIR or CEQA. No revisions to the Draft EIR are necessary in response to this comment.

Response 5-16
The commenter recommends increasing buffer zones around nests and wildlife use areas to 0.5 miles, following the California Department of Fish and Wildlife's (CDFW) guidelines.

As discussed on Page 4.3-1 of the Draft EIR, the City of American Canyon Municipal Code Section

19.24.060 includes requirements for development of areas designated as oak savannah, mixed hardwood forest, and coastal saltmarsh maintain a buffer from the edge of the designated habitat.

In addition, as outlined within Mitigation Measure BIO-1, for projects proposed within undeveloped parcels, the City shall require a baseline Biological Resources Screening and Assessment to determine whether projects proposed within undeveloped parcels have any potential to impact special-status biological resources. If the project would have the potential to impact biological resources, prior to construction, a qualified biologist shall conduct a project specific biological analysis to document the existing biological resources within a project footprint plus a minimum buffer of 500 feet around the project footprint, as is feasible, and to determine the potential impacts to those resources. Furthermore, buffers for nests are established within Mitigation Measure BIO-7.

Accordingly, these existing requirements are sufficient and meet the CDFW requirements and ensure that development projects would comply with both local and state regulations. No revisions to the Draft EIR are required in response to this comment. 2-31
507
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-17
The commenter recommends increasing the tree replacement mitigation ratio from 1:1 to 5:1, reflecting a more accurate survival rate of 20 percent for new tree plantings.

The commenter’s suggestion to increase the tree replacement ratio from 1:1 to 5:1 is infeasible because such a high tree replacement ratio is not always necessary or feasible. Often, there is inadequate space available for planting multiple trees in close proximity. Planting trees too close together can lead to competition for resources such as sunlight, water, and nutrients, which can stress the trees and ultimately be detrimental to their health. Furthermore, overcrowding can also increase the risk of disease and pest infestations.

It is crucial to balance the goals of tree replacement with the practical considerations of space and tree health. No revisions to the Draft EIR are required in response to this comment.

Response 5-18
The commenter suggests that all replacement trees and vegetation should be watered and maintained for at least one year after planting. They recommend replacing any failed mitigations and conducting a one-year survival review to ensure any unsuccessful plantings are replaced before the year ends.

The issue of landscape maintenance is addressed by the zoning code. According to American Canyon Municipal Code Section 19.22.040, trees and vegetation shall be continually maintained in good condition and kept clean and weeded. Good maintenance shall be interpreted to include:
watering and maintaining water efficiency, weeding, pruning, insect and disease control, and replacement of plant materials and irrigation equipment as needed to preserve the health and appearance of plant materials.. No revisions to the Draft EIR are required in response to this comment.

Response 5-19
The commenter suggests creating a mitigation enforcement statute with clear accountability standards, including consequences for non-compliance and requiring city review and final approval of all mitigation efforts upon completion.

The City will prepare and adopt a Mitigation Monitoring and Reporting Program (MMRP) to track the implementation of mitigation measures identified in the Draft EIR. The purpose of the MMRP is to ensure that the mitigation measures are implemented effectively and in a timely manner. The MMRP includes a detailed list of all mitigation measures, a timeline for their implementation, identification of responsible parties, specific monitoring actions, and procedures for documenting and reporting progress. This program serves as a tool to track and verify that the mitigation measures are carried out as intended, ensuring accountability and transparency throughout the process. No revisions to the Draft EIR are required in response to this comment. 2-32
508
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-20
The commenter suggests defining vague terms like "large" with specific numbers.

It is unclear which areas of the Draft EIR the commenter is referring to. Nevertheless, due to the programmatic nature of the analysis and associated mitigation, it is not always possible to define terms more specifically. However, the Draft EIR does define terms wherever possible to provide clarity and ensure a comprehensive understanding of the potential impacts and mitigation measures. No revisions to the Draft EIR are required in response to this comment.

Response 5-21
The commenter suggests that any development activity removing habitat, such as roosting or nesting trees, should replace these habitats as close to the original site as possible.

As discussed within Mitigation Measure BIO-8, all future development under the 2040 General Plan that will require the removal of large trees identified during the Biological Resources Screening and Assessment (Mitigation Measure BIO-1), prior to tree and/or structure removal, a qualified biologist shall conduct a focused survey of all trees and structures to be removed or impacted by construction activities to determine whether active roosts of special-status bats are present on site.

If no signs of day roosting activity are observed, no further actions will be required. If bats or signs of day roosting by bats are observed, a qualified biologist will prepare specific recommendations such as partial dismantling to cause bats to abandon the roost, or humane eviction, both to be conducted during seasonal periods of bat activity, if required. Additionally, the qualified biologist shall determine compensatory mitigation for temporary or permanent habitat loss due to tree removal, in conjunction with CDFW. No revisions to the Draft EIR are required in response to this comment.

Response 5-22
The commenter advocates for banning discing as a weed control method, highlighting that it destroys habitats for ground-dwelling animals like burrowing owls, lizards, and snakes. They note that burrowing owls have been spotted in the American Canyon wetlands area.

The Draft EIR is a programmatic document and does not analyze details and designs specific to individual development projects, such as the use of discing as a weed control method. Furthermore, discing is a site-specific activity, and its appropriateness must be evaluated on a case-by-case basis.

No revisions to the Draft EIR are required in response to this comment.

Response 5-23
The commenter suggests prohibiting the capture, killing, or relocation of animals without explicit authorization from CDFW or U.S. Fish and Wildlife Service (USFWS), and banning all wildlife killings in construction zones.

As discussed within Section 4.3, Biological Resources, of the Draft EIR, projects must comply with the Federal Endangered Species Act and the California Endangered Species Act, which prohibit the unauthorized capture, killing, or relocation of listed species. As discussed on Page 4.3-6 of the Draft EIR, the California Endangered Species Act allows for incidental take to otherwise lawful activities under CFGC Section 2081. The process of incidental take allows for the unintentional harm or harassment of these species during lawful activities, provided that specific permits are obtained.

These permits require the implementation of measures to minimize and mitigate impacts on the 2-33
509
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
species. Project proponents wishing to obtain incidental take permits can do so through a permitting process outlined in California Code of Regulations (CCR) Section 783.

Additionally, the Draft EIR includes Mitigation Measure BIO-6 on page 4.3-16, which outlines the following requirements:
 All projects occurring within or adjacent to sensitive habitats that may support federally and/or state-listed endangered/threatened species shall have a CDFW- and/or USFWS-approved biologist present during all initial ground disturbing/vegetation clearing activities. Once initial ground disturbing/vegetation clearing activities have been completed, the biologist shall conduct daily pre-activity clearance surveys for endangered/threatened species. Alternatively, and upon approval of the CDFW and/or USFWS, the biologist may conduct site inspections at a minimum of once per week to ensure all prescribed avoidance and minimization measures are fully implemented.
 No endangered/threatened species shall be captured and relocated without express permission from the CDFW and/or USFWS.
 If at any time during project construction an endangered/threatened species enters the construction site or otherwise may be impacted by the project, all project activities shall cease.

A CDFW/USFWS-approved biologist shall document the occurrence and consult with the CDFW and USFWS, as appropriate, to determine whether it is safe for project activities to resume.  For all work occurring in areas where endangered/threatened species may be present and are at risk of entering the project site during construction, the applicant shall install exclusion fencing along the project boundaries prior to the start of construction (including staging and mobilization). The placement of the fence shall be at the discretion of the CDFW/USFWSapproved biologist. This fence shall consist of solid silt fencing placed at a minimum of three feet above grade and two feet below grade and shall be attached to wooden stakes placed at intervals of not more than five feet. The applicant shall inspect the fence weekly and following rain events and high wind events and shall maintain it in good working condition until all construction activities are complete.

These measures ensure that projects comply with the Federal Endangered Species Act and the California Endangered Species Act, and provide necessary protections for endangered and threatened species. No revisions to the Draft EIR are required in response to this comment.

Response 5-24
The commenter suggests placing large signs at all sites to direct wildlife injuries to the Napa Wildlife Rescue Center, including a map and phone number.

It is important to note that the Napa Wildlife Rescue Center has not indicated a desire for such signage. Additionally, the City does not have the authority to require the Napa Wildlife Rescue Center to take in injured animals from project sites. This comment is not related to the Draft EIR. No revisions to the Draft EIR are required in response to this comment. 2-34
510
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-25
The commenter recommends banning pesticides and bait stations within 500 feet of wildlife habitats, including creeks, sloughs, and watering sites.

The activities outlined in the General Plan do not include specific details related to pesticide use or control. This matter falls within the jurisdiction of the Napa County Agricultural Commissioner's Office, which is responsible for the implementation and enforcement of pesticide regulations. The Napa County Agricultural Commissioner's Office oversees the safe use of pesticides through various programs and regulations designed to protect people, wildlife, and the environment. This includes monitoring pesticide applications near sensitive areas such as creeks, sloughs, and watering sites to minimize potential harm to wildlife habitats. For further information on pesticide use and control measures, please contact the Napa County Agricultural Commissioner's Office. This comment is not related to the Draft EIR. No revisions to the Draft EIR are required in response to this comment.

Response 5-26
The commenter recommends no overnight lighting on buildings within 500 feet of a wildlife area.

As discussed on pages 4.1-12, impacts to light pollution would be less than significant with mitigation. While the project would increase nighttime light, implementation of Mitigation Measure AES-2 would reduce operational light spillage to the extent feasible. The City has adopted California Green Building Code into its municipal code, which includes requirements to reduce light pollution.

Overall, implementation of Mitigation Measure AES-2 would ensure that lighting and glare is minimized during operation of future development facilitated by the project, and impacts would be less than significant. No revisions to the Draft EIR are required in response to this comment.

Response 5-27
The commenter suggests that mitigation measures for warehouse and urban park developers should include expanding the urban forest, applying soil or compost to sequester carbon, and incentivizing rooftop gardens.

The Draft EIR is a programmatic document and does not analyze details and designs specific to individual development projects, such as development associated with warehouses and urban park developers. This comment is not related to the Draft EIR. No revisions to the Draft EIR are required in response to this comment.

Response 5-28
The commenter suggests supporting a regional plan with Napa and Solano Counties to protect open spaces and wildlife.

This comment does not pertain to the Draft EIR or CEQA. The City of American Canyon collaborates with Napa and Solano Counties on several regional plans to protect open space and wildlife. Most notably, development projects within the City must adhere to the General Plan, which includes policies for the protection of natural resources and open spaces. A prospective regional plan with Napa and Solano Counties would be a subsequent action that follows the General Plan and EIR. No revisions to the Draft EIR are required in response to this comment. 2-35
511
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-29
The commenter suggests banning plastic grass in schools, residential, and in industrial development lands.

The Draft EIR is a programmatic document and does not analyze details and designs specific to individual development projects, such as the use of plastic grass in development. Public schools are not subject to local regulation. Consideration of other circumstances where plastic grass may be subject to local regulation would be a subsequent action that follows the General Plan and EIR. No revisions to the Draft EIR are required in response to this comment.

Response 5-30
The commenter suggests that future EIRs and Biological Resource Studies should include data and information from local environmental groups, such as the Audubon Society, Napa Plant Society, Beekeepers, and ICare.

CEQA does not mandate the inclusion of data and information from local environmental groups.

Local environmental groups are encouraged to provide their input during the scoping and public review periods of future EIRs. During these times, they can submit relevant information from their sources to be considered in the environmental review process. No revisions to the Draft EIR are required in response to this comment.

Response 5-31
The commenter suggests including data from verification apps like iNaturalist and eBird.org in planning processes, stating an opinion that local bird watchers and regular walkers often have more current knowledge of local flora and fauna than outdated data sources. They also encourage involving local environmental groups in land use planning to protect critical habitats for special status species.

This comment is similar to Comment 5-30, please see the response above. As described therein, local environmental groups are always encouraged to provide their input during the scoping and public review periods of future EIRs. During these times, they can submit relevant information from their sources to be considered in the environmental review process. No revisions to the Draft EIR are required in response to this comment.

Response 5-32
The commenter suggests banning diesel truck idling in warehouse districts and imposing fines for idling over three minutes.

As stated in Section 4.5, Greenhouse Gas Emissions, the 5-minute idling time of nonworking vehicles would be consistent with the California Airborne Toxics Control Measure Title 13, Section 2485 of the California Code of Regulations requirements. Adherence to these requirements for nonworking vehicles would reduce GHG emissions associated with idling. No revisions to the Draft EIR are required in response to this comment.
2-36
512
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 5-33
The commenter suggests that the City of American Canyon hire or assign dedicated staff to protect wildlife and preserve land for habitat.

Hiring new staff fall under the purview of the City's administrative and budgetary processes. This comment does not pertain to the Draft EIR or CEQA. No revisions to the Draft EIR are required in response to this comment.

Response 5-34
The commenter suggests banning black asphalt in all new roads, developments, parking lots, and replace with permeable concrete.

On page 4.3-11, the project would be subject to Bay Area Air Quality Management District Regulation 8, Rule 15 which dictates the reactive organic gases content of asphalt available for use during construction by regulating the sale and use of asphalt and limiting the ROG content in asphalt. No revisions to the Draft EIR are required in response to this comment.

Response 5-35
The commenter suggests that the 203 acres of Green Island Vineyard should be set aside as an area of study for a conservation easement.

This comment does not pertain to the Draft EIR or CEQA. The Green Island Vineyard is not included as part of the General Plan scope of work. No revisions to the Draft EIR are required in response to this comment.

Response 5-32
The commenter expresses gratitude for the opportunity to provide public comments and hopes their suggestions will be considered and incorporated into the Final EIR.

This comment is appreciated and no revisions to the Draft EIR are required in response to this comment.
2-37
513
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
November 20, 2024
Brent Cooper
City of American Canyon, Community Development Director 4381 Broadway Street, Suite 201
American Canyon, CA 94503
[email protected]
Subject: American Canyon 2040 General Plan Update, Program Environmental Impact Report, SCH No. 2022070038, Napa County
Dear Mr. Cooper:

The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of a Draft Program Environmental Impact Report (EIR) from the City of American Canyon (City) for the American Canyon 2040 General Plan Update (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW
previously provided comments in response to the Notice of Preparation (NOP) of the EIR in a letter dated July 28, 2022.

After receiving a two-week extension from the City, CDFW is submitting comments on the EIR to inform the City, as the Lead Agency, of potentially significant impacts to biological resources associated with the Project.

