SUPPLEMENTAL REPORTS AND COMMUNICATIONS — Napa City Council, December 3, 2024

SUPPLEMENTAL REPORTS & COMMUNICATIONS
Office of the City Clerk

City Council of the City of Napa Regular Meeting
December 3, 2024

FOR THE CITY COUNCIL OF THE CITY OF NAPA

AFTERNOON SESSION:

SUBMITTED PRIOR TO THE CITY COUNCIL MEETING

6. PUBLIC HEARINGS:

6.A Master Fee Schedule
• Presentation from Staff
• Memo from Staff

6.B. Amendment of Napa Municipal Code Section 10.36.090 – Parking Exceeding 72 Hours
• Presentation from Staff
• Memo from Staff

6.C. Amendment of Napa Municipal Code Section 10.36.070 – Trailers and Oversized Vehicle Regulations
• Presentation from Staff
• Memo from Staff

1) Email from Larry Brown received November 9, 2024 (was inadvertently left off ATCH 2 in report).
2) Email from Lisa Poppen received November 26, 2024.
3) Email from Jim McNamara received November 30, 2024.
4) Email from Tracy Mayne received on December 2, 2024. 5) Email from Scott Brown received on December 2, 2024. 6) Email from Jim Nicolette received on December 3, 2024. 7) Email from Valerie Saribalis Cole received on December 3, 2024. 8) Email from Andrea Leavitt received on December 3, 2024. 9) Email from DeeAnn Valine received on December 3, 2024. 10) Email from Janice Clifton received on December 3, 2024 11) Email from James Kress received on December 3, 2024

EVENING SESSION:

12. PUBLIC COMMENT

13. PUBLIC HEARINGS

13.A. Big Ranch Road Annexation – 34 total emails, letters, and voicemails received • Presentation from Staff

1) Letter from Deborah Staats received September 18, 2024. 2) Email from Ruth Gardner received on November 11, 2024. 3) Email from Olive Lopez received on November 19, 2024. 4) Email from Pamela Condos received on November 19, 2024. 5) Email from Jackie Harrison received November 19, 2024. 6) Letter from Marilynn Breckenridge-Yarborough received November 20, 2024 7) Email from Jacqueline Wessel received November 22, 2024 8) Email from John and Peggy Wilkinson received November 22, 2024. 9) Email from Molly Silcox received November 22, 2024.
10) Email from Rachel Stark received on November 22, 2024. 11) Email from Stanley Masuda received on November 23, 2024. 12) Email from Lori Van Winden received on November 25, 2024 13) Email from Pat Puccinelli received on November 27, 2024. 14) Email from Richard Drury_LozeauDrury LLP received on November 27, 2024. 15) Email from Louise Diana received on November 30, 2024. 16) Email from Norma I. Quintana received on November 30, 2024 17) Email from Suzanne & Ninad Dabadghav received on December 1, 2024. 18) Email from Ardy and Lori Van Winden received on December 1, 2024. 19) Email from Jana Cohen received on December 2, 2024. 20) Email from Corinne and Mike McGue received on December 2, 2024. 21) Voicemail from Susan Rushing-Hart received on December 2, 2024. 22) Email from Janet and Steven Krupka received on December 2, 2024. 23) Email from Jacqueline Hawker-Wessel received on December 2, 2024. 24) Email from Mark Stephenson_Audubon Society received on December 2, 2024. 25) Email from Ben Hardisty and Rachel Stark received on December 3, 2024. 26) Email from Susan Rushing-Hart received on December 3, 2024. 27) Email from Gene Tartaglia received on December 3, 2024. 28) Letter from Richard Drury_LozeauDrury LLP received on December 3, 2024. 29) Email Joe Andrighetto received on December 3, 2024
30) Email from Stephanie Chandler received on December 3, 2024 31) Email from Eric Schmitt_Schmitt Company received on December 3, 2024 32) Email from Kenton Johansson received on December 3, 2024 33) Email from Karen Knoll received on December 3, 2024 34) Email from Jerilyn and Stanley Masuda received on December 3, 2024

Master Fee Schedule
December 3, 2024
Item 6.A
Fee Updates: Best Practices
• User fees help the City provide essential
services to the public.
• Regular fee updates prevent unintended
subsidies and ensure fees remain fair, accurate,
and aligned with service costs.
• Consistent updates demonstrate transparency
and accountability in managing public funds.
2 Master Fee History
• The last comprehensive fee study and full update
were presented to Council in October 2021.
• The fee schedule included three years of fees, with
the final year taking effect on January 1, 2024.
• In October 2024, City staff reviewed the latest CPI
data, which showed a 2.7% inflation factor for all
items in the San Francisco-Oakland-Hayward, CA
region.
3 Considerations for Updates
• Apply a 2.7% increase to most fees based on the
latest Consumer Price Index (CPI) data to account
for inflation.
• Adjust fees using the CPI factor, rounded down to
the nearest whole dollar to simplify calculations and
ensure they would not exceed the City’s cost of
providing service.
• Exclude fees from the CPI increases that are
capped or regulated, such as CA state laws or
government codes.
4 Updates to Water Fees-Section 13
Remove fees for services the City no longer provides:
• Section 13.4 - Service Installation/Abandonment/Relocation • 13.5.31-13.5.40 - Service Pipe and Hot Tap (less excavation) • 13.5.41-13.5.45 - Fire Service Pipe and Hot Tap (less excavation) • 13.5.46-13.5.49 - Metered Fire Service Pipe and Hot Tap (less excavation)
• Update the numbering sequence in Section 13 to reflect these changes.
5 Hydrant Meter Service Charge
Section 13.3.5
• Consolidate the current daily charge ($10) and
weekly charge ($50) into a single fee of $230,
prorated for the first and last billing cycles.
• This change simplifies the billing and aligns with
the capabilities of the City’s existing billing
software.
6 Looking ahead
• In early 2025, City staff to
issue RFP for a
comprehensive user fee
study.
• City staff will present
findings and
recommendation to
Council in Q3-Q4 of
2025.
7 Recommended Action

1.Adopt a resolution updating Citywide fees,
charges, and fines effective February 3, 2025.
8 End of Presentation
December 3, 2024
Updated
Parking
Regulations

10.36.090
Item 6.B
Purpose of this Discussion
• Public Hearing
– Consideration of a complete rewrite of

10.36.090 pertaining to parking of vehicles on
City streets in excess of 72 Hours
• Requested Council Action:
– First reading and intention to adopt
History
• 10.36.090 Last Updated in 1954
– Lacks modern day context and definitions
– Does not define “parking space” or movement
requirements
– Needs updating for consistency with California Vehicle Code
• Parking in the City of Napa
– New housing laws have changed minimum parking
requirements, putting greater demands on City streets
– Increase in complaints
Proposed Rewrite
• Maintains 72-hour rule for parking in one parking
space
– Applies to all vehicles, regardless of size or purpose (personal, business, etc.)
• Defines a parking space as 1,320 feet (1/4 mile)
– Exception: Parked on the street registered with DMV,
then definition is 100 feet, about ½ of an average City block
• Member of the police department may remove
vehicles in violation of code
Enforcement Process
• Service Center
– Complaints of vehicles violating the 72-hour rule can be made on Service Center
– Community members do not need to wait 72 hours to log in service center.
• Parking Enforcement Responds to Service
Center Requests
– Tags vehicle and starts 72-hour period
• 72 Hours After Tagging
– Police Department can act to tow subject to availability of tow companies
– Tow companies generally available for regular sized
vehicles.

Resources
• Tow Service
– Police Department maintains several contracts for tow service on a rotating basis
• Community Service Officer
– At least one day a week, pending emergency-based
needs
• Increased Funding for Overtime
– Heavy enforcement period: January- March to
implement new regulations
Questions and Feedback
December 3, 2024
Updated
Parking
Regulations

10.36.070
Item 6.C
Purpose of this Discussion
• Public Hearing
– Consideration of a complete rewrite of

10.36.070 pertaining to parking of oversized
vehicles and trailers on City streets
• Requested Council Action
– First reading and intention to adopt
• Implementation:
– January 17, 2025
History
• 10.36.070 Last Updated in 1954
– Lacks modern day context and definitions, particularly as it pertains to recreational vehicles
– Does not define “parking space” or movement
requirements
• Parking in the City of Napa
– Increase in complaints
– In areas with a tremendous demand on City streets
around multi-family housing, trailers and oversized
vehicles are taking up limited parking spaces
Proposed Rewrite
• Allows parking in one space for 4 hours
– Must move every 4 hours to a new space, and not
return to a previous space for 72-hours
• Defines a parking space as 1,320 feet (1/4 mile)
• Defines oversized vehicles and trailers
consistent with State vehicle code
• Member of the police department may remove
vehicles in violation of code; community
caretaking provisions apply
Proposed Rewrite-Exceptions
• Pick-ups or deliveries (i.e. moving vans) parked
immediately adjacent to the property affected
• Permitted and licensed food trucks, open and
operating in non-residential areas
• Loading and unloading of recreational vehicles
for a period of up to 48 consecutive hours
parked in front of registered address
• Public safety vehicles
• Emergency repairs-for up to 8 hours
• Government vehicles conducting government
business
Enforcement Process
• Service Center
– Complaints of vehicles in violation can made on Service Center or by calling dispatch
– Community members do not need to wait 4 hours to log in service center.
• Parking Enforcement Responds to Service
Center Requests
– Tags vehicle which starts 4-hour window
• 4 Hours After Tagging
– Police Department apply community care test and can act to tow
– There is one tow company that has equipment to tow
oversized vehicles
Community Care Provisions
• Police Department Compliance
– Vehicle Code 22650; unlawful search and seizure,
unless community caretaking need is documented
• Community Caretaking Thresholds
– The vehicle itself if a public safety or traffic hazard – The driver cannot legally move vehicle to safer location – The vehicle is blocking a driveway or sidewalk
– The vehicle’s location may be a target to theft or
vandalism
– The vehicle is unsafe to be operated on a public
roadway
Resources
• Tow Service
– There is one tow company available to do this work in Napa County
• Community Service Officer
– At least one day a week, pending emergency-based
needs
• Increased Funding for Overtime
– Heavy enforcement period: January- March to
implement new regulations
Resources
• Storage
– Support for storing vehicles for individuals transition to shelter or other diversion opportunity in homeless
services system
• Outreach Services
– Connection with shelter or other housing support
services
Questions and Feedback

From: Lisa Poppen
To: Clerk
Subject: Public Comment 12/3
Date: Tuesday, November 26, 2024 10:38:18 PM
[EXTERNAL]
Dear Napa City Council,
As a resident of the Napa Abajo neighborhood, I am sharing my strong support for updating the city’s Parking Regulations to dissuade abuse of our public thoroughfares.

It is high time we address those who actively refuse to participate in shelter programs and have established encampments on the residential streets throughout Napa.

While one has individual rights, living in vehicles on public streets should not supersede societal norms or the rights of other residents. As a taxpayer, homeowner, and voter, I believe it is crucial to take action.

Updating 70-year-old code is a first step toward restoring our neighborhoods and thoroughfares to provide a clean, safe, and pleasant community environment.

I encourage the city council to support the two proposed amendments that prohibit vehicles parked more than 72-hours and all oversized vehicles parked with no connection to the homes surrounding them.

10.36.090: Parking in Excess of 72 Hours

10.36.070: Parking of Trailers and Oversized Vehicles
Please prioritize your constituents that actively participate in the community.

Thank you,
Lisa Poppen

From: Beth Painter
To: Steve Potter; Clerk
Subject: Fwd: Parking Regulations | Napa, CA
Date: Monday, December 2, 2024 7:58:22 AM
Begin forwarded message:

From: " " <[email protected]>
Subject: Re: Parking Regulations | Napa, CA
Date: December 2, 2024 at 5:44:19 AM PST
To: Beth Painter <[email protected]>
Beth,
There’s an issue with the height definition of an “oversized” vehicle. My neighbor has a mother in a wheelchair and has a wheelchair van. It exceeds the height requirement. Food trucks exceed the height requirement. If I have a party with a food truck (of food trucks are parked for a festival)
it’s limited to 4 hours? The
height definition needs to be revised higher. Am going out with a tape measure today to make a proposed revision.

The four hour limit is unrealistic. When I moved to Napa, my movers were there for 11 hours. They would only be allowed to unload for 4 hours and would then have to wait 3 days to come back?
I don’t think whoever drafted this thought it all the way through.

Tracy

December 2, 2024
City of Napa Council,
It was brought to my attention that one of the issues tomorrow night would be parking of travel trailers, work trailers and other vehicles on city streets. Unfortunately, I am unable to attend the meeting. However, I would like to voice my opinion.

I live in Browns Valley and walk four miles each morning. There are many work trailers with debris to end up at the dump. These are permanent in the sense that they are used daily, Travel trailers will spend weeks to months parked on the street. Often used for visitors or just because the side yard is not big enough to accommodate them. I know storage is expensive; however, perhaps that should have been a consideration when the purchase was made.

Along Redwood Road food trucks are parked when not in use. In neighborhoods cars with expired tags stay parked for years. I am embarrassed to drive guests from downtown up Browns Valley Road with all the cars parked on the street.

I am not sure what your feelings are about this. Napa should look better than it does. We have done a great job with the tourist areas. Yet, our streets look like blite. When you discuss the issue, I hope ALL of you drive to the different neighborhoods together and at different times of the week and day.

Respectfully,

Jim Nicolette

From: Valerie Saribalis Cole
To: Clerk
Subject: Public comment parking regulations
Date: Monday, December 2, 2024 9:08:25 PM
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[EXTERNAL]
Please add to the supplemental statement:

In recent weeks there has been a marked increase in the number of commercial vehicles with trailers parking on Stonehouse Drive near and into the Stonehouse circle area and down the street toward Lake Park.

More than one
Vehicle has a For Sale sign on it and has been parked for several weeks, while the rest of the vehicles are work vehicles with long trailers.

Not only do they take up 2 to 3 parking spaces that residents in the area need, but they also are causing congestion in this part of the neighborhood and blocked visual access to drivers as well as changing the overall appearance of the neighborhood.

Ordinance enforcement
needs to follow up on this increasing commercial parking issue on our street.

My family has been in residence in this neighborhood since 1989 and while we have witnessed other transformations in the neighborhood, this is a new and increasingly bothersome one.

Thanks you for your support of parking enforcement with commercial vehicles in residential areas.

Valerie Saribalis Cole
Sent from my iPhone

From: Andrea Leavitt
To: Clerk
Subject: Public Comment-Parking Regulations. support
Date: Tuesday, December 3, 2024 11:06:00 AM
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[EXTERNAL]
>
>
>
> We are expressing our support for tighter restrictions on parking in Napa.

We have seen many recreational
vehicles, campers and large vehicles parked for long periods of time in the Jordan Lane, Imperial Lane area of Napa. >
> Such vehicles pose danger for a variety of reasons.

We have asked the CIty to take action on this issue for years now as the problem of people living on the streets has increased. >
> The city should limit the amount of time, as proposed, vehicles can park especially in the area on Imperial and Jordan Lane.
>
> We appreciate the ordinance changes the City is proposing to help businesses and citizens enjoy a safer, cleaner environment.
>
> Thank you for your action in support.
>
>
> Andrea Leavitt
>
>
>
> Soscal Park area Jordan Lane & Imperial
> Napa, CA 94559
>
>

From: Academy of Danse
To: Clerk
Subject: limit long term parking in Napa
Date: Tuesday, December 3, 2024 12:06:35 PM
You don't often get email from [email protected]. Learn why this is important [EXTERNAL]
Hello,
I am a small business owner at 1123 Jordan Ln.

I am unable to attend the meeting today because I will be teaching classes.

The long term parking of Rvs on Imperial Way and Jordan Lane have been an ongoing issue for years.

The problem has increased over the last 2 years significantly.

Today there are 6 Rvs and 2 motorcycles parked on Imperial Way and they haven't moved in weeks.

This is a typical situation on this street.

Sometimes there can be as many as 12 Rv's on the street for days, weeks, and months.

The 72 hour policy does not help the issue at all.

Some rvs literally move a few feet or right across the street only to move back to the original spots the next day or so.

I feel the best solution would be to have signs posted that do not allow any overnight parking.

That would be ideal .

Thank you
--
DeeAnn Valine
Owner & Choreographer
ACADEMY of DANSE
1123 Jordan Lane
Napa, CA 94559
(707) 226-6170
www.academyofdanse.com
www.facebook.com/theAcademyofDanse
From: Janice Clifton
To: Clerk
Subject: New ordinances to the City Municipal Code re street parking Date: Tuesday, December 3, 2024 1:03:23 PM
You don't often get email from [email protected]. Learn why this is important [EXTERNAL]
I will be at the meeting today, but just wanted to be sure to add my positive input to these new codes. I think the codes regarding large vehicle parking have needed to be revised for many years. I hope this will be helpful for the many accidents that occur or almost occur when you are pulling out of a parking lot and cannot see any oncoming traffic due to large vehicles blocking your line of sight. The parking lot at our store is often a hazard due to the fact that you absolutely cannot see oncoming traffic either direction due to the parking of large vehicles for significant time next to our driveways.

Thank you for your consideration in approving this ordinance. --
Janice Clifton
Abbey Carpets Unlimited
[email protected]
707-261-8001 (direct)
707-261-8000 (main line)

Big Ranch Road Annexation
(PL23-0143)
December 3, 2024
Item 13.A
Project Location
2275, 2285, 2305, 2331 Big Ranch Rd., 1130
Trower Avenue & 1438 Rosewood Lane

Requested Action
• Annexation of six (6) parcels totaling
approximately 51.5 acres into City limits.
• Pre-zoning approximately 66 acres to a
Master Plan District (placeholder).

Parcels Requesting Annexation
2275, 2285, 2305, 2331 Big Ranch Rd., 1130 Trower
Avenue & 1438 Rosewood Lane

Annexation Process
• California Government Code Section 56000,
“the Cortese-Knox-Hertzberg Local Government
Reorganization Act of 2000” (the “Act”)
establishes procedures for city incorporations
and annexations.
• Local Agency Formation Commission
(LAFCO)
Rural Urban Limit Line and Sphere of Influence

1998 Rural Urban Limit Line

Parcels Opposed to Annexation
(Shaded red)

General Plan 2040
Adopted October 2022
• Amended General Plan Land Use Designation
from: Single Family Residential - [density ranges;
(0 to 2), (0 to 3), (0 to 4), (0 to 6) units/acre]
• To Medium Density Residential - 8 – 18 units/acre
Former General Plan Land Use Designations

Current General Plan Land Use Designations

General Plan 2040
Adopted October 2022
• Goal LUCD-24: Promote development of the Big
Ranch Road area as cohesive, vibrant
neighborhood, integrated with surrounding uses.
• LUCD 24-1: Prior to allowing new development as
part of a subdivision, require a master plan.

Intended to provide walkable, connected
neighborhood, easy access to high school, stores
and amenities on Trancas Street.

Existing Pre-Zones

Proposed Pre-Zone to Master Plan District

Planning Commission Meeting
September 19, 2024
Commission heard from (15) members of the public
during public comment;
Most opposed the annexation with concerns related to
actual development application, such as:
• negative traffic impacts
• drainage issues
• other environmental issues
• Noticing complaints
• Up-zoning
Commission unanimously recommend approval by a vote
of 4-0-1 (one Commissioner absent).

Environmental Review
Consistency Analysis for the Annexation Project
determined the potential environmental effects
related to the Project were adequately analyzed by
the General Plan 2040 Update Final EIR certified by
the Council on 9/20/2022.

Future development projects within the annexed area
would be subject to subsequent project specific
environmental analysis.

Recommended Action
(1) adopt resolution authorizing City Staff City Staff to submit an application to the Local Agency Formation Commission to initiate proceedings for the annexation of the six properties at 2275, 2285, 2305, 2331 Big Ranch Road, 1130 Trower Avenue (only the portion within the RUL and south of the future Trower Avenue extension) and 1438 Rosewood Lane and determining that the actions authorized by this resolution were analyzed by a previously certified Environmental Impact Report;
(2) Approve first reading and introduction of an ordinance amending Title 17 of the Napa Municipal Code to add a new Chapter 17.31 establishing a Master Plan Zone District (MP), amending the Zoning Map to Pre-Zone (APNs 038-240-005, 038-240-006, 038-240-014, 038-240-015, 038-240- 020, 038-240-022, 038-240-023, 038-160-023, 038-160-024, 038-160-025, 038-160-026, 038-160-029), from single-family residential (RS-5, RS-7, RS-10, RS-20) to MP and determining that the action authorized were analyzed by a previously certified Environmental Impact Report.

End of Presentation
Possible Future Trower Ave. Extension

To The Planning Commission, Staff and The City Council of the City of Napa, 09/18/24 I live off Big Ranch Road and Garﬁeld. I would like to be heard regarding the Annexation and change of zoning from single-family residential to Master Plan District and the annexing 53.5 acres of said 66 acres into the cities boundaries. I am against this change for several reasons. Annexing 53.5 acres of said 66 acres into the city boundaries violates the previous restrictions for use of county lands for single family and agricultural. If the city can keep annexing piece by piece county lands then the agriculture that supports this valley will be severely compromised. That was the original reasons for those restrictions and no exceptions should be made because each annexation makes it easier to continue to keep annexing. This change absolutely violates the spirit of what was intended. This change seems contrary to what the city council and planning commission should doing, which is preserving our wine culture and agriculture. Without the viability of the wine culture and agriculture Napa won’t be attractive to visitors or business.

I am also against this change because the infrastructure does not support the traffic that already exists without adding medium density housing into the equation. Big Ranch Road starting at Trancas is a two lane road. It has needed repaving for the last few years from Trancas to the ﬁrst bridge at Catania due to potholes, and really should also be repaved up to just past Garﬁeld.

Central Ave. is an even narrower two lane road. The traffic from Vintage High School across Central to Big Ranch down to Trancas can be backed up all the way to Garﬁeld several times a day. Backups occur during the morning and evening commute times plus start and end of the school day. Adding medium density housing using these roads instead of the single family homes now there will be a detriment to all the students, teachers, wineries, and residents in that entire area. There will be more traffic, road deterioration, frustration and maybe accidents.

In addition more traffic comes from the use of Garﬁeld Little League Park down Garﬁeld onto Big Ranch before and after both games and practice. Hundreds of cars through another two lane residential street feeding onto Big Ranch several times a day, two to three times a week, for the 4 months of the Little League season. There is inadequate parking for the park so the few streets of residents surrounding the Park are inundated with cars lining the residential streets down both sides of the streets making it difficult to get to our own homes and interfering with our own parking needs, even blocking driveways. We have spoken to the Little League regarding these issues many times. This is more traffic, road deterioration, frustration and maybe accidents which would be greatly increased with this change to medium density.

These issues could not have been adequately analyzed with no further environmental review required. No City Council, Planning Commission or staff member should recommend initiating any petition, or proceedings authorizing annexation of the property, or adopting any ordinance until they have driven down these two lane roads themselves during backup hours and Little League season.

It is actually inconceivable to me that staff are making this recommendation.

I am completely against this entire Annexation and Zoning change. I have discussed this with many neighbors, and the consensus is unanimous that this Annexation and Zoning change be rejected. I will be attending any hearings regarding this issue, as will many of my neighbors.

Thank you, Deborah Staats, , Napa, 94558,

10/10/24 Addendum to previous letter
In addition to the issues I identiﬁed in my previous letter to the Planning Commission, Staff and City Council with annexing and rezoning of protected county agricultural lands. The issues I previously identiﬁed were the severe increase in traffic on narrow two- way roads with no bike lanes, water drainage ditches immediately next to the roads, increased probability of accidents, further road deterioration from increased traffic, repaving that has already not been neglected for years, residents increasing frustration, and simply not having the infrastructure to support the density increase. I have addition issues with the annexation and rezoning.

I did not include issues with the fact that the east side of Big Ranch Road will remain agricultural land. There are many times a year when agricultural equipment and tractors for use in the vineyards and vineyard workers use the roads. This creates slow moving traffic and increased traffic besides the high school and Garﬁeld Little League Park, never mind the increased traffic from the rezoning.

The high school students will greatly increase the use of Trower to Big Ranch Road to commute to school, school activities and events. There are NO bike lanes. They ride 2 feet from speeding cars.

This increases the chances of accidents. In conjunction with the students, the teachers and families of students will increase their use of Big Ranch plus the new traffic from the rezoned construction of 8-18 homes per acre vs one. That equates to over 1000 plus homes and 2000 plus vehicles, usually at least 2 per home. Not to mention some of the acres may include low income housing, meaning apartments, condos, townhouses with maybe many hundreds more vehicles.

