ATCH 23_IS Addendum (05-29-25) — Napa City Council, June 24, 2025 (part 1 of 2)

First Street Napa Phase II Project

Initial Study
/
Addendum to the Downtown Napa
Specific Plan Environmental Impact Report (DNSP
EIR) (State Clearinghouse No.
2010042043
)

City of
Napa
,
Napa
County, California

P
ROJECT

APPLICANT
:

Coombs Street
LLC and 300 Venture Group

LEAD

AGENCY:

City of Napa

Planning Division

1600 First Street

Napa, CA 94559

7 07.257.9530

Contact:

Ricky Caperton, AICP

PREPARED BY:

FirstCarbon Solutions

2999 Oak Road, Suite 250

Walnut Creek, CA 94597

925.357.2562

Contact:

Mary Bean
, Project Director

Angela Wolfe
,
Senior
Project Manager

May
2 9
, 202
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Table of Contents

Acronyms and Abbreviations

1 -

Introduction

1 1.1
-

Overview

1 1.2
-

Agency Role

4 1.3
-

Purpose and Background

4 1.4
-

Background Discussion

8 1.5
-

Summary of Results

14 1.6
-

Format of Initial Study/Addendum

15 2
-

Project Description

17 2.1
-

Downtown Napa Specific Plan

17 2.2
-

Location and Setting

27 2.3
-

Project Description

33 2.4
-

Discretionary Approvals

47 3
-

CEQA Guidelines Section 15168: Projects Consistent With Prior Environmental Documentation

49 3.1
-

Public Resources Code Section 21166 and CEQA Guidelines Section 15168

49 3.2
-

CEQA Guidelines Section 15162

50 4
-

Environmental Checklist

53 4.1

Aesthetics

54 4.2

Agriculture and Forestry Resources

64 4.3

Air Quality

68 4.4

Biological Resources

82 4.5

Cultural and Tribal Cultural Resources

92 4.6

Energy

107

4.7 Geology and Soils

112

4.8 Greenhouse Gas Emissions

122

4.9 Hazards and Hazardous Materials

129

4.10 Hydrology and Water Quality

137

4.11 Land Use and Planning

146

4.12 Mineral Resources

150

4.13 Noise

152

4.14 Population and Housing

158

4.15 Public Services

161

4.16 Recreation

167

4.17 Transportation

170

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4.18 Utilities and Service Systems

178

4.19 Wildfire

185

4.20 Mandatory Findings of Significance

190

5 -

Conclusions

195

5.1 -

Section 15183 Exemption for General Plan Consistency

195

5.2 -

Infill Development Project, Class 32 Categorical Exemption

196

5.3 -

Common Sense Exemption

197

6 -

List of Preparers

199

Technical Subconsultants

199

Appendix A: Design Guidelines

Appendix B: DNSP Capacity Analysis

Appendix C: Air Quality Screening Analysis

Appendix D: Biological Resources Supporting Information

Appendix E: Cultural Records Search

Appendix F: VMT and Trip Generation Assessment

List of Tables

Table 1: Proposed Project Parcels

2 Table 2: Town Center Focus Area 1 PD Overlay
–
Development Standards

38 Table 3: Proposed Parking

41 Table 4: Bay Area 2017 Clean Air Plan Applicable Control Measures

69 Table 5: Cumulative Health Risks at the Project Site

77 Table 6: BAAQMD Thresholds for Land Use Projects

123

List of Exhibits

Exhibit 1: Downtown Napa Specific Plan Planning Area

11 Exhibit 2: Building Form Zones

19 Exhibit 3: Focus Areas and Existing Land Use and Zoning

21 Exhibit 4: Town Center Focus Area

25 Exhibit 5: Existing Conditions

29 Exhibit 6: Proposed Site Plan

35 Exhibit 7: Project Diagrams

97 Exhibit 8: Project Design Features

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ACRONYMS AND ABBREVIATIONS

Assembly Bill

ABAG

Association of Bay Area Governments

ADA

Americans with Disabilities Act

AQMD

Air Quality Management District

APN

Assessor’s Parcel Number

ARB

California Air Resources Board

ATCM

Airborne Toxic Control Measure

BAAQMD

Bay Area Air Quality Management District

BMP

Best Management Practice

C&D

c
onstruction and
d
emolition

Cal/EPA

California Environmental Protection Agency

CAL FIRE

California Department of Forestry and Fire Protection

CALGreen

California Green Building Standards Code

Caltrans

California Department of Transportation

CAP

Clean Air Plan

CBC

California Building
Standards
Code

CC&R

Covenants, Conditions, and Restrictions

CCR

California Code of Regulations

CDFW

California Department of Fish and Wildlife

CEQA

California Environmental Quality Act

CGS

California Geological Survey

CNEL

Community Noise Equivalent Level

CO
2 carbon dioxide

Cultural Resources

CRHR

California Register of Historical Resources

dBA

A
-
weighted decibel

DCC

Downtown Commercial Core

DEM

Napa County Department of Environmental Management

DMU

Downtown Mixed
-
Use

DNSP

Downtown Napa Specific Plan

DOC

California
Department of Conservation

DPM

diesel particulate matter

DTSC

California Department of Toxic Substances Control

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dwelling units

du/acre

dwelling units per acre

EIR

Environmental Impact Report

ESA

Environmental Site Asse

electric vehicle

FAR

floor area ratio

FEA

Flood Evacuation Area

FCS

FirstCarbon Solutions

FEIR

Final Environmental Impact Report

FEMA

Federal Emergency Management Agency

FHSZ

Fire Hazard Severity Zone

FTA

Federal Transit Administration

GHG

greenhouse gas

HERS

Home Energy Rating System

HRA

Health Risk Assessment

heating and
ventilation

HVAC

heating, ventilation, and air conditioning

LEED
®

Leadership in Energy and Environmental Design

LOS

Level of Service

M
LD

Most Likely Descendant

MMRP

Mitigation and Monitoring Program

mph

miles per hour

Napa
San

Napa Sanitation
District

NAHC

Native American Heritage Commission

n
egative
d
eclaration

NFD

Napa Fire Department

NOI

Notice of Intent

NPD

Napa Police Department

NPDES

National Pollutant Discharge Elimination System

NRHP

National Register of Historic Places

NRWS

Napa Recycling and Waste Services

NVUSD

Napa Valley Unified School District

NWIC

Northwest Information
Center

Planned Development

PG
&E

Pacific Gas and Electric Company

PRC

Public Resources Code

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RPS

Renewable Portfolio Standard

RWQCB

Regional
Water Quality Control Board

Senate Bill

SFL

Sacred Lands file

State Route

SWPPP

Storm Water Pollution Prevention Plan

State Water Board

California
State Water Resources Control Board

SVP

Society of Vertebrate Paleontology

TAC

toxic air
contaminant

T
-
BACT

Toxics Best Available Control Technology

TCM

Transportation Control Measures

TCR

Tribal Cultural Resource

TDM

Transportation Demand Management

USFWS

United States fish and Wildlife Service

USGS

United States Geological Survey

VMT

Vehicle Miles Traveled

ZEV

Zero
-
Emission Vehicle

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1 -

INTRODUCTION

1.1 -

Overview

This
Addendum

is being prepared for the proposed First Street Napa Phase II Project (proposed Project
), which is located within the City of Napa’s
(City’s) Downtown Napa Specific Plan (DNSP)
boundaries
. As described in more detail in Section 2, the proposed Project

includes

minor changes to
the development
program
adopted
in the
DNSP

and evaluated
in the
certified
DNSP
Environmental
Impact Report (DNSP EIR) (State Clearinghouse No.
2010042043
).

The proposed
City actions
include
the adoption of
a Planned Development
(PD)
Overlay with
p
roject
-
specific Design Guidelines,

Specific Plan Map and Zoning Map Amendment, a Development Agreement, and a Tentative Parcel Map for condominium purposes.

Subsequent
p
roject

approvals would include
, but not
be
limited to,

Major Design Review.

If approved, the proposed
p
roject

would permit the development of
a maximum of
(
1 )
78 units of for
-
sale, market
-
rate, branded residential multi
-
family housing units

in a 6
-
story
(
approximately 75 feet in
height with rooftop features
,
with an additional approximate 12 feet of Roof Top Activation plus 7 feet for equipment including MEP and Elevator Overruns
)

building
,
(
2 )
a 6
-
story

(
approximately 75 feet in
height with rooftop features
,
with an additional approximate 12 feet of Roof Top Activation plus 7 feet for equipment including MEP and Elevator Overruns) upper upscale hotel with a maximum of 161
rooms with ancillary retail

and related amenities, and
(
3 )

up to 30,000 square feet of ground

floor and
second floor retail
.

The
proposed
Project

would be developed on
seven

existing
parcels

totaling approximately 2.
82 acres
,
as well as
a
1 -
acre

Public Realm Parcel, described below
.

The largest
portion

include
s

the

now
closed

Kohl’s
department st
ore and other users located at 1106, 1116
,

and 1118 First Street,
in the

City of
Napa,
in Napa County (County),
California, designated as Assessor’s
Parcel Numbers (APNs):

003
-
166
-
010
,
003
-
166
-
013, 003
-
116
-
015,
and
003
-
166
-
016

(
CS Parcels
)
.

The
Project

site
also
consists of t
he approximately 0.7
-
acre property and the surface parking lot located at 1151 Pearl Street
,

designated as
APNs
003
-
166
-
008
and

003
-
166
-
011 (
Parking Lot
Parcel
s
) and the
approximately

0. 1
8 -
acre

property on First Street adjacent to the CS Parcel
s

known as the Dwight
Murray Plaza, designated as

APN
003
-
166
-
017

(
Dwight Murray

Parcel
).

The
Dwight Murray
Parcel
, the
Parking Lot Parcel
s
,
and
the
CS Parcels

are referred to herein collectively as the
“
Project

site
.
”

Unless specifically
stated, this analysis evaluates the entire
Project

site.

The Tentative
Parcel Map
would configure the 7 parcels into 5 parcels with a condominium map.

Additionally, the
proposed

Project

includes various improvements to the Public Realm
that
would
occur

on APN 003
-
167
-
020

(
Public Realm Parcel)
, as well as a portion of the
Project

site
described
in Section 2.3.2 below
.

Table
1 provides a
detailed
breakdown of each parcel and its acreage.

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Table
1 :

Proposed Project Parcels

APN
(s)

Name

Location

Acreage

003
-
166
-
010
,
003
-
166
-
013, 003
-
116
-
015,
and
003
-
166
-
016

CS Parcels

Project Site

1.94 003
-
166
-
008
and

003
-
166
-
011

Parking Lot Parcels

Project Site

0.7 0

003
-
166
-
017

Dwight Murray Parcel

Project Site

0. 18

Subtotal (Project Site)

2.8 2

003
-
167
-
020

Public Realm Parcel

Public Realm

1.00 Total Acreage (Project Site and Public Realm)

3.8 2

Notes:

APN = Assessor’s Parce
l

Number

Source:

RIOS. 10SB. May 2025.

The proposed
Project

is fully described in Section 2 of this
Initial Study/
Addendum.

This
Initial Study/
Addendum

and attached supporting documents have been prepared to determine whether and to what extent
t
he
proposed

Project

is within the scope of the

DNSP EIR
prepared for
the
City of
Napa

(certified by the Napa City Council in Resolution R2012 54, adopted on May 1,
2012)
. The DNSP program was

reinforced through the certification of the General Plan Final
Environmental Impact Report (
FEIR
)
,

which acknowledges the DNSP FEIR and supports the goals of the Specific Plan, including the land uses and development potential programmed for the Specific Plan buildout
.
1 This
Initial Study/
Addendum
evaluate
s

whether
there are
Project
-
specific significant
effects
peculiar

to the

proposed

Project

or the site

and

whether additional documentation is required
under the California Environmental Quality
Act (CEQA)
(
Public

Resources Code

[PRC]

21000,
et
seq
.)

or its implementing regulations (Title 14, Division 6, Chapter 3 of The California Code of Regulations [CEQA Guidelines]
§
15000,
et seq
.)
.

1.1.1 -

CEQA Approach, Streamlining
,

and Exemption
Applicability

It is the policy of the State of California that environmental review under CEQA be completed efficiently and expeditiously so that the limited resources of S
tate and local agencies can be devoted
to environmental mitigation rather than duplicative administrative processes

(PRC
§ 2100
3(f)
)
.

To th
at
end,
CEQA contains several streamlining provisions intended to reduce duplication

and promote
efficiency in the environmental review process.

(
See, e.g.
,

PRC
§§
21083.3, 21156; CEQA Guidelines
§§

15168, 15183)
.

In addition, and to further avoid and discourage the duplicative and wasteful use of scarce resources, the legislature has determined,
by statute or regulation,
a
nd a
s a matter of law, that
various types of projects are exempt from environmental review under CEQA

(CEQA Guidelines
§§

15 2
6 0
-
15 333
)
.

1 City of Napa
.
2012. Dow
n
town Napa Specific Plan Program Environmental Impact Report

(DNSP EIR)
. March.

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In practice, the various types of exemptions and streamlining mechanisms often
overlap with respect
to their application to certain

types of projects, such that a single project may qualify or be eligible for more than one exemption or
for
different types of streamlined environmental review.

This is often the
case when a site
-
specific development project is within a formally adopted land use or development plan or program that was the subject of a previously certified environmental impact report.

This is th
e
case with the proposed Project.

As explained above, the
proposed
Project is within the boundaries of the Downtown Napa Specific Plan,

and

the City’s implementation of the DNSP was subject to environmental review in the certified DNSP

EIR.

The DNSP EIR was a “program” EIR prepared pursuant to CEQA Guidelines Section 15168
, and it
anticipated and evaluated development of the Project site

as part of the overall
development of

the Downtown area
.

As a result, under Section 15168(c), the
proposed
Project “must
be examined in

light of the program EIR to determine whether an additional environmental document must be prepared.”

T
o perform the required examination,

the City prepared

t
his
comprehensive
I
nitial
S
tudy
, evaluating all of the potential environmental effects from the

pro
posed
Project to determine
whether it would have any effects that were not identified and adequately addressed in the DNSP EIR.

The City’s process for complying with Section 15168 is described in greater detail in Section

1.3.1 below.

In addition to the streamlined environmental review process provided
by Section 15168, the
proposed
P
roject

would also be eligible for a more limited form of
environmental review

under CEQA Guidelines
Section 15183

as a project that is consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified.

Although
both

CEQA
Section
s

15168 and 15183 apply to the
proposed project
, this analysis
focuses on

Section 15168.

Moreover, and in
addition to the streamlining processes afforded by Sections 15168 and 15183, the

City

reviewed the applications to determine whether the
proposed
P
roject
might be
exempt from
any
further
CEQA
review
under any available statutory or categorical exemptions. Based on that review

and on the analyses in this
Initial
Study/Addendum
,
and as explained in detail in
Section
5,
the City

has
determined that
(a)

the
proposed
P
roject
is an
“in
fill

development project” that
is
exempt from
any
additional
environmental review under Section 15332 of the CEQA Guidelines , and (b) the
proposed
P
roject could qualify for CEQA’s common sense exemption under Section 15061(b)(3) of the CEQA Guidelines
.

Based on the analyses and conclusions in this
Initial Study/Addendum
, the City has determined that
,
to the extent that the
proposed
P
roject is not exempt from further environmental review,

this
Initial
Study/
Addendum to the DNSP EIR
constitute
s

full compliance with CEQA
’s environmental review

requirements
because
, among other things,
environmental impacts from
development of the Project
site
were

fully evaluated in the DNSP EIR
;

the Project site is located within the DNSP Town Center Focus Area
,

which addressed development within the Planning Area through 2035 and established policies, programs, and guidelines set forth in the DNSP, including the DNSP development standards that shape the form and character of development within Downtown by promot ing coordinated and
cohesive site planning and design
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of the DNSP buildout, including the Town Center Focus Area Focus Area, which was specifically intended to be used for
approval of subsequent development applications.

1.2 -

Agency Role

City of Napa
–
Lead Agency
:

By virtue of the proposed
Project

being located in the DNSP

Planning
Area

and within the
c
ity limits, the City of Napa is the agency with principal authority for carrying out and approving the proposed
Project
. In accordance with its role as the Lead Agency, the City of Napa was responsible for preparation and certification of the DNSP EIR.

1.3 -

Purpose and Background

When an EIR has been
certified for a
p
roject
,
additional environmental review is only appropriate in
limited circumstances. CEQA Guidelines

§ 15162.

As explained above,
CEQA
also
contains several
streamlining provisions intended to reduce
duplication. This
document
utilizes the process
described
in Section 15168 of the CEQA Guidelines

for review of
projects that may be within the scope of a
development program that was the subject of a certified program EIR.

1.3.1 -

Addendum to a Certified Progra
m EIR

When a program EIR is used to support approval of later activities that are within the program, the agency must examine those activities as they come up for approval to determine whether additional environmental review is required. If it determines that th e activity’s environmental effects were
examined in the program EIR and that a subsequent EIR would not be required, the agency may approve the activity as being within the scope of the
p
roject

covered by the program EIR, and no
additional environmental do
cumentation is required
(
CEQA Guidelines §15168(c)(1)
–
(2), (c)(5), (e)
)
.

I
f
some changes or additions are necessary but none of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent or supplemental EIR or negative declaration

(ND)
have occurred, CEQA

states that
“the lead agency . . .

shall

prepare an addendum
”

to the
certified EIR.

This mandatory provision establishes that an addendum is the appropriate CEQA document where it is determined that
none of the condit
ions described in Section 15162 have
occurred.

As activities within the program are approved, the agency must incorporate, if feasible, the mitigation measures and alternatives developed in the program EIR in its action approving the activity

(
CEQA
Guidelines

§15168(c)(3)
)
.

The DNSP EIR was a
p
rogram EIR, which is defined by CEQA Guidelines Section 15168 as

follows
:

General.

A program EIR is an EIR which may be prepared on a series of actions that can be characterized as one large project and are related either:

Geographically,

As logical parts in the chain of contemplated actions,

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In connection with issues of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or

As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

Pursuant to CEQA Guidelines Section 15168(c),
program

EIRs may be used for subsequent activities
contemplated in the
program

EIR. CEQA Guidelines Section 15168(c) states:

Use with Later Activities.