CDFW ROLE
CDFW is a Trustee Agency with responsibility under CEQA pursuant to CEQA Guidelines section 15386 for commenting on projects that could impact fish, plant, and wildlife resources. CDFW is also considered a Responsible Agency if a project would require discretionary approval, such as permits issued under the California Endangered Species Act (CESA) or Native Plant Protection Act (NPPA), the Lake and Streambed Alteration Program, or other provisions of the Fish and Game Code that afford protection to the state’s fish and wildlife trust resources.

PROJECT DESCRIPTION SUMMARY
Proponent: City of American Canyon
Objective: The Project would adopt and implement the American Canyon 2040 General Plan update per California Government Code section 65300 and the City’s Climate Action Plan. The General Plan Update will reflect recent development decisions and changes in State law. Major components will include the following elements: Land Use, Circulation, Community Services, Open Space and Recreation, Conservation, Safety, Noise, and Housing. The General Plan Update includes buildout estimates of 3,379 residential units and 5,704,000 square feet of nonresidential development. It will serve as the City’s primary guide for future land use and development decisions. Location: The general planning area includes approximately 6.1 square miles of the City, the urban limit line, historic water service area, and sphere of influence. The City is in southern Napa County, approximately 5 miles south of the City of Napa, 25 miles northeast of the City of San Francisco, and approximately 20 miles north of the City of Oakland. The City is bordered by unincorporated Napa County and the Napa County Airport to the north, Sulphur Spring Mountains to the east, Solano County and the City of Vallejo to the south, and a salt marsh and wetland area including the Napa River to 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 Letter 6
6-1
6-2
6-3
2-38
514
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

the west. The GPU planning area is centered at approximately 38.17941°N, - 122.25472°W (NAD 83).

REGULATORY REQUIREMENTS
California Endangered Species Act and Native Plant Protection Act Please be advised that a CESA Incidental Take Permit (ITP) must be obtained if the Project has the potential to result in “take” of plants or animals listed or candidates for listing under CESA or NPPA either during construction or over the life of the Project. As described in CDFW’s response letter to the NOP, the Project has the potential to impact the CESA listed as endangered species Delta smelt (Hypomesus transpacificus), and CESA listed as threatened species including Longfin smelt (Spirinchus thaleichthys), tricolored blackbird (Agelaius tricolor), and Swainson’s hawk (Buteo swainsoni), the latter two of which are documented to nest in and near the Project area. Additionally, the Project has the potential to impact winterrun Chinook salmon (Oncorhynchus tshawytscha) and spring-run Chinook salmon (Oncorhynchus tshawytscha), which are CESA listed as endangered and threatened, respectively, and white sturgeon (Acipenser transmontanus) and burrowing owl (Athene cunicularia), which were recently approved as CESA candidate species (CDFW 2024). In addition to habitat removal and direct impacts, noise-generating or vegetation-disturbing activities, or activities resulting in visual disturbances, could result in take of nesting tricolored blackbird or Swainson’s hawk and nesting or wintering burrowing owl. Plant species such as Mason’s lilaeopsis (Lilaeopsis masonii), which is NPPA listed as rare, and Tiburon paintbrush (Castilleja affinis var. neglecta), which is CESA listed as endangered, may also occur in or near the Project and ground-disturbing activities could result in take of individuals. Due to the large Project area, additional species listed under CESA and NPPA may be impacted, as further described below. Issuance of an ITP is subject to CEQA documentation; the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program. If the Project will impact CESA or NPPA listed species including, but not limited to those described above, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain an ITP.

CEQA requires a Mandatory Finding of Significance if a project is likely to substantially restrict the range or reduce the population of a threatened or endangered species. (Pub.

Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064, & 15065.). Impacts must be avoided or mitigated to less-than-significant levels unless the CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).

The CEQA Lead Agency’s FOC does not eliminate the Project proponent’s obligation to comply with CESA.

Lake and Streambed Alteration
An LSA Notification, pursuant to Fish and Game Code section 1600 et seq., is required for project activities affecting lakes or streams and associated riparian habitat.

Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank including associated riparian or wetland resources; or deposit or dispose of material where it may pass into a river, lake, or stream. Project sites may contain streams, therefore an LSA Notification may be warranted, as further described below. Work within ephemeral streams, washes, watercourses with a subsurface flow, and floodplains are subject to LSA Notification requirements. CDFW would consider the CEQA document for the Project and may issue an LSA Agreement. CDFW may not execute the final LSA Agreement until it has complied with CEQA as a Responsible Agency.

Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-3 cont.
6-4
6-5
6-6
2-39
515
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

Raptors and Other Nesting Birds
CDFW has jurisdiction over actions that may result in the disturbance or destruction of active nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include sections 3503 (regarding unlawful take, possession or needless destruction of the nests or eggs of any bird), 3503.5 (regarding the take, possession or destruction of any birds-of-prey or their nests or eggs), and 3513 (regarding unlawful take of any migratory nongame bird). Migratory birds are also protected under the federal Migratory Bird Treaty Act.

California Fully Protected Species
Fully Protected species may not be taken or possessed at any time and no licenses or permits may be issued for their take except as follows: • Take is for necessary scientific research; • Efforts to recover a fully protected, endangered, or threatened species, live capture and relocation of a bird species for the protection of livestock; or • They are a covered species whose conservation and management is provided for in a Natural Community Conservation Plan (Fish & G. Code, §§ 3511, 4700, 5050, & 5515).

Specified types of infrastructure Projects may be eligible for an ITP for unavoidable impacts to fully protected species if certain conditions are met (Fish & G. Code, § 2081.15). Project proponents should consult with CDFW early in the Project planning process. The Project has the potential to impact the following California Fully Protected species: salt marsh harvest mouse (Reithrodontomys raviventris), also CESA listed as endangered; California Ridgway’s rail (Rallus obsoletus obsoletus), also CESA listed as endangered; California black rail (Laterallus jamaicensis coturniculus), also CESA listed as threatened; golden eagle (Aquila chrysaetos), American peregrine falcon (Falco peregrinus anatum), and whitetailed kite (Elanus leucurus).

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below and in Attachment 1 to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

I. Project Description and Related Impact Shortcoming
COMMENT 1: Program Environmental Impact Report Subsequent Project Review The EIR is a Program EIR but does not include a checklist for subsequent project review. As described in CDFW’s letter response to the NOP, while Program EIRs have a necessarily broad scope, as described in CDFW’s NOP response letter, CDFW recommends providing as much information related to anticipated future activities as possible. CDFW recognizes that, pursuant to CEQA Guidelines section 15152, subdivision (c), if a Lead Agency is using the tiering process in connection with an EIR or large-scale planning approval, the development of detailed, site-specific information may not be feasible and can be deferred, in many instances, until such time as the Lead Agency prepares a future environmental document. This future environmental document would cover a Project of a more limited geographical scale and is appropriate if the deferred information does not prevent adequate identification of significant effects of the planning approval at hand. The CEQA Guidelines section 15168, subdivision (c)(4) states, “Where the later activities involve site-specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-7
6-8
6-9
6-10
2-40
516
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

scope of the program EIR.” Based on CEQA Guidelines section 15183.3 and associated Appendix N Checklist, and consistent with other program EIRs, CDFW recommends creating a procedure or checklist for evaluating subsequent Project impacts on biological resources to determine if they are within the scope of the Program EIR or if an additional environmental document is warranted. This checklist should be included as an attachment to the EIR. Also see an example in the Board of Forestry and Fire Protection’s Appendix PD-3 - Project-Specific Analysis, available at https://bof.fire.ca.gov/projects-and-programs/calvtp-homepage-andstorymap/#:~:text=The%20CalVTP%20Program%20Environmental%20Impact,with%20 the%20CalVTP%20Program%20EIR and template-psa-checklist-508-compliant.dotx https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fbof.fire.ca.gov%2 Fmedia%2Fuqbpmcuq%2Ftemplate-psa-checklist-508-
compliant.dotx&wdOrigin=BROWSELINK. Future analysis should include all specialstatus species and sensitive habitat including, but not limited to species considered rare, threatened, or endangered species pursuant to CEQA Guidelines, section 15380.

When used appropriately, the checklist should be accompanied by enough relevant information and reasonable inferences to support a “within the scope” of the EIR conclusion. For subsequent Project activities that may affect sensitive biological resources, a site-specific analysis should be prepared by a Qualified Biologist to provide the necessary supporting information. In addition, the checklist should cite the specific portions of the EIR, including page and section references, containing the analysis of the subsequent Project activities’ significant effects and indicate whether it incorporates all applicable mitigation measures from the EIR.

II. Environmental Setting and Mitigation Measures Related Impact Shortcomings Mandatory Findings of Significance: Does the Project have the potential to substantially reduce the number or restrict the range of an endangered, rare, or threatened species?
And,
Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or U.S. Fish and Wildlife Service (USFWS)?
COMMENT 2: Listed and other Special-Status Species Unmitigated Impacts Issue, specific impacts, why they may occur and be potentially significant: If the Project may result in physical changes in the environment, such as facilitating development, then the Project could: 1) reduce the number or restrict the range of an endangered, rare, or threatened species, or 2) have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special-status species. The General Plan Area (EIR, page 2-4) has potential to support special-status species described in this letter. These species are documented to occur within 5 miles of the General Plan Area according to the California Natural Diversity Database (CNDDB). The EIR does not include specific and detailed mitigation measures for these species.

California Ridgeway’s Rail and California Black Rail
The Project has the potential to impact nesting California Ridgeway’s rail and California black rail through auditory or visual disturbances above ambient levels, or habitat removal. Disturbances from Project activities on or within 700 feet of suitable nesting habitat may result in California black rail and California Ridgeway’s rail nest abandonment and loss of eggs or reduced health and vigor and loss of young. These species are CESA listed as threatened or endangered and are therefore considered to Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-10 cont.
6-11
6-12
6-13
2-41
517
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

be a threatened or endangered species pursuant to CEQA Guidelines section 15380.

Therefore, if an active nest is disturbed by the Project, the Project could result in a substantial reduction in the species’ population, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1). Suitable marsh habitat for both species is present along the western side of the General Plan Area, including areas near Fagan Marsh Ecological Reserve and the Napa-Sonoma Marshes Wildlife Area.

Salt Marsh Harvest Mouse
The Project has the potential to impact salt marsh harvest mouse through direct salt marsh habitat removal and injury or mortality of the species. Salt marsh harvest mouse is CESA listed as endangered and and is therefore considered to be an endangered species pursuant to CEQA Guidelines section 15380. Therefore, if salt marsh harvest mouse is impacted by the Project, the Project could result in a substantial reduction in the species’ population, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

Swainson’s Hawk
If the work associated with the Project occurs during nesting season, any nesting Swainson’s hawks within 0.5 miles of the Project site could be disturbed by Project activities resulting in nest abandonment or reduced health and vigor of young, and take of the species pursuant to CESA. Swainson’s hawks is CESA listed as threatened and therefore is considered to be a threatened species pursuant to CEQA Guidelines section 15380. Therefore, if an active nest is disturbed by the Project, the Project could result in a substantial reduction in the species’ population, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

The Project could result in the removal of potential foraging habitat for Swainson’s hawk, however no compensatory habitat mitigation is proposed. The breeding population of Swainson’s hawks in California has declined by an estimated 91 percent since 1900 and the species continues to be threatened by on-going and cumulative loss of foraging habitat (CDFW 2016). Therefore, reduction of Swainson’s hawk foraging habitat would be a potentially significant impact. Napa County recently recognized the need to conserve Swainson’s hawk foraging habitat to reduce impacts to less-than-significant and included Swainson’s hawk foraging habitat compensation in their Mitigated Negative Declaration for E&P Technology Way - Building A & B Use Permit, State Clearinghouse No. 2024100855 (see MND at, https://ceqanet.opr.ca.gov/2024100855 specifically Mitigation Measure BIO-5 on page 12).

Tricolored Blackbird
The Project may impact tricolored blackbird, which occurs in Napa County. The Project area encompasses the range and sections of predicted habitat for tricolored blackbird. If active tricolored blackbird nests are not detected by the proposed surveys or appropriate buffer zones are not established, tricolored blackbird could be disturbed by Project activities resulting in nest abandonment and loss of eggs or reduced health and vigor and loss of young. Tricolored blackbird is CESA listed as a threatened species and therefore is considered to be a threatened species pursuant to CEQA Guidelines section 15380. Therefore, if an active tricolored blackbird nest is disturbed by the Project, the Project may result in a substantial reduction in the number of a threatened species, which is considered a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-13 cont.
6-14
6-15
6-16
2-42
518
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

Burrowing Owl
The Project could result in burrowing owl nest abandonment, loss of young, reduced health and vigor of owlets, injury or mortality of adults, and permanent wintering (i.e., non-nesting) or nesting habitat loss. Additionally, the Project may result in a permanent reduction of burrowing owl foraging habitat in Napa County. Burrowing owl is a CESA candidate species and Species of Special Concern (SSC) because the species’ population viability and survival are adversely affected by risk factors such as precipitous declines from habitat loss, fragmentation, and degradation; evictions from nesting sites without habitat mitigation; wind turbine mortality; human disturbance; and eradication of California ground squirrels (Otospermophilus beecheyi) resulting in a loss of suitable burrows required by burrowing owl for nesting, protection from predators, and shelter (Shuford and Gardali 2008; Department of Fish and Game Staff Report on Burrowing Owl Mitigation (2012); personal communication, CDFW Statewide Burrowing Owl Coordinator Esther Burkett, May 13, 2022). Preliminary analyses of regional patterns for breeding populations of burrowing owl have detected declines both locally in their central and southern coastal breeding areas, and statewide where the species has experienced breeding range retraction (Department of Fish and Game Staff Report on Burrowing Owl Mitigation (2012); personal communication, Esther Burkett, May 13, 2022). Burrowing owl have been extirpated from 16 percent of their former range and are at risk of being extirpated from another 13 percent of their range in the State (CDFW 2024). Information indicates a decline in burrowing owl range over time, burrowing owl has experienced population declines in regions of California and threats to burrowing owl, coupled with long-term population declines, suggest a high degree and immediacy of threat to burrowing owl in California (CDFW 2024). Burrowing owl is CESA candidate species and therefore is considered to be a threatened species pursuant to CEQA Guidelines section 15380. Therefore, if an active nest or wintering owl is disturbed by the Project, the Project could result in a substantial reduction in the species’ population, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1).

Special-Status Plants
The EIR includes mitigation measures BIO-2 and BIO-3 for special-status plants, however these measures do not require the Project to obtain a CESA ITP for impacts to CESA or NPPA listed plants, and therefore impacts to listed plants may not be mitigated to less-than-significant.

