October 2023 | Addendum to the Initial Study and Mitigated Negative Declaration
VINTAGE HIGH SCHOOL FARM
Napa Valley Unified School District
Prepared for:
Napa Valley Unified School District
Contact: Jennifer Gibb
2425 Jefferson Street
Napa, California 94558
707.253.6281
Prepared by:
PlaceWorks
2040 Bancroft Way, Suite 400
Berkeley, California 94704
t 510.848.3815
www.placeworks.com
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Introduction
The Napa valley Unified School District (NVUSD or District) prepared an Initial Study/Mitigated Negative Declaration (IS/MND) to evaluate the impacts of the Vintage High School Farm (Original Project). The District certified the IS/MND on December 6, 2018.
1.1 PURPOSE OF THIS ADDENDUM
Per CEQA Guidelines Section 15164, once an IS/MND has been certified, no subsequent report shall be prepared unless the lead agency identifies either a new significant impact, a substantial increase in a previously identified impact, or new information concerning mitigation measures that would substantially reduce a significant impact (State CEQA Guidelines §15162). If the proposed changes to a project do not involve these specific circumstances, the lead agency may prepare an addendum to the CEQA document— in this case, the IS/MND for the Project.
The previously certified IS/MND concluded that the Vintage High School Farm Project, with mitigation, would have no significant effect on the environment. The purpose of this Addendum is to analyze whether modifications to the project (Revised Project) would cause significant impacts on the environment. As presented below, none of the conditions described in State CEQA Guidelines §15162 calling for the preparation of a subsequent environmental document have occurred. Consequently, an Addendum is the appropriate CEQA document for analysis and consideration of the revised Project.
Circulation of an Addendum for public review is not necessary (State CEQA Guidelines, 18 §15164, subd. [c]); however, the Addendum must be considered in conjunction with the previous IS/MND by the decision- making body (State CEQA Guidelines, 20 §15164, subd. [d]), which for this Project is the District.
1.2 PROPOSED PROJECT CHANGES
Following certification of the IS/MND, the District proposed the following two changes to the original Vintage Farm High School project description. The purpose of this Addendum is to assess the environmental impacts of the Revised Project.
1.2.1 WATER PROVISION
According to the 2018 IS/MND, all water for the project, including for irrigation, classrooms, restrooms, livestock and fire suppression, would be provided by on-site wells. Groundwater would be stored in above ground tanks of different sizes for different uses. Water for irrigation would be distributed from the irrigation tank via a system of 3-inch PVC pipes and pressure treated headers.
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In August 2023, the District proposed a new water sourcing plan. Water for irrigation, livestock and barn use would continue to be provided by on-site wells via the same distribution infrastructure. However, water for classrooms, restrooms and fire suppression use would be provided by the City of Napa’s municipal water supply, via an existing eight -inch City water line at the end of Trower Avenue. The Dis trict applied for a Sphere of Influence (SOI) amendment in 2023 to access the existing water line.
The number of students and staff, number and square footage of buildings and agricultural acreage would not change under the Revised Project.
1.2.2 CITY OF NAPA AFFORDABLE HOUSING AGREEMENT
As part of the Revised Project, the District has made an agreement with the City of Napa to restrict future development of a 2.5-acre area on the south side of the parcel south of the Trower Avenue extension (APN 038-240-020-000) to affordable housing. According to this agreement , the site is to be developed at densities consistent with the City of Napa 2040 General Plan and 2040 General Plan EIR, and assuming application of State Density Bonus law, California Government Code Section 65915.
Affordable housing at this site would be consistent with the 2040 General Plan, adopted by the City in October 2022. Per the 2040 General Plan, Parcel 038-240-020-000 is within the City’s Sphere of Influence (SOI) and Planning Area. The General Plan “… provides clear policy direction for areas out-side the City limits but within the [SOI], where urban development has long been contemplated; these include…properties along Big Ranch Road near Vintage High School.”
1 As stressed in the 2040 General Plan EIR, “…properties near Vintage High School, remain a valuable resource for future development with potential for a mix of uses, including housing, employment, and neighborhood commercial uses.” 2 The property is labeled an Unincorporated Pocket on the 2040 General Plan Land Use Map and is designated Medium Density Residential. This designation allows for housing densities ranging from 8 to 18 units per gross acre. Given the size of the site, up to 45 dwelling units could be developed at the site. This number would increase with the application of the State Density Bonus Program, although the number of additional units is dependent on the total proportion of affordable units and the affordability level of those units.
This agreement is not a direct response to, nor is it intended to impact the future development or student body of, the proposed Vintage High School Farm.