Subsequent activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared.

If a later activity would have effects that were not examined in the program EIR, a new study would need to be prepared leading to either an EIR or a negative declaration.

If the agency finds that pursuant to Section 15162, no new effects could occur or no new mitigation measures would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmenta l
document would be required.

An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into subsequent actions in the program.

Where the subsequent activities involve site
-
specific operations, the agency should use a
written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were covered in the program EIR.

A program EIR will be most helpful in dealing with subsequent activities if it deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed analysis of the program, many subsequent activities could be foun d to be within
the scope of the project described in the program EIR, and no further environmental documents would be required.

The DNSP EIR describes the future use of the EIR
for subsequent activities, implementation, and
development:

This EIR may be used for the following direct and indirect actions within the Planning Area :
2 2

“Planning Area” is defined as the Specific Plan Planning Area, which encompasses Downtown Napa, bounded on the east by the eastern bank of the Napa River, on the south by Division and Third streets ,

and on the west by Jefferson
Street. The northern boundary generally follows the edge of the “Downtown Commercial” zoning area boundary adjacent to northern residential neighborhoods along Polk and Caymus streets west of Soscol Avenue. The Planning Area b
oundaries extend east to include the Oxbow Market and former Copia area east of Soscol Avenue. The Planning Area encompasses approximately 210 acres.

DNSP Draft EIR at 3
-

2. These boundaries were later amended
in October 2022
by the
City of Napa 2040

General Plan,

but that expansion does not impact the
proposed
Project.

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City of Napa

The Downtown Specific Plan will be presented to the City of Napa Planning Commission for comment, review and recommendations. The City of Napa City Council, as the City’s legislative body, is the approving authority for the Specific Plan. As part of the Pl an’s approval, the City Council would
take the following actions:

•

Certify of the Downtown Napa Specific Plan
Program

EIR.

•

Adopt required findings for the above actions, including required findings under the CEQA Guidelines, Sections 15090, 15091
,

and 15093.

•

Adopt the Downtown Napa Specific Plan.

•

Adopt a Mitigation Monitoring and Reporting Program (MMRP).

Subsequent actions that may be taken by the City Council regarding the

DNSP
project

include, but
are not limited to, the following:

•

Amendment of the City of Napa General Plan and Land Use Designation Map .

•

Amendment of the City of Napa Municipal Code and Zoning Maps so that the City
zoning maps
and the Specific Plan land use policy map are consistent.

•

Implementation of financing programs or fee programs for public facilities.

•

Approval of subsequent development applications.

•

Approval of subsequent public facility and roadway improvement project
s. (DNSP Draft EIR at
3 -
17, 18
).

The City of Napa
,

in an
EIR

to evaluate the impacts of the 2040 General Plan Update ,

certified on
October 4, 2022 (State Clearinghouse Number 2021010255) the “General Plan EIR,” which also evaluated
t
he City of Napa D
NSP
.

Through the General Plan Update process, the City

confirmed the
DNSP’s goal to revitalize
D
owntown Napa into a vibrant place where residents and visitors alike come together to work, live, play
,

and actively engage in the community. The General Plan EIR evaluated the 2040 General Plan Update policies promoting, supporting ,

and facilitating further
development in
D
owntown Napa in furtherance of the DNSP and recognized that the DNSP provides the guiding framework for realizing the vision of a vibrant, healthy, and balanced pedestrian -
oriented
C
ity Ce
nter. The General Plan EIR recognized and evaluated that implementation of the General Plan could result in a net new development of up to 7,800 residential units, 817,000 square feet of office use, 631,000
square feet

of retail use, and 1,799,000
square feet
of industrial use, including
development within the DNSP area. The General Plan EIR recognized in the General Plan Update that the DNSP includes allowable land uses, overlay districts, development standards, development incentives, design guideli
nes, circulation patterns, a parking strategy, and required utility improvements, and that the greatest residential and commercial densities are allowed in the heart of Downtown. This includes the Project site.

The 2040 General Plan Update did not alter the analysis of
environmental impacts on the Project site
contained
in the DNSP EIR.

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The analysis and conclusions contained herein
constitute
the appropriate level of environmental
review
for the
proposed
P
roject
in accordance with CEQA Guidelines Section 15168. CEQA
Guidelines Section 15168 relies upon
the approach set forth in
CEQA Guidelines

Section
15162
to
determine whether development proposals are within the scope of the project covered by a
program
EIR
.

This approach is consistent with the fact
that there have been

at least
three previous
hotel
project approvals within the DNSP area, all relying upon addendums to the DNSP FEIR:

•

The Archer Hotel:

Use Permit and Design Review approvals for 183
h
otel
r
ooms and 27,000+/
-

s
quare feet

of commercial/restaurant/bar space

•

F
irst and
Oxb
ow Hotel: Use Permit and Design Review approvals for 123 h
otel
r
ooms

•

Franklin Station: General Plan Amendment, Specific Plan Amendment, Certificate of Appropriateness, Development Agreement, and Planned Development and Design Guidelines approved for 163
h
otel
r
ooms and construction of an automated parking structure to accommodate parking for the
h
otel and public use.

Each of the projects listed above
was
approved by the City Council
, which
found
each

to be within the
development capacities established by the DNSP FEIR and which determined
that no new impacts

would be
created that were not already anticipated by the DNSP FEIR.

CEQA Guidelines Section 15162 provides the following guidance on determining when a subsequent EIR shall be prepared:

When an EIR has been certified or negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:

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 identifie d
significant effects;

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 of a substantia l increase
in the severity of previously identified significant effects; or

New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time of the previous EIR was certified as complete or the negative declaration was adopted, shows any of the follo
wing:

The project will have one or more significant effects not discussed in the previous EIR or negative declaration;

Significant effects previously examined will be substantially more severe than shown in the previous EIR;

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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 alternati
ve; or

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 o
r alternative.

If a proposed project is consistent with the development anticipated in the certified program EIR, no further environmental documentation is required.

I
f some changes or additions are necessary but
none of the conditions described
above
in CEQA Guidelines Section 15162 calling for preparation of a subsequent or supplemental EIR or ND have occurred
, then CEQA mandates the preparation of an
addendum

(CEQA Guidelines Section 15164)
.

An Addendum need not be circulated for public review but can be included in or attached to the Final EIR or ND (CEQA Guidelines § 15164, subd. (c)). The decision -
making body shall consider the
Addendum with the Final EIR prior to making a decision on the s ubject project (CEQA Guidelines §
15164, subd. (d)). An agency must also include a brief explanation of the decision not to prepare a subsequent or supplemental EIR or ND pursuant to Section 15162 (CEQA Guidelines § 15164, subd. (e)), which should be inclu
ded in the Addendum, the project findings, or elsewhere in the record and must be supported by substantial evidence.

As will be discussed in greater detail in Section
4 , acknowledging that the development projections for
the DNSP as

contained in the DNSP EIR were included with the certification of the 2040
General Plan
Update
FEIR
, the site
-
specific details and operations of the
proposed
Project

do not alter any of the
previous conclusions contained in the DNSP EIR, and the proposed
would not result in any new
significant effects that were not discussed in the DNSP EIR, or substantially increase the severity of any significant effects that were identified in the DNSP EIR. Therefore, no new environmental document is required under CEQA

Guideline Section 15168.

This
Initial Study/
Addendum has been
prepared pursuant to CEQA Guideline S
ections 15168 and 15164 to document the evaluation of the proposed
Project
’
s site
-
specific operations and impacts and describe how the City determined the environmental effects of the
proposed
Project

were covered in the DNSP EIR
.

1.4 -

Background
Discussion

On January 27, 2012, the City of Napa (Lead Agency) released for public review a Draft Environmental Impact Report (Draft EIR) for the City’s D NSP

(State Clearinghouse No. 2010042043).

The minimum 45
-
day public review and comment period on the Draft EIR began on January 27, 2012, and closed on March 12, 2012. The Napa City Council certified the DNSP EIR and approved
the Specific Plan
on May 1, 2012. (Herein, the Certified Final EIR, Draft EIR ,

and all technical
appendices and documents incorporated therein are referred to collectively
as the

DNSP EIR
)
.

O
n
October 4, 2022
,

the
City of Napa certified the 2040 General Plan Update E
IR

(State Clearinghouse
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Number 2021010255
)
,

which
evaluate
d

the impacts of
the 2040 General Plan and included the
development anticipated and evaluated in the DNSP and DNSP EIR.

The DNSP EIR is an informational document that informed the general public, the local community, responsible and interested public agencies, the decision -
making body and other organizations, and
interested persons of the scope of the DNSP, its potential en vironmental effects, possible measures
to reduce potentially significant environmental impacts, and alternatives that could reduce or avoid the significant effects. The alternatives to
the
DNSP

that were analyzed, with the exception of the
mandatory
No Project Alternative,

were selected due to their potential to achieve basic project objectives and to lessen or avoid significant environmental effects of the project discussed in the DNSP EIR.

The DNSP EIR evaluated the potential environmental effects associated with development in the
Planning Area (
Exhibit
1 )
consistent with

the adoption and implementation of the DNSP, based on the information available to the City at that time. This
Initial Study/
Addendum provides a description of the
DNSP EIR analysis as well as a site
-
specific description of the proposed
Project
. Consistent with
CEQA Guidelines Section 15168 and the DNSP EIR, this
Initial Study/
Addendum is being used for
the environmental analysis of the proposed
Project
, a subsequent development application
that

is a
direct action within the Planning Area.

Consistent

with CEQA,

t
his

Initial Study/
Addendum
evaluates whether any of the circumstances
requiring additional environmental review

under
CEQA Guidelines
Section 15162 are present and

documents the City’s evaluation of the proposed
Project

to describe how the City determined that the
proposed
Project

is within the scope of the development program described in the DNSP and evaluated in the DNSP EIR and
would

not result in any new environmental effects not identified and addressed in the DNSP EIR or substa
ntially increase the severity of any effects identified in the DNSP EIR.

Each topical section of the
DNSP
EIR was reviewed and analyzed
pursuant to
CEQA Guidelines
Section 15162

to determine
whether

any of the conditions
calling for the preparation of a subsequent
EIR have occurred, including
if
any

changes related to the
proposed
Project

would result in new,
significant environmental effects or more severe environmental impacts than those previously analyzed and disclosed in the

DNSP

EIR. The
DNSP
EIR evaluated the potential environmental
impacts that could result from
development under

DNSP, and in particular, it focused on potentially
significant impacts, mitigation measures, and alternatives intended to mitigate or avoid the potentially significant impacts arising from the implementation of the DNSP.

The DNSP addressed development within the Planning Area through 2035. The DNSP EIR evaluated potential development and improvements on
approximately 210 acres of land in Downtown and
concluded that because the Planning Area includes only in fill

sites on land within an urban area
surrounded by similar or compatible uses, it

would not commit future generations to a significant
change in land use.

In accordance with CEQA, the DNSP EIR contained a description of the DNSP, description of the environmental setting, identification of
p
roject impacts, and mitigation measures for impacts found to ATTACHMENT 23

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be significant, as well as an analysis of
p
roject alternatives
.

For purposes of its environmental
analysis, the DNSP EIR used certain assumptions about how development would proceed under the DNSP in each use category
(
i.e., assumptions about the number of residential units and hotel rooms, and the square footage of office and retail space
)

that might be constructed in the
DNSP

a
rea through
2035. Based on these assumptions, the DNSP EIR determined, for each potential environmental impact, the level of signi
ficance of that impact from full buildout of the DNSP in all four use categories.

ATTACHMENT 23
61450001 • 03/2025 | 1_downtown_napa_area.cdr
Exhibit 1
Downtown Napa Specific Plan Planning Area

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: City of Napa. RIOS. 10SB. March 2025.

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The DNSP itself, however, does not impose numerical limits on any of these uses, and actual development in the
DNSP

a
rea has not conformed to the DNSP EIR assumptions in each category.

most categories (i.e., residential units, office space, and retail space), actual development has lagged far behind the assumptions used in the DNSP EIR, and in one case (hotel rooms), actual development has exceeded the assumption used in the DNSP EIR. (S ee Appendix B for an analysis
of the DNSP’s approved development cap
acity as compared to actual development)
.

Because CEQA
concerns itself with the environmental effects from proposed development, without regard to the types of uses that are proposed, this Initial Study/Addendum evaluates whether or not the potentially significant environmental effects from the pr
oposed Project are within the scope of the significant
effects from full buildout of all the uses permitted under the DNSP, given that actual development in the

DNSP

a
rea is well below the assumptions used in the D
NSP EIR in three of the four use
categories.

The DNSP EIR

also

assessed whether any
significant and unavoidable impact
s

would
occur
if the
DNSP buildout reached or exceeded defined thresholds of significance

and no feasible mitigation
measure
s

are
available to reduce the significant impact to a less

than

significant level.

The DNSP EIR
revealed that the DNSP would result in the following significant and unavoidable environmental effects:

Impact 4.B
-
1 Development facilitated by the Specific Plan would result in increased long -
term
emissions of criteria pollutants from increased vehicle traffic and on -
site area
sources.

Impact 4.B
-
4 Growth from development facilitated by the Specific Plan would be fundamentally inconsistent with the growth assumptions of the
Bay Area 2010 Clean Air

Plan
.

Impact 4.B
-
5 Development facilitated by the Specific Plan would generate greenhouse gas (GHG) emissions that may have a significant effect on the environment.

Impact 4.B
-
6 The Specific Plan could potentially conflict with applicable plans, policies or regulations of an agency with jurisdiction over the Specific Plan adopted for the purpose of reducing the emissions of GHGs.

Impact 4.L
-
1 Traffic generated by development facilitated by the Specific Plan would affect levels of service at study intersections under Existing
Plus
Project conditions.

•

SR
-
29 Northbound
off
-
ramp/First Street

Impact 4.L
-
2 Traffic generated by development facilitated by the
Specific Plan would affect levels
of service at study intersections under Cumulative plus Project conditions.

•

Silverado Trail/Third Street/East Avenue/Coombsville Road

•

SR
-
29 Northbound
off
-
ramp/First Street

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The DNSP EIR evaluated potential environmental impacts from the incremental effect of development to determine what impacts would be cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are cons iderable when viewed in connection with
the effects of past projects, the effects of other current projects, and the effects of probable future projects,
when

such impacts can result from a combination of the proposed project together with other projects causing related impacts. Cumulative impacts that could occur as a result of the DNSP were discussed in the DNSP EIR, which concluded that implementation of the DNSP would result in
significant cumulative impacts as follows:

Impact 4.B
-
4 Growth from development facilitated by the Specific Plan would be fundamentally inconsistent with the growth assumptions of the
Bay Area 2010 Clean Air

Plan
.

Impact 4.B
-
5 Development facilitated by the Specific Plan would generate greenhouse gas (GHG) emissions that
may have a significant effect on the environment.

Impact 4.L
-
2 Traffic generated by development facilitated by the Specific Plan would affect levels of service at study intersections under Cumulative plus Project conditions.

•

Silverado Trail/Third Street/East Avenue/Coombsville Road

•

SR
-
29 Northbound
off
-
ramp/First Street

With
certain
impacts determined to be significant and unavoidable, the Council adopted on May 1, 2012
,

“Findings of Fact and Statements of Overriding Considerations ,
” identifying
numerous
beneficial
attributes of the overall DNSP project.

When such a determination is made in a certified
EIR, CEQA provides that the City Council may balance the economic, legal, social, technological, or other benefits of the proposed Project against its unavoidable environmental impacts when determining wheth
er to approve the DNSP. In the case of the DNSP the City Council found that the benefits of the DNSP outweighed the significant unavoidable impacts because the DNSP will provide econ
omic, social and community benefits to the community through its comprehensive land use strategy, design guidelines, historic design guidelines, circulation improvements, sustainability measures, and visioning for future development in Downtown.

1.5 -

Summary of Results

As
demonstrated in
Section 4
Environmental Checklist, the proposed
Project

is
within the scope of
the overall development program that was the subject of the DNSP EIR . This determination supports
a

finding

that no additional environmental review is required for the proposed Project

under
Public
Resources Code Section 21166

CEQA Guidelines Section
s 15162

15168
.

Section 4 also
supports the City’s determinations that (a)

the proposed Project is an “in
fill

development” project
under CEQA Guidelines Section 15332, and (b) qualifies for the common sense exemption under ATTACHMENT 23

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CEQA Guidelines Section 15051(b)(3), and for both of these reasons, the proposed
P
roject is exempt
from additional environmental review.

1.6 -

Format of
Initial Study/
Addendum

The
DNSP
EIR provides program
-
level environmental information to support subsequent review of entitlement actions and development proposals. This
Initial Study/
Addendum provides additional
clarification and information about potential impacts that could result from the approval of the proposed
Project
. This
Initial Study/
Addendum also provides a brief summary of the impact analysis found in the

DNSP

EIR and should be read together with the full text of the

DNSP

EIR
.

The DNSP EIR is available at:

City of
Napa

1600 First Street

Napa, CA 94559

The contents of this
Initial Study/
Addendum are:

•

Section 1, Introduction, describes the CEQA process and the organization of this

Initial
Study/
Addendum.

•

Section 2, Project Description,
describes

the proposed
Project

in the context of the DNSP, the
Project

location, site
-
specific operations, and key characteristics of the proposed Project
.

•

Section

3,
CEQA Guidelines Section 15168: Proje
cts Consistent with Prior Environmental
Documentation.

•

Section
4 , Environmental
Checklist
:

Setting, Impacts, and Mitigation Measures, contains a
discussion of the setting and the environmental impacts that could result from the proposed Project

relative to the impacts
analyzed in the DNSP EIR. The section also identifies the applicable mitigation measures from the DNSP EIR that would reduce or eliminate these adverse impacts.

•

Section
5 ,
Other CEQA Considerations
, identifies
other
statutes with regard to CEQA the
proposed Project may also qualify for
.

•

Section 6, List of Prepar
ers
, contains a list of people who prepared the proposed document and associated technical studies.