Special-Status Fishes and Aquatic Life
The General Plan Area covers or is adjacent to estuarine, riverine, and pelagic habitats that support special-status fishes including Delta smelt, CESA listed as endangered and federally listed as threatened; longfin smelt, CESA listed as threatened and federally listed as endangered; winter- and spring-run Chinook salmon, CESA listed as endangered and threatened, respectively, and white sturgeon, CESA candidate species. Note that Project activities can remotely impact special-status fishes (e.g. pollutants introduced upstream from fish habitat). The above fish species are CESA and federal Endangered Species Act (ESA) listed or candidate species and therefore are considered to be threatened or endangered species pursuant to CEQA Guidelines section 15380. Therefore, if these fish would be impacted by the Project, the Project could result in a substantial reduction in the species’ population, which would be a mandatory finding of significance pursuant to CEQA Guidelines section 15065, subdivision (a)(1). CDFW recommends revising the EIR to include an assessment of special-status fishes and aquatic life including, but not limited to the above fish species, as well as an assessment of overall Project impacts regarding aquatic resources, streams, riparian areas, and in-water work (see Comments 3 and 4 below).

Recommended Mitigation Measures: To reduce potential impacts to listed and special-status species to less-than-significant and comply with CESA and NPPA, CDFW Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-17
6-18
6-19
6-20
2-43
519
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

recommends including mitigation measures in the EIR which evaluate such foreseeable potentially significant impacts. Where future site-specific impacts may not be presently foreseeable based on the Project’s broad scope, the checklist discussed in Comment 1 above should be used to determine if a future CEQA environmental document is required. CDFW would appreciate the opportunity to review a revised EIR and may have further comments once more specific-species information is provided.

For example, CDFW recommends including the mitigation measures below in this EIR:

Mitigation Measure BIO-10 (Fully Protected Species). A qualified biologist or biological monitor shall be present on site to survey and monitor for Fully Protected species, including salt marsh harvest mouse, California Ridgway’s (formerly California Clapper) rail, and California black rail, during: a) all vegetation removal, b) the construction of exclusion fencing, and c) all work within 300 feet of tidal or pickleweed habitats. The qualified biologist or biological monitor shall have the authority to stop work if deemed necessary for any reason to protect these species, or any other special-status species.

Take or possession of these Fully Protected species is prohibited and no permits may be issued for such, except in limited circumstances (Fish & G. Code, §§ 3511 & 4700).

Mitigation Measure BIO-11 (California Ridgeway’s Rail/Black Rail Avoidance and Surveys). A qualified biologist shall assess if suitable habitat for California Ridgway’s rail or California black rail habitat occurs on or within 700 feet of the Project area and shall obtain CDFW’s written acceptance of the assessment prior to the start of Project construction. Project activities within tidal marsh or suitable California Ridgway’s rail or California black rail habitat, and within 700 feet of such habitat, shall be avoided during rail breeding season (January 15 – August 31 for California Ridgway’s rail, February 1 – August 31 for California black rail) each year unless appropriately timed, yearly protocol level surveys are conducted, and survey methodology and results are submitted to and accepted by CDFW in writing. Surveys shall focus on suitable habitat that may be disturbed by Project activities during the breeding season to ensure that these species are not nesting in these locations.

If breeding rails are determined to be present, no activities, visual disturbance (direct line of sight) and/or an increase in the ambient noise level shall occur within 700 feet of areas where California Ridgway’s rail and/or California black rail have been detected during the breeding season, unless otherwise approved in writing by CDFW. If surveys have not been conducted, all work shall be conducted 700 feet from California Ridgway’s rail and/or California black rail habitat during nesting Mitigation Measure BIO-12 (Salt Marsh Harvest Mouse – High Tide Restrictions). No Project activities shall occur within 50 feet of suitable tidal marsh habitat for the salt marsh harvest mouse within two hours before and after an extreme high tide event (6.5 feet or higher measured at the Golden Gate Bridge and adjusted to the timing of local high tides) or when adjacent marsh is flooded unless salt marsh harvest mouse proof exclusion fencing has been installed around the work area.

Mitigation Measure BIO-13 (Salt Marsh Harvest Mouse – Vegetation). Prior to impacting salt marsh habitat, a qualified biologist or biological monitor, familiar with salt marsh harvest mouse, shall walk through and inspect suitable habitat prior to vegetation removal and search for signs of harvest mice or other sensitive wildlife and plants.

Following inspection, personnel, under the supervision of the qualified biologist, will disturb (e.g., flush) vegetation to force movement of salt marsh harvest mouse into adjacent marsh areas. Flushing of vegetation will first occur in the center of the site then progress toward the two sides away from the open water areas or in this case, away from impacted habitat. Immediately following vegetation flushing, personnel, under the supervision of the qualified biologist or biological monitor, will remove vegetation with hand tools (e.g., weed-eater, hoe, rake, trowel, shovel, grazing) so that vegetation is no taller than two inches.

Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-20 cont.
6-21
6-22
6-23
6-24
2-44
520
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

Mitigation Measure BIO-14 (Salt Marsh Harvest Mouse – Exclusion Fencing). After vegetation removal, a mouse proof barrier shall be placed along the edge of the area removed of vegetation to further reduce the likelihood of salt marsh harvest mouse returning to the area prior to construction. The fence shall be made of a heavy plastic sheeting material that does not allow salt marsh harvest mice to pass through or climb, and the bottom shall be buried to a depth of four inches so that salt marsh harvest mouse cannot crawl under the fence. Fence height shall be at least 12 inches higher than the highest adjacent vegetation with a maximum height of 4 feet. All supports for the exclusion fencing shall be placed on the inside of the work area. An approximately two-foot wide de-vegetated buffer shall be created along the habitat side of the exclusion fence.

Mitigation Measure BIO-15 (Salt Marsh Harvest Mouse – Inspections). The salt marsh harvest mouse exclusion fencing shall remain in operating condition throughout the duration of all project activities in salt marsh habitat. The qualified biologist or biological monitor shall daily inspect the integrity of the exclusion fencing to ensure there are no gaps, tears or damage. Maintenance of the fencing shall be conducted as needed. Any necessary repairs to the fencing shall be completed within 24 hours of the initial observance of the damage. Any mice found along or outside the fence shall be closely monitored until they move away from the project area.

Mitigation Measure MM-BIO-16 (Swainson’s Hawk Surveys and Avoidance Buffer): If Project activities are scheduled during the nesting season for Swainson’s hawks (March 1 to September 15), prior to beginning work on the Project, a qualified biologist shall conduct surveys according to the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley, unless otherwise approved by CDFW in writing2
Survey methods shall be closely followed by starting
early in the nesting season (late March to early April) to maximize the likelihood of detecting an active nest (nests, adults, and chicks are more difficult to detect later in the growing season because trees become less transparent as vegetation increases).

Surveys shall be conducted: 1) within a minimum 0.5-mile radius of the Project site or a larger area if needed to identify potentially impacted active nests, unless otherwise approved by CDFW in writing, and 2) for at least the two survey periods immediately prior to initiating Project-related construction activities. Surveys shall occur annually for the duration of the Project. The qualified biologist shall have a minimum of two years of experience implementing the survey methodology resulting in detections. If active Swainson’s hawk nests are detected, the Project shall immediately inform CDFW and implement a 0.5-mile construction avoidance buffer around the nest until the nest is no longer active as determined by a qualified biologist, unless otherwise approved by CDFW in writing. If take of Swainson’s hawk cannot be avoided, the Project shall consult with CDFW pursuant to CESA and obtain an ITP. CDFW Bay Delta Region staff is available to provide guidance on the ITP application process.

Mitigation Measure MM-BIO-17 (Swainson’s Hawk Foraging Habitat Mitigation): Impacts to Swainson’s hawk foraging habitat shall be quantified by a qualified biologist based on the final Project design plans, and the Project shall obtain written acceptance of the acreage of habitat impacts from CDFW. Prior to Project construction, the Project shall provide Swainson’s hawk foraging habitat mitigation at a minimum 1:1 ratio which shall include: 1) permanent preservation of the species’ foraging habitat through a conservation easement and implementing and funding a long-term management plan in perpetuity, or 2) purchase of Swainson’s hawk foraging habitat credits at a CDFW- approved mitigation bank, unless otherwise required by an ITP issued for Swainson’s hawk.

Mitigation Measure MM-BIO-18 (Tricolored Blackbird Avoidance): If nesting tricolored blackbird or evidence of their presence is found during nesting bird surveys within 500 2 Swainson’s Hawk Technical Advisory Committee, 2000. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83990&inline Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-25
6-26
6-27
6-28
6-29
2-45
521
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

feet of Project activities, CDFW shall be notified immediately and work shall not occur without written approval from CDFW allowing the Project to proceed. Project activities shall not occur within 500 feet of an active nest unless otherwise approved in writing by CDFW. If take of tricolored blackbird cannot be avoided, the Project shall consult with CDFW pursuant to CESA and obtain an ITP.

Mitigation Measure MM-BIO-19 (Burrowing Owl Surveys): A qualified biologist shall conduct a burrowing owl habitat assessment within 1,640 feet of the Project area pursuant to the California Department of Fish and Game (now CDFW) 2012 Staff Report on Burrowing Owl Mitigation (CDFW 2012 Staff Report, available here:
https://wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds), unless otherwise approved in writing by CDFW. The qualified biologist shall have a minimum of two years of experience implementing the CDFW 2012 Staff Report survey methodology resulting in detections. The habitat assessment shall focus on searching the CNDDB and potentially other sources for any burrowing owl records on or within one mile of the Project area, vegetation type and height, suitable burrows (with an opening greater than11 centimeters [cm] in diameter and a depth of greater than 150 cm), burrow surrogates (culverts, piles of concrete rubble, piles of soil, burrows created along soft banks of ditches and canals, pipes, and similar structures), and presence of burrowing owl sign (tracks, molted feathers, cast pellets, prey remains, egg shell fragments, owl white wash, and nest burrow decoration material), and the presence of burrowing owl individuals or pairs. If the habitat assessment does not identify suitable habitat and surveys are not conducted as described below, an additional habitat assessment shall be conducted within 14 days prior to construction and if new potentially suitable burrowing owl refugia are present surveys shall be conducted as described below, unless otherwise approved in writing by CDFW. The results of the habitat assessment shall be emailed to the CDFW contact below, or if unavailable another CDFW representative, and the Project shall obtain CDFW’s written approval of the habitat assessment prior to starting Project activities.

If suitable burrowing owl habitat is observed, four surveys shall be conducted to detect the presence of burrowing owl pursuant to the CDFW 2012 Staff Report. The site visits shall be spread evenly throughout the breeding or non-breeding season. The Project shall obtain CDFW’s written approval of the survey results prior to starting Project activities. In addition, a take avoidance survey shall be completed within 14 days prior to the start of construction, as described in the CDFW 2012 Staff Report.

If burrowing owl is detected, the Project shall immediately notify CDFW. The Project shall avoid impacts to the burrowing owl and implement a 1,640-foot buffer area around the owl site in which no Project activities shall occur, unless otherwise approved in writing by CDFW. A Qualified Biologist shall monitor any detected owl to ensure it is not disturbed.

If the Project cannot ensure burrowing owl and their burrows are fully avoided, the Project shall consult with CDFW and obtain a take authorization or otherwise demonstrate compliance with CESA. Take is likely to occur and the Project shall obtain an ITP if: 1) burrowing owl surveys of the Project site detect burrowing owl occupancy of burrows or burrow surrogates, or 2) there is sign of burrowing owl occupancy on the Project site within the past three years and habitat has not had any substantial change that would make it no longer suitable within the past three years. Occupancy means a site that is assumed occupied if at least one burrowing owl has been observed occupying a burrow or burrow surrogate within the last three years. Occupancy of suitable burrowing owl habitat may also be indicated by burrowing owl sign including its molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site. If burrowing owl, or their burrows or burrow surrogates, are detected within 500 meters (1,640 feet) of the Project site during burrowing owl surveys, but not on the Project site, the Project shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted and shall obtain an ITP if deemed necessary by CDFW.

Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-29 cont.
6-30
2-46
522
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

Mitigation Measure MM-BIO-20 (Burrowing Owl Foraging Habitat Mitigation): Impacts to burrowing owl foraging habitat shall be mitigated as described in Mitigation Measure MM-BIO-17 above, except habitat shall be for burrowing owl, unless otherwise required by an ITP for burrowing owl.

Mitigation Measure MM-BIO-21 (Listed Plant Species Permitting). If the Project may result in impacts to CESA or NPPA listed plants, the Project shall obtain an ITP from CDFW prior to Project construction and shall comply with the ITP.

Mitigation Measure MM-BIO-22 (Special Status Fish Protection): In water work shall be avoided where special-status fish such as Delta smelt, longfin smelt, winter- and springrun Chinook salmon and white sturgeon may occur, as determined by a qualified biologist based on a review of CNDDB and consultation with CDFW. If take of the above fish species or any CESA listed or candidate aquatic listed species cannot be avoided, the Project shall obtain a CESA ITP from CDFW prior to commencing Project activities and shall comply with the ITP.

COMMENT 3: Biological Setting, EIR Section 4.3.1 and Appendix B Issue, specific impacts, why they may occur and be potentially significant:

Section 4.3.1 of the EIR describes the biological setting of the Project area to be used for assessing impacts to land cover, special-status species, nesting birds, sensitive vegetation communities and critical habitat, and wildlife movement corridors.

Appendix B - Supporting Biological Resources Information, is referenced in this section of the EIR (page 4.3 -3): “There are 51 plant species and 44 animal species with potential to occur within the Planning Area which meet at least one of the criteria for a special-status species, described above (Appendix B).” However, Appendix B does not reflect recent status updates of several species with potential to occur and be impacted by the Project and thus does accurately characterize the most current biological setting of the Project with respect to special-status species such as burrowing owl and white sturgeon which are both CESA candidate species.

Recommended mitigation measure:

Mitigation Measure MM-BIO-23 (Biological Setting). CDFW recommends revising Appendix B and associated sections of the EIR to ensure an accurate biological setting and assessment of potential impacts to special-status species.

III. Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS?
COMMENT 4: Riparian Habitat, Wetlands, and Lake and Streambed Alteration Notification
Issue, specific impacts, why they may occur and be potentially significant: The Project could result in potentially significant impacts to riparian habitat, wetlands, or other sensitive natural communities.

Recommended Mitigation Measures: If impacts to riparian habitat, wetlands, or other sensitive natural communities may occur, to reduce potential impacts to less-thansignificant, CDFW recommends including the below mitigation measures.