The actual construction will severely restrict traffic for at least a year or two with heavy construction vehicles, workers, and supplies traversing over narrow 2 lane roads. Again, increasing traffic, increasing road deterioration, resident frustration and accidents for a year or two.

How can a CEQA analysis have been adequately analyzed when this plan is completely new with the annexation? How can it can just be skipped because Staff or Planning Commission say so.

There is so much more involved that cannot have been considered but they think it has been adequately analyzed?
I again, restate that unless each member of the planning Commission, Staff and the City Council have driven the roads involved, a vote simply cannot be taken.

This annexation and rezoning absolutely needs to be reconsidered!! Deborah Staats , Napa, 94558,

From: Ruthie Gardner
To: Clerk
Subject: Annexation of property on Big Ranch Rd.

Date: Monday, November 11, 2024 3:10:50 PM
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[EXTERNAL]
I want to express my concern for this project. Big Ranch Rd. has already become a main thoroughfare for traffic. I can’t imagine the congestion it will cause if this development is approved. Between 3:00 and 4:00pm it is backed up from Trancas
to Rosewood. That’s where I live. And then there is the environmental and safety concerns.

Thank you,
Ruth Gardner
Resident of Garfield Lane
Sent from my iPad

From: olive Lopez
To: Clerk
Subject: Yes I am opposed to the development on Big Ranch Road!!Pleasedo not let this happen!!!The traffic and safety of our community is so special and this will ruin our community.

Date: Tuesday, November 19, 2024 11:43:36 AM
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[EXTERNAL]
Olive lopez
Sent from my iPhone

From: Pamela Condos
To: Clerk
Subject: Big Ranch Road project
Date: Tuesday, November 19, 2024 2:45:59 PM
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[EXTERNAL]
Good afternoon,
I am a resident on Old Vine Way in Napa. I understand the Big Ranch project has been approved, however I would like to strongly voice my support for a reduction in density of homes built. The impact on our area community will be multi-fold and severe. I’m sure you understand the problems a high density project would have on our area.

Visually our landscape will be jeopardized. Additionally the environmental impacts and pressure on existing infrastructure will be significant. Already is not uncommon to have traffic backed up early morning and mid day
with commuter traffic from Trancas to Garfield Lane.

We moved here, as did many others, because this part of Napa feels more rural yet is accessible to services. Please reconsider the impact a high density project will have on not only our neighborhood, but surrounding areas as well.

Thank you for your time.

Pamela Condos

From: jackie harrison
To: Clerk
Subject: Big Ranch Road
Date: Tuesday, November 19, 2024 11:17:02 AM
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[EXTERNAL]
I am seriously concerned about the potential development of 1000 houses near Big Ranch Road. There has been a huge increase in traffic over the last few years. The speed limit of 55 mph means cars race by at 65 mph. We live off Garfield and it is a nightmare to make a left or right turn. Creating more traffic throughways, increasing dense development is going to turn this small roadway into a death trap. Please limit the development density and also retain some sense of rural living in this area.

To Napa City Council Members:
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Re: Big Ranch Road Annexation/
Dear Council Members:

I am a member of the Steering Committee for Protect Big Ranch which represents a very large group of residents that oppose the annexation.

We understand that the Big Ranch Road annexation of multiple parcels of land into the City limits is scheduled for inclusion on the Agenda for the December 3, 2024 City Council Meeting.

As you are aware our District 1 Council representative, Liz Alessio, is leaving her position and December 3, 2024 would be her last City Council meeting if she were in attendance. We do not feel we have proper representation in District 1 at this time and are requesting that this agenda item be postponed into 2025 when a new District 1 representative is in place and has had time to review the proposed annexation. In that we have been told that there presently is no project in the works for the parcels involved, a reasonable delay in considering this issue should be of no hardship to the applicants.

Please confirm receipt of this letter and confirmation of the postponement of this agenda item.

Jacqueline Wessel
Napa, CA 94558

From: Molly Silcox
To: Scott Sedgley; Liz Alessio; Clerk; Beth Painter; Mary Luros; Bernie Narvaez; Steve Potter Subject: Postpone 12/3/24 Big Ranch Annexation hearing
Date: Friday, November 22, 2024 1:26:39 PM
You don't often get email from . Learn why this is important [EXTERNAL]
To Napa City Council Members:

[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]

Re: Big Ranch Road Annexation/

Dear Council Members:

I am a member of the Steering Committee for Protect Big Ranch which represents a very large group of residents that oppose the annexation.

We understand that the Big Ranch Road annexation of multiple parcels of land into the City limits is scheduled for inclusion on the Agenda for the December 3, 2024 City Council Meeting.

In that we have been told that there presently is no project in the works for the parcels involved, a reasonable delay in considering this issue should be of no hardship to the applicants.

Please confirm receipt of this letter and confirmation of the postponement of this agenda
item.

Mary (Molly) Silcox
Napa CA 94558
Sent from my iPhone

From: Lori Van Winden
To: Clerk; Scott Sedgley; Liz Alessio; Beth Painter; Mary Luros; Bernie Narvaez Subject: Big Ranch Road Annexation Proposal
Date: Monday, November 25, 2024 2:07:17 PM
[EXTERNAL]
November 25, 2024
To Napa City Council Members
Re:

Proposed Big Ranch Rd. Annexation
Dear Council Members:

We understand that the Big Ranch Road annexation of multiple parcels of land into the city limits is scheduled for inclusion on the agenda for the December 3, 2024 City Council Meeting.

As you are aware our District 1 Council representative, Liz Alessio, is leaving her position and December 3, 2024 would be her last City Council meeting if she were in attendance.

We do not feel we have proper
representation in District 1 at this time and are requesting that this agenda item be postponed into 2025 when a new District 1 representative is in place and has had time to review the proposed annexation.

In that we have been
told that there presently is no project in the works for the parcels involved, a reasonable delay in considering this issue should be of no hardship to the applicants.

Please confirm receipt of this letter and confirmation of the postponement of this agenda item.

Thank you,
Ardy and Lori Van Winden
.

Baiser de Dieu Vineyard
Napa, CA

From: Richard Drury
To: Michael Allen; Steve Potter; [email protected]; Clerk Subject: Big Ranch Road Annexation. Dec. 3, 2024 Agenda Item 13A.

Date: Friday, November 29, 2024 1:54:01 PM
Attachments: 2024.11.29.Big Ranch ComLtr w exhibits.pdf You don't often get email from [email protected]. Learn why this is important [EXTERNAL]
File No. PL23-0143 BIG RANCH ROAD ANNEXATION
City Council Agenda Item 13.A. (Dec. 3, 2024)
Dear Mayor Sedgley and Honorable Members of the City Council:

I am writing on behalf of Protect Big Ranch (“PBR”), a California non-profit unincorporated association composed of residents living in and around the City of Napa (“City”). We are writing concerning the proposed annexation of 51.5 acres of land into the City boundaries in the Big Ranch Road area for the purpose of allowing the construction of up to 927 units of housing (“Project”). While PBR supports construction of housing at a sustainable density in the area, PBR urges the City to conduct environmental review under the California Environmental Quality Act (“CEQA”) prior to approving the annexation proposal. This will ensure that the annexation’s environmental impacts are adequately analyzed, disclosed to the public, and mitigated to the extent feasible.

Our detailed comments are attached
hereto. Thank you for considering our comments.

Richard Drury
Counsel for Protect Big Ranch
--
Richard Drury
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
(510) 836-4200
[email protected]

BY E-MAIL AND OVERNIGHT MAIL

November 29, 2024

VIA EMAIL

Mayor Scott Sedgley, and
Honorable City Council Members
City of Napa
ATTN: City Clerk
955 School Street
Napa, CA 94559
[email protected]
Michael Allen, Senior Planner
City of Napa
Planning Division
1600 First Street
Napa, CA 94559
[email protected]
[email protected]
[email protected]

Re: File No. PL23-0143 BIG RANCH ROAD ANNEXATION
City Council Agenda Item 13.A. (Dec. 3, 2024)

Dear Mayor Sedgley and Honorable Members of the City Council:

I am writing on behalf of Protect Big Ranch (“PBR”), a California non-profit unincorporated association composed of residents living in and around the City of Napa (“City”).

We are writing concerning the proposed annexation of 51.5 acres of land into the City boundaries in the Big Ranch Road area for the purpose of allowing the construction of up to 927 units of housing (“Project”). While PBR supports construction of housing at a sustainable density in the area, PBR urges the City to conduct environmental review under the California Environmental Quality Act (“CEQA”) prior to approving the annexation proposal. This will ensure that the annexation’s environmental impacts are adequately analyzed, disclosed to the public, and mitigated to the extent feasible.

The City contends that CEQA review is not required for three reasons: 1) the annexation itself will not have environmental impacts because it merely moves lines on the map; 2) the annexation is exempt from CEQA pursuant to CEQA section 21083.3 and CEQA guidelines section 15183 because the action was alleged studies in the EIR for the 2040 General Plan Update (“GPU EIR”); and 3) supplemental environmental review is not required under the terms of CEQA Guidelines section 15168 for the same reasons. As discussed below, none of these arguments have merit. The courts have long held that annexation requires CEQA review to analyze the impacts of development that is likely to follow the annexation.

Also, the annexation will have significant impacts that were not analyzed in the GPU EIR, which must be analyzed in a supplemental CEQA document. Wildlife ecologist Dr. Shawn Smallwood conducted a site inspection of the Project site on October 30, 2024. Dr. Smallwood identified a plethora of special status species on the Project site, including American kestrel,

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Nuttal’s woodpecker, oak titmouse and many others. He noted the detection of river otters and great horned owls. Dr. Smallwood identified valuable oak woodlands habitat, a riparian corridor and a likely wetland area. None of these species or habitats were discussed in the GPU EIR. These species and habitats will all be adversely affected by the proposed Project. CEQA review is required to analyzed and mitigate these impacts. Dr. Smallwood’s comments are attached hereto as Exhibit A.

Atmospheric scientist Dr. James Clark concludes that the Project will have significant air quality impacts during both construction and operation. This air pollution will impact the adjacent Vintage High School and residential neighborhood. The GP EIR did not analyze these impacts because it assumed the construction of only 340 units on the Project site. (General Plan p. 2-20).

The proposed Project would allow the construction of almost threes times that number of units. Dr.

Clark’ comments are attached hereto as Exhibit B.

PBR respectfully requests that the City Council continue its decision to proceed with the annexation process until it prepares an environmental impact report (“EIR”) to analyze and mitigate the Project’s impacts.

I. REQUEST FOR CONTINUANCE

PBR requests a continuance of the December 3, 2024 city council meeting. The Big Ranch area is within City Council District One. The Napa City Council Member for District One, Liz Alessio, was recently elected to the Napa County Board of Supervisors, and has not been replaced.

While December 3 will be Councilmember Alessio’s final meeting, she has expressed a preference to allow her replacement to vote on this matter. PBR believes that it is inappropriate to take action on a major annexation when the area proposed to be annexed lacks adequate representation on the City Council. We therefore urge the City Council to continue this matter until after a replacement City Council member has been selected for District One.

II. PROJECT DESCRIPTION

The City is considering an application for a Zoning Amendment to amend the existing prezoning designation of Single Family Residential for approximately 66 acres of land adjacent to the City’s northeastern border and Annexation of approximately 51.5 acres of said land into the City boundaries in the Big Ranch Road area. The Applicant seeks to change the zoning to Medium Density Residential (8 to 18 units per acre), which would allow development of up to 927 units of housing on the 51.5 acres proposed for annexation. Under current zoning, the subject parcels are designated Residential Country (RC), which allows one dwelling unit per parcel.

The Applicant requests the annexation of the six properties at 2275, 2285, 2305, 2331 Big Ranch Road, 1130 Trower Avenue (only the portion within the City’s RUL and south of the future Trower Avenue Extension) and 1438 Rosewood Lane. To facilitate the annexation, the Applicant also requests a Zoning Ordinance Amendment establishing a Master Plan (MP) Zone District and pre-zoning approximately 66 acres (comprised of the six parcels currently seeking annexation and six additional parcels within the City’s RUL and SOI not currently seeking annexation) to the MP District.

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The subject area is located at the northeastern corner of the City of Napa within the Rural Urban Limit (“RUL”), on the west side of Big Ranch Road. The subject parcels currently contain low density single family residential units, limited agricultural uses, and vacant/undeveloped land.

The parcels are entirely within the City’s Sphere of Influence (“SOI”) and are adjacent to the existing City limits along a majority of the south and west sides of the annexation area. For more than 30 years, these parcels have been pre-zoned with a Single-Family Residential zoning designation with varied minimum lot sizes from 5,000 square feet to 20,000 square feet (RS-5, RS- 7, RS-10 & RS-20). Properties that have been pre-zoned means they have been given a zoning designation in advance of their annexation into the City limits. Only properties that are within the City’s RUL and SOI which are expected to one day annex to the City are provided pre-zoning designations. The City proposes to annex the parcels using the island annexation process, which avoids the need to allow a vote of the parcels proposed for annexation. 1

III. LEGAL STANDARD

The EIR is the very heart of CEQA. Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927 (Pocket Protectors). The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” Bakersfield Citizens, 124 Cal.App.4th at 1220. The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392. The EIR process “protects not only the environment but also informed self-government.” Pocket Protectors, 124 Cal.App.4th at 927.

Here, the City contends that no EIR is necessary pursuant to CEQA Guidelines section 15168(c)(2) because the Project is within the scope of activities analyzed in the GPU EIR and will not result in any new significant impacts. (Planning. Comm. Staff Rept. Attach. 3, p.7 (Sept. 19, 2024)). However, CEQA section 15162 of the CEQA Guidelines requires a subsequent EIR when:

(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was

1 The island annexation process does not seem to apply since the annexed property is not an “island” since it is not surrounded on all sides by the City of Napa. Also, the annexation would create two new unincorporated islands, in violation of Government Code section 56744.

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certified as complete or the negative declaration was adopted, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
(B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would, in fact, be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
(D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

(14 CCR § 15162). Since that there have been substantial changes to the Project and Project circumstances, and new information of substantial importance has come out since the certification of the GPU EIR, a subsequent EIR must be prepared.

The City also relies on CEQA section 15183 to claim that the Project is exempt from CEQA review. CEQA identifies certain classes of projects which are exempt from the provisions of CEQA. These are called categorical exemptions. 14 CCR §§ 15300, 15354. “Exemptions to CEQA are narrowly construed and ‘[e]xemption categories are not to be expanded beyond the reasonable scope of their statutory language.” Mountain Lion Foundation v. Fish & Game Com. (1997) 16 Cal.4th 105, 125. The determination as to the appropriate scope of a categorical exemption is a question of law subject to independent, or de novo, review. San Lorenzo Valley Community Advocates for Responsible Education v. San Lorenzo Valley Unified School Dist., (2006) 139 Cal. App. 4th 1356, 1375 (“[Q]uestions of interpretation or application of the requirements of CEQA are matters of law. Thus, for example, interpreting the scope of a CEQA exemption presents ‘a question of law, subject to de novo review by this court.’”)

Here, the City contends that the proposed Project is exempt from CEQA review under Section 15183. Section 15183 of the CEQA Guidelines allows a project to avoid environmental review if it is:

“consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified . . . except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site.” 14 CCR 15183 (emphasis added).

The intention of this section is to “streamline” CEQA review for projects and avoid the preparation of repetitive documents. While this section is considered an exemption from CEQA, environmental review is still required for various types of impacts, including those “peculiar to the project or parcel on which the project would be located,” those which “were not analyzed as significant effects in a prior EIR,” “are potentially significant off-site impacts and cumulative Big Ranch Road Annexation
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impacts which were not discussed in the prior EIR,” or “[a]re previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.” Section (f) of the exemption states that a Project’s environmental effects are not peculiar to a project if “uniformly applied development policies or standards have been previously adopted” which serve to mitigate environmental impacts, “unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect.” (Emphasis added).

Here, there is substantial evidence demonstrating that the Project will have significant impacts which were not addressed in GPU EIR. The Section 15183 Exemption therefore does not apply, and the City must prepare appropriate CEQA documents for this Project.

IV. DISCUSSION

A. The Annexation is a CEQA “Project.”

The City contends that the annexation does not require CEQA review because there is “no development proposed at this time.” (Plan. Comm. Staff Rpt. p. 4). However, the City’s position ignores the fact that the parcels currently have “no development potential,” and after annexation, the parcels would be zoned to allow between 8-18 units per acre. (Id.) Thus, annexation will allow construction of up to 927 units on the 51.5 acres. Since the annexation is a discretionary action that may lead to a reasonably foreseeable environmental impact – namely, the development of 927 units of housing – CEQA review is required.

Under CEQA, a “project” is “the whole of an action” directly undertaken, supported, or authorized by a public agency “which may cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.” (PRC § 21065; 14 Cal. Code Regs. § 15378(a) [“CCR”].) CEQA requires environmental factors to be considered at the “earliest possible stage . . . before [the project] gains irreversible momentum,” (Bozung v. Loc. Agency Formation Com. (1975) 13 Cal. 3d 263, 284), “at a point in the planning process where genuine flexibility remains.” (Sundstrom v. Mendocino County (1988) 202 Cal.App.3d 296, 307.) Under CEQA, a “project” includes “an essential step leading to ultimate environmental impact.” (Kaufman & Broad-South Bay, Inc. v. Morgan Hill (1992) 9 Cal.App.4th 464, 473.) “Agency action is not exempt from CEQA simply because it will not have an immediate or direct effect on the environment. CEQA applies if it is reasonably foreseeable that environmental impacts will ultimately result.” (Kostka & Zischke, Practice Under the California Environmental Quality Act (CEB), § 4.20, citing Bozung v. LAFCO (1975) 13 Cal.3d 263, 277.) “If an agency’s action is a necessary step that starts in motion a chain of events that will foreseeably result in impacts to the physical environment, the activity must be treated as a project subject to CEQA.” (Id.; see also Friends of Mammoth v. Board of Supervisors of Mono County (1972) 8 Cal.3d 247, 265 (holding that the term “project” includes not only activities directly involving actual physical impacts on the environment, but also activities, such as the approval of permits, whose environmental effects are indirect).)

This case is very similar to the Supreme Court case of Bozung v. LAFCO, supra. In Bozung, the city proposed to annex a parcel of property and argued that CEQA review would be Big Ranch Road Annexation
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premature because it was unknown what development would occur on the parcel after annexation.

The Supreme Court roundly rejected this position, stating:

This is not the case of a rancher who feels that his cattle would chew their cuds more contentedly in an incorporated pasture. No one makes any bones about the fact that the impetus for the Bell Ranch annexation is Kaiser’s desire to subdivide 677 acres of agricultural land, a project apparently destined to go nowhere in the near future as long as the ranch remains under county jurisdiction. The city’s and Kaiser’s application to LAFCO shows that this agricultural land is proposed to be used for “residential, commercial and recreational” purposes. … “Urban growth will take place in designated areas and only within the annexation.”

(Bozung, 13 Cal. 3d. at 281). Thus, the Court required the city to analyze the likely impacts of the annexation, and propose feasible mitigation measures.

Similarly, in this case, there is no question that the annexation is proposed for the sole purpose of allowing development of up to 927 residential units, which cannot be developed without the annexation. The potential impacts of that annexation must be analyzed now, before this irreversible action is taken.

The City suggests that CEQA review may be conducted at a later time when a Master Plan is proposed. However, by that time, the irreversible action to annex the parcel will have been completed. Also, given the plethora of recent housing laws exempting many residential projects from CEQA review (e.g. SB 35, SB 423), future proposals may or may not be subject to CEQA review. For these reasons, CEQA review is required before the City decides whether or not to proceed with the annexation.

B. The City May Not Rely on the GPU EIR Because the Proposed Project is not Consistent with the Density and Zoning Analyzed in the GPU EIR.

The City may only rely on the Section 15183 Exemption if the proposed project is “consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified.” 14 CCR 15183(a) (emphasis added).

Section 15183 states,

This section shall apply only to projects which meet the following conditions:
(1) The project is consistent with:
(A) A community plan adopted as part of a general plan, (B) A zoning action which zoned or designated the parcel on which the project would be located to accommodate a particular density of development, or (C) A general plan of a local agency

(Section 15183(d)).

Although the GPU EIR mentions that the Big Ranch parcel will be zoned for medium density residential, the GPU EIR only analyzed the parcel assuming 340 units of residential development. (Napa 2040 General Plan, p. 2-20). The proposed Project, allowing 927 units of Big Ranch Road Annexation
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development is therefore inconsistent with the density and zoning analyzed in the GPU EIR. As such, the City may not rely on the GPU EIR and the 15183 CEQA exemption. Nor can the City rely on 15162 or 15168(c)(2) because the density and zoning may have impacts that were not subject to any analysis in the GPU EIR, and therefore subsequent CEQA review is required. (Save Our Access v. City of San Diego (2023) 92 Cal. App. 5th 819).

The General Plan assumed that the Big Ranch Road parcel would only accommodate 340 residential units. (Napa 2040 General Plan, p. 2-20). The City now proposes to allow construction of up to 927 residential units on the Parcel. This level of development was not analyzed in the GPU EIR. This situation is much like in the Save Our Access case, supra. In that case, the specific plan EIR analyzed buildings of up to 30-feet in height. When the City proposed to allow buildings to exceed that height limit, supplemental CEQA review was required because this level of development was not previously analyzed.

C. The CEQA Review is Required Because the Proposed Project will have Significant Offsite Air Quality Impacts.

Dr. James Clark concludes that the Project will have significant adverse air quality impacts above CEQA significance thresholds. Dr. Clark concludes that the Project’s air pollution will impact the adjacent Vintage High School and nearby residences. (Ex. B, p. 2). Dr. Clark applies the air quality screening thresholds adopted by the Bay Area Air Quality Management District (“BAAQMD”). Based on the new zoning criteria, the Project will have between 8 and 18 units of housing per acre. This is between 412 and 927 units. Under the BAAQMD thresholds, a residential project at the low end, with 412 units would have significant nitrogen oxide (NOx) operational emissions (325 du), significant greenhouse gas operational emissions (56 du), and significant reactive organic gases (ROGs) construction emissions (114 du). (Ex. B, p. 4). Dr. Clark concludes that under new 2022 CEQA guidance from the BAAQMD, the Project exceeds screening thresholds for construction and operational air pollution, requiring further analysis. (Ex.

B., pp. 5-6).

Dr. Clark notes that these pollutants present serious human health impacts. “The excess NOx emissions would impact visibility in the area (NOx reacts with other chemicals in the air to form both particulate matter and ozone) as well as aggravating respiratory diseases (in particular asthma leading to respiratory symptoms, increase hospital admissions and visits to the ER.

Reactive Organic Gases (ROGs) are a class of volatile organic compounds listed by the California Air Resources Board (CARB) which are important in the formation of ground level ozone.” (Id.)

These impacts were not analyzed in the GPU EIR, which assumed development of only 340 units of housing on the Project site. Also, the GPU EIR stated that because the 2040 General Plan development would exceed some of BAAQMD’s significance thresholds, the General Plan’s impact on the cumulatively considerable increase in criteria pollutants for which the region is in nonattainment is significant and unavoidable. (Ex B, p. 3; GPU DEIR pp. 3.2-31, 3.2-37, 3.2-41).

The GPU EIR clearly states that it is a program-level document, and as such, it does not analyze project-level air quality impacts. The EIR states:

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The Project is programmatic and does not propose any specific development projects.

Rather, construction of development would occur incrementally throughout a 20-year time period. As the timing and intensity of future development projects is not known at this time, the precise effects of construction activities associated with buildout of the Planning Area cannot be accurately quantified at this time. (GPU DEIR, p. 3.2-38).

Future development would be subject to individual review; new sources would be evaluated through the BAAQMD permit process and/or the CEQA process to identify and mitigate any significant exposures. (GPU DEIR, p. 3.2-45).

Despite admitting that the GPU EIR did not analyze project-level impacts, and that further CEQA review would be required, the City now attempts to avoid the promised project-level review.

Under Section 15168 (and CEQA section 21166), supplemental CEQA review is required to analyze the Project’s air quality impacts. The GPU EIR clearly states that these impacts were not analyzed and were not knowable at the time. Now expert evidence demonstrates that the Project will have significant impacts that must be analyzed and mitigated.

Under section 15183, review is also requited because the Project will have significant offsite air quality impacts. Section 15183(j) states:

This section does not affect any requirement to analyze potentially significant offsite or cumulative impacts if those impacts were not adequately discussed in the prior EIR. If a significant offsite or cumulative impact was adequately discussed in the prior EIR, then this section may be used as a basis for excluding further analysis of that offsite or cumulative impact.