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2 -

PROJECT DESCRIPTION

2.1 -

Downtown Napa Specific Plan

The 2012 DNSP recognized that
Downtown is a historic, pedestrian
-
oriented district within which
opportunities exist for future public and private development, including reuse of existing historic buildings, redevelopment of existing parcels, and new in fill

development. Future development
was
and
is anticipated to include residential, retail, office, hotel, and flex space that may be used for residential, retail, or office use.

The DNSP provides a blueprint for guiding future development and investment within Napa’s historic
Downtown

to support the community’s vision for an attractive,
vibrant and pedestrian
-
oriented
City Center.

T
he
P
lan
outlines future land use, development
standards
,

and multi
modal

circulation within
D
ow
ntown

and provides an implementation action plan to
achieve its key objectives.

The DNSP
Planning Area

encompasses approximately 210 acres and is bounded on the east by the eastern bank of the Napa River, on the south by Division Street and Third Street, and on the west by Jefferson Street; refer to Exhibit 1. The northern boundary generally follows the edg e of the
residential neighborhoods along Polk Street and Caymus Street west of Soscol Avenue, while the eastern boundary extends east to include the Oxbow Market and the former Copia area east of Soscol Avenue.

It should be noted tha
t
,

upon adoption, the General Plan modified the original DNSP boundary to include properties east of the River to Silverado Trail ,

extending south

to Third
Street
(see Exhibit 1). The land use designations did not change for these additional properties and their buildout is accommodated by the General Plan and
GP
EIR.

The DNSP
Planning Area

includes a diverse mix of land uses, including residential, lodging, retail, restaurant, office
,

and civic uses. Most of the
Downtown

core west of Soscol Avenue is a diverse
mix

of commercial uses ranging from small, local shops and restaurants to larger -
format retail. Office uses
are spread throughout
Downtown
, although several historic residential structures have been converted to office uses south of the commercial core. The DNSP also contains several public facilities, including City and
C
ounty administrative offices, the County Courthouse,
The City of Napa
Police Station, City Fire Station No.1,
and the Napa Library. There are
various

housing units within
the Planning Area, co
nsisting primarily of single
-
family houses, condominiums, and apartments.

Residential neighborhoods are adjacent to
Downtown

on the south, north, east, and west
.

New development projects are required to
conform to

the policies, programs
,

and guidelines set forth
in the DNSP
, including the
DNSP development standards that shape the form and character of development within Downtown by promoting coordinated and cohesive site planning and design.

There are three Building Form Zones in the Planning Area shown in Exhibit
2 :

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•

Downtown I Zone

would allow the most intensive development at the very center of Downtown
, north of First Street and running from the intersection of First Street and Main Street west to School Street.

•

Downtown II Zone

encompasses most of
Downtown

except for the core and edges and all of
the land east of Soscol Drive. The zone would allow medium -

to high
-
density development
designed to support uses located in the heart of
D
owntown.

•

Transition Zone

encompasses blocks or half
-
blocks between the
Downtown

core and the
sensitive lower
-
scale residential neighborhoods surrounding
Downtown
. Generally, the
southern and western blocks are characterized by the
Downtown

Neighborhood land use
district, while the northern blocks are characterized by Mixed -
Use and Downtown Core
Commercial land use districts
.

Six land use designations were established with the adoption of the DNSP , as shown in
Exhibit
3 . As
shown, the majority of the Project site is designated Downtown Core Commercial, while a smaller portion is designated Downtown Mixed
-
Use.

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Exhibit 2
Building Form Zones

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

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Exhibit 3
Focus Areas and Existing Land Use and Zoning

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

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2.1.1 -

Town Center Focus Area

The DNSP
Planning Area
includes three Focus Areas: Town Center, CineDome, and Copia

(Exhibit
3)
. These focus areas are geographic areas which, due to their strategic locations and existing mix and intensity of land uses, offer catalytic development opportunities. The Project

site is located within
the Town Center Focus Are
a (
Exhibit
4 ).

The Town Center Focus Area is located near the center of Downtown on First Street between Main and Franklin streets. It is the commercial center
of

the City
, and the majority of the Town Center
Focus Area is composed of the Napa Town Center and
now
vacant
Kohl’s development. The Town
Center Focus Area is approximately 14 acres, including all surrounding streets and a portion of Napa Creek.

The following are specific objectives guiding future redevelopment of the Town Center Focus Area contained within

the DNSP:

•

Establish a gateway at Main and First streets.

•

Respect the scale and patterns of historic buildings by transitioning taller building heights on the west and north ends to lower heights on the east and south ends .

•

Improve pedestrian, bicycle
,

and auto circulation through the design of streets, pathways ,

and
passageways.

•

Promote mixed
-
use development throughout the area, with retail emphasis on ground floors to activate building edges and housing and/or office above. This site represents the best opportunity for density and height in Downtown.

•

Encourage gathering places such as plazas and outdoor seating areas in public spaces as well as private development projects.

•

Emphasize Napa Creek as an amenity by orienting development toward it and establishing greenways along its edge.

•

Reactivate Brown Street as public space that supports pedestrian and bicycle activity.

•

Redesign Coombs Street Plaza to allow for future two
-
way vehicular circulation and allow for a
safe “shared street” environment for vehicles, bicycles ,

and pedestrians. Variations in paving
design can designate areas where vehicles may pass through and operable bollards or gates can allow the plaza to be closed to vehicles for special events.

•

Redesign and reactivate the Dwight Murray Plaza with an open and inviting “town square” quality. Remove obstructions to open up visibility of storefronts. Regrade the plaza and integrat
e landscaping to create a garden setting.

•

Provide space for a 9
/
11 memorial.

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61450001 • 03/2025 | 4_town_center_focus_area.cdr
Exhibit 4
Town Center Focus Area

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: City of Napa. RIOS. 10SB. March 2025.

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2.2 -

Location and Setting

2.2.1 -

Location

The approximately

2. 82
-
acre
Project

site is located in the City of
Napa
,
in
Napa
County, California
.

The City

is located
in the southern
portion of Nap
a County and is
between
the City of
Yountville to the
north

and

the City of American Canyon to the south
.

There are foothills
and agricultural lands to the
east and west of the City. The foothills
of the
Mayacamas Mountains

are

to the west, and

the

foothills
of the Vaca Mountains

are

to the east.

The
Project

site is located on the
Napa, California

United
States Geological Survey (USGS) 7.5
-
minute Topographic Quadrangle Map.

Regional
a
ccess
to the City is
provided by
State
Route (SR)

121 and
SR
-
29 . Local access
to the
Project

site
would be provided via
First

Street, Main Street,
Pearl Street,
and Coombs Street.

The
project
site
encompasses seven parcels,
located
generally
between First

Street and Pearl Street
and between Coombs Street and the Napa River.

The corresponding
APNs

include the following
:

Parking Lot Parcel

(APNs: 003
-
166
-
011

and

003
-
166
-
08),
C
o
o
mbs
S
treet LLC (CS)

Parcel
s

(APNs: 003
-
166
-
010, 003
-
116
-
015, 003
-
166
-
016,
and

003
-
166
-
016), and
Dwight Murray Parcel

(003
-
166
-
017)

(
Exhibit
5 )
.

Additionally, the
proposed

Project

includes various improvements to the
Public Realm
that
would take place on APN

003
-
167
-
020
,

which is considered an off
-
site
improvement area
(
Public Realm Parcel
)
.

2.2.2 -

Environmental Setting

Existing Land Use Activities

Project Site

The
Project

site currently contains a
vacant
department st
ore

(recently closed

Kohl’s
)
,
two
restaurants,

the recently closed Jax White Mule Diner,

the Dwight Murray Plaza
, which offers a
gathering area for visitors with various seating options , and

a shared parking lot

consisting of
approximately 50 parking spaces
.

Public Realm

The Public Realm
P
arcel also include
s

an existing City parking lot with approximately 36 parking stalls, the 9/11
Memorial Garden
, a
nd
the Brown Street
C
orridor.

Surrounding Land Uses

The
Project

site is surrounded by industrial and commercial buildings to the north, south, east, and wes
t, including the
Gordon Building and Allegria Restaurant located in the First National Bank building
,

First Street Napa Mall, Archer Hotel, and Opera House Plaza. Heritage Park is also located north

of the
Project

site across Pearl Street
.

Napa Creek is also located

north and east of the
Project

site.

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Public Realm Parcel
APN
003-167-020
APN
003-167-019
APN
003-167-010
APN
003-167-011
61450001 • 03/2025 | 5_existing_conditions.cdr
Exhibit 5
Existing Conditions

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: City of Napa. RIOS. 10SB. March 2025.

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2.2.3 -

Land Use Designation and Zoning

The
Project

site is
primarily
designated and zoned
Downtown Core Commercial (DCC) and
partially
design
at
ed (the Parking Lot Parcel)
Downtown Mixed
-
Use (DMU)

by the DNSP and the City’s Zoning
Ordinance, respectively

(Exhibit
3 )
.

The DNSP Land Use Designation
for
Dwight Murray Plaza is
DCC
.

For the most part, the Napa 2040 General Plan Update copied the land use designations throughout the DNSP boundary. However, the General Plan Land Use Diagram (2040 General Plan Update, Figure 2
-
3) depicts Dwight Murray Plaza as
Open Space and Parks

which is consistent with
the City’s Parks plan listing of Dwight Murray Plaza as a Civic Space

(2040 General Plan Update,
Table 4
-
4).

As described in more detail in Section 2.3.2, below,
the relocation of the
Civic Space
plaza
through the
proposed
PD Overlay

and Development Agreement does not
require
a General Plan
Amendment under Section 1.9 of the 2040 General Plan Update.

The DNSP
mandates development density through its Building Form Zones . The majority of the
Project

site

is within the Downtown I Building Form Zone,
which
has a m
aximum development density
of 60 dwelling units per acre (du/ac
re
)
;

a small
er

portion of the
Project

site
(also the Parking Lot
Parcel)
lies within the Downtown II Building Form Zone
,

which has a
maximum development density
of 40 du/ac
re
.

The purpose of the DCC zoning district/land use designation is to promote the continued development and revitalization of the pedestrian
-
oriented Downtown area that serves as the City’s
unique shopping district, as a neighborhood hub for the residences surrounding it, and as the center
of the City’s community. The DCC designation supports a mix of land uses (i.e., shops, restaurants, hotels
,

and entertainment in designated areas) that w
ould

draw people Downtown during the day
s
,
in
the
evening
s
,

and on weekends; develop an improved streetscape to offer visitors a pleasant pedestrian experience; and create a series of outdoor spaces to encourage public gatherings in the City Cen
ter.
3 The DMU
zoning district/land use designation provides for retail uses; administrative and other offices; institutional, recreational, entertainment, arts, and cultural uses; hotels and conference facilities; transportation facilities;
and public and quasi
-
public uses that strengthen Downtown’s role
as the community’s center.
4 The DMU designation/zoning also encourages residential uses ,

primarily
as part of a mixed
-
use designation.

The Project’s proposed PD
Overlay
w
ould

provide the applicable use regulations and development
standards generally consistent with the DCC zoning district/land use designation.

The DNSP Entertainment Overlay District Map also would be amended to include the entirety of the Project site.

Portions of the Project site are currently within the Entertainment Overlay District.

Including the entire site would provide the proposed Project with
a uniform permitting standard to
implement entertainment uses and activities allowed by the DNSP.

3 City of Napa. 2024. Municipal Code Chapter 17.10. Website: https://ecode360.com/43396494. Accessed October 17, 2024.

4 City of Napa.
2012. Downtown Napa Specific Plan (DNSP), Chapter 4, Land Use Designations and Zoning Districts.

May.

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2.3 -

Project Description

The
Project

applicant
(
Coombs Street LLC

and 300 Venture Group
) proposes to demolish the existing
structures
and improvements
on the
Project

site

and construct a
mixed
-
use

development consisting
of
a hotel,
multi
-
family
residential u
nits
, and commercial space

(
Exhibit
6 )
.

The

6 -
story
(
approximately
75 feet in height with rooftop features
,
with an additional approximate 12 feet of Roof Top Activation plus 7 feet for equipment including MEP and Elevator Overruns )
hotel would consist of approximately
1 90
,000 square f
ee
t

hotel
space
and
a maximum of

161 rooms
,

as well as a
ground

floor

restaurant and a rooftop bar/
event space. The
approximately
178,000 square feet
of
residential

space

w
ould

consist of
78 market
-
rate for
-
sale
multi
-
family
condominium units

and
c
ould be expected to
introduce
up
to
20 2

new residents
, and also w
ould

be available for nightly
transient occupancy
rental
affiliated with the hotel
.
5 ,
6 The commercial space w
ould

consist of a total of 30,000 square feet of
first

and
second

floor

retail space
,
with
approximately 50 percent
being
stand
-
alone

commercial
spaces
and
50 percent
being hotel
and residential
accessory spaces.

The

proposed

Project

would
also

include a new pedestrian crossing across Main Street north of the Project

site to improve pedestrian traffic in the area. The proposed Project

would redesign the existing
parking lot off Main Street to include a dedicated arrival/drop -
off zone and renovate the Brown Street
C
orridor.

The redesign would eliminate up to
30 long
-
term parking spaces from the parking lot.

The

redesign

the
Brown Street

C
orridor
would
feature

improved hardscape

and landscape designs,
seating areas, vendors, and public art walls.

The Project site encompasses seven parcels, located generally between First Street and Pearl Street and between Coombs Street and the Napa River. The corresponding APNs include the following:

Parking Lot Parcel

(APNs: 003
-
166
-
011 and 003
-
166
-
08),
C
oombs
S
treet LLC (CS)

Parcel
s

(APNs: 003
-
166
-
010, 003
-
116
-
015, 003
-
166
-
016, and 003
-
166
-
016), and
Dwight Murray Parcel

(003
-
166
-
017) (Exhibit 5).

The

seven

existing
APN
s

would
be reconfigured into
a to
t
al of
five

parcel
s

for financing, ownership
,

and condominium property division purposes
,

made up of
three

fee parcels,
one

condominium
airspace parcel
,
and
one

airspace parcel
.

N
o demolition
,

construction
,

or Project
activities would
occur
within the Napa Creek
C
orridor
.

Additionally, the proposed Project includes various
improvements to the Public Realm
that
would take place on APN 003
-
167
-
020
,

which is considered
an off
-
site improvement area (
Public Realm Parcel
) (Exhibit 5).

5 United States Census Bureau. 2024. Napa, California Quick Facts. Website:
https://www.census.gov/quickfacts/fact/table/napacitycalifornia/PST040223 . Accessed
March 5, 2025.

6 2.58 persons per household *
78 d
welling units

= 201.24 persons

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61450001 • 05/2025 | 6_proposed_site_plan.cdr
Exhibit 6
Proposed Site Plan

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: City of Napa. RIOS. 10SB. March 2025.

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2.3.1 -

Public Realm
Improvements

Public
Realm Parcel

The proposed
Project

would include various improvements on the
Public Realm
P
arcel

(APN

003
-
167
-
020)

to the northeast of the
Project

site. The Brown Street Corridor would be renovated with improved hardscape and landscape design, seating areas, and vendor areas . The proposed
Project

would also include a new pedestrian
crossing

at approximately the mid
-
point location to align with the
existing sidewalk connecting to the 9/11

Memorial Garden, and the existing City parking lot would be improved and redesigned to provide a dedicated drop
-
off at the Brown Street Corridor.

Up to
30 long
-
term parking spaces would be removed from the parking lot, and t he
trash enclosure on
the existing City parking lot would also be
relocated.

T
rash operations that this enclosure served
for
the Project site
would
be
relocated
to strategic locations within the development including the loading area on Coombs Street
, while trash operations that this enclosure served for the businesses on First Street
would
be modified or relocated
.

Public Art

The proposed Project would incorporate public art
in the Public Realm Parcel
at key locations as
identified in the City’s Public Art Master Plan, including a proposed

space in front of the north wall

(backside)

of the
Allegria

restaurant
building.

Dwight Murray Plaza E
xchange

The proposed
Project

would result in the
demolition of Dwight Murray Plaza
within the City Property
Parcel

along
First Street

to allow for the construction of the
proposed h
otel. To
replace Dwight Murray
Plaza
, the proposed
Project

would

develop a new public plaza of a size equal to or greater than

the
Dwight Murray Plaza (approximately 0.18 acre)
. This
New Plaz
a would

aligned with

the former
Clay Street right
-
of
-
way

within the central portion of
APN

003
-
166
-
010

so that
visual connections for
pedestrians
are created
from Coombs

Street to the 9/11 Memorial Garden and the Opera House. The plaza would
be

Americans with Disabilities Act (ADA)

compliant and place heavy emphasis on
pedestrian

travel

with design elements for retail activation

and

public gathering
venues.

The plaza
would

include a public concourse running between

the hotel and residential buildings that
would

lead
from the First Street Napa
M
all to the Brown Street Corridor.

The proposed
Project

would include a
n

i
rrevocable offer to

dedicate public access

and use easement of

approximately 8,310

square feet to
the City.

2.3.2 -

Proposed Zoning

and Design Guidelines

The proposed
Project

would include a
Zoning

Amendment to redesignate the
entire Project site as a
PD Overlay

with standards
that substantially conform to

the DCC/Downtown I standards
.

The PD
Overlay w
ould
establish specific use provisions, intensity and density, maximum floor area, and maximum height, along with other development
and administrative
standards that w
ould

be required
as part of the future design review for the Project.

The PD
Overlay
also establishes
p
roject
-
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Design Guidelines

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plazas and promenades, and natural areas that w
ould

advance some of the key goals for the
Downtown Napa Specific Plan Town Center Focus Area.

The First Street Napa Phase II
Redevelopment Design Guidelines
(A
ppendix

A)
are site
-
specific and supersede the more general
D
NSP

Design Guidelines, Chapter 5, to guide and define the character of new development within the PD
Overlay

and implement the vision and goals of the
DNSP
.

The uses permitted by the PD
Overlay

generally follow those found in the DCC, including
entertainment, food
and

beverage, service commercial, and general retail. The project -
specific
development standards established by the PD
Overlay

substantially conform to

the current
development standards for the DNSP Downtown I Zoning District.