Mitigation Measure MM-BIO-24 (Habitat Restoration and Compensation, and Impacts to Streams and Riparian Areas): The Project shall implement restoration onsite or offsite to mitigate temporary or permanent impacts to sensitive natural communities and wetlands at a minimum 1:1 (restore onsite temporary impacts) or 3:1 (permanent impacts) mitigation to impact ratio for acres and linear feet of impacts, or provide habitat compensation including permanent protection of habitat at the same ratio through a Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-31
6-32
6-33
6-34
6-35
2-47
523
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

conservation easement and preparing and funding implementation of a long-term management plan, unless otherwise approved in writing by CDFW.

Prior to the commencement of Project activities, the Project shall conduct a thorough assessment for potential impacts to streams and riparian habitat including, but not limited to impacts resulting trail clearing, earth moving, and vegetation removal. If impacts to the bed, bank, channel, or riparian area of the streams cannot be avoided, the Project shall notify CDFW for potential Project impacts to the streams pursuant to Fish and Game Code section 1600 et seq., and shall comply with the LSA Agreement, if issued. More information for the Notification process is available at https://wildlife.ca.gov/Conservation/Environmental-Review/LSA.The Project shall not commence activities with potential to impact the stream until the LSA process has been completed. Impacts to the streams and riparian habitat shall be mitigated by restoring riparian habitat at a minimum 3:1 mitigation to impact ratio in area and linear feet for permanent impacts, all temporary impact areas shall be restored, and trees shall be replaced at an appropriate ratio based on size and species, unless otherwise approved in writing by CDFW. An LSA, if issued, may include additional avoidance and minimize measures to protect fish and wildlife resources. Projects shall also obtain permits from the Regional Water Quality Control Board (RWQCB) and U.S. Army Corps of Engineers (USACE) pursuant to the Clean Water Act if applicable.

COMMENT 5: CDFW Napa-Sonoma Marshes Wildlife Area
Issue, specific impacts, why they may occur and be potentially significant: The General Plan Area overlaps with CDFW’s Napa-Sonoma Marshes Wildlife Area, which is a highly sensitive habitat area supporting several listed and special-status species.

Any Project impacts to this area would be potentially significant.

Recommended Mitigation Measure:

Mitigation Measure MM-BIO-25 (CDFW Napa-Sonoma Marshes Wildlife Area): Prior to any Project activities within or adjacent to the CDFW Napa-Sonoma Marshes Wildlife Area, the Project shall coordinate with CDFW and obtain CDFW’s approval to access the Wildlife Area and implement any fish and wildlife protection measures required by CDFW.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to CNDDB. The CNDDB field survey form can be filled out and submitted online at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals. ENVIRONMENTAL DOCUMENT FILING FEES The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (See Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)
Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-35 cont.
6-36
6-37
6-38
2-48
524
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

CONCLUSION
CDFW appreciates the opportunity to comment on the EIR to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Nicholas Magnuson, Environmental Scientist, at [email protected] or (707) 815-4166; or Melanie Day, Senior Environmental Scientist (Supervisory), at [email protected] or (707) 210-4415.

Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
Attachment 1: Draft Mitigation and Monitoring Reporting Plan ec: Office of Planning and Research, State Clearinghouse (SCH No. 2022070038) Laureen Thompson, CDFW Bay Delta Region, [email protected] Docusign
Envelope
ID:
8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 6-51
2-49
525
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

REFERENCES
CDFW. 2024. California Natural Diversity Database (CNDDB) Management Framework.

California Department of Fish and Wildlife. Sacramento, CA. Website https://wildlife.ca.gov/Data/BIOS [accessed August 7, 2024].

California Department of Fish and Wildlife (CDFW). 2024. Petition Evaluation for Western Burrowing Owl (Athene cunicularia hypugaea). Report to the Fish and Game Commission. California Department of Fish and Wildlife, P.O. Box 944209, Sacramento, CA.

CDFW. 2016. Status Review: Swainson’s Hawk (Buteo swainsoni) in California, reported to the California Fish and Game Commission, five-year status report.

State of California Natural Resources Agency, Sacramento, CA. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=133622&inline CDFW. 2012. Department of Fish and Game Staff Report on Burrowing Owl Mitigation.

State of California Natural Resources Agency, Sacramento, CA.

Shuford, W. D., and Gardali, T., editors. 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.

Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-50
526
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

ATTACHMENT 1
Draft Mitigation and Monitoring Reporting Plan
CDFW provides the following language to be incorporated into the Mitigation and Monitoring Program for the Project as examples of mitigation measures. As stated in the enclosed letter, CDFW recommends that the EIR should evaluate potential Project impacts to special-status species and include additional specific mitigation measures for foreseeable potentially significant impacts.

Biological Resources (BIO)
Mitigation
Measures Description Timing Responsible Party
MM-BIO-10
(Fully Protected Species). A qualified biologist or
biological monitor shall be present on site to survey and monitor for Fully Protected species, including salt marsh harvest mouse, California Ridgway’s (formerly California Clapper) rail, and California black rail, during: a) all vegetation removal, b) the construction of exclusion
fencing, and c) all work within 300 feet of tidal or
pickleweed habitats. The qualified biologist or biological monitor shall have the authority to stop work if deemed necessary for any reason to protect these species, or any other special-status species. Take or possession of these Fully Protected species is prohibited and no permits may be issued for such, except in limited circumstances (Fish & G. Code, §§ 3511 & 4700).

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-11
(California Ridgeway’s Rail/Black Rail Avoidance and
Surveys). A qualified biologist shall assess if suitable habitat for California Ridgway’s rail or California black rail habitat occurs on or within 700 feet of the Project area and shall obtain CDFW’s written acceptance of the
assessment prior to the start of Project construction.

Project activities within tidal marsh or suitable California Ridgway’s rail or California black rail habitat, and within 700 feet of such habitat, shall be avoided during rail
breeding season (January 15 – August 31 for California
Ridgway’s rail, February 1 – August 31 for California
black rail) each year unless appropriately timed, yearly protocol level surveys are conducted, and survey
methodology and results are submitted to and accepted
by CDFW in writing. Surveys shall focus on suitable
habitat that may be disturbed by Project activities during the breeding season to ensure that these species are not nesting in these locations.

If breeding rails are determined to be present, no
activities, visual disturbance (direct line of sight) and/or an increase in the ambient noise level shall occur within 700 feet of areas where California Ridgway’s rail and/or California black rail have been detected during the
breeding season, unless otherwise approved in writing by CDFW. If surveys have not been conducted, all work
shall be conducted 700 feet from California Ridgway’s rail and/or California black rail habitat during nesting
Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-12
(Salt Marsh Harvest Mouse – High Tide Restrictions). No project activities shall occur within 50 feet of suitable tidal marsh habitat for the salt marsh harvest mouse within
two (2) hours before and after an extreme high tide event (6.5 feet or higher measured at the Golden Gate Bridge
and adjusted to the timing of local high tides) or when adjacent marsh is flooded unless salt marsh harvest
Prior to and
during
ground
disturbance
Project
Applicant
Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-51
527
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

the work area.

MM-BIO-13
(Salt Marsh Harvest Mouse – Vegetation). Prior to
impacting salt marsh habitat, a qualified biologist or
biological monitor, familiar with salt marsh harvest
mouse, shall walk through and inspect suitable habitat
prior to vegetation removal and search for signs of
harvest mice or other sensitive wildlife and plants.

Following inspection, personnel, under the supervision of the qualified biologist, will disturb (e.g., flush) vegetation to force movement of salt marsh harvest mouse into
adjacent marsh areas. Flushing of vegetation will first occur in the center of the site then progress toward the two sides away from the open water areas or in this case, away from impacted habitat. Immediately following
vegetation flushing, personnel, under the supervision of the qualified biologist or biological monitor, will remove vegetation with hand tools (e.g., weed-eater, hoe, rake, trowel, shovel, grazing) so that vegetation is no taller than 2 inches.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-14
(Salt Marsh Harvest Mouse – Exclusion Fencing). After
vegetation removal, a mouse proof barrier shall be
placed along the edge of the area removed of vegetation to further reduce the likelihood of salt marsh harvest
mouse returning to the area prior to construction. The
fence shall be made of a heavy plastic sheeting material that does not allow salt marsh harvest mice to pass
through or climb, and the bottom shall be buried to a
depth of 4 inches so that salt marsh harvest mouse
cannot crawl under the fence. Fence height shall be at
least 12 inches higher than the highest adjacent
vegetation with a maximum height of 4 feet. All supports for the exclusion fencing shall be placed on the inside of the work area. An approximately 2-foot wide devegetated buffer shall be created along the habitat side of the exclusion fence.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-15
(Salt Marsh Harvest Mouse – Inspections). The salt
marsh harvest mouse exclusion fencing shall remain in
operating condition throughout the duration of all project activities in salt marsh habitat. The qualified biologist or biological monitor shall daily inspect the integrity of the exclusion fencing to ensure there are no gaps, tears or damage. Maintenance of the fencing shall be conducted
as needed. Any necessary repairs to the fencing shall be completed within 24 hours of the initial observance of the damage. Any mice found along or outside the fence shall be closely monitored until they move away from the
project area.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-16
(Swainson’s Hawk Surveys and Avoidance Buffer): If
Project activities are scheduled during the nesting
season for Swainson’s hawks (March 1 to September
15), prior to beginning work on the Project, a qualified biologist shall conduct surveys according to the
Recommended Timing and Methodology for Swainson’s
Hawk Nesting Surveys in California’s Central Valley,
unless otherwise approved by CDFW in writing Survey
methods shall be closely followed by starting early in the nesting season (late March to early April) to maximize the likelihood of detecting an active nest (nests, adults, and chicks are more difficult to detect later in the growing season because trees become less transparent as
vegetation increases). Surveys shall be conducted: 1)
within a minimum 0.5-mile radius of the Project site or a larger area if needed to identify potentially impacted
Prior to and
during
ground
disturbance
Project
Applicant
Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-52
528
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

active nests, unless otherwise approved by CDFW in
writing, and 2) for at least the two survey periods
immediately prior to initiating Project-related construction activities. Surveys shall occur annually for the duration of the Project. The qualified biologist shall have a minimum of two years of experience implementing the survey
methodology resulting in detections. If active Swainson’s hawk nests are detected, the Project shall immediately
inform CDFW and implement a 0.5-mile construction
avoidance buffer around the nest until the nest is no
longer active as determined by a qualified biologist,
unless otherwise approved by CDFW in writing. If take of Swainson’s hawk cannot be avoided, the Project shall
consult with CDFW pursuant to CESA and obtain an ITP.

CDFW Bay Delta Region staff is available to provide
guidance on the ITP application process.

MM-BIO-17
(Swainson’s Hawk Foraging Habitat Mitigation): Impacts
to Swainson’s hawk foraging habitat shall be quantified by a qualified biologist based on the final Project design plans, and the Project shall obtain written acceptance of the acreage of habitat impacts from CDFW. Prior to
Project construction, the Project shall provide Swainson’s hawk foraging habitat mitigation at a minimum 1:1 ratio which shall include: 1) permanent preservation of the
species’ foraging habitat through a conservation
easement and implementing and funding a long-term
management plan in perpetuity, or 2) purchase of
Swainson’s hawk foraging habitat credits at a CDFW- approved mitigation bank, unless otherwise required by an ITP issued for Swainson’s hawk. Prior to
ground
disturbance
Project
Applicant
MM-BIO-18
(Tricolored Blackbird Avoidance): If nesting tricolored blackbird or evidence of their presence is found during nesting bird surveys within 500 feet of Project activities, CDFW shall be notified immediately and work shall not
occur without written approval from CDFW allowing the
Project to proceed. Project activities shall not occur within 500 feet of an active nest unless otherwise approved in writing by CDFW. If take of tricolored blackbird cannot be avoided, the Project shall consult with CDFW pursuant to CESA and obtain an ITP.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-19
(Burrowing Owl Surveys): A qualified biologist shall
conduct a burrowing owl habitat assessment within 1,640 feet of the Project area pursuant to the California
Department of Fish and Game (now CDFW) 2012 Staff
Report on Burrowing Owl Mitigation (CDFW 2012 Staff
Report, available here:
https://wildlife.ca.gov/Conservation/SurveyProtocols#377281284-birds), unless otherwise approved in writing by CDFW. The qualified biologist shall have a minimum of two years of experience implementing the
CDFW 2012 Staff Report survey methodology resulting in
detections. The habitat assessment shall focus on
searching the CNDDB and potentially other sources for
any burrowing owl records on or within one mile of the
Project area, vegetation type and height, suitable
burrows (with an opening of >11 cm in diameter and a
depth of >150 cm), burrow surrogates (culverts, piles of concrete rubble, piles of soil, burrows created along soft banks of ditches and canals, pipes, and similar
structures), and presence of burrowing owl sign (tracks, molted feathers, cast pellets, prey remains, egg shell
fragments, owl white wash, and nest burrow decoration
material), and the presence of burrowing owl individuals or pairs. If the habitat assessment does not identify
suitable habitat and surveys are not conducted as
described below, an additional habitat assessment shall be conducted within 14 days prior to construction and if Prior to and
during
ground
disturbance
Project
Applicant
Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-53
529
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

new potentially suitable burrowing owl refugia are present surveys shall be conducted as described below, unless
otherwise approved in writing by CDFW. The results of
the habitat assessment shall be emailed to the CDFW
contact below, or if unavailable another CDFW
representative, and the Project shall obtain CDFW’s
written approval of the habitat assessment prior to
starting Project activities.

If suitable burrowing owl habitat is observed, four surveys shall be conducted to detect the presence of burrowing
owl pursuant to the CDFW 2012 Staff Report. The site
visits shall be spread evenly throughout the breeding or non-breeding season. The Project shall obtain CDFW’s
written approval of the survey results prior to starting Project activities. In addition, a take avoidance survey shall be completed within 14 days prior to the start of construction, as described in the CDFW 2012 Staff
Report.

If burrowing owl is detected, the Project shall immediately notify CDFW. The Project shall avoid impacts to the
burrowing owl and implement a 1,640-foot buffer area
around the owl site in which no Project activities shall occur, unless otherwise approved in writing by CDFW. A
Qualified Biologist shall monitor any detected owl to
ensure it is not disturbed.