(14 CCR 15183(j); PRC § 21083.3(c) [emph. added].) The use of the term “potentially significant” impact triggers application of the fair argument standard. (Berkeley Hillside Pres. v. City of Berkeley (2015) 60 Cal.4th 1086, 1115; No Oil v. City of Los Angeles (1975) 13 Cal. 3d 68, 85 [fair argument standard applies when a project “[a]rguably will have an adverse environmental impact.”].)

Dr. Clark’s comments constitute substantial evidence creating a fair argument that the Project will have significant offsite impacts not analyzed in the GPU EIR. Supplemental CEQA review is therefore required.

D. The CEQA Review is Required Because the Proposed Project will have Significant Offsite Traffic Impacts.

The annexation will allow the construction of 927 units of housing on Big Ranch Road.

Big Ranch Road is a narrow, two-lane road, without shoulders. The road is often overloaded with traffic, particularly when Vintage High School’s day starts of ends. Adding 927 units of housing to this road will exacerbate existing traffic delays and possibly create evacuation hazards.

While the GPU EIR analyzed traffic impacts for the entire city, it assumed that only 340 units of housing would be developed on the Big Ranch parcels. The GPU EIR states that for Big Ranch Road Annexation
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residential projects, “A proposed project exceeding a level of 15 percent below existing VMT [vehicle miles travelled] per capita may indicate a significant transportation impact.” (GPU DEIR, p. 3.15-4). The City’s Consistency Analysis states, “the Project would not result in any new or more significant impacts related to emergency access than were previously analyzed and described in the General Plan Update EIR.” (Consistency Analysis, p. 46). This is incorrect since the GPU EIR assumed only 340 housing units, while the annexation will allow construction of 927 units.

The City must evaluate the proposed project’s VMT that has nearly 3 times more units than what was analyzed in the GPU EIR. It is highly unlikely that the additional units would be at the lower rate of VMT than was determined for the entire city. To reach the conclusion of no significant VMT impact, the expanded project would typically be limited to 15% less than the City-wide average. To meet that target, the expanded project would need to include ride-sharing, excellent access to transit, and similar measures like walking and biking that should also be monitored to make sure that the reduced limits would not be exceeded.

To address emergency access issue, the City’s Consistency Analysis states, “the General Plan includes Goal TE-9 to ensure that there are safe evacuation routes in case of emergencies and natural disasters. Therefore, the General Plan Update EIR concluded that the impacts would be less than significant.” However, requiring the develop of safe evacuation routes is a goal, not a mitigation measure. A CEQA document must describe the mitigation measures and demonstrate that these measures will be sufficient to achieve the goal. Simply establishing a goal without more is mere wishful thinking. The courts have routinely rejected such deferred mitigation.

“Deferral of the specifics of mitigation is permissible where the local entity commits itself to mitigation and lists the alternatives to be considered, analyzed and possibly incorporated in the mitigation plan. [Citation.] On the other hand, an agency goes too far when it simply requires a project applicant to obtain a biological [or other] report and then comply with any recommendations that [*88] may be made in the report.” (Defend the Bay v. City of Irvine (2004) 119 Cal.App.4th 1261, 1275.) “A study conducted after approval of a project will inevitably have a diminished influence on decisionmaking. Even if the study is subject to administrative approval, it is analogous to the sort of post hoc rationalization of agency actions that has been repeatedly condemned in decisions construing CEQA.” (Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 307.) “[R]eliance on tentative plans for future mitigation after completion of the CEQA process significantly undermines CEQA's goals of full disclosure and informed decisionmaking; and[,] consequently, these mitigation plans have been overturned on judicial review as constituting improper deferral of environmental assessment.” (Communities for a Better Environment v. City of Richmond (2010) 184 Cal.App.4th 70, 92.)

In the CBE v. Richmond case, the court rejected a mitigation measure that required the Chevron Richmond refinery to meet a “net-zero” greenhouse gas goal, without specifying any measures capable of meeting that goal. The court held that an EIR was necessary to describe the specific mitigation measures that would be implemented and to demonstrate that those measures would be sufficient to meet the net zero goal. Similarly, in this case, the City cannot simply point to a goal of “safe evacuation routes” without more. The City must specify how it will create evacuation routes, and demonstrate that those routes will be sufficient to safely evacuate the additional 927 residential units.

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E. CEQA Review is Required Because the Project Will have Significant Biological Impacts.

Dr. Smallwood conducted a site inspection of the subject property on October 30, 2024. (Ex. A). Dr. Smallwood documented a lush habitat and many species of wildlife, most of which are ignored in the GPU EIR. Dr. Smallwood documented oak woodland habitat on the west site of the site, as well as a riparian corridor stream bed. (Ex. A., p. 1). He identified numerous special status species. Dr. Smallwood writes:

I saw Cooper’s hawk and American kestrel (Photos 5 and 6), Nuttall’s woodpecker and oak titmouse (Photos 7 and 8), Anna’s hummingbird and Bewick’s wren (Photos 9 and 10), California towhee and black phoebe (Photos 11 and 12), California quail and California scrub-jay (Photos 13 and 14), Ruby-crowned kinglet and western bluebirds (Photos 15-17), Fox sparrow and dark-eyed junco (Photos 18 and 19), golden-crowned sparrow and yellow- rumped warbler (Photos 20 and 21), downy woodpecker and white-crowned sparrow (Photos 22 and 23), house sparrows (Photos 24 and 25), California ground squirrels and red-winged blackbirds (Photos 26 and 27), house finch and American goldfinch (Photos 28 and 29), Lincoln’s sparrow and northern mockingbird (Photos 30 and 31), among other species listed in Table 1). In all, I detected the presence of 45 species of vertebrate wildlife including five special-status species during my brief survey. In addition to these species, I am aware of the presence of river otter, great horned owls and barn owls based on evidence provided by local residents. (Ex. A. p. 2).

At least two of these species are listed as birds of conservation concern by the US Fish and Wildlife Service, recognizing their rare status. (Ex. A, p. 5). Dr. Smallwood also identified a suspected wetland area on the Project site near the creek. (Ex. A. p. 21).

The GPU EIR failed to identify these habitat areas and special status species. The GPU EIR fails entirely to identify the wetland area on the Project site. As Dr. Smallwood states:

The Initial Study concludes, “No wetlands are known to exist within the Project Site, as the majority of wetlands occur within the southern portion of the City, while the Project Site is located along the City’s northern boundary.” However, this conclusion looks like it is supported by an assumption rather than by due diligence. According to Google Earth imagery, there is a stream channel that traverses the western edge of the project site, and there is also a pond or marsh on the hayfield on the north side of the project (Figure 3). The marsh might be used as a dumping ground for vineyard waste at the moment, but the imagery clearly shows a wet depression (Figure 4). There is also evidence of flows across areas that without the flows would be used as vineyard (see Photo 4 and Figure 3). Without a proper survey by a qualified wetlands ecologist, it would be reckless to move this project forward based solely on the unrealistic assumption that wetlands only occur in south Napa.

The General Plan Update PRDEIR includes no report of wetlands surveys on the project site. (Ex. A. p. 31).

The GPU EIR also failed to identify oak woodlands and oak savannah on the Project site. (Ex. A. p. 21; GPU DEIR p. 2.2-50). Dr. Smallwood notes that the GPU EIR states:

Big Ranch Road Annexation
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Page 11 of 13 ends

“Valley foothill riparian and sensitive oak woodland (blue oak, coast live oak, and valley oak) communities in the study area are primarily in parks or previously developed areas that would not be affected by General Plan update land use change.” In fact, these communities occur on the project site, which the PRDEIR depicts as vineyard. The vegetation cover map of the PRDEIR shows no sign of the oak woodland/oak savannah that occurs on the project site. (Ex. A. p. 21).

Dr. Smallwood notes that none of the five special status species he positively identified on the Project site are discussed at all in the GPU EIR, and 75% of the species that Dr. Smallwood concludes are likely to occur on the Project site are ignored in the GPU EIR. (Ex A. p.22).

Under Section 15168 (CEQA section 21166), Dr. Smallwood’s comments constitute significant new information of environmental impacts that were not known and not analyzed in the GPU EIR. As such, project-level CEQA review is required. The Court of Appeal has held that under Section 21166, supplemental CEQA review is required when a special status species or wetland are identified on the project site, which were not discussed in the prior EIR. (Mira Monte Homeowners Assn. v. Cnty. of Ventura (1985) 165 Cal. App. 3d 357, 365.)

Under Section 15183, project-level CEQA review is required because the presence of oak woodlands, wetland area, and special status species are a “peculiar impact” of the Project that has not been analyzed in the GPU EIR. While section 15183 limits the scope of analysis, additional environmental review is still required for “effects on the environment which are peculiar to the parcel or to the project” and effects “which were not addressed as significant effects in the prior [EIR].” (PRC § 21083.3(a).) “Peculiar” impacts are “project-specific effects,” not strange or unusual impacts. (Hilltop Group v. Co. of San Diego (2024) 99 Cal.App.5th 890, 917.) Even for effects found to be significant in the prior community plan or zoning EIR, § 21083.3 requires further environmental analysis where there is substantial new information that the impacts of the Project will be more significant than previously addressed in the community plan or zoning EIR. (Id.) Since the biological impacts identified by Dr. Smallwood were not analyzed in the GPU EIR, project-level CEQA review is required.

Whether Section 15183 applies to a particular project’s environmental review is subject to a fair argument standard of review. (Wal-Mart Stores v. City of Turlock (2006) 138 Cal.App.4th 273, 288, disapproved on other grounds, Hernandez v. City of Hanford (2007) 41 Cal.4th 279 [assuming, without deciding, that the fair argument applied to reviewing applicability of § 21083.3]; see also Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1373, 1406, fn. 24.) While the recent case of Hilltop Group v. Co. of San Diego (2024) 99 Cal.App.5th 890, 927 held that the substantial evidence standard applies to the scope of the section 15183 exemption, it did not reverse the Walmart case as to the standard of review for peculiar impacts. Accordingly, the Project cannot be considered covered by the GPU EIR if the record contains “a fair argument regarding the existence of a reasonably foreseeable project-specific significant change in the environment that is peculiar to the [Project] or its site.” (Wal-Mart Stores, 138 Cal.App.4th 273 at 288 [citing 14 CCR § 15183(a)].)

Dr. Smallwood’s comments constitute substantial evidence creating a fair argument that the Project will have adverse impacts on several special status species, a wetland area and oak Big Ranch Road Annexation
November 29, 2024

Page 12 of 13 ends

woodlands. None of these impacts were analyzed in the GPU EIR. Therefore, project-level CEQA review is required.

F. Subsequent CEQA Review is Required for Impacts not Mitigated to Less Than Significant in the GPU EIR.

The GPU EIR concluded that several of the impacts identified as a result of the General Plan Update project were significant and unavoidable. These impacts included air quality (GPU EIR p. ES-6), greenhouse gas (Id. at ES-8). These impacts could not be analyzed and mitigated in the SPU EIR because it was a program-level document, and the nature of specific projects was as yet unknown. The GPU EIR stated:

As authorized under CEQA Guidelines Section 15146, the General Plan update’s impacts are analyzed on a general scale, in keeping with the broad level of detail found in the General Plan itself. (GPU DEIR ES-1).

Typically, because not all the components of the program are known in detail, the program EIR will not be detailed enough to analyze all aspects of the later activities. If the later proposal would have effects that were not analyzed in the program EIR or is an activity not included in the program EIR, either a new EIR or a new negative declaration would be prepared to analyze that project. (GPU DEIR 1-2).

The General Plan update is a broad statement of policies not proposing any specific development project. Accordingly, this Draft EIR “need not be as detailed as an EIR on … specific construction projects” (GPU DEIR 1-3).

Section 15183 states that it only applies to impacts that were “adequately discussed in the prior EIR.” (Section 15183(j).) In the case of Communities for a Better Environment v. Cal.

Resources Agency (2002) 103 Cal.App.4th 98, 122-125, the court of appeal held that when a “first tier” EIR admits a significant, unavoidable environmental impact, then the agency must prepare second tier EIRs for later projects to ensure that those unmitigated impacts are “mitigated or avoided.” Id. citing CEQA Guidelines §15152(f)). The court reasoned that the unmitigated impacts were not “adequately addressed” in the first tier EIR since they were not “mitigated or avoided.” Id. Thus, significant effects disclosed in first tier EIRs will trigger second tier EIRs unless such effects have been “adequately addressed,” in a way that ensures the effects will be “mitigated or avoided.” Id. Such a second tier EIR is required, even if the impact still cannot be fully mitigated and a statement of overriding considerations will be required. The court explained, “The requirement of a statement of overriding considerations is central to CEQA’s role as a public accountability statute; it requires public officials, in approving environmentally detrimental projects, to justify their decisions based on counterbalancing social, economic or other benefits, and to point to substantial evidence in support.” Id. at 124-125.

Thus, since the GPU EIR admitted significant, unmitigated impacts, a second tier EIR is now required to determine if mitigation measures can now be imposed to reduce or eliminate those impacts. If the impacts still remain significant and unavoidable, a statement of overriding considerations will be required.

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V. CONCLUSION
In light of the above comments, the City must prepare an EIR prior to proceeding with a vote on the Big Ranch Annexation. The draft EIR should be circulated for public review and comment in accordance with CEQA. Thank you for considering these comments.

Sincerely,
Richard Toshiyuki Drury

LOZEAU DRURY LLP

EXHIBIT A
1 Shawn Smallwood, PhD
3108 Finch Street
Davis, CA 95616

Michael Allen, Senior Planner
Community Development Department – Planning Division
1600 First Street + P.O. Box 660
Napa, CA 94559-0660 20 November 2024

RE: Big Ranch Road Annexation

Dear Mr. Allen,

I write to comment on potentially significant impacts to biological resources that could result from the proposed zoning amendment to annex to the City of Napa 51.5 acres of a 66-acre parcel west of Big Ranch Road. I comment specifically on a 19 September 2024 Planning Commission Staff Report, which recommends that the City Council determines the potential environmental effects from the proposed zoning amendment were adequately analyzed in City of Napa’s General Plan Update FEIR. I also comment on an Initial Study of the zoning amendment and the General Plan and its EIR and PDEIR.

My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a post- graduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I’ve lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached.

VISIT TO THE PROJECT SITE

I visited the site of the proposed zoning amendment for 3.83 hours from 07:36 to 11:26 hours on 30 October 2024. I surveyed from the west end of a driveway that extended onto the property from Big Ranch Road. I scanned for wildlife with use of binoculars. I recorded all species of vertebrate wildlife I detected, including those whose members flew overhead or were seen nearby. Animals of uncertain species identity were either omitted or, if possible, recorded to the Genus or higher taxonomic level.

Conditions were scattered clouds, no wind, and 44° to 58° F. The west side of the site was oak woodland with stands of blackberries inclusive of a stream bed and surrounded be vineyards, a hay field and a few homes with ornamental trees and shrubs (Photos 1 through 4).
2 I saw Cooper’s hawk and American kestrel (Photos 5 and 6), Nuttall’s woodpecker and oak titmouse (Photos 7 and 8), Anna’s hummingbird and Bewick’s wren (Photos 9 and 10), California towhee and black phoebe (Photos 11 and 12), California quail and California scrub-jay (Photos 13 and 14), Ruby-crowned kinglet and western bluebirds (Photos 15-17), Fox sparrow and dark-eyed junco (Photos 18 and 19), golden-crowned sparrow and yellow-rumped warbler (Photos 20 and 21), downy woodpecker and white- crowned sparrow (Photos 22 and 23), house sparrows (Photos 24 and 25), California ground squirrels and red-winged blackbirds (Photos 26 and 27), house finch and American goldfinch (Photos 28 and 29), Lincoln’s sparrow and northern mockingbird (Photos 30 and 31), among other species listed in Table 1). In all, I detected the presence of 45 species of vertebrate wildlife including five special-status species during my brief survey. In addition to these species, I am aware of the presence of river otter, great horned owls and barn owls based on evidence provided by local residents.

Photos 1 and 2. Oak woodland and oak savannah on the project site, 30 October 2024.

3 Photos 3 and 4. Vineyard next to oak savannah (top) and hydrological erosional feature through a vineyard (bottom) on the project site, 30 October 2024.

4 Photos 5 and 6. Cooper’s hawk hunting for quail, and an American kestrel on the project site, 30 October 2024. Both of these species are protected by California’s Birds of Prey Code, and neither was analyzed for occurrence potential in the General Plan Update PRDEIR.

5 Photos 7 and 8.

Nuttall’s woodpecker
and oak titmouse on the
project site, 30 October
2024. Both species are
listed by the US Fish and
Wildlife Service as Birds
of Conservation
Concern, which are
those species with 1.

Documented or
apparent population
declines; 2. Small or
restricted populations,
or 3. Depend on
restricted or vulnerable
habitats. The General
Plan Update PRDEIR
did not analyze the
occurrence potentials of
either of these species.

6 Photos 9 and 10. Anna’s
hummingbird and
Bewick’s wren on the
project site, 30 October
2024.

7 Photos 11 and 12.

California towhee and
black phoebe on the
project site, 30 October
2024.

8 Photos 13 and 14. A flock of California quail seeking refuge and a California scrub- jay on the project site, 30 October 2024.

9 Photos 15−17. Ruby-crowned kinglet and a pair of dueling western bluebirds on the project site, 30 October 2024.

10 Photos 18 and 19. Fox
sparrow and dark-eyed
junco on the project site,
30 October 2024.

11 Photos 20 and 21. Golden-crowned sparrow and yellow-rumped warbler on the project site, 30 October 2024.

12 Photos 22 and 23.

Downy woodpecker and
white-crowned sparrow
on the project site, 30
October 2024.

13 Photos 24 and 25. Young house sparrows on the project site, 30 October 2024.

14 Photos 26 and 27. California ground squirrel and red-winged blackbirds on the project site, 30 October 2024.

15 Photos 28 and 29.

House finch and
American goldfinch on
the project site, 30
October 2024.

16 Photos 30 and 31.

Lincoln’s sparrow and
northern mockingbird in
the blackberries on the
project site, 30 October
2024.

17 Table 1. Species of wildlife I observed during 3.83 hours of survey on 30 October 2024.

Species name Scientific name Status1 Note
Canada goose Branta canadensis Overflights by flock
Mourning dove Zenaida macroura Many
California quail Callipepla californica Many, oak savannah Anna's hummingbird Calypte anna Numerous
Killdeer Charadrius vociferus calling
Turkey vulture Cathartes aura BOP Overflights
Cooper's hawk Accipiter cooperii TWL, BOP Hunted quail, sparrows Nuttall's woodpecker Dryobates nuttallii BCC Oak woodland Downy woodpecker Dryobates pubescens Oak woodland
Northern flicker Colaptes auratus Ornamental trees
American kestrel Falco sparverius BOP Hunted hayfield
Black phoebe Sayornis nigricans Multiple
Cedar waxwing Bombycilla cedrorum Ornamentals/vineyards European starling Sturnus vulgaris Non-native Vineyards Ruby-crowned kinglet Regulus calendula Oak woodland/savannah American crow Corvus brachyrhynchos Many
Common raven Corvus corax Overflight
California scrub-jay Aphelocoma californica Numerous
Northern mockingbird Mimus polyglottos Blackberries; fledglings Hermit thrush Catharus guttatus Oak woodland
American robin Turdus migratorius Vineyards
House finch Haemorphous mexicanus Oak savannah
Lesser goldfinch Spinus psaltria Oak savannah
American goldfinch Spinus tristis Blackberries on savannah Bewick's wren Thryomanes bewickii Oak woodland
White-breasted nuthatch Sitta carolinensis Oak woodland Oak titmouse Baeolophus inornatus BCC Oak woodland/savannah Bushtit Psaltriparus minimus Oak woodland/savannah
House sparrow Passer domesticus Non-native Blackberries California towhee Melozone crissalis Oak woodland/savannah Song sparrow Melospiza melodia Oak savannah
White-crowned sparrow Zonotrichia leucophrys Oak savannah Golden-crowned sparrow Zonotrichia atricapilla Blackberries Fox sparrow Passerella iliaca Blackberries
Lincoln's sparrow Melospiza lincolnii Blackberries
Dark-eyed junco Junco hyemalis All over the site
Red-winged blackbird Agelaius phoeniceus Large flocks on hayfield Brewer's blackbird Euphagus cyanocephalus Hayfield, vineyards Brown-headed cowbird Molothrus ater Oak woodland/savannah Yellow-rumped warbler Setophaga coronata All over the site Coyote Canis latrans Sign all over the site
Gray fox Urocyon cinereoargenteus Oak savannah
Botta's pocket gopher Thomomys bottae Burrows throughout 18 California vole Microtus californicus Sign in oak savannah California ground squirrel Otospermophilus beecheyi Oak savannah 1 Listed as BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, TWL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (CFG Code 3503.5),

The species of wildlife I detected at the project site comprised only a sampling of the species that were present during my survey. To demonstrate this, I fit a nonlinear regression model to the cumulative number of vertebrate species detected with time into my survey to predict the number of species that I would have detected with a longer survey or perhaps with additional biologists available to assist. The model is a logistic growth model which reaches an asymptote that corresponds with the maximum number of vertebrate wildlife species that theoretically could have been detected during the survey. In this case, the model fit to my survey data predicts 79 species of vertebrate wildlife were available to be detected during my survey, or 34 species more than the number of species I detected (Figure 1). No biologist is going to detect all of the species that are present during a reconnaissance survey, but the pattern in my data enables my estimation of the number of species I missed.

Figure 1. Actual
and predicted
relationships
between the
numbers of
vertebrate
wildlife species
detected and the
elapsed survey
time based on my
visual-scan
surveys on 30
October 2024.

The 95%
confidence
interval was
based on 18
surveys I
completed at East
Bay sites.

Unknown are the identities of species I missed, but regardless the pattern in my data indicates relatively high use of the project site compared to 18 surveys at other East Bay 0 50 100 150 200 250 300
Minutes into survey
0 10
20 30
40 50
Model prediction
r2 = 0.994, loss = 32.4
95% CI of 18 visual-
scan surveys 2019-2024
Actual count of species
Cumulative number of wildlife species detected
19 sites I have completed in recent years. My rate of detections of species at the project site exceeded the upper bound of the 95% confidence interval estimated from other surveys in the East Bay Area (Figure 1). Importantly, however, the species I did and did not detect on 30 October 2024 composed only a fraction of the species that would occur at the project site over the period of a year or longer. This is because many species are seasonal in their occurrence.

At least a year’s worth of surveys would be needed to more accurately report the number of vertebrate species that occur at the project site, but I only have the one survey.

However, by use of an analytical bridge, a modeling effort applied to a large, robust data set from a research site can predict the number of vertebrate wildlife species that likely make use of the site over the longer term. As part of my research, I completed a much larger survey effort across 167 km2 of annual grasslands of the Altamont Pass Wind Resource Area, where from 2015 through 2019 I performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods I and other consulting biologists use for surveys at proposed project sites. At each of the 46 survey stations, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours (number of surveys, as each survey lasted 1 hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least-squares, best-fit nonlinear models of the number of cumulative species detected regressed on hours of survey (number of surveys) at the station: 𝑅̂ =
1 1 𝑎⁄ +𝑏×(𝐻𝑜𝑢𝑟𝑠)𝑐 , where 𝑅̂ represented cumulative species richness detected. The coefficients of determination, r2, of the models ranged 0.88 to

1.00, with a mean of 0.97 (95% CI: 0.96, 0.98); or in other words, the models were excellent fits to the data.

I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model-predicted asymptote of species richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations of my research site. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours (Figure 2). On average I would have detected 14.8 species over my first 3.83 hours of surveys at my research site in the Altamont Pass (3.83 hours to match the 3.83 hours I surveyed at the project site), which composed 25.9% of the predicted total number of species I would detect with a much larger survey effort at the research site. Given the example illustrated in Figure 2, the 45 species I detected after 3.83 hours of survey at the project site likely represented 25.9% of the species to be detected after many more visual-scan surveys over another year or longer. With many more repeat surveys through the year, I would likely detect 45 0.259⁄ = 174 species of vertebrate wildlife at the site. Assuming my ratio of special- status to non-special-status species was to hold through the detections of all 174 predicted species, then continued surveys would eventually detect 19 special-status species of vertebrate wildlife.

Because my prediction of 174 species of vertebrate wildlife, including 19 special-status species of vertebrate wildlife, is derived from daytime visual-scan surveys, and would 20 detect few nocturnal mammals such as bats and owls, the true number of species composing the wildlife community of the site must be larger. My reconnaissance survey should serve only as a starting point toward characterization of the site’s wildlife community, but it certainly cannot alone inform of the inventory of species that use the site. More surveys are needed than my survey to inventory the project site for wildlife.