The additional PD
Overlay
standards itemize the proposed Project’s
f
loor
a
rea
r
atio (
FAR
)
, number of housing units
,

and use of
the top floor space for spa and food/beverage uses consistent with regulations provided in the Zoning District. The PD

Overlay

also ties together the Design Guidelines, Design Review Process ,

and
Development Agreement as implementation components of the proposed Project. The specific d
evelopment
s
tandards are listed below:

The following Building Form Standards apply to the
proposed
P
roject in lieu of Table 4.3 Development
Standards in the Downtown Napa Specific Plan and the City’s Zoning Ordinance.

Table
2 :

Town Center Focus Area 1 PD

Overlay
–
Development Standards

Building Form Standards

Downtown I

Town Center Focus Area 1 PD

Overlay

Floor Area Ratio (FAR)

Up to 5 FAR

5 FAR

for the
h
otel and
r
etail
components of the
proposed
P
roject
.

Residential Density

(dwelling units/acre or
du/acre
)

20 (Min) to 60 (Max)
du/ac

A total of 78 residential units if permitted
with the
proposed
P
roject
.

Building Height (f
ee
t)

Max 75

feet

Max
imum

75 feet

for the Project site
,
subject to Additional PD

Overlay

Regulations Note 1.

Front Setback

No requirement

First Street setback shall be consistent
with the existing Gordon Building front
setback and the building face may
maintain the historic zero lot line along
First Street.

Pearl Street setback: No requirement

Side Setback

No requirement

Rear Setback

No requirement

Step

backs

No requirement

Per Project Guidelines

Minimum Lot Area (
square feet
)

No requirement

Lot Width (feet) at front set
back

line

No requirement

Lot Frontage (feet) at front property line

No requirement

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Additional PD

Overlay

Regulations:

1. Rooftop Features
.

In addition to those height limit exclusions listed in Section 17.52.220, the Project height limits specified in Title 17 may be exceeded for rooftop patios with conditioned space that are for food and bar service with restrooms and food and bar service st ructures
provided that such features are accessory to the
proposed
P
roject on the site and are setback,
screened
,

or otherwise designed to minimize visibility from First and Main Streets

adjacent to
the site, further provided that portions of structures providing rooftop and building fire access are not required to minimize visibility from Main Street.

2. Parking
.

110 parking stalls
would

be supplied in the
proposed
P
roject’s residential structure
and 129 stalls
would

be supplied in the Pearl Street garage or other parking facilities owned by the
C
ity. The
proposed
P
roject

requires 239 parking stalls for Project operations: 78
residential parking stalls parked at 1 space per residence; 129 parking stalls for the hotel parked at 0.8 spaces per room, which parks at the same rate as the Archer Hotel within the Pearl Street Gara
ge; and an additional 32 flex spaces for
proposed
Project demands. The City
shall not require any parking quantities above the Parking Requirements and Supply and as contained in the Planned Development Overlay District for the proposed
P
roject
.

3. Uses
. Other uses

may be allowed if deemed appropriate by the Community
Development
Director.

4. Design Guidelines
.

The First Street Napa Phase II Redevelopment Design Guidelines shall supersede the Downtown Napa Specific Plan Design Guidelines, Chapter 5, to guide and define the character of new development within
PD

Overlay

and implement the vision and
goals of the Specific Plan and
PD

Overlay
.

In connection with its review of any Design Review
Permit application(s) in
PD

Overlay

for the
proposed
P
roject, the City shall exercise its
discretion in a manner
consistent with the design
-
related criteria, guidelines and standards set
forth The First Street Napa Phase II Redevelopment Design Guidelines.

5. Design Review
.

The

City Manager or the Manager’s designee
shall make the final
determinations on any Use Permit applications subject to Ch. 17.60

of the Napa Municipal
Code
;

all Design Review applications for the
proposed
P
roject subject to Ch. 17.62 of the
Napa Municipal Code
;

all Certificate of Appropriateness applications subject to Ch. 15.52 of the Napa Municipal Code
;

or any other discretionary permit that
does

not include a
modification
and does

not increase the intensity of the permitted uses
, increase the density
,

or
increase the maximum height or size of proposed buildings that also conforms to the Design Guidelines, provided that such applications are filed and processed in accordance with the
Agreement

within 18 months of the Effective Date
.

For applications filed more the 18 months
after the Effective Date, all determinations shall be made in accordance with the decision -
making authority as provided in the applicable provisions of the Napa Municipal Code. The decision of the Manager
may be appealed to the City Council within
10 days of the
Manager’s

decision.

6. Napa Creek Setback
. The minimum Project
building or disturbance setbacks from Napa Creek
shall be established by the extent of previously developed, disturbed ,

or urbanized areas. The
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following uses, structures, facilities
,

or Public Realm Improvements depicted in the Guidelines shall be allowed within setback areas with approval of Design Review Permit for the

proposed

P
roject:

Sidewalks, trails, and pedestrian circulation areas and facilities;

Fencing
, screening, stormwater and bioretention facilities
,

and similar features;

Landscaping
(including hardscape);

Signage
and graphic displays.

7. Signage
. The Community Development Director shall make the final determinations on any uniform sign program and creative sign program applications for the proposed
P
roject filed
pursuant to Municipal Code Sections

17.55.070(A)

and

(B) in accordance with the processing
requirements of Section 5, Design Review.

8. Modifications
. Modifications to the above development standards for the proposed
P
roject that
do not increase the intensity of the permitted uses, increase the density ,

or increase the
maximum height or size of proposed buildings shall be processed in accordance with Napa Municipal Code Section 17.56
-
Administrative Exceptions.

9. Development Agreement
. The Development Agreement establishes the rules, regulations, official policies, standards and specifications of the City to be applied to the proposed
P
roject,
including the processing of Subsequent Approval applications and other requirements, which supersede conflicting regulations under the City Municipal Code.

DNSP
Design Guidelines

As outlined in Appendix A, t
he
DNSP
D
esign
G
uidelines
contain standards
applicable to development
projects located

within the
DNSP area
. Ultimately,
the
project
-
specific Design Guidelines’
conformance with the DNSP

guidelines are determined by the Planning Commission and City Council for the City of

Napa.

Administration of the Design Guidelines is established in the Development Agreement and PD.

2.3.3 -

Site Access and Circulation

Parking

The proposed
Project

would include 110
residential
parking stalls within the on
-
site residential
structure, and an additional 129
hotel
parking stalls would be provided in the existing Pearl Street parking garage and other parking facilities owned by the City

as detailed in Table
3 , below
.

The
proposed
Project

would be required to provide 78 residential parking stalls, equivalent to 1 parking space per residence
, and 129 hotel parking stalls,
equivalent

to 0.8 parking spaces per room
,
7 as well
as
the potential
for
32 flex parking spaces for other
Project

demands.

The proposed
Project

includes a
110
-
space,
two
-
level garage structure integrated into the podium of
the residence building
, providing
the required 78 residential parking spaces

and
up to

32 flex parking

7 The
same rate of
parking spaces per room as the nearby Archer Hotel.

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spaces
, which would be valet operated

for non
-
hotel visitors arriving at the new drop
-
off
.

Parking on
-

and off
-
site would be regulated by the proposed Development Agreement and PD Overlay as part of the proposed Project.

Table
3 :

Proposed Parking

On
-
s
ite
Garage

Parking Spaces

Public Realm

Parking Spaces

Off
-
s
ite

Parking
Spaces

Total

Residential

78 —

—

78 Hotel

—

129

Flex (Valet

Operated)

32 10

—

42 Total

1 10

10 129

2 49

Sources: Compiled by FirstCarbon Solutions (FCS). 2025.

Vehicular

Circulation and

Access

The proposed
Project

would include vehicular access

to the resident garage

and the Pearl Street
garage on

Coombs Street. Coombs Street would also include a residence loading location and a hotel loading location.

As described above, the proposed
Project

would also include a
drop
-
off
/loading
loop

as part of the public realm
improvements to the existing parking lot off Main Street .

Fire access
would be provided via
Main

Street
through
the Main Street drop
-
off/loading
loop
.

Adequate
turnaround distance would be provided for
fire truck access and
emergency vehicles

through a
turnaround area in a portion of the Brown Street
C
orridor adjacent to the drop
-
off/
loading loop.

Bicycl
e Circulation and Access

Bicyclists w
ould

be directed to travel along the mid
-
block corridors and through the p
roposed
improved
Brown Street

Corridor
.

Per the City of Napa General Plan and City of Napa Bicycle Plan, the proposed Class I bicycle facilities along the Brown Street Corridor shall continue along Pearl Street to connect at the Pearl St/Coombs Street intersection.

This plan w
ould

ensure a clear path of
travel f
or
bicyclists through
the proposed

Project

and particularly through parking lots and
common

spaces. Bicyclists w
ould

be provided with
conveniently located

bicycle parking
,

and route and
wayfinding signage
would be included
along bike pathways for orientation and to encourage long -
distance use
.

The proposed
Project

would include
3 4

b
icycle parking
spaces
serving

the residential
units
.
8 Bike
r
acks are also currently located in the
existing
p
arking lot adjacent to Main
Street
and
Pearl Street
.

8 City of Napa Municipal Code Section

17.54.060 also provides bicycle parking requirements for non -
residential uses,
which the proposed Project would be required to comply with.

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Pedestrian Circulation and Access

Pedestrians would access the
Project

site from pedestrian pathway entrances along
the
Main Street

crosswalk
,
First
Street, Coombs Street, and Pearl Street. A new
pede
strian plaza w
ould

run east to
west through the center of the
Project

site
,
separating the hotel from the residential area. It w
ould

connect the
existing pedestrian corridors from
First

Street Napa Mall
to
Main Street and provide a
connection to the existing 9/11 Memorial Garden

and the Brown

Street Corridor
.

It w
ould

also provide
access to the proposed retail spaces along the plaza. Additionally, the proposed
P
roject

would
incorporate an overhead pedestrian walkway connecting the residential building to the hotel building.

The
Project

site is

also

approximately

0.17 mile north of the
Third
Street at Brown Street bus stop.

2.3.4 -
Design and Appearance

T
he proposed
Project

would incorporate design elements
from

former historic buildings
nearby
,
such
as the
adjacent
Gordon Building, near street level, with higher floors taking on a more modern aesthetic
.

The building setback on First Street
would

be consistent
with

the setbacks of the

adjacent
Gordon Building, creating a continuation of the historic zero lot line and building face along First Street.

T
he
l
ower
-
level podium that matches

historic design

patterns, including the former Migliavacca
Building located on the site in the 1900s and includes

a corner design aesthetic reminiscent of the
Migliavacca Building that
would

be implemented
.

Upper stories w
ould

incorporate setbacks
/step
backs

with b
alconies and roof gardens
to

maintain a pedestrian
-
scale

setting

and to separate
from
the
historic aesthetic of the ground floors.

Key use and design considerations included in the site
-
specific Design Guidelines for the proposed
Project include
a
n integrated, active, and inviting expansion of
D
owntown Napa with both private and
public realms of development.

Key Public Realm Elements

•

Outdoor and Public Spaces: The outdoor and public spaces w ould

include both raised and

at
-
grade spaces facilitating a myriad of public and private uses. This would
include spaces
designed

for active engagement and connections for pedestrians on adjacent public property on First

Street and the former Brown Street. Programming includes the potential for public gatherings,

food and beverage sales, and organized public and private events.

•

The proposed
P
roject
w
ould

develop a new public plaza (the
New Plaza
) of a size equal to or
greater than

the Dwight Murray Plaza (approximately 0.18 acres) and in a location roughly aligned with

the former

Clay Street right
-
of
-
way (to create visual connections for pedestrians
from Coombs

Street to the 9/11 Memorial Garden and the Opera House). The New Plaza w
ould

be a pedestrian
-
oriented ADA
-
compliant space with design elements for retail activation compl
e
mentary to First

Street and public

gathering opportunities that w
ould

include a public
concourse running between

the hotel and residential buildings that w
ould

lead from the First
Street Napa
Mall
to the Brown

Street Corridor.

•

The former Brown Street
C
orridor w
ould
be restored and is intended to be designed to

meaningfully engage the adjacent public rights
-
of
-
way between the Project site, new hotel

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drop
-
off, the 9/11

Memorial Garden, Main Street, Napa Creek and the surrounding D
owntown

areas and Oxbow district. This w
ould
transform the currently underutilized spaces adjacent to the

Creek into an extension of the
Project
’s spaces for public and private uses.

•

A new pedestrian crossing extending from the existing sidewalk and aligning with the mid -
block

bridge across the Napa Creek w
ould

further connect the
Project

to the Oxbow district to the

east.

Key Private Realm Elements

Given the
P
roject’s proximity to nearby
D
owntown Napa historic landmarks and

buildings, the
proposed Project

would

incorporate

various features to acknowledge this historic relationship.

•

Historic Patterns: The
P
roject w
ould
restore the historic urban grain, aligning

the street frontage
with the existing historic resources while bringing back the

implied building mass from the
former
Migliavacca
Building
and extension of the urban grid through the new pedestrian paseo.

•

Height, Setbacks and Step backs:

The buildings w
ould

reinforce the historic

pattern with
heights, setbacks and upper
-
level step backs oriented to the many

existing
2 -

and
3 -
story
buildings. Proposed buildings near historic

commercial buildings abut walls and aim to create a
solid block face
.

•

Along First Street, the Project proposes consistent setbacks with adjacent the existing Gordon Building

and continuation of historic zero lot line and building façade along First Street.

•

Style and Materials: Selected styles and materials would complement the character of the existing historic buildings.

•

Primary Fa
ç
ades
and

Entries: The
Project

site design prioritizes orienting

buildings so that
primary façades and key pedestrian entries face major streets or

plazas.

•

Corners: The buildings w
ould

incorporate corner
s
accentuated with

height, articulation
,

and
unique roof silhouettes to emphasize their presence. The P
roject w
ould

aim to locate ground

floor commercial uses on street

corners at key intersections.

•

First Floor Height: The buildings’ first floor height
s

w
ould

be a minimum of 14 feet,

which is in
alignment with the D
NSP
’s Ground Floor

Height Guideline Area; this height requirement w
ould

distinguish that area as

the retail core of Downtown.

•

Primary Fa
ç
ades
and
Entries: The
P
roject site design prioritizes orienting

buildings so that
primary façades and key pedestrian entries face major streets or

plazas.

•

Upper
-
s
tory Step
B
acks:

Buildings w
ould
incorporate upper
-
story step

backs in

order to retain
a

pedestrian
-
scale

setting; these setbacks w
ould

include

balconies or roof gardens.

Buildings
w
ould

incorporate upper
-
story step

backs at the

roof top in order to

retain a pedestrian
-
scale
setting; these
setbacks w
ould
include balconies or roof gardens.

Additionally, the upper
penthouse level

of hotel
rooms

and residences
would
step back from the primary fa
ç
ade for
additional

massing articulation.

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•

Shade: Building design considers the
potential shading impacts on

surroundings. Building
height, mass, setbacks, and arrangement respond

to potential shading issues, minimizing
shading impacts where they would be

undesirable or maximizing shading where it is desired
.

•

Building Setbacks: Along
F
irst
S
treet, consistent with
the
adjacent existing Gordon

Building, the
front

setback shall maintain the historic zero lot line and building

face
. Other property
boundaries hold no requirements, consistent

with the zero lot line within the D
NSP
.

•

Height Exceptions: In addition to those height limit exclusions listed in Section

17.52.220, the
Project

height limits specified in Title 17 may be exceeded for rooftop

patios with conditioned
space that are for food and bar service with restrooms and food

and bar service structures
provided that such features are accessory to the Project on

the site and are setback,

screened
,

or otherwise designed to minimize visibility from

First and Main Streets adjacent to the site,
further provided that portions of structures

providing rooftop and building fire access are not
required to

minimize visibility from

Main Street.

•

Overall Façade Design: The buildings w
ould

create a human
-
scale environment

and avoid
large uninterrupted expanses of wall
surfaces by enlivening

façade
s with projecting elements
such as entrance porches, porticoes, canopies,

awnings and trellises; recessed entries to
develop small alcoves;

complete commercial storefronts with details including

doors, display
windows, bulkheads, signage areas and awnings; expressive

elements such as cornices,
lintels, sills, balconies; and well
-
designed

upper
-
level features such as balconies and bay
windows. While it w
ould
be

important to create dynamic
façade
s, designs w
ould
prioritize
features and details

that have purpose rather than being applied or strictly decorative.

•

Rear
and

Side
Façade
s: The site design
—
with mid
-
block pedestrian passages
—
w
ould

create
a context with most building
façade
s being visible to the public realm.

Building designs w
ould
accommodate this layout by develop rear and side
façade
s

that w
ould
still be pleasant and
inviting and have the same level of trim and

finish as the front
façade
.

•

Windows: Building design w
ould
maximize
transparent windows on all sides

of building and
create unobstructed views into interior spaces. Ground

floor commercial areas w
ould

feature
display windows to enliven the street and

provide pedestrian views into the interior of the
storefront; to the extent

possible, these areas w
ould

have floor
-
to
-
ceiling windows. Window
design

w
ould

prioritize clear or lightly tinted glass on ground floor building façades that

preserves transparenc
y
and avoid opaque, reflective
,

or dark tinted glass
.

•

Overall Material Quality: Selected building materials w ould

be of high

quality,

provide visual
interest, and suggest durability and permanence to last into the

future. Building trim and
metalwork
would

be related to the building

architecture.

•

Balconies:

Upper
-
level balconies w
ould
incorporate transparent or semi
-
transparent railings to
enhance natural lighting and maximize eyes on the

street.