If the Project cannot ensure burrowing owl and their
burrows are fully avoided, the Project shall consult with CDFW and obtain a take authorization or otherwise
demonstrate compliance with CESA. Take is likely to
occur and the Project shall obtain an ITP if: 1) burrowing owl surveys of the Project site detect burrowing owl
occupancy of burrows or burrow surrogates, or 2) there is sign of burrowing owl occupancy on the Project site
within the past three years and habitat has not had any substantial change that would make it no longer suitable within the past three years. Occupancy means a site that is assumed occupied if at least one burrowing owl has
been observed occupying a burrow or burrow surrogate
within the last three years. Occupancy of suitable
burrowing owl habitat may also be indicated by burrowing owl sign including its molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a
burrow entrance or perch site. If burrowing owl, or their burrows or burrow surrogates, are detected within 500
meters (1,640 feet) of the Project site during burrowing owl surveys, but not on the Project site, the Project shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted and shall obtain an ITP if deemed necessary by CDFW.

MM-BIO-20
(Burrowing Owl Foraging Habitat Mitigation): Impacts to burrowing owl foraging habitat shall be mitigated as
described in Mitigation Measure MM-BIO-17 above,
except habitat shall be for burrowing owl, unless
otherwise required by an ITP for burrowing owl.

Prior to
ground
disturbance
Project
Applicant
MM-BIO-21
(Listed Plant Species Permitting). If the Project may
result in impacts to CESA or NPPA listed plants, the
Project shall obtain an ITP from CDFW prior to Project
construction and shall comply with the ITP.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-22
(Special Status Fish Protection): In water work shall be avoided where special-status fish such as Delta smelt,
longfin smelt, winter- and spring-run Chinook salmon,
and white sturgeon may occur, as determined by a
qualified biologist based on a review of CNDDB and
consultation with CDFW. If take of the above fish species or any CESA listed or candidate aquatic listed species
Prior to and
during
ground
disturbance
Project
Applicant
Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-54
530
Brent Cooper
City of American Canyon, Community Development Director November 20, 2024

cannot be avoided, the Project shall obtain a CESA ITP
from CDFW prior to commencing Project activities and
shall comply with the ITP.

MM-BIO-23
(Biological Setting). CDFW recommends revising
Appendix B and associated sections of the EIR to ensure an accurate biological setting and assessment of
potential impacts to special-status species.

Prior to
adopting
the Final
EIR
Lead Agency
MM-BIO-24
(Habitat Restoration and Compensation, and Impacts to
Streams and Riparian Areas): The Project shall
implement restoration onsite or offsite to mitigate
temporary or permanent impacts to sensitive natural
communities and wetlands at a minimum 1:1 (restore
onsite temporary impacts) or 3:1 (permanent impacts)
mitigation to impact ratio for acres and linear feet of impacts, or provide habitat compensation including
permanent protection of habitat at the same ratio through a conservation easement and preparing and funding
implementation of a long-term management plan, unless
otherwise approved in writing by CDFW.

Prior to the commencement of Project activities, the
Project shall conduct a thorough assessment for potential impacts to streams and riparian habitat including, but not limited to impacts resulting trail clearing, earth moving, and vegetation removal. If impacts to the bed, bank,
channel, or riparian area of the streams cannot be
avoided, the Project shall notify CDFW for potential
Project impacts to the streams pursuant to Fish and
Game Code section 1600 et seq., and shall comply with
the LSA Agreement, if issued. More information for the
Notification process is available at
https://wildlife.ca.gov/Conservation/EnvironmentalReview/LSA.The Project shall not commence activities with potential to impact the stream until the LSA process has been completed. Impacts to the streams and riparian habitat shall be mitigated by restoring riparian habitat at a minimum 3:1 mitigation to impact ratio in area and linear feet for permanent impacts, all temporary impact areas
shall be restored, and trees shall be replaced at an
appropriate ratio based on size and species, unless
otherwise approved in writing by CDFW. An LSA, if
issued, may include additional avoidance and minimize
measures to protect fish and wildlife resources. Projects shall also obtain permits from the RWQCB and USACE
pursuant to the Clean Water Act if applicable.

Prior to and
during
ground
disturbance
Project
Applicant
MM-BIO-25
(CDFW Napa-Sonoma Marshes Wildlife Area): Prior to
any Project activities within or adjacent to the CDFW
Napa-Sonoma Marshes Wildlife Area, the Project shall
coordinate with CDFW and obtain CDFW’s approval to
access the Wildlife Area and implement any fish and
wildlife protection measures required by CDFW.

Prior to and
during
ground
disturbance
Project
Applicant
Docusign Envelope ID: 8C185B2E-85EE-4CA7-8AE5-74FD35178CF4 2-55
531
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 6
COMMENTER: Erin Chappell, Regional Manager – Delta Bay Region, California Department of Fish and Wildlife
DATE: November 20, 2024
Response 6-1
The commenter notes that the California Department of Fish and Wildlife (CDFW) previously commented on the Notice of Preparation (NOP) of the EIR in a letter dated July 28, 2022. The commenter is now submitting comments on the EIR to inform the City of potential significant impacts to biological resources associated with the project.

The comment does not pertain to the adequacy of the Draft EIR, and no response is required.

Response 6-2
The commenter states that CDFW is considered as both a Trustee Agency and a Responsible Agency.

stating the following:
“The California Department of Fish and Wildlife (CDFW) has responsibility for issuing take permits and streambed alteration agreements for any projects with the potential to affect plant or animal species listed by the State of California as rare, threatened, or endangered or that would disturb waters of the State.”
No revisions to the Draft EIR are required in response to this comment.

Response 6-3
The commenter provides a summary of the project, the project’s location, and the project’s timeframe.

The comment does not pertain to the adequacy of the Draft EIR, and no response is required.

Response 6-4
The commenter states that if the project has the potential to result in take of plants and/or animals listed under the California Endangered Species Act (CESA). The commenter opines that a CESA Incidental Take Permit (ITP) must be obtained and encourages early consultation due to the possibility of significant modification to the project and mitigation measures in order to obtain a CESA Permit.

As discussed on pages 4.3-5 and 4.3-6 of the Draft EIR, impacts to state or federally listed species would require state and/or federal Incidental Take Permits. The Draft EIR determined that impacts to special-status species would be less than significant with mitigation, independent from regulatory permitting requirements. Mitigation Measure BIO-1 on page 4.3-13 of the Draft EIR stipulates that for projects within undeveloped parcels, a Biological Resources Screening and Assessment should occur to inform which additional mitigation measures, including as applicable to state-listed species, should apply. Mitigation Measure BIO-1 also states: “Pending the results of the project-specific biological analysis, design alterations, further technical studies (e.g., protocol surveys) and 2-56
532
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
consultations with the USFWS, CDFW, and/or other local, state, and federal agencies may be required.” As such, consultation with CDFW regarding impacts to state-listed species would occur, as appropriate based on project-level impacts. Please see Responses 6-12 regarding special-status species. No revisions to the Draft EIR are required in response to this comment.

Response 6-5
The commenter summarizes CEQA requirements regarding Mandatory Finding of Significance for threatened or endangered species and Findings of Overriding Consideration.

The Draft EIR identifies potentially significant impacts of the project, including potentially significant impacts to biological resources. All potentially significant biological resource impacts of the project would be reduced to a less than significant level with implementation of mitigation measures found in Section 4.3, Biological Resources, of the Draft EIR. Specifically, Mitigation Measures BIO-1 through BIO-9 would mitigate impacts to threatened or endangered species to less than significant levels.

Therefore, a Statement of Overriding Considerations is not required for biological resources, as this is a requirement only when a significant impact is unavoidable (CEQA Guidelines Section 15093).

Therefore, the Draft EIR provides determinations of potentially significant impacts of the project.

Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 6-6
The commenter states that the project would impact streams and therefore a Lake and Streambed Alteration (LSA) Notification(s) may be required and obtained from the CDFW.

As discussed on pages 4.3-3, 4.3-8 and 4.3-9, 4.3-20 and 4.3-21, streams and wetlands under CDFW jurisdiction are present in the Planning Area. The American Canyon Municipal Code requires new development to be sited to preserve wetlands, including the retention of sufficient natural space and Section 19.24.040 of the Municipal Code restricts residential, commercial, and industrial uses in riparian corridors, limiting the potential for new development to substantially affect these areas.

Further, as discussed under Impacts BIO-1 and on Page 4.3-20 and 4.3-21 of the Draft EIR, compliance with the NPDES Construction General Permit and MS4 Storm Water Permit would ensure that potential impacts to riparian habitat, sensitive natural communities, and wetlands would be less than significant. Mitigation Measure BIO-1 also states: “Pending the results of the project-specific biological analysis, design alterations, further technical studies (e.g., protocol surveys) and consultations with the CDFW may be required.” As such, the City would submit an LSA Notification for impacts to CDFW jurisdiction, as appropriate based on project-level impacts. No revisions to the Draft EIR are necessary in response to this comment.

Response 6-7
The commenter states that the CDFW has jurisdiction over actions that may result in the disturbance or destruction of active nest sites or the unauthorized take of birds, and that migratory birds are also protected under the federal Migratory Bird Treaty Act.

The comment provides information on protections for nesting and migratory birds and does not pertain to the adequacy of the Draft EIR. The Draft EIR includes a section titled California Fish and Game Code – Nesting Bird Protection on page 4.3-7, which outlines the protections for nesting birds under California Fish and Game Code Sections 3503 and 3513. Additionally, the Draft EIR references the Migratory Bird Treaty Act under federal regulations in Section 4.3.2 on page 4.3-5, describing 2-57
533
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
the provisions of this federal law. No revisions to the Draft EIR are required in response to this comment.

Response 6-8
The commenter addresses the regulations for Fully Protected species, noting they cannot be taken or possessed except under specific circumstances, such as scientific research, recovery efforts, or inclusion in a Natural Community Conservation Plan. Certain infrastructure projects may qualify for an ITP if conditions are met. The commenter emphasizes consulting with CDFW early in the planning process and identifies several Fully Protected species that could be impacted by the project, including the salt marsh harvest mouse, California Ridgway’s rail, California black rail, golden eagle, American peregrine falcon, and white-tailed kite.

As discussed within Revised Appendix B, there are 52 plant species and 45 animal species with potential to occur within the Planning Area, including six fully protected. Please see Responses 6-12 for additional information regarding special-status species. No revisions to the Draft EIR are required in response to this comment.

Response 6-9
The commenter states that they provide comments and recommendations to help the City identify and mitigate the project’s significant or potentially significant impacts on biological resources. The commenter also states that these suggestions are detailed in Attachment 1 to the comment letter.

The commenter provides no specific comments on the adequacy of the Draft EIR, but rather introduces comments that follow later in the letter. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 6-10
The commenter notes that the EIR is a Program EIR but lacks a checklist for subsequent project review. They recommend including a checklist to evaluate future project impacts on biological resources, ensuring they fall within the scope of the Program EIR or require additional documentation. The commenter asserts this checklist should be attached to the EIR and include all special-status species and sensitive habitats.

While the Draft EIR does not include a formal checklist, Mitigation Measure BIO-1 provides a robust framework to evaluate project-specific impacts on biological resources. Mitigation Measure BIO-1 requires that for projects proposed on undeveloped parcels, a Qualified Biologist must conduct a Biological Resources Screening and Assessment to determine whether any special-status species, sensitive vegetation communities, or other biological resources may be affected. If biological resources are identified, a project-specific biological analysis is required. This analysis identifies applicable mitigation measures (BIO-2 through BIO-8) to reduce impacts to a less than significant level.

This approach aligns with CEQA Guidelines Section 15152(c), which allows detailed, site-specific information to be prepared at the project level as long as the EIR identifies broad environmental effects and mitigation frameworks. Since Mitigation Measure BIO-1 ensures future project-specific impacts will be evaluated and mitigated, a separate checklist is not necessary. The mitigation framework also supports the ongoing identification and protection of biological resources. The City would review all future development proposals in the Plan Area to determine whether they are 2-58
534
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
within the scope of the EIR or if additional CEQA review is required. No revisions to the Draft EIR are required in response to this comment.

Response 6-11
The commenter suggests that the checklist should include sufficient information and reasonable inferences to support a "within the scope" conclusion of the EIR. For activities affecting sensitive biological resources, a site-specific analysis by a Qualified Biologist is recommended. The commenter suggests the checklist should also reference specific EIR sections and pages, and indicate whether all applicable mitigation measures are incorporated.

Please see the Response to Comment 6-10 for a detailed explanation of how the Draft EIR evaluates subsequent project-specific impacts on biological resources. Mitigation Measure BIO-1 requires a site-specific biological analysis to be conducted by a Qualified Biologist for future projects on undeveloped parcels. This analysis documents the presence of sensitive biological resources and ensures that applicable mitigation measures from the EIR are incorporated to reduce impacts.

The biological analysis required by Mitigation Measure BIO-1 includes identification of all specialstatus species and sensitive habitats within the project area, application of relevant mitigation measures (BIO-2 through BIO-8), and consultations with CDFW, USFWS, and other agencies, where needed. While the Draft EIR does not include a formal checklist (as none is required by CEQA), the required biological analysis achieves the same purpose by ensuring that subsequent project activities are assessed for consistency with the EIR. This process provides sufficient documentation to demonstrate whether a project falls within the scope of the EIR. No revisions to the Draft EIR are necessary in response to this comment.

Response 6-12
The commenter notes that the project could significantly impact endangered, rare, or threatened species, or adversely affect candidate, sensitive, or special-status species through habitat modifications. The planning area has the potential to support these species, as documented within 5 miles according to the CNDDB. The commenter states the EIR lacks specific and detailed mitigation measures for these species.

As discussed in Impact BIO-1 on Draft EIR pages 4.3-11 through 4.3-13, implementation of General Plan Policies U-4.1 and U-4.8 require storm drainage maintenance and low impact development standards to protect water quality and special-status species that utilize aquatic and riparian habitats. As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policies ENV-1.2 and ENV-1.3 require avoidance and preservation of sensitive habitat for rare and endangered species s, including coastal saltmarsh, mixed hardwood forest, oak savannah, vernal pools, and riparian habitats. Additionally, Mitigation Measures BIO-1 requires that for projects proposed on undeveloped parcels, a Qualified Biologist must conduct a Biological Resources Screening and Assessment to determine whether any special-status species, sensitive vegetation communities, or other biological resources may be affected. If biological resources are identified, a project-specific biological analysis is required. This analysis identifies applicable mitigation measures (BIO-2 through BIO-8) to reduce impacts to a less than significant level.

Following the project-specific assessment, as required by Mitigation Measure BIO-1, additional mitigation measures may be required on individual projects depending on the findings of the biological resources evaluation, including botanical surveys, protocol-level wildlife surveys and habitat assessments, plant and wildlife avoidance and minimization measures, and habitat restoration at a minimum of 1:1 for project related impacts. Specific Mitigation Measures also 2-59
535
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
include nesting bird, roosting bat, and Crotch’s Bumblebee Surveys and avoidance. Therefore, impacts to special-status species would be appropriately evaluated by a qualified biologist prior to project approval for projects tiering from the EIR. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-13
The commenter notes that the project could impact nesting California Ridgeway’s rail and California black rail within 700 feet through disturbances or habitat removal. Disturbing an active nest could significantly reduce the species' population, a mandatory finding of significance under CEQA.