Nevertheless, the large number of species I predict at the project site is indicative of a relatively species-rich wildlife community that warrants a serious survey effort.

Figure 2. Mean (95% CI)
predicted wildlife species
richness, 𝑅̂, as a nonlinear
function of hour-long
survey increments across
46 visual-scan survey
stations across the
Altamont Pass Wind
Resource Area, Alameda
and Contra Costa
Counties, 2015‒2019. Note
that the location of the
study is largely irrelevant
to the utility of the graph
to the interpretation of
survey outcomes at the
project site. It is the
pattern in the data that is
relevant, because the
pattern is typical of the
pattern seen elsewhere.

EXISTING ENVIRONMENTAL SETTING

The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the wildlife community and any key ecological relationships and known and ongoing threats to special-status species. A reasonably accurate characterization of the environmental setting can provide the baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project site’s regional setting, is one of the CEQA’s essential analytical steps. Methods to achieve this first step typically include (1) surveys of the site for biological resources, and (2) reviews of literature, databases and local experts for documented occurrences of special-status species. In the case of the proposed project, these required steps remain incomplete.

A zoning amendment in support of land annexation to the City is an apt time to accurately characterize the existing environmental setting. The public and the City Council need to know about the wildlife community that exists on the 51.5 acres at issue. 0 20 40 60 80 100
0 10
20 30
40 50
Cumulative number of surveys (hours)
(95% CI)
21 Environmental Setting informed by Field Surveys

To the CEQA’s primary objective to disclose potential environmental impacts of a proposed project, the analysis should be informed of which biological species are known to occur at the proposed project site, which special-status species are likely to occur, as well as the limitations of the survey effort directed to the site. Analysts need this information to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.

I found no evidence that the City has had the site surveyed for plants and wildlife.

Environmental Setting informed by Desktop Review

The purpose of literature and database review and of consulting with local experts is to inform the field survey, and to augment interpretation of its outcome. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special-status species could conceivably occur at the site due to geographic range overlap and migration flight paths.

I found no evidence that the City has performed a desktop review to identify the likelihoods of occurrence of special-status species of wildlife specific to the project site.

A desktop review was completed in the General Plan Update Partial Recirculated DEIR, but only at the scale of the City’s Sphere of Influence. One of the shortfalls of this desktop review to project-specific applications can be viewed in Figure 3.3-1 of the General Plan Update PRDEIR. The shortall is visible when scrutinizing the portion of the Figure (map) that depicts vegetation cover types of the project site. The vegetation map fails to depict the oak woodland and oak savannah (Figure 3), nor does it show the potential wetlands on the project site (Figures 3 and 4). The vegetation cover map of Figure 3.3-1 is too crude and too inaccurate to be of any use to characterizing the existing environmental setting of the project site.

The erroneous vegetation cover map of the General Plan Update PRDEIR (p. 3.3-50) resulted in the unsatisfactory conclusion, “Valley foothill riparian and sensitive oak woodland (blue oak, coast live oak, and valley oak) communities in the study area are primarily in parks or previously developed areas that would not be affected by General Plan update land use change.” In fact, these communities occur on the project site, which the PRDEIR depicts as vineyard. The vegetation cover map of the PRDEIR shows no sign of the oak woodland/oak savannah that occurs on the project site.

Because the vegetation cover of the project site is inaccurate in the General Plan Update PRDEIR, so too is the PDEIR’s analyses of occurrence likelihoods of special-status species of plants and wildlife, none of which applied specifically to the project site, anyhow. Because the City has not performed a desktop review for special-status species occurrence likelihoods specific to the project site, I performed a cursory review to get a first look at which species likely occur. In my assessment based on database reviews and site visits, 125 special-status species of wildlife are known to occur near enough to the site to warrant analysis of occurrence potential (Table 2). Of these species, five were 22 recorded on the project site, and another 29 (23%) species have been documented within 1.5 miles of the site (Very close), another 28 (22%) within 1.5 and 4 miles (Nearby), and another 58 (46%) within 4 to 30 miles (In region). Half (50%) of the species in Table 2 have been reportedly seen within 4 miles of the project site. The site therefore supports multiple special-status species of wildlife, and it carries the potential for supporting many more special-status species of wildlife based on proximity of recorded occurrences. The site is far richer in special-status species than is characterized in the City’s Staff Report and Initial Study.

Of the special-status species listed in Table 2, the PRDEDIR analyzes the occurrence likelihoods of only 31 (25%) of them, even though the PRDEIR’s geographic scope of analysis was much larger than mine for the project site. The PRDEIR’s conclusions did not comport well with mine, often assigning high likelihood of occurrence to species for which I could not find occurrence records within 4 miles of the site, and too often assigning no chance for occurrence or low likelihood of occurrence to species for which I found occurrence records within 4 miles and even within 1.5 miles of the site. Of the 75% of the special-status species whose occurrence likelihoods are not analyzed in the PRDEIR, I detected five of them on the project site, and I found occurrence records of 22 of them within 1.5 miles and of 23 more within 1.5 and 4 miles of the site. The General Plan Update PRDEIR is not a reliable source for the needed desktop review of the wildlife community of the project site. A much more directed effort is needed to more accurately characterize the wildlife community of the project site.

Figure 3. Some of the details of vegetation cover on the project site that are missing from Figure 3.3-1 of the General Plan Update PRDEIR. Source: Google Earth.

Ephemeral
stream channel
Ephemeral
stream channel
Oak woodland
Blackberries
Drainage
23 Figure 4. Ponding features on the project site that are not identified in Figure 3.3-1 of the General Plan Update PRDEIR. Source: Google Earth.

Ponding
24 Table 2. Occurrence likelihoods of special-status bird species at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where “Very close” indicates within 1.5 miles of the site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles, and ‘in range’ means the species’ geographic range overlaps the site. Entries in bold font identify species I detected on site. Also included are the PRDEIR’s occurrence likelihoods of special-status species for the City of Napa’s Sphere of Influence.

Common name

Species name

Status1
PRDEIR
occurrence
likelihood
Data base
records,
Site visit
Conservancy fairy shrimp Branchinecta conservatio FE Moderate In region Vernal pool fairy shrimp Branchinecta lynchi FT Moderate In region California freshwater shrimp Syncaris pacifica FE, CE Moderate In region Monarch Danaus plexippus FC Moderate Very close
Marin Elfin butterfly Callophrys mossii marinensis SSC None In region Obscure bumble bee Bombus caliginosus SSC In region
Crotch’s bumble bee Bombus crotchii CCE In region
Western bumble bee Bombus occidentalis CCE High In range California tiger salamander Ambystoma californiense FT, CT, WL In region California giant salamander Dicamptodon ensatus SSC Moderate Nearby Red-bellied newt Taricha rivularis SSC None Nearby
Foothill yellow-legged frog Rana boylii CT, SSC Moderate In region California red-legged frog Rana draytonii FT, SSC Moderate In region Western pond turtle Emys marmorata SSC High Very close
Brant Branta bernicla SSC2 Nearby
Cackling goose (Aleutian) Branta hutchinsii leucopareia TWL Nearby Redhead Aythya americana SSC2 Nearby
Harlequin duck Histrionicus histrionicus SSC2 In region Barrow’s goldeneye Bucephala islandica SSC In region
Western grebe Aechmophorus occidentalis BCC Nearby
Clark’s grebe Aechmophorus clarkii BCC Nearby
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE In region Black swift Cypseloides niger SSC3, BCC Low In region
Vaux’s swift Chaetura vauxi SSC2 Very close
Calliope hummingbird Selasphorus calliope BCC Nearby
25 Common name

Species name

Status1
PRDEIR
occurrence
likelihood
Data base
records,
Site visit
Rufous hummingbird Selasphorus rufus BCC Very close
Allen’s hummingbird Selasphorus sasin BCC Very close
Ridgway’s rail (San Francisco Bay) Rallus obsoletus obsoletus FE, CE, CFP Moderate In region Yellow rail Coturnicops noveboracensis BCC, SSC None In region Black oystercatcher Haematopus bachmani BCC In region
Mountain plover Charadrius montanus SSC2, BCC In region Snowy plover Charadrius nivosus BCC In region
Western snowy plover Charadrius nivosus nivosus FT, SSC None In region Long-billed curlew Numenius americanus TWL Nearby
Marbled godwit Limosa fedoa BCC Nearby
Black turnstone Arenaria melanocephala BCC In region
Red knot (Pacific) Calidris canutus BCC In region
Pectoral sandpiper Calidris melanotos BCC Nearby
Short-billed dowitcher Limnodromus griseus BCC Nearby
Wandering tattler Tringa incana BCC In region
Lesser yellowlegs Tringa flavipes BCC Nearby
Willet Tringa semipalmata BCC Nearby
Laughing gull Leucophaeus atricilla TWL In region
Heermann’s gull Larus heermanni BCC In region
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, TWL Very close California least tern Sternula antillarum browni FE, CE, CFP Moderate In region Black tern Chlidonias niger SSC2, BCC In region
Elegant tern Thalasseus elegans BCC, TWL In region
Black skimmer Rynchops niger BCC, SSC3 In region
Common loon Gavia immer SSC In region
Brandt’s cormorant Urile penicillatus BCC In region
Double-crested cormorant Phalacrocorax auritus TWL Very close American white pelican Pelacanus erythrorhynchos SSC1 Very close California brown pelican Pelecanus occidentalis californicus CFP In region 26 Common name

Species name

Status1
PRDEIR
occurrence
likelihood
Data base
records,
Site visit
Least bittern Ixobrychus exilis SSC2 In region
White-faced ibis Plegadis chihi TWL In region
Turkey vulture Cathartes aura BOP On site
Osprey Pandion haliaetus TWL, BOP Very close
White-tailed kite Elanus luecurus CFP, BOP High Very close Golden eagle Aquila chrysaetos BGEPA, CFP, BOP,
TWL
Low Nearby
Northern harrier Circus cyaneus BCC, SSC3, BOP Moderate Very close Sharp-shinned hawk Accipiter striatus TWL, BOP Very close Cooper’s hawk Accipiter cooperii TWL, BOP On site
Bald eagle Haliaeetus leucocephalus CE, BGEPA, BOP Low Very close Red-shouldered hawk Buteo lineatus BOP Very close
Swainson’s hawk Buteo swainsoni CT, BOP High Very close Red-tailed hawk Buteo jamaicensis BOP Very close
Ferruginous hawk Buteo regalis TWL, BOP Nearby
Rough-legged hawk Buteo lagopus BOP In region
American barn owl Tyto furcata BOP Very close
Western screech-owl Megascops kennicotti BOP Very close Great horned owl Bubo virginianus BOP Very close
Burrowing owl Athene cunicularia BCC, SSC2, BOP, CCE Moderate In region Long-eared owl Asio otus BCC, SSC3, BOP In region
Short-eared owl Asia flammeus BCC, SSC3, BOP In region Northern saw-whet owl Aegolius acadicus BOP Nearby
Northern pygmy-owl Glaucidium gnoma BOP Very close
Lewis’s woodpecker Melanerpes lewis BCC Nearby
Nuttall’s woodpecker Picoides nuttallii BCC On site
American kestrel Falco sparverius BOP On site
Merlin Falco columbarius TWL, BOP Very close
Peregrine falcon Falco peregrinus BOP Moderate Very close Prairie falcon Falco mexicanus TWL, BOP Nearby
27 Common name

Species name

Status1
PRDEIR
occurrence
likelihood
Data base
records,
Site visit
Olive-sided flycatcher Contopus cooperi BCC, SSC2 Nearby Willow flycatcher Empidonax trailii CE Very close
Vermilion flycatcher Pyrocephalus rubinus SSC2 In region Loggerhead shrike Lanius ludovicianus SSC2 Very close
Yellow-billed magpie Pica nuttalli BCC In region
Oak titmouse Baeolophus inornatus BCC On site
California horned lark Eremophila alpestris actia TWL Nearby Bank swallow Riparia riparia CT Low In region
Purple martin Progne subis SSC2 Nearby
Wrentit Chamaea fasciata BCC Very close
California thrasher Toxostoma redivivum BCC Nearby
Cassin’s finch Haemorhous cassinii BCC In region
Lawrence’s goldfinch Spinus lawrencei BCC Nearby
Grasshopper sparrow Ammodramus savannarum SSC2 Nearby
Samuel’s song sparrow Melospiza melodia samuelis BCC, SSC Moderate Nearby Black-chinned sparrow Spizella atrogularis BCC In region Bell’s sparrow Amphispiza b. belli TWL In region
Yellow-breasted chat Icteria virens SSC3 Very close
Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 In region Bullock’s oriole Icterus bullockii BCC Very close
Tricolored blackbird Agelaius tricolor CT, BCC, SSC1 High In region Lucy’s warbler Leiothlypis luciae SSC3 In region
Virginia’s warbler Leiothlypis virginiae WL, BCC In region San Francisco common
yellowthroat
Geothlypis trichas sinuosa SSC3, BCC High In range
Yellow warbler Setophaga petechia SSC2 Very close
Summer tanager Piranga rubra SSC1 In region
Little brown bat Myotis lucifugus WBWG: M In region
Yuma myotis Myotis yumanensis WBWG: LM In region
Long-eared myotis Myotis evotis WBWG: M In region
28 Common name

Species name

Status1
PRDEIR
occurrence
likelihood
Data base
records,
Site visit
Fringed myotis Myotis thysanodes WBWG: H In range
Long-legged myotis Myotis volans WBWG: H In range
Canyon bat Parastrellus hesperus WBWG: M In region
Silver-haired bat Lasionycteris noctivagans WBWG: M In region Hoary bat Lasiurus cinereus WBWG: M In region
Western red bat Lasiurus blossevillii SSC, WBWG: H High In region Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG: H In region Pallid bat Antrozous pallidus SSC, WBWG: H High In region Big free-tailed bat Nyctinomops macrotis SSC, WBWG: MH In range Salt-marsh harvest mouse Reithrodontomys raviventris FE, CE, CFP Moderate In region American badger Taxidea taxus SSC High Nearby
Mountain lion Puma concolor SA Nearby
1 Listed as FT or FE = federal threatened or endangered, FC = federal candidate for listing, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, CT or CE = California threatened or endangered, CCT or CCE = Candidate California threatened or endangered, CFP = California Fully Protected (California Fish and Game Code 3511), SSC = California Species of Special Concern (not threatened with extinction, but rare, very restricted in range, declining throughout range, peripheral portion of species' range, associated with habitat that is declining in extent), SSC1, SSC2 and SSC3 = California Bird Species of Special Concern priorities 1, 2 and 3, respectively (Shuford and Gardali 2008), WL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (CFG Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H). 29 POTENTIAL BIOLOGICAL IMPACTS

An impacts analysis should consider whether and how a proposed project would affect members of a species, larger demographic units of the species, the whole of a species, and ecological communities. The accuracy of this analysis depends on an accurate characterization of the existing environmental setting. In the case of the proposed project, the existing environmental setting has not been accurately characterized, and several important types of potential project impacts have been inadequately analyzed or not analyzed at all. These types of impacts include habitat loss, wetlands loss, interference with wildlife movement, wildlife-automobile collision mortality, bird- window collision mortality, and depredation by house cats that come with residential development (discussed below).

The Initial Study is misleading in its characterization of the “project,” as it attempts to separate the zoning amendment from what is intended to result from the zoning amendment. According to the Initial Study (p. 16), “No development or construction is proposed as part of the Project. Thus, the Project would not directly result in any impacts to sensitive or special status plant or animal species. Therefore, the Project would not result in any new significant impacts not already analyzed in the General Plan Update EIR or increase the severity of a significant impact as previously identified and analyzed in that EIR.” According to the zoning amendment, the project is the zoning amendment and nothing more. However, it is clear from the Staff Report that the whole of the project is to clear the way for the planning free of any further CEQA considerations and the construction of at least 1,000 residential units. The whole of the project would cause substantial and potentially highly significant impacts to the wildlife community.

As part of a consistency analysis, the Initial Study (p. 16) reasons, “The General Plan Update PRDEIR found that the 2040 General Plan would have a less-than-significant impact to candidate, sensitive, and special status species because implementing projects within the City would be required to adhere review under CEQA and permitting requirements for impacts on special-status plants and animals. Therefore, the General Plan Update EIR concluded that implementation of the General Plan would result in less than significant impacts to special-status plant and animal species, and no mitigation is required.” However, the Initial Study fails to explain how mitigation required under the General Plan Update PRDEIR would conserve the wildlife community along with its special-status species on the project site, which also underwent no survey or desktop review to characterize the wildlife community that exists on the site.

PRODUCTIVE CAPACITY REDUCED BY HABITAT LOSS

The whole of the project would convert 66 acres of open space to a residential development consisting of at least 1,000 units, or about three times more residential units that assumed in the General Plan Update PRDEIR. Wildlife habitat would be lost.

Along with Noriko Smallwood as my co-investigator, I measured the impacts of habitat loss to wildlife caused by mitigated development projects, such as by industrial 30 warehouses. We revisited 80 sites of proposed projects that we had originally surveyed in support of comments on CEQA review documents (Smallwood and Smallwood 2023).

We revisited the sites to repeat the survey methods at the same time of year, the same start time in the day, and the same methods and survey duration to measure the effects of mitigated development on wildlife. We structured the experiment in a before-after, control-impact experimental design, as some of the sites had been developed since our initial survey and some had remained undeveloped. We found that mitigated development resulted in a 66% loss of species on site, and 48% loss of species in the project area. Counts of vertebrate animals declined 90%. “Development impacts measured by the mean number of species detected per survey were greatest for amphibians (-100%), followed by mammals (-86%), grassland birds (-75%), raptors (- 53%), special-status species (-49%), all birds as a group (-48%), non-native birds (- 44%), and synanthropic birds (-28%). Our results indicated that urban development substantially reduced vertebrate species richness and numerical abundance, even after richness and abundance had likely already been depleted by the cumulative effects of loss, fragmentation, and degradation of habitat in the urbanizing environment,” and despite the mitigation measures per existing policies and regulations. We also specifically tested for the effects of projects to wildlife in neighboring habitats, and we found significant decreases in species richness and overall abundance in those areas as well.

Habitat loss not only results in the immediate numerical decline of wildlife, but it also results in permanent loss of productive capacity. Habitat fragmentation multiplies the negative effects of habitat loss on the productive capacities of biological species by preventing recruitment to habitat patches that have become too isolated or too small (Smallwood 2015). In the case of birds, two methods exist for estimating the loss of productive capacity that would be caused by the project. One method would involve surveys to count the number of bird nests and chicks produced. The alternative method would be to infer productive capacity from estimates of total nest density elsewhere.

Several studies have estimated total avian nest density at locations that had likewise been highly fragmented. Two study sites in grassland/wetland/woodland complexes within agricultural matrices had total bird nesting densities of 32.8 and 35.8 nests per acre (Young 1948, Yahner 1982) for an average 34.3 nests per acre. To acquire a total nest density closer to conditions in California, I surveyed various patches of vegetation cover in northern California throughout the breeding seasons of 2023 and 2024. The most relevant study site to the vegetation covers on the project site consisted of a 12.74- acre complex composed of 1.32 acres of riparian forest, 2 acres of dense shrubbery including blackberries, and 9.42 acres of walnut orchard in Rancho Cordova, CA, where I estimated 18.05 nests/acre in 2023. Applying this estimate to the 66 acres of the project site would predict an annual average 1,191 nest sites on the project site.

Assuming 1.39 broods per nest site, which is the average among 322 North American bird species I asked Noriko Smallwood to review, then I predict the project would cost California 1,655 nest attempts/year.

The loss of 1,191 nest sites and 1,655 nest attempts per year would qualify as significant impacts that have not been analyzed by the City. But the impacts would not end with the 31 immediate loss of nest sites. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young’s (1948) study was 2.9. Assuming Young’s (1948) study site typifies bird productivity, the project would prevent the production of 4,800 fledglings per year. Assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production can be estimated from an equation in Smallwood (2022): {(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number of years ÷ years/generation)} ÷ (number of years) = 5,276 birds per year denied to California.

Most if not all the predicted 5,276 birds annually lost to the project are protected by the federal Migratory Bird Treaty Act and by California’s Migratory Bird Protection Act, both of which most strongly protect breeding migratory birds. Other than the general conclusion of the General Plan Update PRDEIR (p. 3.3-48) that “Future development could result in the direct mortality of special-status wildlife and/or the loss or disturbance of habitat types that could support special-status wildlife,” nowhere in the General Plan Update PRDEIR, Initial Study or Staff Report is this potential impact seriously analyzed, nor is any analysis directed specifically to the project site.

WETLANDS

INTERFERENCE WITH WILDLIFE MOVEMENT

One of CEQA’s principal concerns regarding potential project impacts is whether a proposed project would interfere with wildlife movement in the region. However, the Initial Study does not seriously address the question of whether the project would interfere with wildlife movement. The General Plan Update PRDEIR addresses wildlife corridors, but it does so at a scale that is inappropriate to the project site. The analysis is directed to the scale of the City of Napa’s Sphere of Influence, and it is focused on corridors rather than on the more general question of whether the General Plan would interfere with wildlife movement in the region. Wildlife movement is not constrained to corridors.

32 While the General Plan Update PRDEIR’s analysis is too crude and a bit misdirected, the Initial Study’s analysis is misleading. According to the Initial Study (p. 17), “No development or construction would occur within the Project Site as part of the Project.” This is misleading because the whole of the project would result in the construction of about 1,000 residential units and the concomitant destruction of 66 acres of open space that I found to be used by wildlife for movement through the area, e.g., see Photo 27. A qualified biologist needs to be assigned to survey the site for wildlife movement, and it needs to be based on evidence from sign (trails) and a program of observation of use of the airspace and of stopovers on the project site.

TRAFFIC IMPACTS TO WILDLIFE

Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic to and from the project site (Photos 32―34), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife (Forman et al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year (Bishop and Brogan 2013), and the US estimate of avian mortality on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al. 2014). Local impacts can be more intense than nationally.

Photo 32. A Gambel’s
quail dashes across a
road on 3 April 2021.

Such road crossings are
usually successful, but
too often prove fatal to
the animal. Photo by
Noriko Smallwood.

33 Photo 33. Mourning dove killed
by vehicle on a California road.

Photo by Noriko Smallwood, 21
June 2020.

Photo 34. Raccoon killed on Road 31 just east of
Highway 505 in Solano County. Photo taken on
10 November 2018.

The nearest study of traffic-caused wildlife mortality was performed along a 2.5-mile stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find (or not find) during their routine periodic fatality searches. This step was not taken at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study next to Vasco Road (Brown et al. 2016). Brown et al.’s (2016) adjustment factors for carcass persistence resembled those of Santos et al. (2011). Also applying searcher detection rates from Brown et al. (2016), the adjusted total number of fatalities was estimated at 9,462 animals killed by traffic on the road. This fatality number projected over 1.25 years and 2.5 miles of road translates to 3,028 wild animals per mile per year. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. (2009) study would translate to 188,191 animals killed per 100 km of road per year, or 22 times that of Loss et al.’s (2014) upper bound estimate and 53 times the Canadian estimate.

An analysis is needed of whether increased traffic generated by the project site would similarly result in local impacts on wildlife.

For wildlife vulnerable to front-end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. (2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data resulted in an estimated 3,028 animals killed per mile along a county road in Contra Costa County. The estimated numbers of fatalities were 1.75% birds, 26.4% mammals (many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others), 67.4% amphibians (large numbers of California tiger salamanders and California red-legged frogs, but also Sierran treefrogs,

34 western toads, arboreal salamanders, slender salamanders and others), and 4.4% reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. (2009) study, hence enabling a rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates.

Predicting project-generated traffic impacts to wildlife

The City’s Initial Study reports no prediction of annual VMT for the housing development that would follow the proposed zoning amendment, but I can infer the annual VMT from the average of annual VMT predicted for eight other residential developments I reviewed as an expert. For residential developments, the average annual VMT per square foot of floor space has been 26. Assuming an average 1,700 sf per residential unit, one can assume 1,700,000 sf. Thus, one can predict the project would generate 44,200,000 annual VMT.

During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non-volant fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years = 22,242,187.5 vehicle miles per 9,462 wildlife fatalities, or 2,351 vehicle miles per fatality. This rate divided into the predicted annual VMT would predict 18,800 vertebrate wildlife fatalities per year.