•

Awnings, Lintels, Sills, Overhangs, and Arcades:

Façade
s
—
particularly on

south or southeast
facing fronts
—
would

feature protruding vertical or horizontal

shading devices such as awnings,
lintels, sills, overhangs, and arcades to

provide sun and weather protection and create spaces
where pedestrians can

comfortably walk, shop, eat, and sit. These design features w ould
be
decorative

and complementary to the overall façade design

and w
ould
also help to

highlight
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entrances and assist in wayfinding. Awnings w
ould

be in scale with

the building, be regularly
maintained and cleaned, and may incorporate

signage on the street
-
facing side of the valance
with a subtle design reflecting

the business name or service. Design of awnings w
ould

avoid
features which

inhibit pedestrian movement or views; cover transom windows or

architectural
elements such as belt courses,
decorative trim or other notable

architectural façade elements;
cover building piers; or include

signage on the sloping portion of the awning
.

Based on the
Design
Guidelines, the
proposed
Project

w
ould

avoid large uninterrupted expanses of
wall surfaces by enlivening fa
ç
ades with
p
roject
ing elements
,
such as entrance porches, porticoes,
canopies, awnings
,

and trellises
;
recessed entries to develop small alcoves; complete commercial storefronts with details including doors, display windows, bulkheads, signage areas ,

and awnings;
expressive elements
,

such as cornices, lintels, sills; and
upper
-
level

features
,

such as balconies and
bay windows
.

The p
roposed
Project

would maximize window use wherever po
ssible, creating
unobstructed views into retail space
s.

Materials

used in the construction of the proposed
Project

would include brick, limestone, dark grey anodized aluminum, and perforated metal paneling.

Rooftop Height Exemption

While the Downtown I Zone limits the maximum height of 75 feet, under certain circumstances height limits may be exceeded for certain rooftop features. In addition to those height limit exclusions listed in Section 17.52.220, height limits specified in Tit
le 17 may be exceeded for rooftop patios with
conditioned space that are for food and bar service with restrooms and food and bar service structures provided that such features are accessory to the proposed Project on the site and are setback, screened or
otherwise designed to minimize visibility from First and Main Streets adjacent to the site, further provided that portions of structures providing rooftop and building fire access are not required to minimize visibility from Main Street. The PD

Overlay

allows rooftop patios with conditioned
space that are for food and bar service with restrooms and food and bar service structures which are accessory to the proposed Project and are set back, screened, or otherwise designed to minimize visibility from the

str
eets adjacent to the Project site.

The main portion of the proposed building would
extend to 74 feet

5 inches in height, but portions of the proposed Project would reach

approximately

86 feet
3 inches with the inclusion of a rooftop deck and patio. With the screening

and minimizing
visibility

of the features, the height of the proposed Project would be consistent with the general requirements of the Zoning Ordinance and Municipal Code.

2.3.5 -

Landscaping

Th
e proposed
Project

would
incorporate trees and plants that are na
tive to the area and drought
resistant.

The proposed
Project

would include approximately
18,200 square feet of landscaping at
ground level

and approximately
13,000 square feet of landscaping on the proposed buildings.

Prior to
construction, approximately 38 trees would be removed. Approximately 63 new trees would be
planted at ground level as part of the proposed
Project

along with approximately 119 trees on the
proposed buildings
.

Alleyways
of vegetation in planter boxes w
ould

line

p
ublic
r
ealm spaces including

pedestrian spaces
, and
the proposed buildings w
ould

incorporate green spaces on
rooftop

gathering
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spaces

and courtyards.

Street
-
facing

trees would line the perimeter of the
Project

site, and the
proposed improvements to the Brown Street Corridor would be lined with native trees and shrubbery.

2.3.6 -

Lighting

The
proposed
Project

would rely primarily on building
-
mounted lighting for retail spaces and
pedestrian pathways

designed to accent the building’s architectural characteristics. The lighting would be
appropriately scaled

to complement the building’s architectural style and harmonize with the building’s metalwork
.

The proposed
Project

would also utilize illuminated signage
.

Additional
o
pportunities for

light posts along the Brown Street Corridor
would
be identified and located to be

compl
e
mentary to the architectural lighting along the public realm .

2.3.7 -

Utilities

The
proposed
Project

would be served by the following utility providers:

•

Electricity

and Natural Gas
:

Pacific Gas and Electric Company (PG&E)

•

Potable Water: City of
Napa Water Division

•

Wastewater:

Napa Sanitation District

(NapaSan)

•

Storm Drain: City of Napa

•

Solid Waste
/Recycling: Napa Recycling and Waste
Services (NRWS)

•

Telecommunications:

AT&T

2.3.8 -

Storm Drainage

The
Project

site would utilize planters on rooftops to minimize roof runoff. Pedestrian pathways and gathering spaces would limit the use of impervious surfaces and instead incorporate planted areas and permeable pavers to the extent possible to maximize water infilt ration. Strategies, such as bio
treatment planters and planter strips (i.e., in landscaped bulb outs and along sidewalk edges), would be used to the extent possible to collect stormwater runoff. This approach would help to create an environment
of natural percolation and replace piped percolation where possible. Runoff from the roof w
ould

be conveyed to biotreatment planters at the ground level for treatment. The common space between the
hotel portion and multi
-
family residential units

w
ould

utilize permeable pavers for
stormwater collection and treatment. The common space along the
Brown
S
treet
C
orridor
w
ould

she
et

flow into biotreatment planters. Runoff from the roof of the hotel

and
s
outhern portion of the
multi
-
family residential

building
w
oul
d

be conveyed to the existing storm drain at the
s
outh
ern

portion
of
the
Brown
S
treet

C
orridor
. Runoff from
the
n
orthern portion of
the
multi
-
family residential

building
w
ould

be conveyed to bio treatment planters and then connected to the
existing storm drain in Pearl
S
t
reet
.

2.3.9 -

Phasing and Construction

The proposed
Project

would
include
demoli
tion

of
the existing on
-
site structures

and surface parking
lots

and

c
onstruction of the proposed
Project

and off
-
site roadway and frontage improvements
.

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Demolition

activities

of
existing structures

and proper abatement and removal of

ma
terial
would
commen
ce

as early as

the
second

quarter of

2025.

Construction

is
currently
estimated to be
completed in
a single

phase
,

project
ed to conclude in
2027
. Construction would take approximately
2 6

months, including demolition and grading. The proposed
Project

is expected to be operational in
August of
2027
.

However, the Development Agreement allows phasing and proposes a 10 -
year term
for the
proposed
P
roject to be able to adjust to changing market conditions.

2.3.10 -

Project Design Features

The proposed buildings would utilize materials and finishes that are durable and long -
lasting to
prolong architectural integrity and longevity. Proposed buildings would also include architectural features, such as canopies, awnings
,

or light shelves on south
-
facing windows and entries to control
natural lighting while minimizing direct solar heat gain. The proposed Project

would be solar ready
and comply with all
California

Building
Code
and California Energy Efficiency Standards (Title 24)
requirements. E
lectric

vehicl
e (EV)

charging equipment would be provided for all EV stalls described above in Section 2.3.4, Site Access and Circulation.

2.4 -

Discretionary Approvals

T
he
proposed
Project

includes

the following discretionary approval
s
:

•

Planned Development Overlay

Zoning Amendment

•

Development Agreement

with an
Affordable Housing Alternative Equivale
nt

and other
agreements

•

Specific Plan
Map
Amendment

(
f
or P
lanned
D
eve
lopment

Overlay and Entertainment Zone)

•

Zoning
M
ap

Amendments

(
f
or PD
O
verlay
)

•

Tentative Parcel Map

It is anticipated that the proposed
Project

would require the following subsequent approvals:

•

Design Review
(per the P
lanned
D
evelopment

Overlay and Development Agreement)

•

Building Permits

•

Final Map

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3 -

CEQA
GUIDELINES SECTION 151
68 : PROJECTS

CONSISTENT WITH

PRIOR ENVIRONMENTAL

DOCUMENTATION

3.1 -

Public Resources Code Section 21166 and
CEQA
Guidelines Section 15168

Public Resources Code 21166 states:

When an environmental impact report has been prepared for a project pursuant to this division, no

subsequent or supplemental environmental impact report shall be required by the lead agency or by

any responsible agency, unless one or more of the following events occurs:

(a)

Substantial changes are proposed in the project which will require major revisions of the

environmental impact report.

(b)

Substantial changes occur with respect to the circumstances under which the project is being

undertaken which will require major revisions in the environmental impact report.

(c)

New information, which was not known and could not have been know n.

The DNSP EIR is considered a program EIR under CEQA Guideline Section 15168, as described in detail in Section 1.3.1 of this Addendum.

Pursuant to CEQA Guideline Section 15168, l
ater activities

(the specific
p
roject development)

in
a

program

(such as the DNSP)
must be examined in the light of the

program EIR to determine whether
an additional environmental document must be prepared

for those later activities.

If the agency finds
that pursuant to
CEQA Guideline
Section 15162, no subsequent EIR would be required,

the agency
can approve the activity as being within the scope of the project covered by the

program EIR, and no
new environmental
document would be required
.

Where the later activities involve site
-
specific
operations,
the CEQA Guidelines advise that
the agency should use a written

checklist or similar
device to document the evaluation of the site and the activity to

determine whether the environmental
effects of the operation were within the scope of the

program EIR
. Pursuant to CEQA Guideline
Section 15164, t
he lead agency or responsible agency shall prepare an addendum to a previously certified EIR

if some changes or additions are necessary but none of the conditions described in Section 15162

call
ing for preparation of a subsequent EIR have occurred.

As described in Section 1.3.1 of this Addendum, under the CEQA Guidelines an
addendum shall be
prepared and
no

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identified in the prior EIR. If both requirements are met, the lead agency may approve the activity as being within the scope of the
p
roject

covered by the prior EIR, and no additional environmental documentation is required
, provided that t
he lead agency incorporate
s

all applicable mitigation
measures and alternatives developed in the prior EIR into subsequent actions.

As described in Section 4, Environmental Checklist, t
he
proposed
Project

fits within the scope of the
program analyzed in the
prior
DNSP
EIR

and
,

therefore
,

does not require additional environmental
review

in an
EIR

or
ND
. As discussed below, the
proposed
Project

would not have any new effects
that were
not
already
examined in the
prior EIR
, nor
would
the
proposed
Project

require any new
mitigation measures; all applicable mitigation measures required by
DNSP

EIR

have been
incorporated.

3.2 -

CEQA
Guidelines Section 15162

As mandated in Section 15168, “if the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the
activity as being within the scope of the project
covered by the
program
EIR and no new environmental review document would be required.” Public

Resources Code Section 21166 and CEQA Guidelines Section 15162(a) direct that once an EIR has been certified, no subsequent EIR shall be prepared unless the lead agency determines, based on substantial evidence, one or more of the following:

(1)

Substantial changes are proposed in the
p
roject

which will require major revisions of the
previous EIR 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 p
roject

is
undertaken which will require major revisions of the previous EIR 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 certified as complete, shows any of the following:

The project will have one or more significant effects not discussed in the previous EIR;

Significant effects previously examined will be substantially more severe than shown in the previous EIR;

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As described in Section
4 , Environmental Checklist, none of the situations requiring the preparation of subsequent or supplemental environmental documentation are present for the proposed Project
. In
accordance with CEQA, Section
4 of this document analyzes the proposed
Project

with respect to the
DNSP

EIR

and

demonstrates that all of the potential environmental impacts associated with the proposed
Project

would be within the envelope of impacts already evaluated in the DNSP

EIR
.

The
proposed
Project

does n
ot have any substantial changes that would result in significant environmental effects or result in a substantial increase in the severity of a previously identified impact. As demonstrated by the analysis herein, the proposed Project

would not result in any new
additional significant impacts, nor would it substantially increase the severity of previously anticipated significant impacts. Rather, all of the impacts associated with the proposed Project

are within the
scope of impacts addressed in the
DNSP

EIR

and do not constitute a new or substantially increased
significant impact. Based on this determination, the proposed Project

does not meet the requirements
for preparation of a
subsequent
or
supplemental
EIR pursuant to CEQA Guidelines Section 15162
,
and therefore no additional EIR shall be required for the

proposed

Project
.

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4 -

ENVIRONMENTAL CHECKLIST

As required by Section 15168(c) of the CEQA Guidelines, t his
Section

analyzes whether
the
proposed Project
, as
described in
Section

2 , is within the scope of the project covered by the
program

DNSP EIR

to determine whether an

additional environmental document must be prepared for the proposed
Project. Because
(a)

this

Initial Study/
Addendum
shows that the proposed Project will not
have any new significant environmental effects that were not identified and addressed in the DNSP EIR

or result in a substantial increase in the severity of any previously identified effects, and (b) the City is not aware of any new information of substantial importance within the meaning of CEQA Guidelines Section 15162(a)(3),
the City has determined that no
additional environmental review is
necessary and no
new environmental document is required. This

Section

analyzes the above
-
described
proposed
Project in relationship to the environmental topics considered

in the DNSP, which
are set forth below.

The discussion following each environmental category provides information regarding

policies that
are included in the DNSP that mitigate the potential impacts identified in the DNSP EIR

that would
apply to the proposed Project. These discussions may also list additional, related General

Plan and
DNSP policies and refer to other relevant evidence to demonstrate consistency of the

proposed
Project with the DNSP and determine whether the

proposed
Project would result in any new

significant environmental effect
s or increase the severity of previously identified environmental

effects
resulting from implementation of the DNSP.

This
Section

also
contains the list of Mitigation Measures
from the DNSP EIR which apply to the
proposed
Project as required by the DNSP EIR.

This
Section

analyze
s

the environmental topics listed below:

•

Aesthetics

•

Agriculture and Forestry Resources

•

Air Quality

•

Biological Resources

•

Cultural
and Tribal Cultural
Resources

•

Energy

•

Geology and Soils

•

Greenhouse Gas Emissions

•

Hazards and Hazardous Materials

•

Hydrology and Water Quality

•

Land Use and Planning

•

Mineral Resources

•

Noise

•

Population and Housing

•

Public Services

•

Recreation

•

Transportation

•

Utilities and Service Systems

•

Wildfire

•

Mandatory Findings

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Environmental Issues

DNSP EIR
Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New or
More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .1

Aesthetics

Except as provided in Public Resources Code Section 21099, would the project:

Have a
substantial
adverse effect on a
scenic vista?

Less than
significant
impact

None

Substantially damage
scenic resources,
including, but not
limited to, trees, rock
outcroppings, and
historic building
within a State Scenic
Highway?

Less than
significant
impact

None

In non
-
urbanized
areas,

s
ubstantially
degrade the existing
visual character or
quality of
public
views of

the site and
its surroundings?

(Public views are
those that are
experienced from
publicly accessible
vantage point). If the
project is in an
urbanized area,
would the project
conflict with
applicable zoning
and other regulations
governing scenic
quality?

Less than
significant
impact

None

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Environmental Issues

DNSP EIR
Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New or
More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

Create a new source
of substantial light or
glare which would
adversely affect day
or nighttime views in
the area?

Less than
significant
impact

None

D
isc
ussion

Scenic Vista

Would the project:

Have a substantial adverse effect on a scenic vista?

Summary of DNSP EIR Findings

The DNSP EIR did not
identify any significant impacts to scenic views or vistas as a result of DNSP implementation.

The DNSP EIR noted that the City of Napa does not have any officially designated scenic views or vistas but that views of the hills from the Oxbow area and views along the Napa Creek

C
orridor are view corridors that could potentially be affected by DNSP implementation ,

as well
as short
-

and medium
-
range views from inside the DNSP ar
ea.

T
he Building Form Standards
prescribe

a maximum building height of
75 feet in the Downtown I
Zone, a maximum building height of
60 feet in the Downtown II
Zone
,

and a maximum height of 35
feet in the Transitional zone
, with certain special design features that may extend beyond the height limit
.

T
he Design Guidelines contained in the DNSP require that new development not overwhelm the existing pedestrian experience of the street and that massing elements be incorporated into the future project
s to appropriately transition between the structures of different heights.

Further, the DNSP
contains policies designed to preserve and enhance existing views along the Napa Creek
Corridor
.

The 2020 General Plan, which
was the active General Plan at the time the DNSP EIR was published, contains two goals related to scenic resources with associated policie s
:

(1)
Goal LU
-
6 –
To improve the
vitality and character of
Downtown

through planning, design, business
-
community partnerships, and
City programs and
project
s that encourage a variety of social, entertainment, cultural, retail, administrative, and government uses; and
(2)
Goal HR
-
4 –
To achieve a vital
Downtown

that reflects its
historic urban for
m and setting, offering a mix of old and new buildings.

(Since the adoption of the
DNSP, the City adopted its 2040 General Plan Update, which contains the following updated goals related to scenic resources
:

Goal LUCD
-
2 , Goal LUCD
-
5,
Goal LUCD
-
10 , Goal LUCD
-
11 , etc.)
.

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The
DNSP EIR determined that buildout of the
DNSP would be consistent with the goals and policies
in the
2020
General Plan
related to scenic resources
, which mainly focus on the scenic value of the
built environment

rather than natural scenic views.

The DNSP EIR concluded that
compliance with
the provisions of the DNSP would ensure that impacts to view corridors and short -

and medium
-
range
views from inside the DNSP area are reduced to a less than significant level.

The
2040
General Plan EIR evaluated the 2040 General Plan Update policies promoting, supporting ,

and facilitating further development in
D
owntown Napa in furtherance of the DNSP and recognized
the DNSP
as

the guiding framework for
development in
D
owntown.

The 2040 General Plan Update
did not
alter the analysis of scenic resources evaluated in the DNSP EIR.

Proposed Project Analysis and Conclusions

The
Project

site is located in an urban area with
existing
development that obstructs views of
surrounding areas.

Scenic resources

in the area around the
Project

site include Napa Creek and the
Oxbow area,

hillsides to the
northeast of the
Project

site,

as well as the many historic buildings
scattered throughout
Downtown
, such as the Gordon Building on the corner of
First

Street and
Coombs Street. Existing development to the east of the
Project

site currently blocks views of the
Oxbow area

and the hillsides
.

The proposed Project w
ould

be developed pursuant to a PD
Overla
y
establishing use provisions and
development standards for the
p
roperty
including the adoption of site
-
specific
Design Guidelines
. The
PD
Overlay
establishes a 75
-
foot height limit for the entire Project site and allows rooftop patios with conditioned space to exceed the height limit in addition to the special design features permitted in the DNSP. Such patio and related improvements
would include

site setback
s for

screen
ing

or other

design

features

to minimize visibility from First and Main Streets adjacent to the site, except in areas
required for
fire access.