Suitable marsh habitat for these species is present along the western side of the General Plan Area.

The General Plan Update does not propose development or change land use designations that would facilitate development within salt marsh habitat or within 700 feet of the salt marsh habitat.

Rather, changes in the proposed General Plan Update within 700 feet of salt marsh habitat include land use amendments converting Low Residential to Open Space, thus removing some development potential compared to existing conditions. The American Canyon Municipal Code states that only public recreational facilities and outdoor recreation and sports are conditionally allowed within the Open Space zoning district. Accordingly, it can be concluded that the conversion from Low Residential to Open Space would not result in greater impacts.

Furthermore, as discussed in Impact BIO-1 on pages 4.3-11 through 4.3-13, implementation of General Plan Policy U-4.1 and U-4.8 requires storm drainage maintenance and low impact development standards to protect water quality and special-status species habitats. As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policy ENV1.2 and ENV-1.3 require avoidance and preservation of sensitive habitat for rare and endangered species, including coastal saltmarsh. Mitigation Measures BIO-1, BIO-5, and BIO-6 require a biological resources evaluation including the potential for agency consultation and permitting, protocol-level surveys and habitat assessments, and avoidance and minimization measures for project related impacts. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-14
The commenter notes that the project could impact the salt marsh harvest mouse through habitat removal and potential injury or mortality. If impacted, the project could significantly reduce the species' population, a mandatory finding of significance under CEQA Guidelines section 15065(a)(1).

Please see Response 6-13, which explains that the project would not impact salt marsh habitat.

Therefore, impacts on salt marsh harvest mouse are not expected and no revisions to the Draft EIR are required.

Response 6-15
The commenter notes that if the project occurs during nesting season, it could disturb nesting Swainson’s hawks within 0.5 miles, potentially causing nest abandonment or harm to young.

Swainson’s hawks are listed as threatened under CESA and CEQA. The project could also remove potential foraging habitat for Swainson’s hawk, with no compensatory habitat mitigation proposed.

The commenter adds that Napa County has recognized the need to conserve Swainson’s hawk foraging habitat and included compensation measures in a recent Mitigated Negative Declaration. 2-60
536
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Development facilitated by the project would occur primarily within existing development, and changes to land uses under the General Plan Update are primarily conversions of other uses to Open Space. Mitigation Measures BIO-1, BIO-5, and BIO-6 require a biological resources evaluation including the potential for agency consultation and permitting, protocol-level surveys and habitat assessments, and avoidance and minimization measures for project related impacts. Therefore, impacts to Swainson’s hawk would be appropriately evaluated with coordination from a qualified biologist prior to project approval for projects tiering from the EIR. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-16
The commenter notes that the project may impact tricolored blackbirds, as the project area includes predicted habitat for this species. If active nests are not detected or appropriate buffer zones are not established, project activities could disturb the birds, leading to nest abandonment, loss of eggs, or harm to young.

Development facilitated by the project would occur primarily within existing development, and changes to the land uses under the General Plan Update are primarily conversions of other uses to Open Space. As discussed under Response 6-13, the American Canyon Municipal Code states that only public recreational facilities and outdoor recreation and sports are conditionally allowed within the Open Space zoning district. As such, no development would occur within zoned Open Space.

As discussed in Impact BIO-1 on Draft EIR pages 4.3-11 through 4.3-13, implementation of General Plan Policy U-4.1 and U-4.8 requires storm drainage maintenance and low impact development standards to protect water quality and special-status species habitats. As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policies ENV-1.2 and ENV1.3 require avoidance and preservation of sensitive habitat for rare and endangered species, including coastal saltmarsh and riparian habitats. Additionally, Mitigation Measures BIO-1, BIO-5, and BIO-6 require a biological resources evaluation, protocol-level surveys and habitat assessments, and avoidance and minimization measures for project related impacts. Therefore, impacts to tricolored blackbird would be appropriately evaluated by a qualified biologist prior to project approval for projects tiering from the EIR. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-17
The commenter notes that the project could lead to burrowing owl nest abandonment, loss of young, reduced health of owlets, injury or mortality of adults, and loss of wintering or nesting habitat.

Additionally, the project may reduce burrowing owl foraging habitat in Napa County.

Development facilitated by the project would occur primarily within existing development, and changes to land use under the General Plan Update are primarily conversions of other uses to Open Space. As discussed in Impact BIO-1 in Section 4.3-11 through 4.3-13, Mitigation Measures BIO-1, BIO-5, and BIO-6 require a biological resources evaluation including potential permitting requirements, protocol-level surveys and habitat assessments, avoidance and minimization measures for project related impacts. As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policies ENV-1.2 and ENV-1.3 require avoidance and preservation of sensitive habitat for rare and endangered species. Therefore, impacts to burrowing owl would be appropriately evaluated with coordination from a qualified biologist prior to project approval for projects tiering from the EIR. As such, no revisions to the Draft EIR are required in response to this comment.
2-61
537
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 6-18
The commenter notes that while the EIR includes Mitigation Measures BIO-2 and BIO-3 for specialstatus plants, these measures do not require the project to obtain a CESA ITP for impacts to CESA or NPPA listed plants. Therefore, impacts to listed plants may not be mitigated to a less-than-significant level.

As discussed in Impact BIO-1 in Section 4.3-11 through 4.3-13, Mitigation Measures BIO-1, BIO-2, BIO-3, and BIO-4 require a biological resources evaluation including the potential for agency consultation and permitting, botanical surveys, avoidance and minimization measures, and habitat restoration at a minimum of 1:1 for project related impacts. Therefore, impacts to special status plants would be appropriately evaluated with coordination from a qualified biologist prior to project approval for projects tiering from the EIR. Obtaining a regulatory permit itself is not mitigation, and the City would obtain an ITP for impacts to state-listed plants should those impacts be anticipated to occur. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-19
The commenter notes that the planning area includes habitats that support special-status fish species such as Delta smelt, longfin smelt, winter- and spring-run Chinook salmon, and white sturgeon. The commenter recommends revising the EIR to assess impacts on special-status fish and aquatic life, as well as overall impacts on aquatic resources, streams, riparian areas, and in-water work.

Development facilitated by the project would occur primarily within existing development, and no development is proposed in riverine habitat. As discussed in Impact BIO-1 on pages 4.3-11 through

4.3-13, implementation of General Plan Policy U-4.1 and U-4.8 requires storm drainage maintenance and low impact development standards to protect water quality and special-status species habitats.

As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policy ENV-1.2 and ENV-1.3 require avoidance and preservation of sensitive habitat for rare and endangered species, including coastal saltmarsh. Mitigation Measures BIO-1, BIO-5, and BIO-6 require a biological resources evaluation including the potential for agency consultation and permitting, protocol-level surveys and habitat assessments, and avoidance and minimization measures for project related impacts. As such, no revisions to the Draft EIR are required in response to this comment.

Response 6-20
The commenter recommends including mitigation measures in the EIR to reduce impacts on listed and special-status species to less-than-significant levels and comply with CESA and NPPA. They suggest using a checklist to determine if future CEQA documentation is needed for unforeseeable site-specific impacts. CDFW requests the opportunity to review a revised EIR and may provide further comments with more specific species information.

Please see Responses 6-10, and 6-11 regarding project applicability within the scope of the EIR and the site-specific biological evaluation conducted under Mitigation Measure BIO-1. No revisions to the Draft EIR are required in response to this comment. 2-62
538
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 6-21
The commenter suggests a new mitigation measure to address Fully Protected species.

Please see Responses 6-15, 6-16, 6-17, and 6-18 regarding project impacts to Swainson’s hawks, tricolored blackbirds, burrowing owls, and CESA or NPPA listed plants. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-22
The commenter suggests a new mitigation measure to address California Ridgeway’s Rail/Black Rail avoidance and surveys.

Please see Responses 6-13 regarding project impacts to salt marsh habitats and California Ridgeway’s Rail/Black Rail. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-23
The commenter suggests a new mitigation measure to address salt marsh harvest mouse high tide restrictions.

Please see Responses 6-13 regarding project impacts to salt marsh habitats and salt marsh harvest mouse. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-24
The commenter suggests a new mitigation measure to address salt marsh harvest mouse vegetation.

Please see Responses 6-13 regarding project impacts to salt marsh habitats and salt marsh harvest mouse. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-25
The commenter suggests a new mitigation measure to address salt marsh harvest mouse exclusion fencing.

Please see Responses 6.13 regarding project impacts to salt marsh habitats and salt marsh harvest mouse. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-26
The commenter suggests a new mitigation measure to address salt marsh harvest mouse inspections.

Please see Responses 6.13 regarding project impacts to salt marsh habitats and salt marsh harvest mouse. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.
2-63
539
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 6-27
The commenter suggests a new mitigation measure to address Swainson’s hawk surveys and avoidance buffer.

Please see Responses 6.15 regarding project impacts to Swainson’s hawk. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-28
The commenter suggests a new mitigation measure to address Swainson’s hawk foraging habitat.

Please see Responses 6.15 regarding project impacts to Swainson’s hawk. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-29
The commenter suggests a new mitigation measure to address tricolored blackbird avoidance.

Please see Responses 6.16 regarding project impacts to tricolored blackbird. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-30
The commenter suggests a new mitigation measure to address burrowing owl surveys.

Please see Responses 6.17 regarding project impacts to burrowing owl. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-31
The commenter suggests a new mitigation measure to address burrowing owl foraging habitat mitigation.

Please see Responses 6.17 regarding project impacts to burrowing owl. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-32
The commenter suggests a new mitigation measure to address listed plant species permitting.

Please see Responses 6.18 and 6.12 regarding project impacts to special status plants. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-33
The commenter suggests a new mitigation measure to address special status fish protection.

Please see Responses 6.13 regarding project impacts to salt marsh and river habitats. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.
2-64
540
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 6-34
The commenter notes that Section 4.3.1 of the Draft EIR describes the biological setting for assessing impacts on various ecological aspects. However, Appendix B, which lists potential special-status species in the planning area, does not reflect recent status updates for species like burrowing owl and white sturgeon, both CESA candidate species. Therefore, the commenter recommends revising Appendix B and associated sections of the EIR to ensure an accurate biological setting and assessment of potential impacts to special-status species.

The definition of special-status species has been updated in Revised Appendix B in accordance with this comment. Further, the following changes have been made to page 4.3-3 of the Draft EIR:

The results of these scientific database queries are provided as Revised Appendix B of this EIR.

There are 51 52 plant species and 44 45 animal species with potential to occur within the Planning Area which meet at least one of the criteria for a special status species, described above (Appendix B).

The updated table is included as Revised Appendix B to this Final EIR. No additional revisions to the Draft EIR are required.

Response 6-35
The commenter notes that the project could result in potentially significant impacts to riparian habitat, wetlands, or other sensitive natural communities and recommends a mitigation measure to address habitat restoration and compensation, and impacts to streams and riparian areas.

Please see Responses 6-6, 6-12 and 6-18 regarding project impacts to wetlands, riparian habitats, and sensitive plant communities. As stated therein, Mitigation Measure BIO-4 requires a Habitat Restoration Plan and impacts to be mitigated at a ratio not lower than 1:1 per acre of impact (and 1:1 per tree), and to be determined by the City in coordination with CDFW and USFWS as and if applicable. A requirement for 3:1 mitigation for permanent impacts may be a permitting requirement for impacts to CDFW jurisdiction, but is too restrictive to apply to all projects that may require a Habitat Restoration Plan (such as impacts to non-listed special-status CRPR 1B and 2 plant populations). Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-36
The commenter notes that the General Plan Area overlaps with CDFW’s Napa-Sonoma Marshes Wildlife Area, which is a highly sensitive habitat area supporting several listed and special-status species. The commenter provides a mitigation measure to address impacts to the Napa-Sonoma Marshes Wildlife Area.

The General Plan Update does not propose development or land use designations that would facilitate development within Napa-Sonoma Marshes Wildlife Area. Changes to land use under the General Plan Update adjacent to salt marsh habitat include land use amendments converting Low Residential to Open Space. As discussed in Impact BIO-1 on pages 4.3-11 through 4.3-13, implementation of General Plan Policy U-4.1 and U-4.8 requires storm drainage maintenance and low impact development standards to protect water quality and special-status species habitats. As discussed in Impact BIO-2 on Draft EIR pages 4.3-20 through 4.3-21, implementation of General Plan Policy ENV-1.2 and ENV-1.3 require avoidance and preservation of sensitive habitat for rare and endangered species, including coastal saltmarsh. Mitigation Measures BIO-1, BIO-5, and BIO-6 2-65
541
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
require a biological resources evaluation including the potential for agency consultation and permitting, protocol-level surveys and habitat assessments, and avoidance and minimization measures for project related impacts.

Please see Responses 6.6, 6.12, 6.13, and 6.19 regarding project impacts to wetlands, sensitive plant communities, and salt marsh and river habitats. Based on these responses, additional mitigation measures are not warranted and no changes to the Draft EIR are required.

Response 6-37
The commenter asks that any special-status species and natural communities detected during project surveys be reported to the CNDDB.

The comment is noted. Any special-status species and natural communities detected during project surveys will be sent to the CNDDB for reporting. The comment does not pertain to the adequacy of the Draft EIR, and no revision to the EIR is required.

Response 6-38
The commenter reminds the City of CEQA filing fees. The commenter concludes their letter thanking the City for opportunity to comment and provides contact information to follow up.

The City thanks the commenter for their reminder of recording obligations and filing fees. This comment does not pertain to the Draft EIR or CEQA, other than describing the circulation of the Notice of Availability of the Draft EIR. Therefore, no additional revisions to the Draft EIR are required in response to this comment.
2-66
542
P.O. Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org December 28, 2024
Jason Holley, City Manager, City of American Canyon
4381 Broadway Street, Suite 201,
American Canyon, CA 94503
RE: 2040 General Plan Update
Dear Mr. Holley,
The Napa County Bicycle Coalition—which works to make biking in Napa County safe, accessible, and convenient—appreciates many of the goals and guiding principles of the draft 2040 General Plan (“the Plan”), including the intention to “Include funding for the City's Bicycle Plan updates and bikeway improvements consistent with the Bicycle Plan in the City's transportation financing program and TIF, recognizing the multi-modal travel needs of the City.” We appreciate the attention throughout the Plan to active transportation and to how it is recognized as a key strategy to meet climate goals.