The analysis of the General Plan Update PRDEIR is limited to the following statement:
“Indirect effects on special-status wildlife that could occur as a result of increased human occupancy in formerly natural areas include increased mortality from vehicle Collisions…” I agree, but the PRDEIR could have seriously analyzed this potential impact, but it did not.

Based on my analysis, the project-generated traffic would cause substantial, significant impacts to wildlife. The Initial Study does not analyze this potential impact, nor does it propose to mitigate it, and neither does the General Plan Update PRDEIR. Mitigation measures to improve wildlife safety along roads are available and are feasible, and they need exploration for their suitability with the proposed project. Given the predicted level of project-generated, traffic-caused mortality, and the lack of any proposed mitigation, it is my opinion that the proposed project would result in potentially significant adverse biological impacts.

WINDOW COLLISION MORTALITY

The Initial Study fails to consider impacts on wildlife from window collision. The project would add at least 1,000 residential units to 66 acres of open space that is currently habitat to many birds. Whether the project consists solely of single-family homes or a combination of homes and apartment buildings, the residential units would present glass windows to birds attempting to use an essential portion of their habitat – that portion of the gaseous atmosphere that is referred to as the aerosphere (Davy et al. 2017, Diehl et al. 2017). The aerosphere is where birds and bats and other volant animals with 35 wings migrate, disperse, forage, perform courtship and where some of them mate. Birds are some of the many types of animals that evolved wings as a morphological adaptation to thrive by moving through the medium of the aerosphere. The aerosphere is habitat.

Indeed, an entire discipline of ecology has emerged to study this essential aspect of habitat – the discipline of aeroecology (Kunz et al. 2008). Many special-status species of birds have been recorded at or near the aerosphere of the project site, and Noriko saw many birds using the aerosphere while she surveyed the site. Bird-window collision mortality is a potentially significant impact that warrants analysis.

Window collisions are often characterized as either the second or third largest source or human-caused bird mortality. The numbers behind these characterizations are often attributed to Klem’s (1990) and Dunn’s (1993) estimates of about 100 million to 1 billion bird fatalities in the USA, or more recently by Loss et al.’s (2014) estimate of 365-988 million bird fatalities in the USA or Calvert et al.’s (2013) and Machtans et al.’s (2013) estimates of 22.4 million and 25 million bird fatalities in Canada, respectively. The proposed project would impose windows in the airspace normally used by birds.

Glass-façades of buildings intercept and kill many birds, but these façades are differentially hazardous to birds based on spatial extent, contiguity, orientation, and other factors. At Washington State University, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a three-story glass walkway (no fatality adjustments attempted). Prior to marking the windows to warn birds of the collision hazard, the collision rate was 84.7 per year. At that rate, and not attempting to adjust the fatality estimate for the proportion of fatalities not found, 4,574 birds were likely killed over the 54 years since the start of their study, and that’s at a relatively small building façade. Accounting for the proportion of fatalities not found, the number of birds killed by this walkway over the last 54 years would have been about 14,270. And this is just for one 3-story, glass-sided walkway between two college campus buildings.

Klem’s (1990) estimate was based on speculation that 1 to 10 birds are killed per building per year, and this speculated range was extended to the number of buildings estimated by the US Census Bureau in 1986. Klem’s speculation was supported by fatality monitoring at only two houses, one in Illinois and the other in New York. Also, the basis of his fatality rate extension has changed greatly since 1986. Whereas his estimate served the need to alert the public of the possible magnitude of the bird- window collision issue, it was highly uncertain at the time and undoubtedly outdated more than three decades hence. Indeed, by 2010 Klem (2010) characterized the upper end of his estimated range – 1 billion bird fatalities – as conservative. Furthermore, the estimate lumped species together as if all birds are the same and the loss of all birds to windows has the same level of impact.

By the time Loss et al. (2014) performed their effort to estimate annual USA bird- window fatalities, many more fatality monitoring studies had been reported or were underway. Loss et al. (2014) incorporated many more fatality rates based on scientific monitoring, and they were more careful about which fatality rates to include. However, they included estimates based on fatality monitoring by homeowners, which in one 36 study were found to detect only 38% of the available window fatalities (Bracey et al. 2016). Loss et al. (2014) excluded all fatality records lacking a dead bird in hand, such as injured birds or feather or blood spots on windows. Loss et al.’s (2014) fatality metric was the number of fatalities per building (where in this context a building can include a house, low-rise, or high-rise structure), but they assumed that this metric was based on window collisions. Because most of the bird-window collision studies were limited to migration seasons, Loss et al. (2014) developed an admittedly assumption-laden correction factor for making annual estimates. Also, only 2 of the studies included adjustments for carcass persistence and searcher detection error, and it was unclear how and to what degree fatality rates were adjusted for these factors. Although Loss et al. (2014) attempted to account for some biases as well as for large sources of uncertainty mostly resulting from an opportunistic rather than systematic sampling data source, their estimated annual fatality rate across the USA was highly uncertain and vulnerable to multiple biases, most of which would have resulted in fatality estimates biased low.

In my review of bird-window collision monitoring, I found that the search radius around homes and buildings was very narrow, usually 2 meters. Based on my experience with bird collisions in other contexts, I would expect that a large portion of bird-window collision victims would end up farther than 2 m from the windows, especially when the windows are higher up on tall buildings. In my experience, searcher detection rates tend to be low for small birds deposited on ground with vegetation cover or woodchips or other types of organic matter. Also, vertebrate scavengers entrain on anthropogenic sources of mortality and quickly remove many of the carcasses, thereby preventing the fatality searcher from detecting these fatalities. Adjusting fatality rates for these factors – search radius bias, searcher detection error, and carcass persistence rates – would greatly increase nationwide estimates of bird-window collision fatalities.

Buildings can intercept many nocturnal migrants as well as birds flying in daylight. As mentioned above, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a four-story glass walkway at Washington State University (no adjustments attempted for undetected fatalities). Somerlot (2003) found 21 bird fatalities among 13 buildings on a university campus within only 61 days.

Monitoring twice per week, Hager at al. (2008) found 215 bird fatalities of 48 species, or 55 birds/building/year, and at another site they found 142 bird fatalities of 37 species for 24 birds/building/year. Gelb and Delacretaz (2009) recorded 5,400 bird fatalities under buildings in New York City, based on a decade of monitoring only during migration periods, and some of the high-rises were associated with hundreds of fatalities each. Klem et al. (2009) monitored 73 building façades in New York City during 114 days of two migratory periods, tallying 549 collision victims, nearly 5 birds per day. Borden et al. (2010) surveyed a 1.8 km route 3 times per week during 12-month period and found 271 bird fatalities of 50 species. Parkins et al. (2015) found 35 bird fatalities of 16 species within only 45 days of monitoring under 4 building façades. From 24 days of survey over a 48-day span, Porter and Huang (2015) found 47 fatalities under 8 buildings on a university campus. Sabo et al. (2016) found 27 bird fatalities over 61 days of searches under 31 windows. In San Francisco, Kahle et al. (2016) found 355 collision victims within 1,762 days under a 5-story building. Ocampo-Peñuela et al. (2016) searched the perimeters of 6 buildings on a university campus, finding 86 37 fatalities after 63 days of surveys. One of these buildings produced 61 of the 86 fatalities, and another building with collision-deterrent glass caused only 2 of the fatalities, thereby indicating a wide range in impacts likely influenced by various factors. There is ample evidence available to support my prediction that the proposed Project would result in many collision fatalities of birds within the Tennessee Village project.

Bird-window impact prediction

I have reviewed and processed results of bird collision monitoring at 213 buildings and façades for which bird collisions per m2 of glass per year could be calculated and averaged (Johnson and Hudson 1976, O’Connell 2001, Somerlot 2003, Hager et al. 2008, Borden et al. 2010, Hager et al. 2013, Porter and Huang 2015, Parkins et al. 2015, Kahle et al. 2016, Ocampo-Peñuela et al. 2016, Sabo et al. 2016, Barton et al. 2017, Gomez-Moreno et al. 2018, Schneider et al. 2018, Loss et al. 2019, Brown et al. 2020, City of Portland Bureau of Environmental Services and Portland Audubon 2020, Riding et al. 2020). These study results averaged 0.073 bird deaths per m2 of glass per year (95% CI: 0.042-0.102). This average and its 95% confidence interval provide a robust basis for predicting fatality rates at a site of a proposed new project.

The Initial Study provides no details on how much exterior glass might be constructed along with the residential units following the proposed zoning amendment, but I can calculate a crude prediction based on other projects of which I served as an expert.

Assuming a total floor space of 1,700,000 sf as I did under Road Mortality, and on my average 0.0170706 m2 of glass per sf of floor space from 25 previous residential developments I worked on as an expert, I calculate a total glass window area of 29,020 m2 (95% CI: 14,946, 43,094 m2). Multiplying the average number of bird deaths per m2 of glass per year (above) by my calculated window area in the project, I predict annual bird deaths of 2,118 (95% CI: 1,219‒2,960). My analysis reveals that the impacts of bird- window collision mortality would be highly significant. This impact is not considered in the Initial Study or in the General Plan Update PRDEIR.

WILDLIFE DEPREDATION BY HOUSE CATS

House cats would be introduced to the project site by residents of the proposed residential units. However, the Initial Study does not address the impacts of house cats on wildlife. House cats serve as one of the largest sources of avian mortality in North America (Dauphiné and Cooper 2009, Blancher 2013, Loss et al. 2013, Loyd et al. 2017).

Loss et al. (2013) estimated 139 million cats in the USA in 2013 (range 114 to 164 million), which killed an estimated 16.95 billion vertebrate wildlife annually (range 7.6 to 26.3 billion). In 2012 there were 0.44 house cats per human, and 122 vertebrate animals were killed per cat, free-ranging members of which killed disproportionately larger numbers of vertebrate wildlife. According to the Initial Study, the 2040 General Plan assumes 2.3 residents per housing unit. Assuming the proposed project would, following the proposed zoning amendment, add 1,000 residential units, then the project would add 2,300 new residents. A rate of 0.44 house cats per human applied to this number of new residents would add 1,012 house cats, which would kill 123,464 vertebrate wildlife per year.
38 House cats also contribute to downstream loading of Toxoplasma gondii. According to a UC Davis wildlife health research program, “Toxoplasma gondii is a parasite that can infect virtually all warm-blooded animals, but the only known definitive hosts are cats – domesticated and feral house cats included. Cats catch the parasite through hunting rodents and birds and they offload it into the environment through their feces… and …rain that falls on cement creates more runoff than rain that falls on natural earth, which contributes to increased runoff that can carry fecal pathogens to the sea” (http://www.evotis.org/ toxoplasma-gondii- sea-otters/). The Initial Study did not analyze this potential impact, and the analysis of the General Plan Update PRDEIR analyze was limited to the following statement: “Indirect effects on special-status wildlife that could occur as a result of increased human occupancy in formerly natural areas include increased mortality from … predation by pets…”

The City of Napa has not seriously analyzed the potential impacts of house cats to wildlife, and it has not done so specifically for the proposed project.

INTERFERENCE WITH EXISTING HCP OR NCCP

The Initial Study (p. 18) asserts, “there are no HCPs or natural community conservation plans have been adopted in the study area or in Napa County.” However, the PG&E Bay Area Operations and Maintenance HCP covers Napa County.

Thank you for your consideration,

______________________
Shawn Smallwood, Ph.D.

LITERATURE CITED

Barton, C. M., C. S. Riding, and S. R. Loss. 2017. Magnitude and correlates of bird collisions at glass bus shelters in an urban landscape. Plos One 12. (6): e0178667. https://doi.org/10.1371/journal.pone.0178667

Basilio, L. G., D. J. Moreno, and A, J. Piratelli. 2020. Main causes of bird-window collisions: a review. Anais da Academia Brasileira de Ciências 92(1): e20180745 DOI 10.1590/0001-3765202020180745.

Bishop, C. A. and J. M. Brogan. 2013. Estimates of avian mortality attributed to vehicle collisions in Canada. Avian Conservation and Ecology 8:2. http://dx.doi.org/

10.5751/ACE-00604-080202.

39 Blancher, P. 2013. Estimated number of birds killed by house cats (Felis catus) in Canada. Avian Conservation and Ecology 8(2): 3. http://dx.doi.org/10.5751/ACE- 00557-080203

Borden, W. C., O. M. Lockhart, A. W. Jones, and M. S. Lyons. 2010. Seasonal, taxonomic, and local habitat components of bird-window collisions on an urban university campus in Cleveland, OH. Ohio Journal of Science 110(3):44-52.

Bracey, A. M., M. A. Etterson, G. J. Niemi, and R. F. Green. 2016. Variation in bird- window collision mortality and scavenging rates within an urban landscape. The Wilson Journal of Ornithology 128:355-367.

Brown, B. B., L. Hunter, and S. Santos. 2020. Bird-window collisions: different fall and winter risk and protective factors. PeerJ 8:e9401
http://doi.org/10.7717/peerj.9401

Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2016. Final 2012-2015 Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California.

Calvert, A. M., C. A. Bishop, R. D. Elliot, E. A. Krebs, T. M. Kydd, C. S. Machtans, and G.

J. Robertson. 2013. A synthesis of human-related avian mortality in Canada.

Avian Conservation and Ecology 8(2): 11. http://dx.doi.org/10.5751/ACE-00581- 080211

City of Portland Bureau of Environmental Services and Portland Audubon. 2020.

Collisions at the Columbia Building: A synthesis of pre- and post-retrofit monitoring. Environmental Services of City of Portland, Oregon.

Dauphiné, N. and R. J. Cooper. 2009. Impacts of free-ranging domestic cats (Felis catus) on birds in the United States: a review of recent research with conservation and management recommendations. Pages 205-219 in T. D. Rich, C. Arizmendi, D. W. Demarest, and C. Thompson, eds., Proceedings of the Fourth International Partners in Flight Conference: Tundra to Tropics.

Davy, C. M., A. T. Ford, and K. C. Fraser. 2017. Aeroconservation for the fragmented skies. Conservation Letters 10(6): 773–780.

De Groot, K. L., A. G. Wilson, R. McKibbin, S. A. Hudson, K. M. Dohms, A. R. Norris, A.

C. Huang, I. B. J. Whitehorne, K. T. Fort, C. Roy, J. Bourque, and S. Wilson. 2022.

Bird protection treatments reduce bird-window collision risk at low-rise buildings within a Pacific coastal protected area. PeerJ 10(9):e13142 DOI

10.7717/peerj.13142.

Diehl, R. H., A. C. Peterson, R. T. Bolus, and D. Johnson. 2017. Extending the habitat concept to the airspace. USGS Staff -- Published Research. 1129. https://digitalcommons.unl.edu/usgsstaffpub/1129
40 Dunn, E. H. 1993. Bird mortality from striking residential windows in winter. Journal of Field Ornithology 64:302-309.

Forman, T. T., D. Sperling, J. A. Bisonette, A. P. Clevenger, C. D. Cutshall, V. H. Dale, L.

Fahrig, R. France, C. R. Goldman, K. Heanue, J. A. Jones, F. J. Swanson, T.

Turrentine, and T. C. Winter. 2003. Road Ecology. Island Press, Covello, California.

Gelb, Y. and N. Delacretaz. 2009. Windows and vegetation: Primary factors in Manhattan bird collisions. Northeastern Naturalist 16:455-470.

Gómez-Moreno, V. del C., J. R. Herrera-Herrera, and S. Niño-Maldonado. 2018. Bird collisions in windows of Centro Universitario Victoria, Tamaulipas, México.

Huitzil, Revista Mexicana de Ornitología 19(2): 227-236. https://doi.org/10.28947/ hrmo.2018.19.2.347

Hager, S. B., H. Trudell, K. J. McKay, S. M. Crandall, and L. Mayer. 2008. Bird density and mortality at windows. Wilson Journal of Ornithology 120:550-564.

Hager S. B., B. J. Cosentino, K J. McKay, C. Monson, W. Zuurdeeg, and B. Blevins. 2013.

Window area and development drive spatial variation in bird-window collisions in an urban landscape. PLoS ONE 8(1): e53371. doi:10.1371/journal.pone.0053371

Hall, L. S., P. R. Krausman, and M. L. Morrison. 1997. “The habitat concept and a plea for standard terminology.” Wildlife Society Bulletin 25:173-82.

Johnson, R. E., and G. E. Hudson. 1976. Bird mortality at a glassed-in walkway in Washington State. Western Birds 7:99-107.

Kahle, L. Q., M. E. Flannery, and J. P. Dumbacher. 2016. Bird-window collisions at a west-coast urban park museum: analyses of bird biology and window attributes from Golden Gate Park, San Francisco. PLoS ONE 11(1):e144600 DOI

10.1371/journal.pone.0144600.

Klem, D., Jr. 1989. Bird-window collisions. Wilson Bulletin 101:606-620.

Klem, D., Jr. 1990. Collisions between birds and windows: mortality and prevention.

Journal of Field Ornithology 61:120-128.

Klem, D., Jr. 2009. Preventing bird-window collisions. The Wilson Journal of Ornithology 121:314-321.

Klem, D., Jr. 2011. Evaluating the effectiveness of Acopian Birdsavers to deter or prevent bird-glass collisions. Unpublished report.

41 Klem, D., Jr. and P. G. Saenger. 2013. Evaluating the effectiveness of select visual signals to prevent bird-window collisions. The Wilson Journal of Ornithology 125:406–411.

Kunz, T. H., S. A. Gauthreaux Jr., N. I. Hristov, J. W. Horn, G. Jones, E. K. V. Kalko, R.

P. Larkin, G. F. McCracken, S. M. Swartz, R. B. Srygley, R. Dudley, J. K.

Westbrook, and M. Wikelski. 2008. Aeroecology: probing and modelling the aerosphere. Integrative and Comparative Biology 48:1-11. doi:10.1093/icb/icn037

Loss, S. R., T. Will, and P. P. Marra. 2013. The impact of free-ranging domestic cats on wildlife of the United States. Nature Communications 2380. DOI:

10.1038/ncomms2380

Loss, S. R., T. Will, S. S. Loss, and P. P. Marra. 2014. Bird–building collisions in the United States: Estimates of annual mortality and species vulnerability. The Condor: Ornithological Applications 116:8-23. DOI: 10.1650/CONDOR-13-090.1

Loss, S. R., S. Lao, J. W. Eckles, A. W. Anderson, R. B. Blair, and R. J. Turner. 2019.

Factors influencing bird-building collisions in the downtown area of a major North American city. PLoS ONE 14(11): e0224164.
https://doi.org/10.1371/journal. pone.0224164

Loss, S. R., T. Will, and P. P. Marra. 2014. Estimation of Bird-Vehicle Collision Mortality on U.S. Roads. Journal of Wildlife Management 78:763-771.

Loyd, K. A. T., S. M. Hernandez, and D. L. McRuer. 2017. The role of domestic cats in the admission of injured wildlife at rehabilitation and rescue centers. Wildlife Society Bulletin 41:55-61.

Machtans, C. S., C. H. R. Wedeles, and E. M. Bayne. 2013. A first estimate for Canada of the number of birds killed by colliding with building windows. Avian Conservation and Ecology 8(2):6. http://dx.doi.org/10.5751/ACE-00568-080206

Mendelsohn, M., W. Dexter, E. Olson, and S. Weber. 2009. Vasco Road wildlife movement study report. Report to Contra Costa County Public Works Department, Martinez, California.

Ocampo-Peñuela, N., R. S. Winton, C. J. Wu, E. Zambello, T. W. Wittig and N. L. Cagle . 2016. Patterns of bird-window collisions inform mitigation on a university campus. PeerJ4:e1652;DOI10.7717/peerj.1652

O’Connell, T. J. 2001. Avian window strike mortality at a suburban office park. The Raven 72:141-149.

Orff, K., H. Brown, S. Caputo, E. J. McAdams, M. Fowle, G. Phillips, C. DeWitt, and Y.

Gelb. 2007. Bird-safe buildings guidelines. New York City Audubon, New York.

42 Parkins, K. L., S. B. Elbin, and E. Barnes. 2015. Light, glass, and bird–building collisions in an urban park. Northeastern Naturalist 22:84-94.

Porter, A., and A. Huang. 2015. Bird collisions with glass: UBC pilot project to assess bird collision rates in Western North America. UBC Social Ecological Economic Development Studies (SEEDS) Student Report. Report to Environment Canada, UBC SEEDS and UBC BRITE.

Riding, C. S., T. J. O’Connell, and S. R. Loss. 2020. Building façade-level correlates of bird–window collisions in a small urban area. The Condor: Ornithological Applications 122:1–14.

Riggs, G. J., C. M. Barton, C. S. Riding, T. J. O’Connell1, and S. R. Loss. 2023.

Field‑testing effectiveness of window markers in reducing bird‑window collisions.

Urban Ecosystems (2023) 26:713–723. https://doi.org/10.1007/s11252-022- 01304-w

Rössler, M., E. Nemeth, and A. Bruckner. 2015. Glass pane markings to prevent bird- window collisions: less can be more. Biologia 70: 535—541. DOI: 10.1515/biolog- 2015-0057

Sabo, A. M., N. D. G. Hagemeyer, A. S. Lahey, and E. L. Walters. 2016. Local avian density inﬂuences risk of mortality from window strikes. PeerJ 4:e2170; DOI

10.7717/peerj.2170

San Francisco Planning Department. 2011. Standards for bird-safe buildings. San Francisco Planning Department, City and County of San Francisco, California.

Santos, S. M., F. Carvalho, and A. Mira. 2011. How long do the dead survive on the road? Carcass persistence probability and implications for road-kill monitoring surveys.

PLoS ONE 6(9): e25383. doi:10.1371/journal.pone.0025383

Schneider, R. M., C. M. Barton, K. W. Zirkle, C. F. Greene, and K. B. Newman. 2018.

Year-round monitoring reveals prevalence of fatal bird-window collisions at the Virginia Tech Corporate Research Center. PeerJ 6:e4562 https://doi.org/10.7717/ peerj.4562

Sheppard, C., and G. Phillips. 2015. Bird-friendly building design, 2nd Ed., American Bird Conservancy, The Plains, Virginia.

Shuford, W. D., and T. Gardali, [eds.]. 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.

Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84-101 in M. L.

Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, 43 challenges, and solutions. John Hopkins University Press, Baltimore, Maryland, USA.

Smallwood, K. S. 2022. Utility-scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https://doi.org/10.1002/jwmg.22216

Smallwood, K. S., and N. L. Smallwood. 2023. Measured effects of anthropogenic development on vertebrate wildlife diversity. Diversity 15, 1037. https://doi.org/10.3390/d15101037.

Somerlot, K. E. 2003. Survey of songbird mortality due to window collisions on the Murray State University campus. Journal of Service Learning in Conservation Biology 1:1–19.

Swaddle, J. P., B. Brewster, M. Schuyler, and A. Su. 2023. Window films increase avoidance of collisions by birds but only when applied to external compared with internal surfaces of windows. PeerJ 11:e14676 http://doi.org/10.7717/peerj.14676

Yahner, R. H. 1982. Avian nest densities and nest-site selection in farmstead shelterbelts. The Wilson Bulletin 94:156-175.

Young, H. 1948. A comparative study of nesting birds in a five-acre park. The Wilson Bulletin 61:36-47.

Photo 35. A Cooper’s
hawk on the hunt for quail
on the project site, 30
October 2024.

EXHIBIT B

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November 25, 2024

Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612

Attn: Mr. Richard Drury
Subject: Comment Letter on Big Ranch Road Annexation (PL23- 1043) And Need For CEQA Review, Napa, CA.

Dear Mr. Drury:

At the request of Lozeau Drury LLP (Lozeau Drury), Clark and Associates (Clark) has reviewed materials related to the above referenced project.

Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within the City of Napa (the City) Planning Commission Staff Report dated September 19, 2024. If we do not comment on a specific item, this does not constitute acceptance of the item.

Project Description:

The City has received an application for a Zoning Amendment to amend the existing pre-zoning designation for approximately 66 acres of land adjacent to the City’s north-eastern border and Annexation of approximately 51.5 acres of said land into the City boundaries in the Big Ranch Road area. The Applicant requests the annexation of the six properties at 2275, 2285, 2305, 2331 Big Ranch Road, 1130 Trower Avenue (only the portion within the City’s RUL and south of the future Trower Avenue Extension) and 1438 Rosewood Lane. The area of interest is included in the figure below.

Clark & Associates
Environmental Consulting, Inc.

OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]

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Figure 1: Project Site Location

As is evident from the figure above, the annexed area is adjacent to Vintage High School, and other residences. The development of the Project Site would introduce a new source of pollution into the community that are currently not present. The construction of housing on the Project Site would include a number of phases that would generate criteria air pollutants (volatile organic compounds (VOCs), oxides of nitrogen (NO x), carbon monoxide (CO), oxides of sulfur (SO x), and particulate

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matter (including course particulate matter (PM10) and fine particulate matter (PM2.5)) along with toxic air contaminants (e.g, TACs include diesel particulate matter (DPM) and VOCs such as benzene, 1,3- butadiene, and acrolein) during the construction phase of the Project. Emissions are expected from the construction activities including:
 Site Preparation;
 Grading;
 Building Construction of Housing;
 Infrastructure Improvements (i.e., installation of roadways, curbs, gutters, sewer system, and electrical infrastructure);
 Paving;
 Architectural Coating; and
 Materials Deliveries and Construction Workers Commuting Under current County zoning, the subject parcels are designated Residential Country (RC) which provides for one dwelling unit per parcel. They also have a sub-designation of Urban Reserve (UR) that acknowledges the parcels are anticipated to annex to the City prior to any substantial residential development. According to the Staff Report, before any new development can occur on these parcels, General Plan Policy LUCD 24-1 requires that a master plan be prepared for the Big Ranch Road area, including the entire approximately 51.5 acres to be annexed as well as the remaining parcels not being annexed but that are within the Big Ranch Road area and the City’s SOI and RUL.

The Staff recommended that the City Council determine that the potential environmental effects from the actions authorized by this resolution were adequately analyzed in that certain City of Napa General Plan Update Final EIR (SCH #2021010255) certified by the City Council on September 20, 2022 (the “2040 General Plan EIR”).

Attachment 3 to the Annexation Proposal (Big Ranch Road Annexation - CEQA Initial Study for Determination of Consistency (with the 2040 General Plan EIR)) states that the 2040 General Plan would establish buffers between potential air pollution sources and sensitive receptors and limit pollution during construction. The attachment also states that because the effect of these reductions (from feasible mitigation measures) cannot be quantified and in consideration of the extent by which the 2040 General Plan development would exceed some of Bay Area Air Quality Management District’s (BAAQMD’s) significance thresholds, the General Plan’s impact on the cumulatively

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considerable increase in criteria pollutants for which the region is in nonattainment is significant and unavoidable.

In the Air Quality analysis of the annexation, the Staff found that the proposed annexation would not result in a substantial increase in future population beyond what is already assumed by the General Plan Update EIR for the Project Site. No development or construction is proposed as part of the Project. The Air Quality Analysis also found that future development would be subject to individual review; new sources would be evaluated through the BAAQMD permit process and/or the CEQA process to identify and mitigate any significant exposures.

These finding by the Staff are premature and fail to consider the stated purpose of the Annexation which would allow for the development of the Project Site with 8 to 18 single family units of housing per acre. The new zoning would allow 412 (51.5 acres * 8 units/acre) to 927 units of house (51.5 acres * 18 units/acre). Currently the Project site is zoned to allow 340 units of housing.

Under the BAAQMD’s 2010 CEQA Guidance a Screening Criteria based on the allowable Operational Criteria Pollutant, Operational Greenhouse Gas (GHG), and Construction-Related Criteria Pollutant was published. Table 3-1 from the 2010 CEQA Guidance provides the screening size for single family homes (allowable under the current and future zoning).

Figure 2: Table 3-1 From 2010 BA-AQMD CEQA Guidance

Based on the screening above it is clear that even using minimum allowable zoning criteria of 8 units per acre (412 units) would exceed the Operational Criteria Pollutant, Operational GHG, and Construction-Related Criteria Pollutant screening size from the 2010 Guidance. The excess NO x emissions would impact visibility in the area (NOx reacts with other chemicals in the air to form both particulate matter and ozone) as well as aggravating respiratory diseases (in particular asthma leading to respiratory symptoms, increase hospital admissions and visits to the ER. Reactive Organic Gases

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(ROGs) are a class of volatile organic compounds listed by the California Air Resources Board (CARB) which are important in the formation of ground level ozone.

In 2022, BAAQMD released new CEQA guidance which included a new chapter with best practices for centering Environmental Justice, health, and equity; a new appendix with the rationale for the recommended climate impacts thresholds of significance; a new appendix to assist with developing community-scale greenhouse gas (GHG) reduction strategies aligned with the State CEQA Guidelines and the Air District’s plan-level thresholds; an appendix with guidance on using the California Emissions Estimator Model (CalEEMod 2022) for Bay Area projects; and a new criteria pollutants and precursors screening tool for mixed land use projects.

As part of the 2022 guidance, BAAQMD also released an Excel-based tool that provides CEQA lead agencies with a conservative indication of whether implementing a proposed mixed land use project could result in potentially significant criteria air pollutants and precursors impacts. Using the minimum allowable zoning criteria of 8 units per acre (412 units) in the Excel model results in an exceedance of the CEQA construction threshold for BAAQMD, requiring that the Project undergo further analysis.

Figure 3: Screening Model Of Project Site (Minimum)
Using the maximum allowable zoning criteria of 18 units per acre (927 units) in the Excel model results in an exceedance of the CEQA construction and operational thresholds for BAAQMD, requiring that the Project undergo further analysis.

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Figure 4: Screening Model Of Project Site (Maximum)
Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant impacts if allowed to proceed. An EIR should be prepared to address these substantial concerns related to the construction and operational emissions from the Project that clearly were not identified in the 2040 General Plan EIR.

Sincerely,

From: Norma I. Quintana
To: Clerk
Subject: Oppose the Big Ranch Development
Date: Saturday, November 30, 2024 4:21:32 PM
You don't often get email from [email protected]. Learn why this is important [EXTERNAL]
I am writing in opposition of the Big Ranch Development! Our home is on Old Vine Way and as it is... there is a fair amount of traffic just leaving Garfield Road.

Please let me know you have received this email!
Norma I. Quintana
Photographer & Educator
www.normaiquintana.com
+1 707.484.4763 Mobile

We hope you understand how important it is for us to remain in the county.

Another, more general and perhaps more important concern is how this area would be able to
accommodate an influx of medium to high-density units and the traffic impact on Big Ranch Road.

In the 20/40 General Plan it assumed the construction of only 340 units. (General Plan, pages 2-20).

Without notification to the residents and with sweeping generality, the City Planning Department

altered the densities throughout the city, including our area, which is under the influence of the city,
with the intent of allowing 8 to 18 units per acre.

This translates to about 927 units of housing in the proposed Big Ranch area, nearly tripling what had been previously deemed reasonable, and without any special consideration for the rural nature and 2-lane roadways in this portion of Napa.

Thank you for your time.

Ardy and Lori Van Winden
Baiser de Dieu Vineyard
2295 Big Ranch Rd.

at Big Ranch Road just north of Trancas Street this past week. During this holiday week, there were no schools in session, and many people were off work during this holiday week, and thus, the amount of traffic was significantly less than normal.

Noise and density– noise would be a big factor with the density potential for over 1000 homes. Given the fact that there are currently only 12 farming/agricultural properties in this quiet neighborhood, in the proposed Master Plan, this would significantly change with over 1000 new homes.

Market-based housing – given the current status, with medium-density housing, is consideration given for market-based housing?
If a master plan is developed, has consideration been given to the following:
-setbacks
-roads
-preliminary plans
-infrastructure plans
-plot plans

I would like to request a continuance with the decision on annexation given the issues raised by me and many others.

Thank you.

Jana Cohen

From: Corinne McGue
To: Clerk
Cc: Community Big Ranch; Mike McGue; Craig Roche
Subject: Big Ranch Road Project Concerns/Issues
Date: Monday, December 2, 2024 9:37:25 AM
[You don't often get email from . Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]
[EXTERNAL]
To whom it may concern:

As avid, daily runners who moved into Napa Valley Club over 20 years ago for the quality of life offered in this very special part of the world, we are deeply concerned for the prospect of the rezoning and proposed building of high density housing along Big Ranch Road. Here are some of the most significant concerns from our perspective as long-time residents:

1. The high density proposed—the potential of up to 1000 dwellings per this 50-60 acre parcel seems excessive, regardless of the other issues and concerns.

2. Big Ranch Road is already seriously under-built to safely and adequately service the existing traffic, especially during certain times of high-volume workday traffic. In addition to the vehicle traffic woes as they exist currently, there is virtually no safe shoulder, sidewalk or path which makes this road an ongoing danger for anyone who tries to walk, run or bike it.

3. Impact on our schools, primarily financial. Has there been a study on the potential impact of high density housing and how will the substantial increase to the load of students be supported without additional funds? Will the bulk of
the financial support come from the existing taxpayers who have been paying into the schools for many years? There should be some data to share with current taxpayers with these regards.

4. The environmental impacts have been investigated by experts and the results of the study are documented for your perusal.

5. If this project is approved/annexed into the City of Napa as is proposed, regardless of the density, how will the City ensure that our current infrastructure is supportive of safe, quality transport of all traffic for all modes of transport—vehicles, pedestrian and emergency personnel? At the very least, Big Ranch Road has sorely needed and currently requires a substantial shoulder along with a path/sidewalk to provide a safety corridor for pedestrians. The city must ensure that any development moving forward incorporates substantial infrastructure upgrades by those who stand to profit from this controversial project.

The safety of all who frequent this road should be of the utmost concern for the City planners!
We thank you for your service and for seriously considering the needs of the current residents, property owners and taxpayers while you work in concert with the community to enhance our Napa neighborhood for everyone! Sincerely,
Corinne and Mike McGue
127 Valley Club Circle
Napa Valley Club
Sent from my iPad

Napa Solano Audubon Society
P.O. Box 10006
Napa, CA 94581
[email protected]
707-246-2795
December 2, 2024
To: Steve Potter, City Manager; Tiffany Carranza, City Clerk - to be distributed to All City Council Members and Planners for Review Prior to City Council Meeting on 12-3-24 Re: Big Ranch Road Annexation
This report is submitted on behalf of Napa-Solano Audubon Society (NSAS) to address the proposed zoning amendment to annex to the city of Napa. The area is located at the northeastern corner of the City of Napa within the Rural Urban Limit (“RUL”), on the west side of Big Ranch Road.

A key component of the mission of Napa-Solano Audubon is to promote conservation and scientiﬁc understanding of wild birds and their habitats. This report includes observations and recommendations based on the number, abundance, and status of the bird species noted across various habitats on this site.

The observation was conducted on November 30, 2024 by Mark Stephenson, NSAS Board President, and Pam Condos, NSAS Board Director, both experienced with identifying birds and their habitats. The observation lasted from 8:32 am to 11:32 am. Weather was clear with no wind. Beginning temperature was 36°F; ending temperature was 58°F. Birds were identiﬁed visually and by ear. The survey included birds identiﬁed and present on the site, foraging within the habitat, as well as a few ﬂying above and/or landing on the site area.

The total number of species recorded was 44 and the total number of birds recorded was 500 over a three hour observation window.

Habitat at the site included oak woodland, oak savannah, blackberry thickets, open ﬁeld, redwood groves, and vineyards. Additionally, signiﬁcant areas of water with reedy plant growth, indicative of wetlands, were present and observed being utilized by several species for feeding and cover. Photos of the habitats and a number of the species observed are included in this report for reference.

It is critical to note that this single observation represents only a snapshot of the birds and wildlife that use this site and surrounding habitats for territory, breeding, nesting, resting, cover, feeding, and raising young. Species observed during this observation include residents and overwintering birds. It does not by any means include all the species that are present and rely on this land during breeding and migratory seasons throughout the year. It is expected that species numbers would increase signiﬁcantly during migration and nesting seasons and the total number of species that use this area year-round is predictably between 75-100 species based on year-long surveys in similar habitats in our city and county that we have completed.
napasolanoaudubon.com
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783

This report supports the ﬁndings of Dr. S. Smallwood who performed a similar observation October 30, 2024. His report also includes mammals and amphibians and other wildlife that we did not survey that may include other endangered or threatened species such as the Monarch Butterﬂy. (Refer to his detailed and extensive report regarding Big Ranch Road Annexation submitted to Michael Allen, Senior Planner, Community Development Department on November 20, 2024). Both Dr. Smallwood and NSAS observed approximately 50 species of birds across habitats and we concur with Dr. Smallwood that this is a small sampling of what constitutes a rich wildlife environment.

NSAS contends that annexation will have signiﬁcant impacts that were not accurately or responsibly analyzed in the General Plan Update EIR (GPU-EIR). Additionally, there are several special-status species and bird endemic only to California that are not addressed in the GPU-EIR.

Therefore, we strongly emphasize and support the need to perform a comprehensive, year- long, on-site Environmental Impact Report (EIR) that covers seasonal migration and nesting months. This will enable a broad, in-depth, and accurate representation of the species that live, feed, breed, overwinter, and migrate on these varied habitats of the proposed annexation land. To ignore this component would result in an irresponsible and permanent loss of wildlife and critical habitat for many wildlife species.

Sincerely,
Mark Stephenson, President
Napa-Solano Audubon Society
[email protected]
NapaSolanoBirds.org Page 2
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Table 1: Species of birds observed during NSAS survey November 30, 2024.

Key: WL= ‘Watch List’ of California Department of Fish and Wildlife (CDFW) FP = ‘Fully Protected’ by CDFW.

S = Considered ‘Sensitive’ by Bureau of Land Management (BLM) BCC = Considered 'Bird of Conservation Concern’ by U.S. Fish and Wildlife Service (USFWS)
BOP = Raptors, also referred to as "birds of prey” (BOP) , are a valuable resource to the State of California, and therefore all raptors are protected under State law (CDFW)
Bird Species (common name/scientiﬁc name) Count Status Comments Canada Goose (Branta canadensis) 35 Overﬂight, landed in site’s northern open ﬁeld.

California Quail (Callipepla californica) 10 Living in blackberry bushes. Used for cover.

Mourning Dove (Zenaida macroura) 12 Perched on wire at site. Feeding next to blackberry bushes
Anna's Hummingbird (Calypte anna) 7 Feeding around oak woodlands.

Killdeer (Charadrius vociferus) 2 Overﬂight, landed in site’s northern open ﬁeld.

California Gull (Larus californicus) 1 WL Overﬂight. Landed on property adjacent to site.

Great Blue Heron (Ardea herodias) 1 Overﬂight, landed in site’s northern open ﬁeld.

Turkey Vulture (Cathartes aura) 4 BOP Overﬂight.

White-tailed Kite (Elanus leucurus) 2 FP, S Observed on site at another date.

Cooper's Hawk (Astur cooperii) 1 WL, BOP Perched in oak woodland.

Red-shouldered Hawk (Buteo lineatus) 1 BOP Perched in oak woodland Red-tailed Hawk (Buteo jamaicensis) 5 BOP Perched in oak woodland and ﬂying overhead.

American Barn Owl (Tyto furcata) 1 BOP Observed by landowner. Evidence of presence (feather/pellets).

Great Horned Owl (Bubo virginianus) 2 BOP Observed by landowner. See photo.

Evidence of presence (pellets).

Downy Woodpecker (Dryobates pubescens) 2 Feeding in oak woodland.

Nuttall's Woodpecker (Dryobates nuttallii) 4 BCC Feeding in oak woodland.

Northern Flicker (Red-shafted and Intergrade)
(Colaptes auratus [cafer Group])
11 Flying/perching across site.

American Kestrel (Falco sparverius) 1 BOP Heard on site.

Black Phoebe (Sayornis nigricans) 10 Feeding across site.

California Scrub- Jay (Aphelocoma California) 10 Feeding across site.

American Crow (Corvus brachyrhynchos) 20 Flying overhead.

Common Raven (Corvus corax) 2 Flying overhead.

NapaSolanoBirds.org Page 3
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Total number of birds observed during (1) three-hour period = 500 Oak Titmouse (Baeolophus inornatus) 15 BCC Feeding across site, particularly in oak woodland and savannah.

Bushtit (Psaltriparus minimus) 36 Feeding across site.

Ruby-crowned Kinglet (Corthylio calendula) 16 Winter visitor. Feeding across site.

White-breasted Nuthatch (Sitta carolinensis) 8 Feeding in oak woodland.

Bewick's Wren (Thryomanes bewickii) 1 Feeding and using ground cover for hiding.

European Starling (Sturnus vulgaris) 2 Perched on wire at site.

Northern Mockingbird (Mimus polyglottos) 6 Feeding across site.

Western Bluebird (Sialia mexicana) 10 Flying overhead. Feeding on ground.

Hermit Thrush (Catharus guttatus) 1 Feeding and taking cover at western creekside border.

American Robin (Turdus migratorius) 18 Feeding in trees across site.

Cedar Waxwing (Bombycilla cedrorum) 2 Feeding.

House Sparrow (Passer domesticus) 7 Feeding.

House Finch (Haemorhous mexicanus) 40 Feeding.

Lesser Goldﬁnch (Spinus psaltria) 16 Feeding.

American Goldﬁnch (Spinus tristis) 8 Feeding.

Fox Sparrow (Sooty) (Passerella iliaca
[unalaschcensis Group])
3 Feeding in blackberry bushes.

White-crowned Sparrow (Zonotrichia
leucophrys)
62 Winter visitor. Feeding across site.

Golden-crowned Sparrow (Zonotrichia
atricapilla)
10 Winter visitor. Feeding across site.

Lincoln's Sparrow (Melospiza lincolnii) 2 Feeding in water patch reed area.

California Towhee (Melozone crissalis) 6 Across site.

Spotted Towhee (Pipilo maculatus) 1 Flying into blackberry bushes.

Yellow-rumped Warbler (Setophaga coronata) 86 Feeding across site.

NapaSolanoBirds.org Page 4
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Photos of habitats: NSAS survey November 30, 2024.

Aerial view of site and outline of observation area
Oak Woodland (with seasonal creek) and Oak Savannah
Potential Wetlands with Sedges and Reed Species
NapaSolanoBirds.org Page 5
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783

Photos of some of the bird species observed on site:

All photos taken by Pam Condos and Mark Stephenson
NapaSolanoBirds.org Page 6
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Downy Woodpecker Nuttall’s Woodpecker
Bewick’s Wren Bushtit (female)
American Robin Western Bluebird
NapaSolanoBirds.org Page 7
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 California Quail
Oak Titmouse Yellow-Rumped Warbler
Fox Sparrow White-Crowned Sparrows
Northern Flicker
(Rare Intergrade Subspecies
NapaSolanoBirds.org Page 8
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Golden-Crowned Sparrow
Lincoln’s Sparrow
White-Tailed Kite
Barn Owl
Great Horned Owl
Evidence of Barn Owl (feather/pellets)
and Great Horned Owl (pellets)
NapaSolanoBirds.org Page 9
Napa Solano Audubon is a 501(c)(3) Nonpro7it organization. • California tax ID: 94-2375760 • Federal tax ID (EIN): 237325783 Red-Shouldered Hawk
Red-Tailed Hawk
American Kestrel
Cooper’s Hawk
From: Rachel Stark
To: Clerk
Cc: Ben Hardisty
Subject: Big Ranch Annexation: Letter to City Council
Date: Tuesday, December 3, 2024 10:46:27 AM
[EXTERNAL]
Dear City Council-
I write to you today to encourage you to delay the Big Ranch Road annexation decision until a site specific EIR is done on the area specifically due to the below concerns:
1- Environment: A number of species live in the 50+ acres that city planning is proposing to annex. Dr. Smallwood's report and the report from the Napa Audubon Society confirmed this. Both saw over 40+ species some which were on the watch and protected list.

I see rabbits/hares daily, and have also seen coyotes, river otter, hawks and more. 2- Safety access concerns: Big Ranch Road already backs-up daily to Garfield and sometimes Rosewood around 3:30pm. With no access east and access west only between El Centro and Trancas (which is 1.3 miles), I'm very concerned in the current state that I will not be able to have an emergency access vehicle reach our house in a time of need. Big Ranch has very limited shoulders on the road and in many parts no shoulders. In addition, I'm concerned I will not be able to exit in an emergency due to the poor infrastructure of Big Ranch. 3- Drainage: There are current drainage/flooding issues and the City's General Plan EIR mentioned but did not dive into this. These issues are driven by Salvador Creek. The creek has offshoots bordering the annexation parcels.
4- Air Quality and Greenhouse Gas Emissions: There are currently about 450 homes in between El Centro and Trancas. This upzoning would TRIPLE the number of homes. All the homes would be CAR DEPENDENT as there is nothing walkable (also mentioned in General plan) and no bus routes are in walking distance. Dr. Clark confirmed this.

These are a few of the issues of concern and the General Plan EIR was done with broad brush strokes and did not adequately cover any of the above.

A site specific EIR must be done as required by CEQA for this annexation.

Kind regards,
Ben Hardisty and Rachel Stark
1414 Rosewood Lane

Recently, development began on "The Farm" (property that had been donated for a grammar school, was used by Vintage High to teach agriculture, then sold and is now under construction).

It is located between Sierra Ave, Villa Ln and Garfield Park.

With our recent rains, Villa Ln at both Morningglory and Blackberry were flooded.

The houses haven't even been constructed yet.
*
Where does the City of Napa intend for rainwater to be diverted to? With the loss of land for
infiltration and saturation that comes with increased density and build out, there will be an increase in rainwater runoff. Where will this runoff water be diverted to? *
3)
It was known with the previous General Plan
(I believe when the Big Ranch Specific Plan was created), that Trancas would be at a very low functioning level after build out of the area between Jefferson & Big Ranch or Trancas and Rosewood. That was previous to the increase of density and approval of the complexes on Valle Verde and the changes/density for "The Farm" on Sierra Ave.

I believe that by 1970, the City planned to extend Trower to Big Ranch Rd. Instead it has approved the connection between Sierra and Villa, even tho Sierra from Hwy 29 and Jefferson does not meet the citiy's "collector street" requirements or standards. (It is not wide enough, there are no sidewalks and the lighting is not efficient but variances were granted)
(Even the impact of drainage from Sierra, Villa Ln and other streets to Salvador Creek is harmful to species that live within this waterway, such as the Western Pond Turtle.) Thank you,
Susan Rushing-Hart

Napa, Ca 94558

From: Richard Drury
To: Michael Allen; Steve Potter; Vincent Smith; Clerk
Subject: BIG RANCH ROAD ANNEXATION City Council Agenda Item 13.A. (Dec. 3, 2024) Date: Tuesday, December 3, 2024 1:14:42 PM
Attachments: 2024.12.03.BigRanch CC Supp ComLtr 2 w attachment.pdf [EXTERNAL]
Dear Mayor, City Council and City Clerk:

Attached please find the second supplemental comment letter of Protect Big Ranch concerning the proposed annexation of the Big Ranch Road parcels, which is Agenda Item 13.A for tonight's meeting. The attachment includes the recent decision of the Marin County Superior Court in the case of Committee for Tiburon v. Town of Tiburon. In that case, the court held that the agency must consider all reasonably foreseeable environmental impacts of a proposed project in a CEQA document. Please include this letter in the administrative record for the matter.

Thank you.

Richard Drury
--
Richard Drury
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
(510) 836-4200
[email protected]

BY E-MAIL AND HAND DELIVERY

December 2, 2024

VIA EMAIL

Re: File No. PL23-0143 BIG RANCH ROAD ANNEXATION
City Council Agenda Item 13.A. (Dec. 3, 2024)
Supplemental Comment Letter

Dear Mayor Sedgley and Honorable Members of the City Council:

I am writing on behalf of Protect Big Ranch (“PBR”), a California non-profit unincorporated association composed of residents living in and around the City of Napa (“City”).

This letter supplements our letter dated November 29, 2024 concerning the proposed annexation of

51.5 acres of land into the City boundaries in the Big Ranch Road area for the purpose of allowing the construction of up to 927 units of housing (“Project”). While PBR supports construction of housing at a sustainable density in the area, PBR urges the City to conduct environmental review under the California Environmental Quality Act (“CEQA”) prior to approving the annexation proposal. This will ensure that the annexation’s environmental impacts are adequately analyzed, disclosed to the public, and mitigated to the extent feasible.

In addition to the issues raised in our November 29, 2024 letter requiring CEQA review, we submit herewith supplemental comments by atmospheric scientist, Dr. James Clark. Dr. Clark has prepared detailed air quality modeling, using the methodology required by the Bay Area Air Quality Management District (“BAAQMD”). Dr. Clark concludes that the Project will have significant impacts related to reactive organic gases (“ROGs”) and greenhouse gases. These impacts were not analyzed or mitigated in the 2040 General Plan Update Environmental Impact Report (“GPU EIR”). These impacts are significant offsite impacts and peculiar project-specific impacts that must be analyzed and mitigated in project-level EIR prior to a decision of whether to proceed with the annexation. This information is significant new information that requires project- level CEQA review.