The
Project

site contains a
vacant
department store
(formerly Kohl’s)
and several trees that currently
block views of Napa Creek from Coombs Street. The proposed Project

would
not affect

views of the
historic Gordon Building from
First
Street or Coombs Street

since views toward this building from
surrounding streets and sidewalks would be maintained similar to the current condition .

The proposed
Project

would also
incorporate
a step
-
back design that would
blend with the
2 -
story

proportions of the
Gordon Building, while upper floors would be set
back

and would include
balconies and
roof gardens
.

The
step
-
back design would preserve the visual character of the

Gordon Building by
extending the
historic
design along the first two floors of the proposed
Project
.

The
proposed
Project

would also
comply with Items 9 and 10 of the
Secretary of Interior Standards for Treatment of Historic Properties ,
which set requirements for new development
adjacent to or related to existing historic resources.

The
proposed
Project

Design Guidelines incorporate

the City of Napa Downtown
Historic Design
Guidelines
, which would reduce any potential impacts on the Gordon Building by preserving the building and
ensuring that
the design of new buildings
is comptaible with
the Gordon Building.

Additionally, the proposed
Project

would adhere to the requireme
nts

of the
DNSP

Design Guidelines,
which would be implemented
through the City’s Design Review process.

Overall, the Design
Guidelines require new development to respond to the surrounding context.

Therefore, the
proposed
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P
roject would not result in any

new or more severe impacts with respect to
scenic vistas

that were not
previously analyzed and disclosed in

the D
N
SP EIR

and no further environmental analysis is
required
.

As such, development of the proposed
Project

also
would have a less than significant effect
on existing views of scenic resources in the area.

State Scenic Highways

Would the project:

Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State
Scenic High
way?

Summary of DNSP EIR Findings

The
DNSP

EIR states that t
here are currently no officially designated
S
tate scenic highways
with
in
the
DNSP

P
lanning
A
rea
. Additionally, the DNSP EIR determined that there are no rock outcroppings in the DNSP
P
lanning
A
rea
, and the majority of the visual resources in the area include historic buildings, contemporary structures, and natural features along the Napa River and Napa Creek.

Design Guidelines developed as part of the

DNSP

guide future building design within the
Planning
Ar
ea, requir
ing

that new buildings be sensitive to the historic scale and architecture of Downtown and encourage historic preservation.

Furthermore, while some mature street trees may be
removed as
part of the implementation of the DNSP
, the DNSP encourages the addition of trees and landscaping along sidewalks, as well as in plazas and other public spaces. Therefore, the DNSP EIR concluded that
impacts to scenic resources would be less than significant.

Proposed Project Analysis and Conclusions

The nearest officially designated
State Scenic High
way
is

SR
-
12 ,

located
more than
11 miles to the
north
west of the
Project

site
.
9 The
City’s General Plan
designates
part of
Silverado Trail
(
SR
-
121
)
,

from Imola Avenue to Lincoln Avenue
,

as a scenic corridor
, which is just east of the
DNSP

Planning
Area
.
10 H
owever, the
Project

site is not visible
from
SR
-
121
due to
intervening
development and
vegetation.

The proposed
Project

also would not remove or

damage any existing scenic resources in
the area
, such as Napa Creek and the historic Gordon Building
.

The
DNSP

contains policies and
actions that require new buildings
to be sensitive to the scale and
architecture of
existing historic buildings.

As stated above, the proposed
Project

would also comply
with
Items 9 and 10 of the
Secretary of Interior Standards for Treatment of Historic Properties

and

would
include design elements that would extend the visual character of the Gordon Building
along
the new development’s st
reet frontage.

The proposed
Project

would
preserve
views of
the historic
Gordon Building

from surrounding roads

and would be required to make
design
refinements
if
needed
to ensure that
its
architecture

would be compatible with
the Gordon Building.

Therefore, the
proposed
P
roject would not result in any

new or more severe impacts with respect to
State scenic highways

9 California Department of Transportation (Caltrans)
. 2024.

California State Scenic Highway System Map
. Website:

https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa . Accessed
March 14, 2025
.

10 City of Napa. 2022.

City of Napa 2040 General Plan.

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that were not previously analyzed and disclosed in

the D
N
SP EIR

and no further environmental
analysis is required
.

As such, the proposed
Project
’s effects on scenic resources related to scenic
highways
also
would be less than significant.

Visual Character

Would the project:

In non
-
urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project

is in an urbanized area,
would the project conflict with applicable zoning and other regulations governing scenic quality?

Summary of DNSP EIR Findings

The DNSP EIR recognized that development under the DNSP would result in changes to the visual character of the DNSP area and evaluated those changes in the context of community objectives as outlined in the General Plan and the DNSP.

The DNSP acknowledges the need to address the
community’s desire for a more active and vibrant
Downtown
, and it proposes to provide opportunities
to introduce a variety of in
fill

projects, new community public spaces, and new residential uses while modulating the design of the new development to be sensitive to the existing small -
town character.

The DNSP includes various mechanisms to guide implementation of this overall vision, including Development Standards for Building Form Districts, Design Guidelines to Address the Built Form, Design Guidelines for the Town Center Focus Area, Design Guidelin es to Address Historic
Resources, and Design Guidelines to Address the Pu
blic Realm.

These mechanisms respond to the General Plan goal of improving the vitality and character of Downtown

through planning and design.

The DNSP EIR determined that proposed building heights
would channel more intense development to the
Downtown

core, creating a focal point with a strong
civic presence within that area

while transitioning to lower heights consistent with the existing character and lower development intensities of surrounding areas.

Further, the DNSP EIR found that
DNSP Design Guidelines would require varied massing for visual interest; setbacks to ensure consistency with existing historic structures; and street trees and pedestrian amenities to enliven the public realm and create a c
ontinual visual theme along streets
Downtown
.

The DNSP EIR concluded
that, while
DNSP
implementation would lead to changes
from the existing visual character, such
changes would not result in adverse visual impacts and could even p otentially result in a beneficial
impact.

Overall, the DNSP EIR found that impacts to visual character would be less than significant.

Proposed Project Analysis and Conclusions

The proposed
Project

includes a

Zoning

Amendment

to
designate the entire
Project

site

a P
D

Overlay
, which adopts the
Downtown
Standards
I, to
create consistent height and density standards

on the Project site
.

The
DNSP

also contains three different focus areas
—
the
Town Center,
CineDome
,

and Copia

(
see
Exhibit 3)
—
each of
which have specific goals beyond what is outlined in
the rest of the DNSP
.

The
Project

site is entirely within the Town Center
Focus Are
a
, which includes
specific goals related to

visual character
includ
ing

restoring Brown Street as a
pedestrian
/
bicycle

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corridor,
encouraging
outdoor plazas and gathering spaces,
promoting mixed
-
use developments with
ground floor retail,
r
edesign
ing
the
Dwight
Murray Plaza

with an open and inviting “town square”
quality
,

and respecting the scale and patterns of
historical buildings
by
transitioning taller building
heights on the west and north ends to lower heights on the east and south ends .

The proposed
Project

would
generally
conform to the building standards of the Downtown I
B
uilding
F
orm
Z
one

as contained in the PD
Overlay
and Project
-
specific Design Guidelines
.

Development of
the proposed
Project

would also include enhancements to the Brown Street Corridor, the addition of a central public plaza with access to ground floor retail, as well as setbacks for taller floors to
preserve
the visual character of the historic Gordon Building

(Appendix A)
.

The ground floors of
Project

development adjacent to the Gordon Building
would include visual elements
to ensure compatibility
.

As such
,

the proposed
Project

would be consistent with the
goals outlined fo
r

the Town Center
Focus
Are
a and the Downtown I
B
uild
ing
F
orm
Z
one.

The PD
Overlay
establishes
the

First Street Napa Phase II Redevelopment Design Guidelines , which

supersede the
DNSP Design Guidelines,

Chapter 5. The
Project
-
specific guidelines

are intended to
guide and define the character of the
proposed
Project within
the
PD Overlay

and to implement the
vision and goals of the
DNSP

and the PD

Overlay
.

The
Project
-
specific guidelines establish the
following
goals related to scenic quality:

•

Buildings and open spaces throughout the First Street Development will

be designed to the
highest quality and developed with unique structures that complement their surroundings, orienting buildings and entrances to streets and public gathering places.

•

Promoting mixed
-
use development throughout the area, with retail emphasis on ground floors to activate building edges and housing and/or office above. This site represents the best opportunity for density and height in Downtown.

•

T
he Brown Street Corridor
will

be renovated with an improved hardscape and landscape
design, seating areas, and vendor areas. This aligns the Downtown Napa Specific Plan goal of “enhancing and maintaining the North and South Brown Street Plazas as part of the overall pedestrian and bic
ycle circulation system” and creating an area “to serve as a plaza/community gathering space in conjunction with Dwight Murray Plaza .
”

•

T
he Interior Pedestrian Corridor
will

bisect the interior part of the
Project

site and provide
multiple access points to buildings, a direct pedestrian walkway from the First Street Napa Mall, and more general pedestrian connection route through D
owntown. This corridor
will

feature hardscape and landscape design, seating areas, and vendor areas integrated into the Brown Street Corridor.

•

T
he
Project
will

incorporate public art at key locations as identified in the City of Napa Public Art Master Plan. The site plan recognizes that public art is an important component in creating a unique
D
owntown experience and may function as gateway identifiers.

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•

T
he
proposed
Project

will

restore the historic urban grain, aligning the street frontage with the existing historic resources while bringing back the implied building mass from the former

Migliavacca
B
uilding

and
extending the

urban grid through the new pedestrian paseo.

•

The buildings
will

reinforce the historic pattern with heights, setbacks and upper -
level step

backs oriented to the many existing
2 -

and
3 -
story buildings. Proposed buildings near historic
commercials buildings abut walls and aim to create a
solid block face.

•

Selected styles and materials
will

complement the character of the existing historic buildings .

•

Along First Street, consistent setbacks with adjacen
t existing
Gordon Building, continuation of
historic zero lot line and building face along First Street. Other property boundaries hold no requirements, consistent with the zero lot line within the Downtown S
pecific
P
lan.

•

The
Project

site design prioritizes orienting buildings so that primary façades and key pedestrian entries face major streets or plazas
.

•

T
he buildings
will

incorporate corners

accentuated with height, articulation
,

and unique roof
silhouettes to emphasize their presence. The
Project

will

aim to locate ground

floor commercial
uses on street corners at key intersections
.

•

T
he buildings’ first floor
heigh
ts

will

be a minimum of 14 feet, which is in alignment with the Downtown Napa Specific Plan’s Ground Floor Height Guideline Area; this height requirement will

distinguish that area as the retail core of Downtown
.

•

Buildings
will

incorporate upper
-
story step

backs in order to retai
n a

pedestrian
-
scale setting;
these setbacks
will

include balconies or roof gardens
.

•

T
he
Project

site design prioritizes orienting buildings so that primary façades and key pedestrian entries face major streets or plazas
.

•

The buildings
will

incorporate corners

with accentuated with height, articulation and unique roof silhouettes to emphasize their presence. The
Project

will

aim to locate ground

floor commercial
uses on street corners at key intersections.

•

The buildings’ first floor
heigh
ts

will

be a minimum of 14 feet, which is in alignment with the Downtown Napa Specific Plan’s Ground Floor Height Guideline Area; this height requirement will

distinguish that area as the retail core of Downtown
.

•

Buildings
will

incorporate upper
-
story step

backs at the roof top in order to retain
a

pedestrian
-
sca
le

setting; these setbacks
will

include balconies or roof gardens. Additionally
,

the upper
penthouse level of hotel
rooms

and residences step back from the primary
façade

for additional
massing articulation.

•

Building design considers the potential shading impacts on surroundings. Building height, mass, setbacks, and arrangement respond to potential shading issues, minimizing shading impacts where they
will

be undesirable or maximizing shading where it is desired.

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•

Along
F
irst
S
treet
, consistent with adjacent existing Gordon Building, the front setback shall maintain the historic zero lot line and building face along First Street. Other property boundaries hold no requirements, consistent with the zero lot line within the Downtown S
pecific
P
lan.

•

The buildings
will

create a human
-
scale environment and avoid large uninterrupted expanses of wall surfaces

by enlivening
façade
s with projecting elements such as entrance porches,
porticoes, canopies, awnings and trellises; recessed entries to develop small alcoves; complete commercial storefronts with details including doors, display windows, bulkheads, signage areas and awnings;

expressive elements such as cornices, lintels, sills, balconies; and well
-
designed upper
-
level features such as balconies and bay windows. While it will

be
important to create dynamic
façade
s, designs
will

prioritize features and details that have
purpose rather than being applied or strictly decorativ e
.

•

The site design
—
with mid
-
block
pedestrian passages
—
will

create a context with most building
façade
s being visible to the public realm. Building designs
will

accommodate this layout by
develop rear and side
façade
s that
will

still be pleasant and inviting and have the same level of trim and finish as the front
façade
.

•

Building design
will

maximize transparent windows on all sides of building and create unobstructed views into interior spaces. Ground floor commercial areas will

feature display
windows to enliven the street and provide pedestrian views into the interior of the storefront; to the extent possible, these areas
will

have floor
-
to
-
ceiling windows. Window design
will

prioritize
clear or lightly tinted glass on ground floor building façades that preserves transparency and avoid opaque, reflective or dark tinted glass.

•

Selected building materials
will

be of high

quality, provide visual interest, and suggest durability and permanence to last into the future. Building trim and metalwork will

be related to the
building architecture.

•

Upper level balconies
will

incorporate transparent or semi
-
transparent railings to enhance
natural lighting and maximize eyes on the street.

•

Façade
s
—
particularly on south or southeast facing fronts
—
will

feature protruding vertical or
horizontal shading devices

such as awnings, lintels, sills, overhangs, and arcades to provide sun and weather protection and create spaces where pedestrians can comfortably walk, shop, eat, and sit. These design features
will

be decorative and complementary to the overall façade
design and
will

also help to highlight entrances and assist in wayfinding. Awnings will

be in
scale with the building, be regularly maintained an
d cleaned, and may incorporate signage on
the street
-
facing side of the valance with a subtle design reflecting the business name or service. Design of awnings
will

avoid features which inhibit pedestrian movement or views;

cover

transom windows or architectural elements such as belt courses, decorative trim ,

or
other notable architectural façade elements; cover building piers; or include signage on the sloping portion of the awning.

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Based on the detailed Project
-
specific Design Guidelines incorporated into the
proposed
P
roject

to
implement the DNSP Town Center Focus Area within an urbanized area, the proposed
P
roject
would
not conflict with applicable zoning
and other regulations governing scenic quality
.

Thus
, the
proposed

Project would not result in any

new or more severe impacts with respect to
visual character

that were
not previously analyzed and disclosed in

the D
N
SP EIR

and no further environmental analysis is
required
.

Therefore
,

the proposed
Project
’s effects on visual character
also
would be less than
significant.

d
)

Light or Glare

Would the project:

Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

Summary of DNSP EIR Findings

The
DNSP

EIR
concluded that the buildout of the
DNSP

would result in new sources of nighttime
lighting and/or daytime glare
. The
DNSP

EIR analyzed
the following

DNSP

guidelines that would
address potential light and glare impacts: specify exterior lighting where the cone of light and/or glare from the lighting element is kept entirely on the property or below the top of any fence, edge or wall; verify that fixtures do

not cast light directly into adjacent residential windows; recommend

translucent
or optical lens diffuser globe
s

or shield
s
;
and
balance the need to provide illumination and security
with the desire to maintain the ambience of Downtown and minimize light pollution.

According to the
DNSP

EIR these
guidelines would reduce the effects of light and glare from the DNSP

buildout to less
than significant levels.

Proposed Project Analysis and Conclusions

The proposed
Project

would
incorporate
ambient,

strategically placed
,

building
-
mounted lighting and
illuminated signage to
reduce the effects of light pollution

while

accenting the buildings’
architectural

characteristics.

Additional opportunities for light posts along the Brown Street C
orridor
would

also
be
identified and located to be compl
e
mentary to the architectural lighting along the public realm .

F
ixtures would not cast light directly into residential window s

and
would
utilize diffuser globes/shields
when required.

Pro
posed

buildings

would

also
include light

shelves on south
-
facing windows and
entries to maximize natural lighting

and would
maximize window use

while avoiding opaque,
reflective, or dark
tinted glass
.

Therefore, the
proposed
P
roject

would not result in any

new or more
severe impacts with respect to
light or glare

that were not previously analyzed and disclosed in

the
D
N
SP EIR

and no further environmental analysis is required
.

As such, the proposed
Project
’s
effects
on lighting and glare
also
would be less than significant.

Relevant
DNSP
EIR

Mitigation Measures

None
.

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Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Aesthetics, Light, and Glare
,

t
he proposed Project would not result in new
significant
source of light or glare that adversely
impacts
views
that were not

evaluated in the DNSP
EIR.

The proposed Project would not result in an increase in the severity of a previously

identified
significant

aesthetics

impact
s
.

There is no new information of substantial importance showing that significant
aesthetics

impacts described in the DNSP EIR could be substantially reduced by ad opting
new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
2 Agriculture and Forest
ry

Resources

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment
Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland.

In determining whether impacts to forest
resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the
S
tate’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy

Assessment project; and forest carbon measurement
methodology provided in Forest Protocols adopted by the California Air Resources Board.

Would the project:

Convert Prime
Farmland, Unique
Farmland, or
Farmland of
Statewide
Importance
(Farmland), as
shown on the maps
prepared pursuant to
the Farmland
Mapping and
Monitoring Program
of the California
Resources Agency,
to nonagricultural
use?

N
o

impact

None

Conflict with existing
zoning for agricultural
use, or a
Williamson
Act Contract?

N
o impact

None

Conflict with existing
zoning for, or cause
rezoning of, forest
land (as defined in
N
o impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

Public Resources
Code Section
12220(g)), timberland
(as defined by Public
Resources Code
Section 4526), or
timberland zoned
Timberland
Production (as
defined by
Government Code
Section 51104(g))?