We also noticed several opportunities where we believe new or updated language would make the plan stronger and better set it up for success. Those changes are detailed in the table below, but we also wanted to note the following to give context to our requests and recommendations:
• We would like to see the Open Space, Active Transportation, and Sustainability Commission (OSATS) explicitly included in decision-making on active transportation facilities, especially when the City of American Canyon is considering deviating from its Active Transportation Plan, on which, presumably, the OSATS will have provided input.

This will help leverage the unique perspective and expertise the OSATS can provide and to increase the return on investment the City has made in convening this advisory body. • We urge the City to be as specific and measurable as possible in setting goals and policies. If including specific targets, such as those related to reducing Vehicle Miles Traveled or implementing the Active Transportation Plan, comes with concerns, then inserting “strive to meet…”, or a similar phrase is an option, too. Setting and including specific targets helps all staff and community members to be on the same page, it signals true commitment, and it aids in setting appropriate timelines. • We request that the City consider including policies related to Safe Routes to School, a partnership that is integral to increasing safety and educating and encouraging active transportation users. Funding for Safe Routes programming is tenuous each year and will need the ongoing collaboration of all jurisdictions to ensure its sustainability.

Currently, the American Canyon Police Department supports Safe Routes programming in American Canyon by sharing the quarterly data that is required to secure funding, and a representative will begin participating in the Safe Routes to School Advisory Committee in 2025. As well, a policy related to securing and maintaining a Bicycle Friendly Communities designation would help build on current momentum toward this goal and would help maintain the effort into the future.

Letter 7
7-1
7-2
7-3
7-4
7-5
7-6
2-67
543
P.O. Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org Napa County Bicycle Coalition’s
Recommended Changes to the Draft 2040 General Plan
Policy Current Language Suggested Revisions/Comments/Questions MOB-1.2
Complete Street Standards. Review current
arterial, collector, and local street standards
and update as necessary to conform to best
practice classification standards and
NACTO complete streets guidelines.

Consider also including the recently released 5th
Edition of Comprehensive Bike Guide by AASHTO,
which will be incorporated into NVTA’s Active
Transportation Plan update.

MOB-1.4
Development Review. Evaluate new
development to ensure that the safety,
comfort, and convenience of pedestrians,
bicyclists and transit users are given equal
level of consideration to motor vehicle
operators.

Development Review. Evaluate new development
to ensure that the safety, comfort, and convenience
of pedestrians, bicyclists and transit users are given
an equal or greater level of consideration to motor
vehicle operators. (Note: this change will help
reduce VMT).

MOB1.7
Promote Walking and Bicycling. Promote
walking and bicycling for transportation,
recreation, and improvement of public
Health.

Promote Walking and Bicycling. Promote walking
and bicycling for transportation, recreation, and
improvement of public Health and the
environment.

MOB1.9
SR 29 Mobility. Work with regional
partners, including Caltrans, NVTA, and
other agencies to explore a complete streets
approach that will expand the travel
capacity of SR 29.

SR 29 Mobility. Work with regional partners,
including Caltrans, NVTA, and other agencies to
explore a complete streets approach that will
expand the travel capacity of SR 29 and establish a
low-stress method for crossing for students walking
and biking to school and other active transportation
users
MOB1.15
Existing Facility Use. Make efficient use of
existing transportation facilities and
improve these facilities as necessary in
accordance with the Circulation Map.

Existing Facility Use. Make efficient use of
existing transportation facilities and improve these
facilities as necessary in accordance with the
Circulation Map and NVTA Active Transportation
Plan.

MOB1.17
Reduce Vehicle Miles Traveled. Through
layout of land uses, improved alternate
travel modes, and provision of more direct
routes, strive to reduce the total vehicle
miles traveled by city and non-residents
traveling to American Canyon to work or
shop.

Reduce Vehicle Miles Traveled. Through layout of
land uses, improved alternate travel modes, and
provision of more direct routes for all modes of
travel, strive to reduce the total vehicle miles
traveled by city and non-residents traveling to
American Canyon to work or shop by 30% by 2045
(with 2019 levels as the baseline), per the
California Air Resources Board’s Scoping Plan.

MOB1.22
Non-motorized Circulation System. Provide
safe and direct pedestrian routes and
bikeways between places.

Non-motorized Circulation System. Provide safe,
low-stress, and direct pedestrian routes and
bikeways between places. Aim to complete at
least 50% of the planned bike and pedestrian
network outlined in NVTA’s Active
Transportation Plan by 2040.

MOB1.24
Bicycle Facilities. Bicycle facilities shall be
provided to complete a continuous bikeway
system, consistent with state standards,
as shown on the Bikeway Plan Map. In
cases where existing right of way
Bicycle Facilities. Bicycle facilities shall be
provided to complete a continuous, low-stress
bikeway system, consistent with state standards the
Active Transportation Plan as shown on the
Bikeway Plan Map. In cases where existing right of
7-7
7-8
7-9
7-10
7-11
7-12
7-13
7-14
2-68
544
P.O. Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org constraints limit development of Class II or
Class IV facilities, Class Ill signage and
demarcation may be permitted at the
discretion of the City Engineer. Deviations
from these standards and from the routing
shown on the diagram shall be permitted
with the approval of the City Engineer.
way constraints limit development of Class I, II or
IV facilities, Class Ill signage and demarcation may
be permitted at the discretion of the City Engineer
the City of American Canyon will strive to provide
an alternative low-stress route, rather than
installing facilities that are not low-stress.

Deviations from these standards and from the
routing shown on the diagram shall be first
reviewed by the Open Space, Active
Transportation, and Sustainability Commission and
will be permitted with the approval of the City
Engineer only when an Exception Standard has
been met with substantial evidence.

MOB-2.2
Context Sensitive Design. Improve
multimodal transportation safety by
expanding the City’ s non- motorized
transportation infrastructure using context
sensitive design.

Context Sensitive Design. Apply a context
sensitive design lens to improve multimodal
transportation safety while expanding the City’s
non- motorized transportation infrastructure using
context sensitive design.

MOB2.3
Bicycle Safety. Increase the safety of those
traveling by bicycle by sweeping debris
from and repairing bicycle paths and lanes.

Bicycle Safety Facilities Maintenance. Increase the
safety of those traveling by bicycle by sweeping
debris from bicycle paths and lanes at least twice
per month and repairing and restriping worn or
damaged facilities.

MOB2.4
Improved Bikeway Visibility. Use visual
cues, such as brightly colored paint on bike
lanes or a one-foot painted buffer strip,
along bicycle routes to provide a visual
signal to drivers to watch out for bicyclists
and nurture a " share the lane" ethic,
prioritizing bikeways with recent
automobile- bicycle collisions.

Upgrade Existing Bikeways using all means
available—such as conflict markings, buffers,
rumble strips, and delineators—to make bikeways
safer and lower stress and to catch up with evolving
best practices, prioritizing bikeways with recent
automobile- bicycle collisions and those that are
routes to school.

MOB2.5
Speeds on Residential and Arterial Streets.

Explore innovative ways to reduce
vehicular speeds through residential
neighborhoods to posted speed limits, such
as implementing traffic calming strategies
such as: enhanced cross walks, lighted
crosswalks, reducing lane widths, and
others.

Speeds on Residential, Collector, and Arterial
Streets. Explore innovative ways to Implement
American Canyon’s Traffic Calming Program that
includes evidence-based ways to methods of
reducing vehicular speeds through residential
neighborhoods to posted speed limits, such as
implementing traffic calming strategies: enhanced
cross walks, lighted crosswalks, reducing lane
widths, and others.

MOB 2.7
Partner with public, nonprofit, and community
stakeholders to secure dedicated funding for the
education and infrastructure needs of the
Countywide Safe Routes To School Partnership
to provide safe and equitable access for students
going by active transportation to local schools.

MOB

1.29 Secure and maintain status as a Bicycle
Friendly Community.
7-14
cont.
7-15
7-16
7-17
7-18
7-19
7-20
2-69
545
P.O. Box 5157 | Napa, CA 94581 | (707) 258-6318 | www.napabike.org ENV9.5
Vehicle Miles Travelled Reduction.

Reduce vehicle miles travelled by
encouraging future land uses that
feature a compact mixed- use urban
form connected with pedestrian
and bicycle trails.

Vehicle Miles Travelled Reduction. Reduce
vehicle miles travelled by 30% by 2045 (with
2019 levels as the baseline), per the California Air
Resources Board’s Scoping Plan by encouraging
future land uses that feature a compact mixeduse urban form connected with pedestrian and bicycle trails.

ENV10.10
Active Transportation. Improve active
transportation options within the city by
connecting local bikeways and trails to
City bus stops and public transportation
centers.

Active Transportation. Improve active
transportation options within the city by
connecting local bikeways and trails to City
bus stops, public transportation centers, and
major destinations, and aiming to complete at
least 50% of the planned bike and pedestrian
network by 2040.

ENV11.9
Countywide Bicycle and Pedestrian
Plans. Work with the County to
implement the best practices provided
within the American Canyon edition of
the Napa Countywide Bicycle Plan
and Napa Countywide Pedestrian Plan.

Countywide Bicycle and Pedestrian Plans.

Work with the County to implement the best
practices provided within the American
Canyon edition of the most up-to-date Napa
Countywide Bicycle Plan and Napa
Countywide Pedestrian Plan/Active
Transportation Plan, aiming to complete at least
50% of the planned bike and pedestrian
network by 2040.

MOBFigure 6
Pg M-17
MOB- Figure 6: Standard Roadway
Cross Sections
Update this figure or note that 5’ bike lanes
excluding gutter pan with 3’ buffers containing
delineators are standard for bike lanes along all
types of arterials and often for major collectors,
too.

Types of
Bikeways
Pg M-21
Types of Bikeways
Update to include Class 2Bs.

Thank you for your consideration of these changes. Given the significance and scope of this Plan, and the opportunity it presents to address our climate emergency and create a meaningful shift to Complete Streets, we urge all involved to ensure the document reflects more commitment to its goals and truly enables and empowers the City to realize the 2040 General Plan.

Should you have any questions about the above comments, please contact me at (707) 258- 6318 or at [email protected]. Thank you for your time and your ongoing hard work on this Plan.

Sincerely,
Kara Vernor
Executive Director
7-21
7-22
7-23
7-24
7-25
7-26
2-70
546
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 7
COMMENTER: Napa County Bike Coalition
DATE: December 28, 2024
Response 7-1
The commenter states that they appreciate the draft 2040 General Plan's goals and guiding principles. They specifically commend the Plan's intention to include funding for Bicycle Plan updates and bikeway improvements in the City's transportation financing program, recognizing the importance of active transportation in meeting climate goals.

This comment is noted and no revisions to the Draft EIR are required in response to this comment.

Response 7-2
The commenter identifies opportunities for new or updated language to strengthen the plan and set it up for success [as discussed in Responses 7-3 through 7-25, below], providing context for their requests and recommendations.

This comment is noted and no revisions to the Draft EIR are required in response to this comment.

Response 7-3
The commenter suggests explicitly including the Open Space, Active Transportation, and Sustainability Commission in decision-making on active transportation facilities, especially when deviating from the Active Transportation Plan.

This comment addresses organizational policy for the City but does not pertain to the Draft EIR or CEQA. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-4
The commenter urges the City to set specific and measurable goals and policies. They suggest including specific targets, such as reducing VMT or implementing the Active Transportation Plan, and using phrases like "strive to meet" if there are concerns.

The General Plan, at its core, serves as a guiding document for the City's long-term vision and strategic direction. As noted by the commenter, specific and measurable goals and policies are important, but it is crucial to recognize that the document is inherently programmatic and broad in nature. Specific targets, such as reducing VMT or implementing the Active Transportation Plan, are indeed valuable but are more appropriately addressed as a subsequent action to the General Plan and EIR. As such, the following General Plan policies are discussed on page 4.11-8 of the Draft EIR:
 Policy MOB-1.1: Complete Streets. Maintain and update street standards that that serves not just automobile operations, but also multi-modal movement and adjacent land uses, including pedestrians, motorists, bicyclists, and transit riders of all ages and abilities, in a form that is compatible with and complementary to adjacent land uses, and promotes connectivity between uses and areas.
 Policy MOB-1.7: Promote Walking and Bicycling. Promote walking and bicycling for transportation, recreation, and improvement of public health. 2-71
547
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
 Policy MOB-1.17: Reduce Vehicle Miles Traveled. Through layout of land uses, improved alternate travel modes, and provision of more direct routes, strive to reduce the total vehicle miles traveled by city and non-residents traveling to American Canyon to work or shop.  Policy MOB-1.20: Bicycle Plan Funding. Include funding for the City's Bicycle Plan updates and bikeway improvements consistent with the Bicycle Plan in the City's transportation financing program and TIF, recognizing the multi-modal travel needs of the City.  Policy MOB-1.22: Non-motorized Circulation System. Provide safe and direct pedestrian routes and bikeways between places.
 Policy MOB-1.23: 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.
 Policy MOB-1.24: Bicycle Facilities. Bicycle facilities shall be provided to complete a continuous bikeway system, consistent with state standards, as shown on the Bikeway Plan Map. In cases where existing right of way constraints limit development of Class II or Class IV facilities, Class Ill signage and demarcation may be permitted at the discretion of the City Engineer. Deviations from these standards and from the routing shown on the diagram shall be permitted with the approval of the City Engineer.

However, the broad scope of the General Plan necessitates flexibility in how these targets are approached and achieved. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 7-5
The commenter requests the City to include policies related to Safe Routes to School, emphasizing its importance for safety and active transportation education. They highlight the need for ongoing collaboration to ensure sustainable funding and note the American Canyon Police Department's current support and future participation in the Safe Routes to School Advisory Committee.