1 City of Napa, October 2022, Napa 2040 Geneal Plan, page 2-2. 2 City of Napa, March 2022, Napa 2040 General Plan Environmental Impact Report, page 2-8.
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Environmental Analysis
The comparative analysis in this Addendum is to analyze whether the Revised Project would result in any significant environmental impacts that were not addressed in the 2018 IS/MND certified by the District.
Therefore, the analysis in this Addendum addresses the following:
Any impacts increased, decreased, or unchanged from the conclusions discussed in the IS/MND. Any changes required to mitigation measures.
The analysis in the IS/MND and this Addendum found that no impacts would occur for the following environmental resource areas; therefore, these topics are not discussed further in this Addendum:
Agriculture and Forestry Resources
Mineral Resources
2.1 AESTHETICS
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and no impact for aesthetics, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant and no impact for aesthetics, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical develop ment of the site will be subject to separate environmental review.
2.2 AIR QUALITY
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and less-than significant-with-mitigation for air quality, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less- than-significant and less -than significant-with- mitigation for air quality, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm.
Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
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2.3 BIOLOGICAL RESOURCES
The partial replacement of well water with City of Na pa-provided water would not change the findings of less-than-significant and less-than significant-with-mitigation for biological resources, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant and less -than significant-with- mitigation for biological resources, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.4 CULTURAL RESOURCES
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and less-than significant-with-mitigation for cultural resources, analyzed in th e 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less- than-significant and less -than significant-with- mitigation for cultural resources, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.5 TRIBAL CULTURAL RESOURCES
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and less-than significant-with-mitigation for tribal cultural resources, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less- than-significant and l ess-than significant-with- mitigation for tribal cultural resources, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
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2.6 GEOLOGY AND SOILS
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and less -than significant-with-mitigation for geology and soils, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of the less-than-significant and less-than significant-with- mitigation geology and soils -related impacts analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.7 GREENHOUSE GAS EMISSIONS
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant for greenhouse gas impacts, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of the less -than-significant for greenhouse gas impacts, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical develop ment of the site will be subject to separate environmental review.
2.8 HAZARDS AND HAZARDOUS MATERIALS
The partial replacement of well water with City of Napa -provided water would not change the findings of the less-than-significant and no impact for hazards and hazardous materials analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of the less-than-significant and no impact for hazards and hazardous materials analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm.
Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
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2.9 HYDROLOGY AND WATER QUALITY
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and no impact for hydrology and water quality, analyzed in the 2018 IS/MND. These include:
a. Violate water quality standards or waste discharge requirements. Under the Revised Project, the District would still be required to obtain State Water Resources Control Board (SWCRB) General Permit coverage and adhere to the project’s Storm Water Control Plan (SWCP). Like the Original Project, the Revised Project would also include two underground stormwater detention/drainage facilities, resulting in a less-than-significant impact. b. Substantially deplete groundwater supplies. The Revised Project would partially replace well water with City of Napa water supply without increasing overall water demand. It would therefore lessen the original less-than-significant impact.
c. Substantially alter the existing drainage pattern of the site. Like the Original Project, the Revised Project would not involve the alteration of any watercourse, stream or river . It would also continue to comply with the standard erosion and sediment control measures required as part of the Storm Water Pollution Prevention Plan (SWPPP), resulting in a less-than-significant impact. d. Create excess runoff. Like the Original Project, the Revised Project would comply with National Pollutant Discharge Elimination System requirements for minimizing pollution of storm water through preparation and implementation of an SWCP , which would specify Best Management Practices that would be implemented in the project during the construction stage, and a Water Quality Management Plan that would detail which BMPs would be implemented in project design and during project operation. This would result in a less-than-significant impact. e. Degrade water quality. Like the Original Project, the Revised Project would adhere to NPDES requirements and the requirements of the General Permit. This would substantially reduce potential impacts related to water quality, resulting in a less-than-significant impact. f. Danger related to flooding, dam failure, seiche, tsunami or mudflow. The location of the Revised Project would not change. As such, impacts related to hydrological hazard areas would remain less-than-significant or no impact.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less-than-significant and no impact for hydrology and water quality, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical develop ment of the site will be subject to separate environmental review.
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2.10 LAND USE AND PLANNING
The partial replacement of well water with City of N apa-provided water would not change the findings of less-than-significant and no impact for land use and planning, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant and no impact for land use and planning, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical develop ment of the site will be subject to separate environmental review.
2.11 NOISE
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and less-than-significant with mitigation for noise, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant and less -than-significant with mitigation for noise, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm.
Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.12 POPULATION AND HOUSING
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and no impact for population and housing, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less-than-significant and no impact for population and housing, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical develop ment of the site will be subject to separate environmental review.