Result in the loss of
forest land or
conversion of forest
land to non
-
forest
use?

N
o impact

None

Involve other
changes in the
existing environment
which, due to their
location or nature,
could result in
conversion of
Farmland, to
nonagricultural use or
conversion of forest
land to non
-
forest
use?

N
o impact

None

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D
isc
ussion

a
-
e
)

Conversion of Important Farmland
, Agricultural Zoning and Williamson Act
Contracts, Forest Zoning, Conversion of Forest
Land, Pressures to Convert
Farmland or Forest Land

Would the project:

Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps
prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use?

Conflict with existing zoning for agricultural use, or a Williamson Act Contract?

Conflict with existing zoning for forest land or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?

Result in the loss of forest land or conversion of forest land to non
-
forest use?

Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forest land to non -
forest
use?

Summary of DNSP EIR Findings

The DNSP EIR found no impacts with respect to agricultural or forest resources.

Agricultural
resources were discussed in DNSP EIR Chapter 6, Impact Overview and Growth Inducement, under Section 6.E, Effects Found
n
ot to be Significant.

The DNSP area, including the Master Plan area, is
developed with urban uses and is classified as urban and built -
up land by the California Department
of Conservation

(DOC)
.

Proposed Project Analysis and Conclusions

According to DOC’s
Important Farmland Finder
, the area in and around the
Project

site is designated
as Urban and Buil
t

Up Land that

is currently developed

with commercial buildings.
11 The proposed
Project

would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.

Additionally, the
Project

site is not under a current Williamson Act Contract, zoned for agriculture, or zoned for forestry uses. As such, no impacts

would occur. Therefore, the proposed
Project

would not

11 California Department of Conservation

(DOC)
. 202
5 . California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/
. Accessed
March 14, 2025
.

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result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

Relevant
DNS
P

EIR

Mitigation Measures

None
.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Agriculture and Forestry Resources
, t
he proposed Project would not result in new
significant
agriculture and forestry resources

impacts that were not

evaluated in the DNSP EIR.

The
proposed
Project would not result in an increase in the severity of a previously

identified significant

agriculture and forestry resources

impact.

There is no new information of substantial importance
showing that significant
agriculture and forestry resources

impacts described in the DNSP EIR could
be substantially reduced by adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
3 Air Quality

Where available, the significance criteria established by the applicable air quality management
district
or air pollution control district may be relied upon to mak e the following
determinations.

Would the project:

Conflict with or
obstruct
implementation of the
applicable air quality
plan?

Significant and
unavoidable
impact

MM 4.B
-
1 MM 4.B
-
4 b)

Result in a
cumulatively
considerable net
increase of any
criteria pollutant for
which the project
region is
nonattainment under
an applicable federal
or State ambient air
quality standard?

Significant and
unavoidable
impact

MM 4.B
-
1 , MM

4.B
-
2 and MM

4.B
-
4 c)

Expose sensitive
receptors to
substantial pollutant
concentrations?

Less than
significant
impact

4.B
-
2 d)

Result in other
emissions (such as
those leading to
odors or) adversely
affecting a substantial
number of people?

Less than
significant
impact

MM 4.B
-
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Discussion

a
)

Air Quality Plan Conflict

Would the project:

Conflict with or obstruct implementation of the applicable air quality plan?

Summary of DNSP EIR Findings

The DNSP EIR identified a significant and unavoidable impact with respect to implementation of the
Specific Plan

and implementation of the Bay Area 2010 Clean Air Plan
, the most recent air quality
plan in effect at the time the document was published
, since the
DNSP

would exceed the

population
projections

in the
Clean Air Plan
.

The DNSP EIR implemented Mitigation Measure (MM)

4.B
-
1 , which
would
ensure consistency with the
Clean Air Plan

T
ransportation Control Measures

to promote clean,
fuel efficient and zero
-
emission vehicles.

However, even with mitigation, growth produced by the
DNSP would produce a
rate of increase in
Vehicle Miles Traveled (VMT) that

would be more than the
rate of increase in population for the
DNSP

and would be considered inconsistent with the population and VMT assumptions of the
Clean Air Plan
. As such, the DNSP EIR identified a significant and
unavoidable impact related to consistency with the
Clean Air Plan
.

Proposed Project Analysis and Conclusions

Construction
and operational

activities for the proposed
Project

would generate criteria pollutant
emissions.

Construction

emissions would be temporary
,

would not impact any long
-
term air quality
improvement plans or policies and would not interfere with the goals and policies of the most recently adopted
2017 C
lean Air Plan

for ozone compliance.

Projects potentially generating l
ong
-
term,
operational emissions would incorporate
MM 4.B
-
1, MM 4.B
-
2, MM 4.B
-
3, MM B
-
4 ,

and MM 4.B
-
5 , as
applicable,

to reduce overall emissions and demonstrate consistency with the C lean Air Plan
. In
particular, MM
B
-
4 requires implementation of
MM

4.B
-
1 to ensure consistency with the C
l
ea
n
Air
Plan

Transportation Control Measures.

As discussed in Section 5.17, Transportation, in accordance with
CEQA Guidelines Section 15064.3, subdivision (b)
, the proposed
Project
would have a less than
significant impact on VMT due to its proximity to a major transit center: the Soscol Gateway Transit
Center
. Additionally, the proposed
Project
would comply with all applicable control measures outlined in the 2017 C
lean Air Plan
. These control measures and their consistency with the proposed Project
are shown below in
Table
4 . I
mpacts relating to conflicts with an applicable air quality plan would therefore be less than significant.

Table
4 : Bay Area 2017 Clean Air Plan Applicable Control Measures

Control Measures

Description

Project Consistency

Transportation Control Measures

Trip Reduction Programs

E
ncourage trip reduction policies
and programs in local plans, e.g.,
general and specific plans.

Consistent:

The proposed
Project

would include restoring the Brown
Street Corridor as a pedestrian and
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Control Measures

Description

Project Consistency

Encourage local governments to
require mitigation of vehicle travel
as part of new development
approval, to develop innovative
ways to encourage rideshare,
transit, cycling, and walking for work
trips.

bicycle pathway, as well as creating
a new public plaza which would
connect the
First

Street Napa Mall
to Main Street through pedestrian
and bicycle pathways. The
proposed
Project
, therefore,
would
be

consistent with this measure.

Bicycle and Pedestrian Access and
Facilities

E
ncourage planning for bicycle and
pedestrian facilities in local plans,
e.g., general and specific plans,
fund bike lanes, routes, paths and
bicycle parking facilities.

Consistent:

The proposed
Project

would include restoring the Brown
Street Corridor as a pedestrian and
bicycle pathway, as well as
improving the Napa Creek Corridor
and creating a new public plaza
which would connect the
First

Street Napa Mall to Main Street
through pedestrian and bicycle
pathways. The proposed
Project
,
therefore,
would be

consistent with
this measure.

Building Control Measures

Green Building

Identify barriers to effective local
implementation of the CALGreen
(Title 24)
statewide building energy
code; develop solutions to improve
implementation/enforcement.

Engage with additional partners to
target reducing emissions from
specific types of buildings.

Consistent:

The
proposed
Project

would be built to comply with
CALGreen Standards. The
proposed
Project
, therefore,
would
be

consistent with this measure.

Urban Heat Island Mitigation

Develop and urge adoption of a
model ordinance for “cool parking”
that promotes the use of cool
surface treatments for new parking
facilities. Develop and promote
adoption of model building code
requirements for new construction
or re
-
roofing/ roofing upgr
ades for
commercial and residential multi
-
family housing.

Consistent:

The proposed
Project

would be constructed to conform to
the
DNSP’s

sustainability
measures, High
-
Performance
Building Ordinance, and the
Citywide Sustainability Plan. The
proposed
Project
, therefore,
would
be

consistent with this measure.

Waste Management Control Measures

Recycling and Waste Reduction

Develop or
identify and promote
model ordinances on community
-
wide zero waste goals and recycling
of construction and demolition
Consistent:

The
proposed
Project

would be required to comply with
the City’s Construction and
Demolition Debris Ordinance
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Control Measures

Description

Project Consistency

materials in commercial and public
construction projects.

(Chapter 15.32), which would
require that 50 percent of waste be
diverted from landfill disposal. The
proposed
Project
, therefore, would
be consistent with this measure.

Water Control Measures

Support Water
Conservation

D
evelop a list of best practices that
reduce water consumption and
increase on
-
site water recycling in
new and existing buildings;
incorporate into local planning
guidance.

Consistent:

The

proposed

Project

would comply with CALGreen and
reduce outdoor water use by
planting drought
-
tolerant
noninvasive landscaping. The
proposed
Project
, therefore, would
be consistent with this measure.

shown above
, the proposed
Project
would result
in
less than significant
impacts

related to
consistency with the C
lean Air Plan
. Therefore, the proposed
Project
would not result in any peculiar
effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Air Quality Standard, Criteria Pollutants

Would the project:

Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard?

Summary of DNSP EIR Findings

The DNSP EIR was found to be consistent with the 2010
Bay Area Air Quality Management District
(
BAAQM
D
)

Transportation Control Measures (
TCMs
)

wi
th implementation of
MM

4.B
-

1. While
implementation of
MM

4.B
-
1 would ensure consistency with BAAQMD
TCMs
, the rate of increase in
VMT would be more than the rate of increase in population and ,

therefore, would be considered
inconsistent with the population and VMT assumptions of the C AP
.

As such, the DNSP was found to
result in a cumulatively considerable criteria air pollutant impact.

Proposed Project Analysis and Conclusions

Construction

The proposed
Project

consists of a mixed
-
use development, including residential, retail, and hotel uses, in accordance with the provisions of the DNSP.

Construction activities, particularly during site
preparation and grading, would temporarily generate

criteria pollutants.

Sources of
criteria pollutants

would include disturbed soil at the construction site and trucks carrying uncovered loads of soils , as
well as exhaust emissions from construction equipment.

The proposed
Project

would

implement MM

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4.B
-
2,
which requires the use of
construction equipment utilizing new diesel equipment to minimize diesel particulate matter (DPM) emissions during construction.

The proposed
Project
would
also
be required to employ BAAQMD Best Management Practices
(BMPs)
to control dust and exhaust
. These BMPs are listed below:

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

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

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

4. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph).

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

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

6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]) .

7. Clear signage shall be provided for construction workers at all access points.

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

9. Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure

compliance with
applicable regulations.

Implementation of the measures recommended by BAAQMD would reduce the air quality impacts associated with grading and new construction to a less

than

significant level

and impacts from
construction would
be less than significant
.

Operation

Following
Project

construction, long
-
term operational emissions would be generated from daily operations. Operational emissions would include area, stationary, and mobile sources. Area sources would include emissions from architectural coatings, consumer products, landscap e equipment
,

and
the combustion of natural gas for water heaters and other heat sources. Mobile sources include exhaust and road dust emissions from the automobiles that would travel to and from the Project

site.

Stationary sources include emissions from s
tationary source equipment,

such

as backup generators,
which would require a permit issued by the BAAQMD.

The proposed
Project

is not anticipated to
use
stationary sources. However, if
implemented, any stationary sources
,

such as emergency diesel
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generators
,

would

require
a permit to operate from the BAAQMD, which
would
limit and control
emissions

to less than significant levels
.

To evaluate potential impacts from area and mobile
source
emissions, the

BAAQMD developed
screening criteria for criteria air pollutants and precursors. These screening criteria provide lead agencies with a conservative indication of whether implementing a proposed project

could result in
potentially significant criteria air pollutants and precursor impacts. If all screening criteria for criteria air pollutants and precursors are met by a proposed project, then the L
ead
A
gency would not need to
perform a detailed assessment of the project’s criteria air pollutant and precursor emissions.

Section 4.1.2 of the BAAQMD’s 2022 CEQA Guidelines includes guidance on

screening

evaluation

for
p
roject

operations, which provides lead agencies with a conservative indication of whether implementing the proposed
Project

would result in the generation of operational criteria air pollutant or precursors that exceed the thresholds of significance. 27 The
BAAQMD provides a Mixed Land Use
Screening Tool for Criteria Pollutants and Precursors when a project is associated with multiple land use types.

Therefore,
the

proposed
Project
’s
potential impacts were

calculated using the BAAQMD
Mixed Use Screening Tool for Criteria Pollutants and Precursors, and the output indicated that the proposed
Project

would meet operational screening

and n
o further analysis is required. The
screening

analysis

is available in Appendix
C
.

Thus
, the proposed
Project

meets the operational
screening criteria established by BAAQMD

and a more detailed assessment is not required.

The proposed
Project

would not result in a considerable net increase of any criteria pollutant for which the
Project

region is
in
nonattainment and impacts would be less than significant.

Summary

Accordingly
, impacts associated with the development of the proposed Project

would be consistent
with the analysis in the DNSP EIR

and the proposed
Project

would not result in any impacts that
would not be mitigated to a less than significant level. Therefore, the proposed Project

would not
result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

c
)

Sensitive Receptors

Would the project:

Expose sensitive receptors to substantial pollutant concentrations?

Summary of DNSP EIR Findings

The
DNSP

EIR identified a less than significant impact related to sensitive receptors.

T
oxic
a
ir
contaminant
(
TAC
)

emissions from construction activities under the
DNSP

would be related to
DPM

emissions from heavy equipment operations during grading, excavation, building construction, and transportation activities. Health effects from carcinogenic air toxics are usually described in terms of individual cancer risk. Existing and new residents wo
uld be occupying the site concurrently with on
-
site construction activities. Short
-
term construction activities could therefore expose sensitive receptors to levels that exceed applicable standards because of the close proximity between on -
site
diesel equi
pment and residences. This impact
was found to

be potentially significant

by the DNSP
EIR
.

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As discussed previously, any

land uses that would be developed under the
DNSP

that would include
stationary sources that may emit TACs would be subject to BAAQMD permitting and Toxics Best Available Control Technology (T
-
BACT) requirements. BAAQMD would assess such sources for potential health risk impacts based on their potential
to emit TACs. If it is determined that the sources
would emit TACs in excess of BAAQMD’s applicable threshold of significance, T -
BACT would be
implemented to reduce emissions. If the implementation of T -
BACT would not reduce the risk below
the threshold, t
hen BAAQMD would deny the required permit. As a result,

the DNSP EIR determined

impacts associated with exposure of sensitive receptors to substantial toxic air emissions from stationary source operations would be less than significant.

On
-
site mobile sources of TAC emissions would primarily be associated with the operation of diesel -
fueled delivery trucks associated with commercial land uses proposed under the DNSP
.

The
California Air Resources Board
(
ARB
)

adopted an idling
-
restriction Airborne Toxic Control Measure
(ATCM) for large commercial diesel
-
powered vehicles, which became effective February 1, 2005. In accordance with this measure, affected vehicles are required to limit idling to no longer than fi ve
minutes under most circumstan
ces. Nonetheless, given that proposed on
-
site commercial land uses
had

not yet been identified and given the potential proximity of nearby sensitive receptors, exposure of nearby on
-
site receptors to mobile

source TACs associated with commercial activities
was

considered a potentially significant impact

by the DNSP EIR
.

The DNSP EIR implemented MM

4.B
-
2 , which
requires
that
future

development incorporate
measures to reduce or avoid exposure of sensitive receptors to TACs. With this mitigation, as well as following BAAQMD Guidelines on sensitive receptors, the DNSP EIR identified

that impacts related to
exposing sensitive receptors to substantial pollutant concentrations would be reduced to less than significant levels.

Proposed Project Analysis and Conclusions

Construction

The proposed
Project
would include the development of a hotel,
multi
-
family residential
,

and retail
uses
, which would result in construction
-
related emissions
.

There are existing residential receptors
within 1,000 feet of the proposed
Project
site;

however
,

i
t is not anticipated
that they would be
exposed

to substantive DPM or TAC concentration
s

during construction.

The proposed
Project
would

be required to

implement
MM

4.B
-
2 , which requires

the following

measures
specifically related to
construction activi
ties
:

MM 4.B
-
2 The City shall ensure that all projects in the Planning Area incorporate the following
measures to reduce or avoid exposure of sensitive receptors to TACs:

For construction activities, measure may include, but are not limited to, the following:

•

Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes (as required by the state airborne toxics control measure [Title 13, Section 2485 of the California Code of Regulations ]). Provide
clear signage that posts this requirement for workers at the entrances to the site.

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•

Use new diesel engines that are designed to minimize DPM emissions (usually through the use of catalyzed particulate filters in the exhaust) or

retrofitting older
engines with catalyzed particulate filters which would reduce up to 85 percent of DPM emissions.

Prior to approval of demolition permits or grading permits, the proposed Project
must demo
nstrate
compliance
with

MM 4.B
-2
by incorporating
applicable
specifications into construction plans and/or
Project design.

Therefore, with implementation of MM 4.B
-
2, construction
-
related impacts would not
expose nearby sensitive receptors to substantial pollutant concentrations

and
impacts from
construction would be less than significant.

Operation

The proposed
Project
would include the development of a hotel, multi
-
family residential
,
and retail
uses and is not expected to generate substantive DPM or TAC emissions during operational activity.

The proposed
Project

is not anticipated to have stationary sources or on
-
site sources of TACs during
operation.

However, as discussed previously, any

projects

that would be developed under the
DNSP

that would include stationary sources that may emit TACs would be subject to BAAQMD permitting and T
-
BACT requirements. BAAQMD would assess such sources for potential health risk impacts based on their potential to emit TACs. If it is determined that the sources would emit TACs in excess of BAAQMD’s applicable threshold of significance, T
-
BACT would be implemented to reduce
emissions. If the implementation of T
-
BACT would not reduce the risk below the threshold, then BAAQMD would deny the required permit
.

Traffic generated by the proposed
Project

would consist of mostly light
-
duty gasoline
-
powered
vehicles, which, unlike diesel
-
fueled heavy
-
duty trucks, are not a significant source of DPM or TAC emissions.