This comment pertains to the General Plan, but not the Draft EIR or CEQA. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-6
The commenter suggests including a policy to secure and maintain a Bicycle Friendly Communities designation, which would build on current momentum and sustain future efforts.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. However, as discussed on page 4.11-7 and 4.11-8 of the Draft EIR, the General Plan includes the following policies related to bicycle infrastructure and active transportation:
 Policy MOB-1.1: Complete Streets. Maintain and update street standards that that serves not just automobile operations, but also multi-modal movement and adjacent land uses, including pedestrians, motorists, bicyclists, and transit riders of all ages and abilities, in a form that is compatible with and complementary to adjacent land uses, and promotes connectivity between uses and areas.
2-72
548
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
 Policy MOB-1.4: Development Review. Evaluate new development to ensure that the safety, comfort, and convenience of pedestrians, bicyclists and transit users are given equal level of consideration to motor vehicle operators.
 Policy MOB-1.7: Promote Walking and Bicycling. Promote walking and bicycling for transportation, recreation, and improvement of public health.  Policy MOB-1.20: Bicycle Plan Funding. Include funding for the City's Bicycle Plan updates and bikeway improvements consistent with the Bicycle Plan in the City's transportation financing program and TIF, recognizing the multi-modal travel needs of the City.  Policy MOB-1.22: Non-motorized Circulation System. Provide safe and direct pedestrian routes and bikeways between places.
 Policy MOB-1.24: Bicycle Facilities. Bicycle facilities shall be provided to complete a continuous bikeway system, consistent with state standards, as shown on the Bikeway Plan Map. In cases where existing right of way constraints limit development of Class II or Class IV facilities, Class Ill signage and demarcation may be permitted at the discretion of the City Engineer. Deviations from these standards and from the routing shown on the diagram shall be permitted with the approval of the City Engineer.

Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-7
The commenter suggests including the recently released 5th Edition of Comprehensive Bike Guide by AASHTO into General Plan Policy MOB-1.2.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-8
The commenter suggests minor text edits to General Plan Policy MOB-1.4.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-8
The commenter suggests minor text edits to General Plan Policy MOB-1.4.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-9
The commenter suggests minor text edits to General Plan Policy MOB-1.7.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.
2-73
549
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 7-10
The commenter suggests text edits to General Plan Policy MOB-1.9 to include mention of low-stress method for crossing for students walking and biking to school and other active transportation users.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-11
The commenter suggests minor text edits to General Plan Policy MOB-1.15.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-12
The commenter suggests minor text edits to General Plan Policy MOB-1.17.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-13
The commenter suggests text edits to General Plan Policy MOB-1.22 to include an intention to complete at least 50 percent of the planned bike and pedestrian network outlined in NVTA’s Active Transportation Plan by 2040.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-14
The commenter suggests text edits to General Plan Policy MOB-1.24 to include the provision of alternative low-stress routes rather than installing facilities that are not low-stress. The commenter also suggests the inclusion of review by the Open Space, Active Transportation, and Sustainability Commission.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-15
The commenter suggests minor text edits to General Plan Policy MOB-2.2.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.
2-74
550
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 7-16
The commenter suggests minor text edits to General Plan Policy MOB-2.3.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-17
The commenter suggests text edits to General Plan Policy MOB-2.4 to upgrade existing bikeways using all means available—such as conflict markings, buffers, rumble strips, and delineators—to make bikeways safer and lower stress and to catch up with evolving best practices.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-18
The commenter suggests minor text edits to General Plan Policy MOB-2.5.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-19
The commenter proposes the addition of a new policy, MOB-2.7, which suggests partnership with public, nonprofit, and community stakeholders to secure dedicated funding for the education and infrastructure needs of the Countywide Safe Routes To School Partnership to provide safe and equitable access for students going by active transportation to local schools.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-20
The commenter proposes the addition of a new policy, MOB-1.29, which suggests that the City Secure and maintain status as a Bicycle Friendly Community.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-21
The commenter suggests minor text edits to General Plan Policy ENV-9.5.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.
2-75
551
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 7-22
The commenter suggests text edits to General Plan Policy ENV-10.10 to include an intention to complete at least 50 percent of the planned bike and pedestrian network by 2040.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-23
The commenter suggests text edits to General Plan Policy ENV-11.9 to include an intention to complete at least 50 percent of the planned bike and pedestrian network by 2040.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-24
The commenter suggests updates to Figure 6: Standard Roadway Cross Sections to denote that 5’ bike lanes excluding gutter pan with 3’ buffers containing delineators are standard for bike lanes along all types of arterials and often for major collectors, too.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-25
The commenter suggests the inclusion of Types of Bikeways on page M-21 of the General Plan to include Class 2B bicycle lanes.

This comment pertains to the General Plan, but not to the Draft EIR or CEQA. Accordingly, City staff is considering edits to the General Plan goals and policies, as needed. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 7-26
The commenter thanks the City for considering their suggested changes and emphasizes the Plan's significance in addressing the climate emergency and promoting Complete Streets. They urge a stronger commitment to the Plan's goals to empower the City to achieve the 2040 General Plan.

They also offer to answer any questions and express gratitude for the ongoing efforts on the Plan.

This comment is appreciated. No revisions to the Draft EIR are required in response to this comment.
2-76
552
Brent, the only comment on the EIR is for the City to acknowledge that the County has (i) general planned and rezoned the Hess-Laird properties for industrial use and (ii) the Napa ALUC has adopted a new ALUCP that modifies the treatment of the Hess-Laird properties, among other things.

Clark Morrison
Letter 8
8-1
2-77
553
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 8
COMMENTER: Clark Morrison
DATE: December 30, 2024
Response 8-1
The commenter requests the City to acknowledge that the County has general planned and rezoned the Hess-Laird properties for industrial use and that the Napa ALUC has adopted a new ALUCP modifying the treatment of these properties.

As discussed on page 2-6 of the Draft EIR, the City would evaluate updating the Urban Limit Line to include the Hess/Laird Property, which would subsequently need to be incorporated into the City with a Napa County LAFCO sphere of influence amendment and annexation approval before any future development could occur in that area within the City limits. Because these lands are not within the City’s jurisdiction, the potential environmental impacts from future development in the Hess Laird Property will be addressed when or if the City pursues annexation of that area.

Consideration of expanding the Urban Limit Line would not result in an environmental impacts and is not discussed further in the Draft EIR. Accordingly, no revisions to the Draft EIR are required in response to this comment.
2-78
554
December 27, 2024
Mr. Brent Cooper, AICP
Community Development Director
City of American Canyon
4381 Broadway Street, Suite 201
American Canyon, CA 94503
RE: American Canyon 2040 General Plan – Draft Environmental Impact Report Comments Dear Brent:

Thank you for the opportunity to review and provide comments on the City of American Canyon General Plan 2040 Draft Environmental Impact Report (DEIR). Our team has reviewed the document, and would like to share the following comments:

2.6 – Project Characteristics
− Pg. 2-10 – Under Section 2.6.5, first bullet, please add reference to safety and transit improvements for the SR 29 corridor
o Consider updating Figure 2-6 (Pg. 2-12) or adding a new Figure, to show proposed improvements identified in Section 2.6.5 and elsewhere in the DEIR for active transportation modes (including corridor and intersection improvements) and fixed route transit service

3.3 – Cumulative Development
− Pg. 3-2 – Under 4th paragraph, add language to clarify that cumulative impacts also include programs or policies implemented within the Planning Area that may not be tied to a specific development project. This is particularly relevant in the area of transportation (TDM programs, for example) as well as GHG reduction efforts (see in-progress Countywide RCAAP) Chapter 4.2 – Air Quality
− Pg. 4.20-17 – Under the Transportation section, NVTA is unclear as to why only two of the 23 Transportation-related Control Measures (CMs)identified in the 2017 CAP are discussed. o Several additional CMs , such as TR9 (Bicycle and Pedestrian Access and Facilities), TR3 (Local and Regional Bus Service), and TR15 (Public Outreach & Education) are consistent with proposed Mobility Element policies and existing programs supported by the City. o Related to TR2: Trip Reduction Programs, suggest that within the General Plan Mobility Element, creation of a new stand-alone Policy to explicitly reference public transit, including existing Vine fixed route and ACT on-demand transit systems. This would strengthen Plan consistency with this Control Measure, as well as that of AQ-2 discussed below.

Letter 9
9-1
9-2
9-3
2-79
555
− Pg. 4.2-22 – Reference to “VINE” fixed route public transit should be changed to “Vine” as the name is not used as an acronym. Change should be applied anywhere else Vine transit is referenced in the General Plan or the DEIR.

Chapter 4.3 – Biological Resources
− Pg. 4.3-22 – Related to Proposed ENV-1.5, consider revision to preceding paragraph to include discussion existing and/or future proposed active transportation facilities (paths/trails) through or adjacent to the “network of open spaces.”
Chapter 4.5 – Greenhouse Gas Emissions
− Pg. 4.5-14 – Napa Valley Transportation Authority – Please revise second sentence to replace “county transportation plan” with “countywide transportation plan.” Make this same change in the final sentence of the paragraph.

Chapter 4.6 – Land Use & Planning
− Pg. 4.6-4 – Suggest change in leading paragraph, modifying second sentence from “…and transportation strategies that, if implemented, would allow the region to meet CARB’s targets,” to “…would support regional efforts to meet…”
o Addititionally, under subsection c., Local Regulations, consider updating discussion to reflect Plan Bay Area 2050+, a limited and focused update to Plan Bay Area 2050. o Update other references in the DEIR to Plan Bay Area 2050 to reflect same (eg: 4.11-4).

Chapter 4.7 – Noise
− Pg. 4.7-19 – Related to Program C: Active Transportation Plan, as well as prior references in the DEIR to Policy MOB-1.20, Bicycle Plan Funding, consider updating this Program/Policy in the General Plan document to reflect City coordination with NVTA in developing a locally-adopted Active Transportation Plan. This comment will also be provided as part of stand-alone comments on the Draft General Plan.

Chapter 4.11 - Transportation
− Pg. 4.11-1 – Last paragraph. Note that NVTA will provide City with updated mileage totals for existing bicycle/pedestrian facilities in January of 2025, reflecting updated methodologies as well as newly constructed facilities subsequent to the 2019 Bicycle Plan. If schedules allow, consider updating distances prior to publication of the FEIR and adoption of the 2040 General Plan. Also, correct double comma on 3rd line of paragraph. − 4.11-2 – Transit Services. Add to existing paragraph reference to Regional transit routes 11 (Napa Vallejo Connector) and 11x (Napa Vallejo Express), providing American Canyon residents public transit service North to the City of Napa, and South to the Vallejo Ferry Terminal. − 4.11-2 – Americans with Disabilities Act of 1990 – Update discussion to reflect 2023 Final Rule published by the Access Board in the Federal Register addressing access improvements within the public ROW. See Federal Register, Vol 88, No. 151, Tuesday, Aug 8 2023, pp53604 et seq. 9-4
9-5
9-6
9-7
9-8
9-9
9-10
9-11
2-80
556
− 4.11-3 – Federal Highway Administration – Update discussion to reflect that FHWA funding authorization is Infrastructure Investment and Jobs Act (IIJA), commonly known as the Bipartisan Infrastructure Law (BIL), not MAP 21.
− 4.11-3 – Complete Streets Act – Update discussion to reflect Caltrans Directors Policy 37. See also SB 960 (Weiner, 2024).
− 4.11-4 – Senate Bill 743 – Second Paragraph, update reference to OPR (Office of Planning & Research) to reflect new name for the state’s comprehensive planning agency, Office of Land Use & Climate Innovation (LCI).

NVTA will be providing a separate set of comments on the Draft General Plan (as separate and distinct from the DEIR) in the coming days. Those comments will largely focus on opportunities to strengthen or clarify proposed policies and discussion of existing conditions.

Thank you again for the opportunity to provide comments. Should you or your team have any questions regarding the above comments, please do not hesitate to reach out.

Regards,
Patrick Band
Associate Planner/Administrator
Napa Valley Transportation Authority

ON BEHALF OF NVTA
9-12
9-13
9-14
9-15
2-81
557
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 9
COMMENTER: Patrick Band, Associated Planner/Administrator – Napa Valley Transportation Authority
DATE: December 27, 2024
Response 9-1
The commenter requests a reference to safety and transit improvements for the State Route 29 corridor is added to Section 2.6, Project Characteristics, of the Draft EIR. The commenter requests an updated Figure 2-6 or new figure to show proposed improvements identified in Section 2.6.5 and elsewhere in the Draft EIR for active transportation modes and fixed route services.

Section 4.11, Transportation, provides a detailed description of existing pedestrian bicycle, and transit facilities that serve American Canyon and therefore revisions to Figure 2-6 or additional figures identifying active transportation modes and fixed route services are not warranted. In response to the comment regarding safety and transit improvements on State Route 29, the following revision has been made to the Draft EIR Section 2.6.5, Mobility Updates. The revision would not alter the impact analysis or findings of the Draft EIR and, as such, would not warrant recirculation of the Draft EIR.

The City is in partnership with the Napa Valley Transportation Authority to identify improvements to SR 29, including landscaping improvements, pedestrian improvements, safety and transit movements, and multimodal features.

Response 9-2
The commenter requests language is added to the fourth paragraph of page 3-2 to clarify cumulative impacts include programs or policies that are not tied to a specific development project.

In response to this comment, the following revision has been made to the Draft EIR Section 3.3, Cumulative Development. The revision would not alter the impact analysis or findings of the Draft EIR and, as such, would not warrant recirculation of the Draft EIR.

By its nature, a general plan considers cumulative impacts insofar as it considers cumulative development that could occur within the Planning Area, including implementation of programs and policies included in regional planning documents.

Response 9-3
The commenter requests additional transportation-related control measures (i.e., TR9, TR3, TR15, and TR2) identified in the 2017 Climate Action Plan are discussed in page 4.2-17. The commenter suggests that within the General Plan Mobility Element, a new policy should be created to explicitly reference public transit which would strengthen consistency with TR2 and the analysis of Impact AQ-2.

The Draft EIR concluded that the 2040 General Plan Update would have less than significant impacts related to conflicts with an air quality plan and release of cumulatively considerable criteria pollutants. The commenter states the listed transportation-related control measures would be consistent with the proposed Mobility Element policies. Therefore, further evaluation of these transportation-related control measures would not identify new or more severe environmental 2-82
558
City of American Canyon
American Canyon 2040 General Plan Update Responses to Comments on the Draft EIR Final Environmental Impact Report
impacts related to conflicts with an air quality plan. The commenter’s suggestion pertaining to the inclusion of an additional General Plan policy is not directly related to the analysis within the Draft EIR. As stated, the Draft EIR concluded that the 2040 General Plan Update would have less than significant impacts related to conflicts with an air quality plan and release of cumulatively considerable criteria pollutants, and therefore the inclusion of an additional policy to the General Plan would not substantially reduce environmental impacts to a lower level of significance.

Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 9-4
The commenter requests the use of “VINE” on page 4.2-22 is changed to “Vine”.

The use of “VINE” on Page 4.2-22 of the Draft EIR is language from Policy MOB-5.3 of the 2040 General Plan Update. Therefore, this comment does not pertain directly to the Draft EIR. No revisions to the Draft EIR are necessary in response to this comment.

Response 9-5
The commenter requests a revision to page 4.3-22 that includes a discussion of existing and future proposed active transportation facilities through or adjacent to the “network of open spaces”.