Big Ranch Road Annexation
December 2, 2024

Page 2 of 2 ends

In light of the attached comments from Dr. Clark, and for the reasons set forth in our letter dated November 29, 2024, the City must prepare an EIR prior to proceeding with a vote on the Big Ranch Annexation. The draft EIR should be circulated for public review and comment in accordance with CEQA. Thank you for considering these comments.

Sincerely,
Richard Toshiyuki Drury

LOZEAU DRURY LLP
1 | Page

December 2, 2024

Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612

Attn: Mr. Richard Drury
Subject: Co
mment Letter on Big Ranch Road Annexation (PL 23-
1043) And Need For CEQA Review, Napa, CA.

Dear Mr. Drury:

At the request of Lozeau Drury LLP (Lozeau Drury), Clark and Associates (Clark) has reviewed materials related to the above referenced project.

Project Description:

Clark & Associates
Environmental Consulting, Inc.

OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]

2 | Page

Figure 1: Project Site Location

As is evident from the figure above, the annexed area is adjacent to Vintage High School, and other residences. The development of the Project Site would introduce a new source of pollution into the community that are currently not present. The c onstruction of housing on the Project Site would include a number of phases that would generate criteria air pollutants (volatile organic compounds (VOCs), oxides of nitrogen ( NOx), carbon monoxide ( CO), oxides of sulfur ( SOx), and particulate

3 | Page
matter (including course particulate matter (PM10) and fine particulate matter (PM2.5)) along with toxic air contaminants (e.g, TACs include diesel particulate matter (DPM) and VOCs such as benzene, 1,3- butadiene, and acrolein) during the construction phase of the Project . Emissions are expected from the construction activities including:
• Site Preparation;
• Grading;
• Building Construction of Housing;
• Infrastructure Improvements (i.e., i nstallation of roadways, curbs, gutters, sewer system, and electrical infrastructure);
• Paving;
• Architectural Coating; and
• Materials Deliveries and Construction Workers Commuting Under current County zoning, the subject parcels are designated Residential Country (RC) which provides for one dwelling unit per parcel. They also have a sub- designation of Urban Reserve (UR) that acknowledges the parcels are anticipated to annex to the C ity prior to any substantial residential development. According to the Staff Report, before any new development can occur on these parcels, General Plan Policy LUCD 24 -1 requires that a master plan be prepared for the Big Ranch Road area, including the entire approximately 51.5 acres to be annexed as well as the remaining parcels not being annexed but that are within the Big Ranch Road area and the City’s SOI and RUL.

Attachment 3 to the Annexation Proposal (Big Ranch Road Annexation - CEQA Initial Study for Determination of Consistency (with the 2040 General Plan EIR)) states that the 2040 General Plan would establish buffers between potential air pollution sources and sensitive receptors and limit pollution during construction. The attachment also states that because the effect of these reductions (from feasible mitigation measures) cannot be quantified and in consideration of the extent by which the 2040 General Plan development would exceed some of Bay Area Air Quality Management District’s ( BAAQMD’s) significance thresholds, the General Plan’s impact on the cumulatively

4 | Page
considerable increase in criteria pollutants for which the region is in nonattainment is significant and unavoidable.

In the Air Quality analysis of the annexation, the Staff found that the proposed annexation would not result in a substantial increase in future population beyond what is already assumed by the General Plan Update EIR for the Project Site. No development or construction is proposed a s part of the Project. The Air Quality Analysis also found that future development would be subject to individual review; new sources would be evaluated through the BAAQMD permit process and/or the CEQA process to identify and mitigate any significant exposures.

Under the BAAQMD’s 2010 CEQA Guidance a Screening Criteria based on the allowable Operational Criteria Pollutant, Operational Greenhouse Gas (GHG), and C onstruction-Related Criteria Pollutant was published. Table 3-1 from the 2010 CEQA Guidance provides the screening size for single family homes (allowable under the current and future zoning).

Figure 2: Table 3-1 From 2010 BA-AQMD CEQA Guidance

Based on the screening above it is clear that even using minimum allowable zoning criteria of 8 units per acre (412 units) would exceed the O perational Criteria Pollutant, Operational GHG, and Construction-Related Criteria Pollutant screening size from the 2010 Guidance . The excess NOx emissions would impact visibility in the area (NOx reacts with other chemicals in the air to form both particulate matter and ozone) as well as aggravating respiratory diseases (in particular asthma leading to respiratory symptoms, increase hospital admissions and visits to the ER. Reactive Organic Gases

5 | Page
(ROGs) are a class of volatile organic compounds listed by the California Air Resources Board (CARB) which are important in the formation of ground level ozone.

In 2022, BAAQMD released new CEQA guidance which included a new chapter with best practices for centering Environmental Justice, health, and equity; a new appendix with the rationale for the recommended climate impacts thresholds of significance; a new appendix to assist with developing community-scale greenhouse gas (GHG) reduction strategies aligned with the State CEQA Guidelines and the Air District’s plan -level thresholds; an appendix with guidance on using the California Emissions Estimator Model (CalEEMod 2022) for Bay Area projects; and a new criteria pollutants and precursors screening tool for mixed land use projects.

As part of the 2022 guidance, BAAQMD also released an Excel -based tool that provides CEQA lead agencies with a conservative indication of whether implementing a proposed mixed land use project could result in potentially significant criteria air pollutants and precursors impacts. Using the minimum allowable zoning criteria of 8 units per acre (412 units) in the Excel model results in an exceedance of the CEQA construction threshold for BAAQMD, requiring that the Project undergo further analysis.

6 | Page

Figure 4: Screening Model Of Project Site (Maximum)

To further assess the likely impacts from the annexation of the property into the City’s sphere of influence along with the development of the property into single family homes I have used the latest version of the California Air Pollution Control Officers Association (CAPCOA) California Emissions Estimator Model (CalEEMOD) to calculate the site -specific potential construction and operational emissions. Version 2022.1, released in April 2022, utilizes widely accepted methodologies for estimating emissions combined with default data that can be used when site -specific information is not available. Sources of these methodologies and default data include the United States Environmental Protection Agency’s (USEPA) AP -42 emission factors, California Air Resources Board’s (CARB) vehicle emission models, and studies commissioned by California agencies such as the California Energy Commission (CEC) and California Department of Resources Recycling and Recovery (CalRecycle).

The results of my analysis are include d as an attachment to this letter. Using the maximum allowable zoning criteria of 18 units per acre (927 units) on the 51.5-acre site, allowing the model to run with all the default model input parameters, and assuming the construction would occur in a linear manner, I have confirmed that the Project would results in air quality impacts during the construction phase that would exceed the BA -AQMD’s significance thresholds for at least one criter ia pollutant.

Table 2.1 of the model output shows that during the construction phase releases of reactive organic gases (ROGs) would exceed the daily al lowable maximum level of 54 lbs per day. During the construction phase of the project the greenhouse gas emissions (GHGs) would be approximately 4,400 metric tons of carbon dioxide equivalent (MTCO
2eq). Amortizing that amount over thirty years would
add an additional 146.7 MTCO2eq of GHG to the operational emissions of 8,477 MTCO 2eq of GHG calculated by the model (equaling 8,624 MTCO2eq of GHG per year). Even with mitigation measures

7 | Page
to reduce ope rational GHG emissions this would represent a significant increase in GHG for the community.

Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant impacts if allowed to proceed. A n EIR should be prepared to address these substantial concerns related to the construction and operational emissions from the Project that clearly were not identified in the 2040 General Plan EIR.

Sincerely,

Attachment: CalEEMOD Model Output
Big Ranch Housing Detailed Report, 12/1/2024
1 / 54
Big Ranch Housing Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Y ear, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Site Preparation (2025) - Unmitigated

3.3. Grading (2025) - Unmitigated

3.5. Building Construction (2025) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated
Big Ranch Housing Detailed Report, 12/1/2024
2 / 54

3.11. Building Construction (2028) - Unmitigated

3.13. Building Construction (2029) - Unmitigated

3.15. Building Construction (2030) - Unmitigated

3.17. Paving (2030) - Unmitigated

3.19. Architectural Coating (2030) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use
Big Ranch Housing Detailed Report, 12/1/2024
3 / 54

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles
Big Ranch Housing Detailed Report, 12/1/2024
4 / 54

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Big Ranch Housing Detailed Report, 12/1/2024
5 / 54

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report
Big Ranch Housing Detailed Report, 12/1/2024
6 / 54

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
Big Ranch Housing Detailed Report, 12/1/2024
7 / 54

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Big Ranch Housing
Construction Start Date 1/1/2025
Operational Y ear 2030
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.60
Precipitation (days) 42.2
Location 38.33679413921547, -122.29924256127384
County Napa
City Unincorporated
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 808
EDFZ 2
Electric Utility Pacific Gas & Electric Company
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Single Family
Housing
927 Dwelling Unit 51.5 1,807,650 10,857,818 — 2,540 Single Family Homes
Big Ranch Housing Detailed Report, 12/1/2024
8 / 54

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 340 340 31.7 31.0 0.06 1.37 7.81 9.18 1.26 3.97 5.23 — 7,868 7,868 0.27 0.53 18.1 8,050 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.89 3.28 29.8 29.1 0.06 1.23 3.75 4.99 1.14 1.46 2.60 — 7,770 7,770 0.29 0.54 0.50 7,938 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 70.2 70.1 14.1 19.2 0.03 0.57 2.41 2.91 0.53 0.96 1.49 — 5,500 5,500 0.19 0.38 5.58 5,625 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 12.8 12.8 2.57 3.51 0.01 0.10 0.44 0.53 0.10 0.18 0.27 — 911 911 0.03 0.06 0.92 931 Exceeds
(Daily
Max)
— — — — — — — — — — — — — — — — — —
Threshol
d
— 54.0 54.0 — — 82.0 — — 54.0 — — — — — — — — —
Unmit. — Y es No — — No — — No — — — — — — — — —
Exceeds
(Average
Daily)
— — — — — — — — — — — — — — — — — —
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—————————54.0——82.0——54.054.0—Threshol
d
Unmit. — Y es No — — No — — No — — — — — — — — —

2.2. Construction Emissions by Y ear, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Y ear TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 4.02 3.38 31.7 31.0 0.06 1.37 7.81 9.18 1.26 3.97 5.23 — 6,772 6,772 0.27 0.06 0.74 6,798 2026 2.91 2.47 14.3 28.8 0.04 0.42 3.46 3.87 0.39 0.84 1.22 — 7,868 7,868 0.26 0.53 18.1 8,050 2027 2.69 2.36 13.6 27.7 0.04 0.37 3.46 3.83 0.35 0.84 1.19 — 7,764 7,764 0.24 0.51 16.7 7,939 2028 2.61 2.21 12.9 26.8 0.04 0.34 3.46 3.79 0.31 0.84 1.15 — 7,654 7,654 0.23 0.51 15.2 7,827 2029 2.51 2.12 12.3 26.0 0.04 0.31 3.46 3.77 0.27 0.84 1.11 — 7,537 7,537 0.23 0.49 13.8 7,703 2030 340 340 6.31 10.4 0.01 0.22 0.55 0.56 0.20 0.13 0.23 — 1,630 1,630 0.06 0.01 1.56 1,636 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 3.89 3.28 29.8 29.1 0.06 1.23 3.75 4.99 1.14 1.46 2.60 — 7,770 7,770 0.29 0.54 0.50 7,938 2026 2.86 2.43 14.8 27.4 0.04 0.42 3.46 3.87 0.39 0.84 1.22 — 7,676 7,676 0.28 0.54 0.47 7,844 2027 2.66 2.32 14.0 26.5 0.04 0.37 3.46 3.83 0.35 0.84 1.19 — 7,577 7,577 0.26 0.52 0.43 7,738 2028 2.56 2.15 13.3 25.7 0.04 0.34 3.46 3.79 0.31 0.84 1.15 — 7,470 7,470 0.25 0.52 0.39 7,631 2029 2.47 2.07 12.7 24.9 0.04 0.31 3.46 3.77 0.27 0.84 1.11 — 7,357 7,357 0.24 0.50 0.36 7,512 2030 2.40 2.01 12.3 24.2 0.04 0.28 3.46 3.74 0.26 0.84 1.10 — 7,239 7,239 0.24 0.50 0.32 7,394 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 1.93 1.62 14.1 15.1 0.03 0.57 2.34 2.91 0.53 0.96 1.49 — 3,458 3,458 0.13 0.08 1.01 3,486 2026 2.03 1.72 10.4 19.2 0.03 0.30 2.40 2.70 0.28 0.58 0.86 — 5,500 5,500 0.19 0.38 5.58 5,625 2027 1.88 1.64 9.89 18.6 0.03 0.27 2.40 2.67 0.25 0.58 0.83 — 5,429 5,429 0.18 0.37 5.14 5,549 Big Ranch Housing Detailed Report, 12/1/2024
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2028 1.82 1.53 9.38 18.1 0.03 0.24 2.41 2.65 0.22 0.59 0.81 — 5,367 5,367 0.18 0.37 4.72 5,486 2029 1.76 1.48 8.99 17.5 0.03 0.22 2.40 2.63 0.19 0.58 0.78 — 5,271 5,271 0.17 0.36 4.26 5,386 2030 70.2 70.1 2.44 4.61 0.01 0.07 0.40 0.47 0.06 0.10 0.16 — 1,032 1,032 0.04 0.05 0.59 1,047 Annual — — — — — — — — — — — — — — — — — —
2025 0.35 0.30 2.57 2.76 0.01 0.10 0.43 0.53 0.10 0.18 0.27 — 572 572 0.02 0.01 0.17 577 2026 0.37 0.31 1.90 3.51 0.01 0.05 0.44 0.49 0.05 0.11 0.16 — 911 911 0.03 0.06 0.92 931 2027 0.34 0.30 1.81 3.39 0.01 0.05 0.44 0.49 0.05 0.11 0.15 — 899 899 0.03 0.06 0.85 919 2028 0.33 0.28 1.71 3.30 0.01 0.04 0.44 0.48 0.04 0.11 0.15 — 889 889 0.03 0.06 0.78 908 2029 0.32 0.27 1.64 3.19 0.01 0.04 0.44 0.48 0.04 0.11 0.14 — 873 873 0.03 0.06 0.71 892 2030 12.8 12.8 0.44 0.84 < 0.005 0.01 0.07 0.09 0.01 0.02 0.03 — 171 171 0.01 0.01 0.10 173

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 81.4 78.8 31.1 209 0.43 1.27 32.3 33.6 1.25 8.22 9.47 375 55,233 55,608 41.2 2.14 106 57,382 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 75.4 73.0 33.5 163 0.41 1.25 32.3 33.6 1.23 8.22 9.45 375 53,385 53,760 41.6 2.32 15.4 55,506 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 76.5 74.2 29.0 174 0.39 1.01 30.8 31.8 0.99 7.82 8.81 375 49,092 49,467 41.3 2.19 52.2 51,203 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 14.0 13.5 5.30 31.8 0.07 0.18 5.61 5.80 0.18 1.43 1.61 62.1 8,128 8,190 6.83 0.36 8.64 8,477 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Exceeds
(Daily
Max)
Threshol
d
— 54.0 54.0 — — 82.0 — — 54.0 — — — — — — — — —
Unmit. — Y es No — — No — — No — — — — — — — — —
Exceeds
(Average
Daily)
— — — — — — — — — — — — — — — — — —
Threshol
d
— 54.0 54.0 — — 82.0 — — 54.0 — — — — — — — — —
Unmit. — Y es No — — No — — No — — — — — — — — —
Exceeds
(Annual)
— — — — — — — — — — — — — — — — — —
Threshol
d
— 10.0 10.0 — — 15.0 — — 10.0 — — — — — — — — —
Unmit. — Y es No — — No — — No — — — — — — — — —

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 29.5 27.9 18.7 152 0.35 0.28 32.3 32.6 0.27 8.22 8.49 — 35,822 35,822 1.80 1.88 93.0 36,521 Area 50.8 50.4 3.57 54.1 0.02 0.27 — 0.27 0.27 — 0.27 0.00 4,044 4,044 0.08 0.01 — 4,049 Energy 1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 14,851 14,851 1.58 0.09 — 14,918 Water — — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783 Waste — — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098 Refrig. — — — — — — — — — — — — — — — — 12.9 12.9
Total 81.4 78.8 31.1 209 0.43 1.27 32.3 33.6 1.25 8.22 9.47 375 55,233 55,608 41.2 2.14 106 57,382 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Daily,
Winter
(Max)
Mobile 28.4 26.6 21.6 158 0.33 0.29 32.3 32.6 0.27 8.22 8.49 — 34,115 34,115 2.16 2.06 2.41 34,786 Area 46.0 45.8 3.08 1.31 0.02 0.25 — 0.25 0.25 — 0.25 0.00 3,904 3,904 0.07 0.01 — 3,908 Energy 1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 14,851 14,851 1.58 0.09 — 14,918 Water — — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783 Waste — — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098 Refrig. — — — — — — — — — — — — — — — — 12.9 12.9
Total 75.4 73.0 33.5 163 0.41 1.25 32.3 33.6 1.23 8.22 9.45 375 53,385 53,760 41.6 2.32 15.4 55,506 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 27.4 25.8 19.9 144 0.33 0.28 30.8 31.0 0.26 7.82 8.08 — 33,560 33,560 1.94 1.94 39.3 34,225 Area 48.0 47.9 0.32 26.1 < 0.005 0.02 — 0.02 0.02 — 0.02 0.00 166 166 < 0.005 < 0.005 — 166 Energy 1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 14,851 14,851 1.58 0.09 — 14,918 Water — — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783 Waste — — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098 Refrig. — — — — — — — — — — — — — — — — 12.9 12.9
Total 76.5 74.2 29.0 174 0.39 1.01 30.8 31.8 0.99 7.82 8.81 375 49,092 49,467 41.3 2.19 52.2 51,203 Annual — — — — — — — — — — — — — — — — — —
Mobile 5.00 4.71 3.63 26.3 0.06 0.05 5.61 5.66 0.05 1.43 1.48 — 5,556 5,556 0.32 0.32 6.50 5,666 Area 8.77 8.74 0.06 4.76 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 27.4 27.4 < 0.005 < 0.005 — 27.5 Energy 0.19 0.09 1.61 0.69 0.01 0.13 — 0.13 0.13 — 0.13 — 2,459 2,459 0.26 0.02 — 2,470 Water — — — — — — — — — — — 10.1 85.3 95.5 1.05 0.03 — 130 Waste — — — — — — — — — — — 52.0 0.00 52.0 5.19 0.00 — 182 Refrig. — — — — — — — — — — — — — — — — 2.14 2.14
Total 14.0 13.5 5.30 31.8 0.07 0.18 5.61 5.80 0.18 1.43 1.61 62.1 8,128 8,190 6.83 0.36 8.64 8,477

3. Construction Emissions Details
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3.1. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.94 3.31 31.6 30.2 0.05 1.37 — 1.37 1.26 — 1.26 — 5,295 5,295 0.21 0.04 — 5,314 Dust
From
Material
Movement
— — — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.43 0.36 3.47 3.31 0.01 0.15 — 0.15 0.14 — 0.14 — 580 580 0.02 < 0.005 — 582 Dust
From
Material
Movement
— — — — — — 0.84 0.84 — 0.43 0.43 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
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96.4—< 0.005< 0.00596.196.1—0.03—0.030.03—0.03< 0.0050.600.630.070.08Off-Roa d
Equipm
ent
Dust
From
Material
Movement
— — — — — — 0.15 0.15 — 0.08 0.08 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.05 0.81 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 152 152 < 0.005 0.01 0.64 154 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.03 15.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.59 2.59 < 0.005 < 0.005 0.01 2.63 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Big Ranch Housing Detailed Report, 12/1/2024
15 / 54
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.80 3.20 29.7 28.3 0.06 1.23 — 1.23 1.14 — 1.14 — 6,599 6,599 0.27 0.05 — 6,622 Dust
From
Material
Movement
— — — — — — 3.59 3.59 — 1.42 1.42 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.15 0.96 8.94 8.53 0.02 0.37 — 0.37 0.34 — 0.34 — 1,989 1,989 0.08 0.02 — 1,996 Dust
From
Material
Movement
— — — — — — 1.08 1.08 — 0.43 0.43 — — — — — — —
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Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.21 0.18 1.63 1.56 < 0.005 0.07 — 0.07 0.06 — 0.06 — 329 329 0.01 < 0.005 — 330 Dust
From
Material
Movement
— — — — — — 0.20 0.20 — 0.08 0.08 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.06 0.92 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 173 173 < 0.005 0.01 0.74 176 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.08 0.84 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 162 162 0.01 0.01 0.02 164 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.02 0.02 0.24 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 49.2 49.2 < 0.005 < 0.005 0.10 49.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 8.14 8.14 < 0.005 < 0.005 0.02 8.27 Big Ranch Housing Detailed Report, 12/1/2024
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.35 1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.14 0.12 1.10 1.38 < 0.005 0.05 — 0.05 0.04 — 0.04 — 253 253 0.01 < 0.005 — 254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.02 0.20 0.25 < 0.005 0.01 — 0.01 0.01 — 0.01 — 41.9 41.9 < 0.005 < 0.005 — 42.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.44 1.32 1.26 14.0 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,698 2,698 0.09 0.12 0.32 2,735 Vendor 0.20 0.10 3.97 1.52 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,674 2,674 0.10 0.40 0.18 2,797 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.15 0.14 0.12 1.42 0.00 0.00 0.28 0.28 0.00 0.07 0.07 — 288 288 0.01 0.01 0.56 292 Vendor 0.02 0.01 0.41 0.16 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 283 283 0.01 0.04 0.32 296 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.02 0.26 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 47.6 47.6 < 0.005 < 0.005 0.09 48.4 Vendor < 0.005 < 0.005 0.08 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.8 46.8 < 0.005 0.01 0.05 49.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Big Ranch Housing Detailed Report, 12/1/2024
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite truck
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.91 0.77 7.04 9.26 0.02 0.27 — 0.27 0.25 — 0.25 — 1,712 1,712 0.07 0.01 — 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.14 1.28 1.69 < 0.005 0.05 — 0.05 0.05 — 0.05 — 283 283 0.01 < 0.005 — 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.42 1.31 0.92 14.4 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,842 2,842 0.06 0.11 11.3 2,887 Vendor 0.20 0.10 3.57 1.41 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,629 2,629 0.10 0.40 6.74 2,757 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Big Ranch Housing Detailed Report, 12/1/2024
20 / 54
Worker 1.38 1.26 1.15 13.0 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,649 2,649 0.08 0.12 0.29 2,686 Vendor 0.20 0.09 3.78 1.43 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,630 2,630 0.10 0.40 0.18 2,753 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.97 0.88 0.74 8.95 0.00 0.00 1.92 1.92 0.00 0.45 0.45 — 1,910 1,910 0.05 0.08 3.50 1,939 Vendor 0.14 0.07 2.64 1.02 0.01 0.03 0.49 0.51 0.03 0.13 0.16 — 1,878 1,878 0.07 0.29 2.08 1,967 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.18 0.16 0.14 1.63 0.00 0.00 0.35 0.35 0.00 0.08 0.08 — 316 316 0.01 0.01 0.58 321 Vendor 0.03 0.01 0.48 0.19 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 311 311 0.01 0.05 0.34 326 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.23 1.03 9.39 12.9 0.02 0.34 — 0.34 0.31 — 0.31 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Big Ranch Housing Detailed Report, 12/1/2024
21 / 54
2,405—0.020.102,3972,397—0.31—0.310.34—0.340.0212.99.391.031.23Off-Roa d
Equipm
ent
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.88 0.74 6.71 9.24 0.02 0.24 — 0.24 0.22 — 0.22 — 1,712 1,712 0.07 0.01 — 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.16 0.13 1.22 1.69 < 0.005 0.04 — 0.04 0.04 — 0.04 — 283 283 0.01 < 0.005 — 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.28 1.25 0.82 13.4 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,790 2,790 0.06 0.11 10.4 2,834 Vendor 0.18 0.08 3.41 1.34 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,577 2,577 0.08 0.38 6.25 2,700 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.25 1.21 1.05 12.2 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,601 2,601 0.08 0.12 0.27 2,638 Vendor 0.18 0.08 3.60 1.37 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,579 2,579 0.08 0.38 0.16 2,695 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Average
Daily
Worker 0.87 0.85 0.67 8.37 0.00 0.00 1.92 1.92 0.00 0.45 0.45 — 1,875 1,875 0.05 0.08 3.21 1,904 Vendor 0.13 0.06 2.51 0.97 0.01 0.03 0.49 0.51 0.03 0.13 0.16 — 1,841 1,841 0.06 0.27 1.93 1,926 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.16 0.15 0.12 1.53 0.00 0.00 0.35 0.35 0.00 0.08 0.08 — 310 310 0.01 0.01 0.53 315 Vendor 0.02 0.01 0.46 0.18 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 305 305 0.01 0.05 0.32 319 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Building Construction (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.18 0.99 8.92 12.9 0.02 0.30 — 0.30 0.28 — 0.28 — 2,397 2,397 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.18 0.99 8.92 12.9 0.02 0.30 — 0.30 0.28 — 0.28 — 2,397 2,397 0.10 0.02 — 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Average
Daily
Off-Roa
d
Equipm
ent