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2.13 PUBLIC SERVICES
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant for public services, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less-than-significant for public services, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policie s in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.14 RECREATION
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant for recreation, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant for recreation, analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.15 TRANSPORTATION/TRAFFIC
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant and no impact for transportation/traffic, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings of less -than-significant and no impact for transportation/traffic, analyzed in the 2018 IS/MND. T he agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm.
Future affordable housing on the proposed site would be consistent with land use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.16 UTILITIES AND SERVICE SYSTEMS
The partial replacement of well water with City of Napa -provided water would not change the findings of less-than-significant for utilities and service systems, analyzed in the 2018 IS/MND. These include:
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a. Exceed waste water treatment requirements of the applicable Regional Water Quality Control Board. Like the Original Project, the Revised Project would include an on-site septic system designed and constructed per Napa County’s OWTS Standards. Per the San Francisco Bay Regional Water Quality Control Board, on-site wastewater systems, especially septic tanks, are regulated by local agencies, which provide permitting. The resulting impact is less than significant. b. Result in the construction of new water or waste water treatment facilities. The Original Project was to rely entirely on groundwater and a septic system, and thus would not impact existing water or waste water treatment facilities. The Revised Project would rely on City of Napa water for classroom, restroom and fire suppression use.
As documented in the 2018 IS/MND, annual water demand for the Original Project was 9.16 acre- feet per year (AFY). This included 1.08 AFY for domestic (classroom and restroom) use and 0.18 AFY for fire suppression. Therefore, the Revised Project, which would use the City of Napa’s municipal water supply for domestic uses and fire suppression, would require an approximately 1.26 AFY net increase in municipal water demand.
A net incre ase of 1.26 AFY would not require new or significantly upgraded water facilities.
According to the City of Napa’s 2020 Urban Water Management Plan (UWMP), the City has a significant excess of water in normal years. The total project water demand for the City for the year 2025 is 15,065 AFY ,
3 and the amount of water use is expected to increase by about 1,000 AFY between 2020 and 2025. The increased demand associated with the Revised Project represents
0.008 percent of the current total projected demand. This increase would not require construction or upgrades to water facilities, and the result would be less-than-significant. c. Result in the construction of new storm water drainage facilities. Like the Original Project, the Revised Project be required to adhere to a WQMP with specified BMPs for minimizing water pollution through project design features, and a SWCP specifying BMPs for minimizing water pollution during project construction. The result would be less-than-significant impact. d. Have sufficient water supplies available to serve the project from existing entitlements. The Revised Site is located in the same place as the Original Project and would therefore have the same groundwater yields. However, the partial use of municipal water would reduce demand on existing entitlements, lessening the already less-than-significant impact. e. Landfill capacity. The partial replacement of well water with City of Napa-provided water would not change the findings of less-than-significant for landfill capacity, analyzed in the 2018 IS/MND. f. Solid waste regulations. The partial replacement of well water with City of Napa-provided water would not change the findings of less-than-significant for compliance with solid waste regulation, analyzed in the 2018 IS/MND.
The District’s commitment to restrict future development on a portion of parcel 038 -240-020-000 to affordable housing would not change the findings analyzed in the 2018 IS/MND. The agreement with the City does not constitute proposal or approval of a specific physical project or program, or a component of Vintage High School Farm. Future affordable housing on the proposed site would be consistent with land
3 City of Napa, January 2022, 2020, Urban Water Management Plan, page 4-6.
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use and density policies in the 2040 General Plan GP & EIR, and any future physical development of the site will be subject to separate environmental review.
2.17 WILDFIRE
The 2018 IS/MND was certified before Section XX. Wildfire was included in CEQA Guidelines Appendix G, Environmental Checklist Form. Section XX. Wildfire requires various assessment of projects “located in or near state responsibility areas or lands classified as very high for hazard severity zones.” Like the majority of the Napa Valley, the Vintage High School Farm project site is not located in or near a California Department of Forestry and Fire Protection (CAL FIRE) State Responsibility Area (SRA). 4 The
project site and surrounding area are also outside any Very High Fire Severity Zone. The nearest Very High Fire Severity Zone is approximately 3.5 miles northeast of the site.5 Therefore, both the Original and Revised Project would have no impact related to wildfire hazards.
4 State of California, Office of the State Fire Marshall, Fire Hazard Severity Zones (FHSZ), https://osfm.fire.ca.gov/divisions/community-wildfire-preparedness-and-mitigation/wildfire-preparedness/fire-hazard-severity- zones/ accessed October 19, 2023.
5 Ibid.
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