0.85 0.71 6.39 9.26 0.02 0.22 — 0.22 0.20 — 0.20 — 1,717 1,717 0.07 0.01 — 1,723 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 1.17 1.69 < 0.005 0.04 — 0.04 0.04 — 0.04 — 284 284 0.01 < 0.005 — 285 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.25 1.14 0.72 12.5 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,741 2,741 0.05 0.11 9.52 2,784 Vendor 0.18 0.08 3.23 1.28 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,516 2,516 0.08 0.38 5.72 2,637 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.20 1.09 0.95 11.4 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,555 2,555 0.07 0.12 0.25 2,592 Vendor 0.18 0.07 3.40 1.33 0.02 0.04 0.70 0.73 0.04 0.19 0.23 — 2,517 2,517 0.08 0.38 0.15 2,633 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.85 0.76 0.60 7.89 0.00 0.00 1.92 1.92 0.00 0.45 0.45 — 1,847 1,847 0.05 0.08 2.94 1,876 Vendor 0.13 0.05 2.39 0.93 0.01 0.03 0.49 0.51 0.03 0.14 0.16 — 1,802 1,802 0.06 0.27 1.77 1,887 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
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Worker 0.15 0.14 0.11 1.44 0.00 0.00 0.35 0.35 0.00 0.08 0.08 — 306 306 0.01 0.01 0.49 311 Vendor 0.02 0.01 0.44 0.17 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 298 298 0.01 0.05 0.29 312 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Building Construction (2029) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.15 0.97 8.58 12.9 0.02 0.28 — 0.28 0.25 — 0.25 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.15 0.97 8.58 12.9 0.02 0.28 — 0.28 0.25 — 0.25 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.82 0.69 6.13 9.22 0.02 0.20 — 0.20 0.18 — 0.18 — 1,712 1,712 0.07 0.01 — 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 1.12 1.68 < 0.005 0.04 — 0.04 0.03 — 0.03 — 283 283 0.01 < 0.005 — 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.19 1.08 0.63 11.8 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,693 2,693 0.05 0.11 8.64 2,736 Vendor 0.16 0.08 3.06 1.24 0.02 0.04 0.70 0.73 0.02 0.19 0.21 — 2,447 2,447 0.08 0.36 5.17 2,562 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.16 1.04 0.85 10.7 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,512 2,512 0.07 0.12 0.22 2,548 Vendor 0.16 0.07 3.23 1.28 0.02 0.04 0.70 0.73 0.02 0.19 0.21 — 2,448 2,448 0.08 0.36 0.13 2,559 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.82 0.74 0.59 7.37 0.00 0.00 1.92 1.92 0.00 0.45 0.45 — 1,811 1,811 0.04 0.08 2.66 1,839 Vendor 0.12 0.05 2.26 0.90 0.01 0.03 0.49 0.51 0.01 0.13 0.15 — 1,748 1,748 0.06 0.26 1.60 1,829 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.15 0.13 0.11 1.34 0.00 0.00 0.35 0.35 0.00 0.08 0.08 — 300 300 0.01 0.01 0.44 304 Vendor 0.02 0.01 0.41 0.16 < 0.005 < 0.005 0.09 0.09 < 0.005 0.02 0.03 — 289 289 0.01 0.04 0.26 303 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.15. Building Construction (2030) - Unmitigated
Big Ranch Housing Detailed Report, 12/1/2024
26 / 54
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.12 0.94 8.39 12.9 0.02 0.26 — 0.26 0.24 — 0.24 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.07 0.66 1.01 < 0.005 0.02 — 0.02 0.02 — 0.02 — 188 188 0.01 < 0.005 — 188 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.01 0.12 0.18 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 31.1 31.1 < 0.005 < 0.005 — 31.2 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Big Ranch Housing Detailed Report, 12/1/2024
27 / 54
——————————————————Daily,
Winter
(Max)
Worker 1.12 1.00 0.85 10.1 0.00 0.00 2.76 2.76 0.00 0.65 0.65 — 2,470 2,470 0.07 0.12 0.20 2,506 Vendor 0.16 0.07 3.07 1.22 0.02 0.02 0.70 0.72 0.02 0.19 0.21 — 2,373 2,373 0.08 0.36 0.12 2,483 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.06 0.76 0.00 0.00 0.21 0.21 0.00 0.05 0.05 — 195 195 < 0.005 0.01 0.26 198 Vendor 0.01 0.01 0.24 0.09 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 186 186 0.01 0.03 0.16 194 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.01 0.14 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 32.3 32.3 < 0.005 < 0.005 0.04 32.8 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 30.7 30.7 < 0.005 < 0.005 0.03 32.2 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.17. Paving (2030) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.77 0.64 6.28 9.90 0.01 0.22 — 0.22 0.20 — 0.20 — 1,511 1,511 0.06 0.01 — 1,516 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
28 / 54
——————————————————Daily,
Winter
(Max)
Off-Roa
d
Equipm
ent

0.77 0.64 6.28 9.90 0.01 0.22 — 0.22 0.20 — 0.20 — 1,511 1,511 0.06 0.01 — 1,516 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.16 0.13 1.29 2.03 < 0.005 0.05 — 0.05 0.04 — 0.04 — 310 310 0.01 < 0.005 — 311 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.02 0.24 0.37 < 0.005 0.01 — 0.01 0.01 — 0.01 — 51.4 51.4 < 0.005 < 0.005 — 51.6 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.05 0.03 0.50 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 119 119 < 0.005 < 0.005 0.35 120 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Daily,
Winter
(Max)
Worker 0.05 0.04 0.04 0.45 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 111 111 < 0.005 0.01 0.01 113 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 0.01 0.01 — 23.0 23.0 < 0.005 < 0.005 0.03 23.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.81 3.81 < 0.005 < 0.005 0.01 3.87 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.19. Architectural Coating (2030) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.78 1.11 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s
339 339 — — — — — — — — — — — — — — — —
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite truck
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 0.16 0.23 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 27.4 27.4 < 0.005 < 0.005 — 27.5 Architect
ural
Coating
s

69.7 69.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.54 4.54 < 0.005 < 0.005 — 4.56 Architect
ural
Coating
s

12.7 12.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.23 0.21 0.12 2.21 0.00 0.00 0.55 0.55 0.00 0.13 0.13 — 530 530 0.01 < 0.005 1.56 533 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.03 0.40 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 102 102 < 0.005 < 0.005 0.14 104 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 17.0 17.0 < 0.005 < 0.005 0.02 17.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

29.5 27.9 18.7 152 0.35 0.28 32.3 32.6 0.27 8.22 8.49 — 35,822 35,822 1.80 1.88 93.0 36,521 Total 29.5 27.9 18.7 152 0.35 0.28 32.3 32.6 0.27 8.22 8.49 — 35,822 35,822 1.80 1.88 93.0 36,521 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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34,7862.412.062.1634,11534,115—8.498.220.2732.632.30.290.3315821.626.628.4Single Family
Housing
Total 28.4 26.6 21.6 158 0.33 0.29 32.3 32.6 0.27 8.22 8.49 — 34,115 34,115 2.16 2.06 2.41 34,786 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing

5.00 4.71 3.63 26.3 0.06 0.05 5.61 5.66 0.05 1.43 1.48 — 5,556 5,556 0.32 0.32 6.50 5,666 Total 5.00 4.71 3.63 26.3 0.06 0.05 5.61 5.66 0.05 1.43 1.48 — 5,556 5,556 0.32 0.32 6.50 5,666

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 3,641 3,641 0.59 0.07 — 3,677
Total — — — — — — — — — — — — 3,641 3,641 0.59 0.07 — 3,677 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 3,641 3,641 0.59 0.07 — 3,677
Total — — — — — — — — — — — — 3,641 3,641 0.59 0.07 — 3,677 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 603 603 0.10 0.01 — 609
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Total — — — — — — — — — — — — 603 603 0.10 0.01 — 609

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 11,209 11,209 0.99 0.02 — 11,240 Total 1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 11,209 11,209 0.99 0.02 — 11,240 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 11,209 11,209 0.99 0.02 — 11,240 Total 1.03 0.52 8.83 3.76 0.06 0.71 — 0.71 0.71 — 0.71 — 11,209 11,209 0.99 0.02 — 11,240 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.19 0.09 1.61 0.69 0.01 0.13 — 0.13 0.13 — 0.13 — 1,856 1,856 0.16 < 0.005 — 1,861 Total 0.19 0.09 1.61 0.69 0.01 0.13 — 0.13 0.13 — 0.13 — 1,856 1,856 0.16 < 0.005 — 1,861

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Daily,
Summer
(Max)
Hearths 0.36 0.18 3.08 1.31 0.02 0.25 — 0.25 0.25 — 0.25 0.00 3,904 3,904 0.07 0.01 — 3,908 Consum
er
Product
s

38.7 38.7 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

6.97 6.97 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

4.81 4.55 0.49 52.8 < 0.005 0.02 — 0.02 0.02 — 0.02 — 141 141 0.01 < 0.005 — 141 Total 50.8 50.4 3.57 54.1 0.02 0.27 — 0.27 0.27 — 0.27 0.00 4,044 4,044 0.08 0.01 — 4,049 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.36 0.18 3.08 1.31 0.02 0.25 — 0.25 0.25 — 0.25 0.00 3,904 3,904 0.07 0.01 — 3,908 Consum
er
Product
s

38.7 38.7 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

6.97 6.97 — — — — — — — — — — — — — — — —
Total 46.0 45.8 3.08 1.31 0.02 0.25 — 0.25 0.25 — 0.25 0.00 3,904 3,904 0.07 0.01 — 3,908 Annual — — — — — — — — — — — — — — — — — —
Hearths < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 15.9 15.9 < 0.005 < 0.005 — 16.0 Consum
er
Product
s

7.06 7.06 — — — — — — — — — — — — — — — —
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————————————————1.271.27Architect
ural
Landsca
pe
Equipm
ent

0.43 0.41 0.04 4.75 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.5 11.5 < 0.005 < 0.005 — 11.5 Total 8.77 8.74 0.06 4.76 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 27.4 27.4 < 0.005 < 0.005 — 27.5

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783
Total — — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783
Total — — — — — — — — — — — 61.3 515 577 6.37 0.16 — 783 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 10.1 85.3 95.5 1.05 0.03 — 130
Total — — — — — — — — — — — 10.1 85.3 95.5 1.05 0.03 — 130 Big Ranch Housing Detailed Report, 12/1/2024
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4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098
Total — — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098
Total — — — — — — — — — — — 314 0.00 314 31.4 0.00 — 1,098 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 52.0 0.00 52.0 5.19 0.00 — 182
Total — — — — — — — — — — — 52.0 0.00 52.0 5.19 0.00 — 182

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Big Ranch Housing Detailed Report, 12/1/2024
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——————————————————Daily,
Summer
(Max)
Single
Family
Housing
— — — — — — — — — — — — — — — — 12.9 12.9
Total — — — — — — — — — — — — — — — — 12.9 12.9
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 12.9 12.9
Total — — — — — — — — — — — — — — — — 12.9 12.9
Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 2.14 2.14
Total — — — — — — — — — — — — — — — — 2.14 2.14

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
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Remove — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 4/10/2025 6/5/2025 5.00 40.0 Site Preparation Grading Grading 6/6/2025 11/7/2025 5.00 110 Grading
Building Construction Building Construction 11/8/2025 2/9/2030 5.00 1,110 Building Construction Paving Paving 2/10/2030 5/26/2030 5.00 75.0 Paving
Architectural Coating Architectural Coating 5/27/2030 9/9/2030 5.00 75.0 Architectural Coating

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Big Ranch Housing Detailed Report, 12/1/2024
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Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor — 8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
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Grading — — — —
Grading Worker 20.0 11.7 LDA,LDT1,LDT2
Grading Vendor — 8.40 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 334 11.7 LDA,LDT1,LDT2
Building Construction Vendor 99.1 8.40 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor — 8.40 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 66.7 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor — 8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
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Architectural Coating 3,660,491 1,220,164 0.00 0.00 —

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation — — 60.0 0.00 —
Grading — — 330 0.00 —
Paving 0.00 0.00 0.00 0.00 10.2

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Single Family Housing 10.2 0%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Y ear and Emission Factor (lb/MWh)
Y ear kWh per Y ear CO2 CH4 N2O
2025 0.00 204 0.03 < 0.005
2026 0.00 204 0.03 < 0.005
2027 0.00 204 0.03 < 0.005
2028 0.00 204 0.03 < 0.005
2029 0.00 204 0.03 < 0.005
2030 0.00 204 0.03 < 0.005
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5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Y ear VMT/Weekday VMT/Saturday VMT/Sunday VMT/Y ear Single Family
Housing
8,751 8,844 7,926 3,155,885 44,991 45,468 40,750 16,225,532

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Single Family Housing —
Wood Fireplaces 0
Gas Fireplaces 185
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 742
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
3660491.25 1,220,164 0.00 0.00 —
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5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 6,515,551 204 0.0330 0.0040 34,975,827

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 31,984,698 144,946,075

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Single Family Housing 582 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
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Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Single Family Housing Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Y ear Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
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Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 13.1 annual days of extreme heat Extreme Precipitation 9.15 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 11.1 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Big Ranch Housing Detailed Report, 12/1/2024
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Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation 3 0 0 N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation 3 1 1 3
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
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The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 20.8
AQ-PM 46.4
AQ-DPM 38.6
Drinking Water 43.0
Lead Risk Housing 19.6
Pesticides 73.6
Toxic Releases 52.1
Traffic 51.8
Effect Indicators —
CleanUp Sites 60.4
Groundwater 48.5
Haz Waste Facilities/Generators 63.6
Impaired Water Bodies 23.9
Solid Waste 0.00
Sensitive Population —
Asthma 53.8
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Cardio-vascular 56.0
Low Birth Weights 12.2
Socioeconomic Factor Indicators —
Education 43.4
Housing 53.1
Linguistic 26.4
Poverty 44.1
Unemployment 5.57

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 60.18221481
Employed 97.89554729
Median HI 63.87783909
Education —
Bachelor's or higher 64.48094444
High school enrollment 26.06185038
Preschool enrollment 86.35955345
Transportation —
Auto Access 48.06877967
Active commuting 64.69908893
Social —
2-parent households 86.57769793
Voting 81.32939818
Neighborhood —
Alcohol availability 15.92454767
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Park access 58.32157064
Retail density 57.80828949
Supermarket access 55.63967663
Tree canopy 78.35236751
Housing —
Homeownership 46.75991274
Housing habitability 73.60451687
Low-inc homeowner severe housing cost burden 83.66482741 Low-inc renter severe housing cost burden 54.72860259
Uncrowded housing 69.47260362
Health Outcomes —
Insured adults 82.56127294
Arthritis 3.8
Asthma ER Admissions 52.3
High Blood Pressure 10.4
Cancer (excluding skin) 5.1
Asthma 46.1
Coronary Heart Disease 5.6
Chronic Obstructive Pulmonary Disease 16.6
Diagnosed Diabetes 39.3
Life Expectancy at Birth 72.3
Cognitively Disabled 36.6
Physically Disabled 29.8
Heart Attack ER Admissions 58.7
Mental Health Not Good 60.0
Chronic Kidney Disease 14.8
Obesity 46.0
Pedestrian Injuries 19.6
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Physical Health Not Good 43.5
Stroke 17.3
Health Risk Behaviors —
Binge Drinking 69.8
Current Smoker 63.8
No Leisure Time for Physical Activity 53.2
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 81.0
Elderly 5.4
English Speaking 49.7
Foreign-born 32.9
Outdoor Workers 24.7
Climate Change Adaptive Capacity —
Impervious Surface Cover 63.7
Traffic Density 27.9
Traffic Access 23.0
Other Indices —
Hardship 18.6
Other Decision Support —
2016 Voting 89.7

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 37.0 Healthy Places Index Score for Project Location (b) 83.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Big Ranch Housing Detailed Report, 12/1/2024
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Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use Estimate based on max per acre
Construction: Construction Phases Using default assumptions from CalEEMOD From: Joe Andrighetto
To: Clerk
Subject: Big Ranch Annexation.

Date: Tuesday, December 3, 2024 1:27:25 PM
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[EXTERNAL]
I am opposed to the Big Ranch Annexation plan. I believe the impact to our home value and quality of life would be negative.

Regards,
Joseph Andrighetto.

STREET ADDRESS, CITY, ST ZIP CODE
T (123) 456-7890 U WWW.COMPANY.COM
Big Ranch Annexation Opposition

12.02.2024

Napa City Council:

We are highly in opposition to any hurried vote on this annexation by Napa City Council at this time. We encourage City Council to "delay voting on the annexation until a site specific EIR is done on the area per CEQA".

We are especially concerned with traffic on Big Ranch that is not set to handle 1000 new homes that all would be car dependent especially as the plan has Trower going through to Big Ranch.

We do currently experience Big Ranch weekday traffic backing up from Trancas to, our property and beyond to Garfield lane area. There are limited shoulders creating a risk for emergency access vehicles to access the current houses and developments.

Specific Question on Big R an ch Spe cific Road & Street Improvements:

As a part of this development, would the developer be required to pay for and implement the proposed widening, turn lanes, and sidewalks as well as sewer and water extensions from Trancas north as proposed in Big Ranch Specific plan?

2 It’s obvious that recent site inspections from the report below have proven that the current EIR is not addressing the actual wildlife habitat & concerns as required per CEQA.

Sincerely,
Eric & Melissa Schmitt
2159 Big Ranch Rd.

Napa, Ca 94558

Some excerpts from Dr. Smallwood's report are below:

" In all, I detected the presence of 45 species of vertebrate wildlife including five special-status species during my brief survey" (Page 2)

"Photos 5 and 6. Cooper’s hawk hunting for quail, and an American kestrel on the project site, 30 October 2024. Both of these species are protected by California’s Birds of Prey Code, and neither was analyzed for occurrence potential in the General Plan Update PRDEIR." (Page 4)

3 "Photos 7 and 8. Nuttall’s woodpecker and oak titmouse on the project site, 30 October 2024. Both species are listed by the US Fish and Wildlife Service as Birds of Conservation Concern, which are those species with 1. Documented or apparent population declines; 2. Small or restricted populations, or 3. Depend on restricted or vulnerable habitats. The General Plan Update PRDEIR did not analyze the occurrence potentials of either of these species. " (Page 5)

4 "I found no evidence that the City has performed a desktop review to identify the likelihoods of occurrence of special -status species of wildlife specific to the project site. A desktop review was completed in the General Plan Update Partial Recirculated D EIR, but only at the scale of the City’s Sphere of Influence. One of the shortfalls of this desktop review to project -specific applications can be viewed in Figure 3.3 -1 of the General Plan Update PRDEIR. The shortall is visible when scrutinizing the portion of the Figure (map) that depicts vegetation cover types of the project site. The vegetation map fails to depict the oak woodland and oak savannah (Figure 3), nor does it show the potential wetlands on the project site (Figures 3 and 4). The vegetation cover map of Figure 3.3-1 is too crude and too inaccurate to be of any use to characterizing the existing environmental setting of the project site." (Page 21)

"Because the vegetation cover of the project site is inaccurate in the General Plan Update PRDEIR, so too is the PDEIR’s analyses of occurrence likelihoods of special-status species of plants and wildlife, none of which applied specifically to the project site, anyhow. Because the City has not performed a desktop review

5 for special-status species occurrence likelihoods specific to the project site, I performed a cursory review to get a first look at which species likely occur. In my assessment based on database reviews and site visits, 125 special-status species of wildlife are known to occur near enough to the site to warrant analysis of occurrence potential (Table 2). Of these species, five were recorded on the project site, …. " (Page 21)

"The accuracy of this analysis depends on an accurate characterization of the existing environmental setting. In the case of the proposed project, the existing environmental setting has not been accurately characterized, and several important types of potential project impacts have been inadequately analyzed or not analyzed at all. These types of impacts include habitat loss, wetlands loss, interference with wildlife movement, wildlife-automobile collision mortality, bird-window collision mortality, and depredation by house cats that come with residential development recorded on the project site" (page 29)

" The Initial Study is misleading in its characterization of the “project,” as it attempts to separate the zoning amendment from what is intended to result from the zoning amendment. According to the Initial Study (p. 16), “No development or construction is proposed as part of the Project. Thus, the Project would not directly result in any impacts to sensitive or special status plant or animal species. Therefore, the Project would not result in any new significant impacts not already analyzed in the General Plan Update EIR or increase the severity of a significant impact as previously identified and analyzed in that EIR.” According to the zoning amendment, the project is the zoning amendment and nothing more. However, it is clear from the Staff Report that the whole of the project is to clear the way for the planning free of any further CEQA considerations and the construction of at least 1,000 residential units. The whole of the project would cause substantial and potentially highly significant impacts to the wildlife community." (page 29)

6 " As part of a consistency analysis, the Initial Study (p. 16) reasons, “The General Plan Update PRDEIR found that the 2040 General Plan would have a less-than- significant impact to candidate, sensitive, and special status species because implementing projects within the City would be required to adhere review under CEQA and permitting requirements for impacts on special-status plants and animals. Therefore, the General Plan Update EIR concluded that implementation of the General Plan would result in less than significant impacts to special-status plant and animal species, and no mitigation is required.” However, the Initial Study fails to explain how mitigation required under the General Plan Update PRDEIR would conserve the wildlife community along with its special-status species on the project site, which also underwent no survey or desktop review to characterize the wildlife community that exists on the site." (Page 29)

" The whole of the project would convert 66 acres of open space to a residential development consisting of at least 1,000 units, or about three times more residential units that assumed in the General Plan Update PRDEIR. Wildlife habitat would be lost." (Page 29)

" While the General Plan Update PRDEIR’s analysis is too crude and a bit misdirected, the Initial Study’s analysis is misleading. According to the Initial Study (p. 17), “No development or construction would occur within the Project Site as part of the Project.” This is misleading because the whole of the project would result in the construction of about 1,000 residential units and the concomitant destruction of 66 acres of open space that I found to be used by wildlife for movement through the area, e.g., see Photo 27. A qualified biologist needs to be assigned to survey the site for wildlife movement, and it needs to be based on evidence from sign (trails) and a program of observation of use of the airspace and of stopovers on the project site." (Page 32)

7 "Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic to and from the project site (Photos 32―34), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level" (Page 32)

Johansson Family

Napa, CA 94558

To: Napa City Council

Purpose: Oﬃcially oppose the Big Ranch Annexation plan

Napa City Council Members,

Thank you for taking a moment to read our direct opposition to the planned Big Ranch Road Annexation. My family is not from Napa but fell in love with this city, bought our ﬁrst home here oﬀ Big Ranch Road, and are raising our family here as Napa residents for the last 10 years plus.

After careful review, we strongly oppose the Big Ranch Annexation for a variety of reasons but mainly due to the negative impact on the local environment, the heavy increase in traﬃc and reduction in safety, and the direct reduction in quality of life that has us even discussing moving should this get approved.

We strongly ask that you reject the current proposal.

Thank you
Kenton & Marea Johansson

From: KNOLL
To: Clerk
Subject: Opposition to the Big Ranch Development
Date: Tuesday, December 3, 2024 4:18:06 PM
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[EXTERNAL]
We bought our lovely townhome several years ago and loved the country feel off of big ranch road but the proximity to the stores and town.

We recently found out about the possible building of hundreds of homes off of big ranch and are very disappointed.

The traffic flow of big ranch is horrible now during peak rush hours and the amount of accidents is on the rise. The road will have to be widened at a huge expense and also the traffic nightmare would be totally unsafe for anyone driving or walking or biking. It’s a safely issue now. Can’t imagine hundreds of more cars added into the mix.

There is another huge development close to the high school going on right now. It’s been a huge mess and the noise from trucks and construction has been going on almost a year.

I am encouraging the committee to put the property back to low density and table this whole nightmare until any specific traffic and noise problems can be studied. This is just a bad idea.

Karen Knoll
Valley Club Circle

Napa City CouncilDecember 3, 2024

Napa City Council
December 3, 2024