For operational activities
, the

proposed Project
would be required to implement MM 4.B
-2
, which
requires the following specifically related to
operation
:

MM 4.B
-2

The City shall ensure that all projects in the Planning Area incorporate the following measures to reduce or avoid exposure of sensitive receptors to TACs:

For operational activities, in order to comply with the Air Quality and Land Use
Handbook: A Community Health Perspective (
ARB 2005) and achieve an acceptable
interior air quality level for sensitive receptors, appropriate measures, shall be incorporated into residential building design. For projects to be developed under the DNSP that include residential receptors within 1,000 feet of a source of TACs (stationary or CNR railroad), the appropriate measures shall include one of the following methods (as required by the 2010 California Green Building Standards Code, Chapter 5, Sections 5.106.5.2):

1. The project applicant shall retain a qualified air quality consultant to prepare a Health Risk Assessm
ent (HRA) in accordance with the AR and the Office of
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Environmental Health and Hazard Assessment requirements to determine the exposure of project residents to TACs prior to issuance of a demolition, grading, or building permit. The HRA shall be submitted to the Planning Division for review and approval. The
applicant shall implement the approved HRA
recommendations, if any. If the HRA concludes that the air quality risks from nearby sources are at or below acceptable levels, then additional measures are not required.

2. The project applicant shall implement the following features that have been found
to reduce the air quality risk to sensitive receptors and shall be included in the project construction plans. These shall be submitted to the Planning Division and the Building Division for review and approval prior to the issuance of a demolit ion,
grading, or building permit and ongoing.

Do not locate sensitive receptors near distribution center’s entry and exit points.

Do not locate sensitive receptors in the same building as a perchloroleythene dry cleaning facility.

Maintain a 50’ buffer from a typical gas dispensing facility (under 3.6 million gallons of gas per year).

Install, operate and maintain in good working order a central

heating and
ventilation (HV) system or other air take system in the building, or in each individual residential unit, that meets the efficiency standard of the MERV 13.

The HV system shall include the following features: Installation of a high efficiency f
ilter and/or carbon filter to filter particulates and other chemical matter from entering the building. Either HEPA filters or ASHRAE 85

percent

supply filters shall be used.

Retain a qualified HV consultant or HERS
[
Home Energy Rating System
]
rater
during the design phase of the project to locate the HV system based on exposure modeling from
the mobile and/or stationary pollutant sources.

Maintain positive pressure within the building.

Achieve a performance standard of at least one air exchange per hour of fresh outside filtered air.

Achieve a performance standard of at least 4 air exchanges per hour of recirculation
.

Achieve a performance standard of 0.25 air exchanges per hour of

unfiltered
infiltration if the building is not positively pressurized.

Project applicant shall maintain, repair and/or replace HV system or prepare an Operation and Maintenance Manual for the HV system and the filter. The manual shall include the operating instructions and maintenance and replacement schedule. This manual sha
ll be included in the CC&R
s
[Covenants, Conditions, and Restrictions]
for residential projects and
distributed to the building maintenance staff. In addition, the applicant shall prepare a separate Homeowners Manual. The manual shall contain the operating instructions and maintenance and replacement schedule for the HV ATTACHMENT 23

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system and the filters. It shall also include a disclosure to the buyers of the air quality analysis findings.

Because the proposed
Project
would include residential receptors, an analysis

was conducted to
assess the impacts on new residences from existing sources of TACs within 1,000 feet.

Table
6 summarizes the potential health impacts
at the
Project
site
, including stationary sources, existing
roadways and rail
sources.

As shown in Table
5 , the cumulative health impacts to future on
-
site residences from existing TAC
emissions sources are below BAAQMD’s cumulative thresholds for cancer risk, chronic hazards and PM

2.5 concentrations.

The latest California Building Code update in 2022 requires heating, ventilation and air conditioning (HVAC) systems with Minimum Efficiency Reporting Values (MERV -
13) or
better filtration in newly
constructed multi
-
family homes, which serves to effectively mitigate the impacts of TACs and/or PM

2.5 for indoor exposure (and is consistent with
MM 4.B
-
2 ).

Therefore, MERV
-
13 filtration would serve to
further reduce any potential health risks shown in Table 5 below.

Table
5 :

Cumulative Health Risks at the Project Site

Source

Cancer Risk

(per million)

Chronic

2.5 Concentration
(
m
g/m
3 )

Cumulative Health Risks at
Project Site

Air Basin Roadways

(Soscol Avenue)

20.69 0.04

0.23 Air Basin Railways

0 0

0 BAAQMD Permitted Stationary Source:

Generator

(Facility ID
13492
)

7.12 0

0.01 BAAQMD Permitted Stationary Source:

Generator

(Facility ID 13992)

0.01 0

0 BAAQMD Permitted Stationary Source:

Generator

(Facility ID 13993)

7.01 0

0.01 BAAQMD Permitted Stationary Source:

Generator

(Facility ID
18913
)

5.57 0

0.01 BAAQMD Permitted Stationary Source:

Generator

(Facility ID
18950
)

0 0

0 BAAQMD Permitted Stationary Source:

Generator

(Facility ID
19478
)

1.92 0

0 BAAQMD Permitted Stationary Source:

Generator

(Facility ID
19851
)

2.31 0

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Source

Cancer Risk

(per million)

Chronic

2.5 Concentration
(m
g/m
3 )
BAAQMD Permitted Stationary Source:

Generator

(Facility ID
200573
)

2.74 0

0 Cumulative Health Risks at
Project Site

47.37 0.04

0.26 BAAQMD’s Cumulative Thresholds of
Significance

100

0.8 Threshold Exceeded?

Notes:

BAAQMD = Bay Area Air Quality Management District

DPM = diesel particulate matter

HI = hazard index

2.5 = particulate matter, including dust, 2.5 micrometers or less in diameter

mg/m
3 = micrograms per cubic meter

The health risks and concentrations from railway, roadway ,
and stationary sources are based on BAAQMD screening tools.

Therefore, the proposed
Project
would be consistent with the requirements of MM 4.B
-
2, Part 1, and
no additional measures would be required.

Thus, the proposed
Project

would not result in significant
health impacts to nearby sensitive receptors during operation, nor

would it result in
significant health
impacts to new residential receptors upon
Project

build
out
.

The analysis under the DNSP EIR remains accurate with respect to the proposed Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP and would occur within the area previously evaluated in the DNSP EIR.

As such, impacts associated with the
development of the proposed
Project

would be consistent with the analysis in the DNSP EIR
,
and the
proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar effects to expose sensitive receptors
and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Odors

Would the project:

Result in other emissions (such as those leading to odors or) adversely affecting a substantial number of people?

Summary of DNSP EIR Findings

The DNSP EIR

identified a less than significant impact related to odors. According to the DNSP EIR, t
ypical odor sources of concern include wastewater treatment plants, sanitary landfills, transfer stations, composting facilities, petroleum refineries, asphalt batch plants, chemical manufacturing facilities, fiberglass manufacturing facilities, auto body shops, rendering plants, and coffee roasting facilities. The
DNSP

does not include the development of these types of facilities. However, commercial develo
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food service) that could be perceived as offensive to some individuals. Regarding land use compatibility of locating new sensitive receptors, there are no substantial existing sources of odor identified in the vicinity of the
DNSP
.

In certifying the

DNSP EIR
, the City required the

implement
ation
of

4.B
-
3 , which would require DNSP design guidelines and development standards, to include measures to reduce
or avoid exposure of sensitive receptors to odors during development under the

DNSP. As such, the DNSP

EIR identified a less than significant impact.

Proposed Project Analysis and Conclusions

The proposed
Project

includes a mixed
-
use
development that would consist of residential, retail, and hotel uses.

Odor impacts could occur if the proposed
Project

introduces a new odor source near existing
receptors. The BAAQMD provides a list of specific odor
-
generating facilities. According to BAAQMD,
residential
, hotel
,

and retail uses

are not odor
-
generating facilities.

Potential sources that may emit odors during construction activities include exhaust from diesel construction equipment. However, because of the temporary nature of these emissions, the intermittent nature of construction activities, and the highly diffusi ve properties of diesel PM exhaust,
nearby receptors would not be affected by diesel exhaust odors associated with Project

construction.

Odors from these sources would be localized and generally confined to the immediate area surrounding the
Project

site.

The proposed
Project

would utilize typical construction techniques, and
the odors would be typical of most construction sites and temporary in nature.

The proposed
Project

does not include any uses that may produce objectionable odors but would be required to implement

all development standards and design guidelines in the DNSP .

As such,
impacts related to objectionable odors would be less than significant.

Therefore
, impacts associated with the development of the proposed Project

would be consistent with
the analysis in the DNSP EIR and the proposed
Project

would not result in any impacts that would not
be mitigated to a less than significant level. Therefore, the proposed Project

would not result in any
peculiar effects and would not result in a new or more severe adverse emissions
impact

affecting a
substantial number of people

that was not previously identified in the DNSP EIR.

Relevant
DNSP
EIR

Mitigation Measures

MM 4.B
-
1 In order to be consistent with the MSM A
-
1 and MSM A
-
2 T
ransportation
Control
Measures (TCMs), the City shall require that the following measures be included as potential Transportation Demand Management (TDM) strategies to be implemented by individual project applicants, where feasible and appropriate:

•

Install charging units for electric vehicles at residences and businesses.

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•

Develop incentives for businesses to include preferential parking for electric and/or hybrid vehicles. (As required by the 2010 California Green Building Standards Code, Chapter 5, Section 5.106.5.
2).

MM 4.B
-
2 The City shall ensure that the Specific Plan design guidelines and development standards incorporate the following measures to reduce or avoid exposure of sensitive receptors to TACs:

For construction activities, measures may include, but not limited to, the following:

•

Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to 5 minutes (as required by the State Airborne Toxics Control Measure [Title 13, Section 2485 of the California Code of Regulations]). Provide clear signa
ge that posts this requirement for workers at the entrances to the site.

•

Use new diesel engines that are designed to minimize DPM emissions (usually through the use of catalyzed particulate filters in the exhaust) or retrofitting older engines with catalyzed particulate filters which would reduce up to 85 percent of DPM emissio
ns.

For operational activities, in order to comply with the Air Quality and Land Use Handbook: A Community Health Perspective (ARB 2005) and achieve an acceptable interior air quality level for sensitive receptors, appropriate measures, shall be incorporated i
nto residential building design. For projects to be developed under the Specific Plan that include residential receptors within 1,000 feet of a source of TACs (stationary or CNR railroad), the appropriate measures shall include one of the following methods
:

1. The project applicant shall retain a qualified air quality consultant to prepare a Health Risk Assessment (HRA) in accordance with the ARB and the Office of Environmental Health and Hazard Assessment requirements to determine the exposure of project reside
nts to TACs prior to issuance of a demolition, grading, or building permit. The HRA shall be submitted to the Planning Division for review and approval. The applicant shall implement the approved HRA recommendations, if any. If the HRA concludes that th
e air quality risks from
nearby sources are at or below acceptable levels, then additional measures are not required.

2. The project applicant shall implement the following features that have been found to reduce the air quality risk to sensitive receptors and shall be included in the project construction
plans. These shall be submitted to the Planning Division and the Building Division for review and approval prior to the issuance of a demolition, grading, or building permit and ongoing.

Do not locate sensitive receptors near distribution center’s entry and exit points.

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Do not locate sensitive receptors in the same building as a p
erchloroethylene

dry cleaning facility.

Maintain a 50’ buffer from a typical gas dispensing facility (under 3.6 million gallons of gas per year).

Install, operate and maintain in good working order a central heating and ventilation (HV) system or other air take system in the building, or in each individual residential unit that meets the efficiency standard of the MERV 13.

The HV system shall includ
e the following features: Installation of a high
efficiency filter and/or carbon filter to filter particulates and other chemical matter from entering the building. Either HEPA filters or ASHRAE 85

percent

supply filters shall be used.

Retain a qualified HV consultant or HERS rater during the design phase of the project to locate the HV system based on exposure modeling from the mobile and/or stationary pollutant sources.

Maintain positive pressure within the building.

Achieve a performance standard of at least one air exchange per hour of fresh outside filtered air.

Achieve a performance standard of at least
four

air exchanges per hour of
recirculation
.

Achieve a performance standard of 0.25 air exchanges per hour of unfiltered
infiltration if the building is not positively pressurized.

Project applicant shall maintain, repair and/or replace HV system or prepare an Operation and Maintenance Manual for the HV system and the filter. The manual shall include the operating instructions and
maintenance and
replacement schedule. This manual shall be included in the CC&R s
[
Covenants, Conditions, and Restrictions
]
for residential projects and
distributed to the building maintenance staff. In addition, the applicant shall prepare a separate Homeowners Manual. The manual shall contain the operating instructions and maintenance and replacement schedule for the HV syste
m and the filters. It shall also include a disclosure to the buyers of the air quality analysis findings.

4.B
-
4 Implement Mitigation Measure 4.B
-
1 to ensure consistency with the BAAQMD TCMs
to promote clean, fuel efficient
,

and zero
-
emission vehicles.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Air
Quality, t
he proposed Project would not result in new significant air quality
impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in an
increase in the severity of a previously

identified significant

air quality resources

impact.

There is no
new information of substantial importance showing that significant

air quality resources
impacts
described in the DNSP EIR could be substantially reduced by adopting new or

different mitigation
measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
4 Biological Resources

Would the project:

Have a substantial
adverse effect, either
directly or through
habitat modifications,
on any species
identified as a
candidate, sensitive,
or special
-
status
species in local or
regional plans,
policies, or
regulations, or by the
California
Department of Fish
and
Wildlife

or
United
States

Fish and
Wildlife Service?

Less than
significant

impact
with
mitigation

incorporated

MM 4.C
-
1a

4.C
-
1b

MM 4.C
-
1c

Have a substantial
adverse effect on any
riparian habitat or
other sensitive
natural community
identified in local or
regional plans,
policies, and
regulations or by the
California
Department of Fish
and
Wildlife

or
United
States

Fish and
Wildlife Service?

Less than
significant

impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

Have a substantial
adverse effect on
State or
federally
protected wetlands
(including, but not
limited to, marsh,
vernal pool, coastal,
etc.) through direct
removal, filling,
hydrological
interruption, or other
means?

Less than
significant

impact

None

Interfere substantially
with the movement of
any native resident or
migratory fish or
wildlife species or
with established
native resident or
migratory wildlife
corridors, or impede
the use of
wildlife
nursery sites?

Less than
significant

impact
with
mitigation

incorporated

MM 4.C
-
1a

MM 4.C
-
1b

Conflict with any
local policies or
ordinances protecting
biological resources,
such as a tree
preservation policy or
ordinance?

Less
than
significant

impact

None

Conflict with the
provisions of an
adopted Habitat
Conservation Plan,
Natural Community
Less than
significant

impact

No
ne

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

Conservation Plan,
or other approved
local, regional, or
State Habitat
Conservation Pla
n?

Discussion

Special
-
s
tatus Species

Would the project:

H
ave a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special
-
status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife

or
United States

Fish and Wildlife Service?

Summary of DNSP EIR Findings

While
D
owntown is
and
is
surrounded by a developed urban environment and relatively few special -
status species are present, the DNSP EIR evaluated the potential impacts to special -
status species
that could result from full buildout of the DNSP.

The DNSP EIR identified special
-
status plant and
animal species known to occur or to have the potential to occur in the DNSP area, including Mason’s
lilaeopsis, Central Valley Chinook salmon, Central Coast steelhead, Sacramento splittail, California red
-
legged frog, foothill yellow
-
legged frog, northwestern pond turtle, special
-
status birds, and
special
-
status bats.

The DNSP EIR identified several General Plan policies that address potential impacts to special -
status species, including
Policy NR
-

1.7, aimed specifically at protecting significant species and groves or clusters of trees during the development process ;
Policy NR
-

2.1, which requires the City to
maintain information about the location of endangered, threatened, and rare species; Policy NR -

2.3,
which requires the City to refer development proposals in sensitive areas to appropriate State
and
federal agencies
for review and comment; Policy NR
-

2.4, which requires
the City
to ensure
the
environmental review
documents
identify any feasible means of avoiding any net loss of habitat or habitat value for
endangered
, threat
ened, and rare species
and their habitats;

and Policy NR
-

4.7,
which encourages projects to avoid covering creeks whenever possible.

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Additionally,
in certifying
the DNSP EIR
the City required the implementation of

mitigation measures
to further address potential impacts to threatened, endangered, candidate, sensitive, or special -
status
species.

These mitigation measures included
MM

4.C
-
1a, which requires implementation of design
guidelines and development standards to protect fish species; MM

4.C
-
1b, which requires pre
-
construction special
-
status avian surveys; and
MM

4.C
-
1c, which requires coordination with
appropriate federal and
S
tate

agencies on the avoidance of active nests.

The DNSP EIR concluded
that compliance with the above listed General Plan policies and implementation of the recommended mitigation measures would reduce impacts to a less than significant level.

Proposed Project Analysis and Conclusions

The

Project

site is
currently fully developed with an existing department store, restaurants, and associated parking lot.

According to the

DNSP EIR

and
Appendix
D
: Biological Resurces Supporting
Information
, s
everal special
-
status
wi
l
dlife
species are known to occur or have the potential to occur within or adjacent to the
DNSP

a
rea
,

such as: the Mason’s lilaeopsis, Central Valley Chinook salmon, Central Coast steelhead, Sacramento splittail, California red -
legged frog, foothill yellow
-
legged frog,
northwestern pond turtle, special
-
status birds, and special
-
status bats.

Because of the developed
nature of the
Project

site and lack of habitats that could support special
-
status species
, i
t is
unlikely
that any
of the specia
l
-
status species identifies in the
P
lanning
A
rea would

have
the potential to occur
on the
Project

site. However,
notw
ithstanding the unlikely presence of any special species or habitat, the proposed
Project

would be required to comply with all mitigation measures adopted

by the DNSP
EIR

for the purpose of protecting special
-
status species, including MM

4.C
-
1a
, MM

4.C
-
1b
, and MM

4.C
-
1 c
.

As such, the proposed
Project

would be required to
avoid
or compensate for the
removal of riparian
vegetation
,
d
esign creek and river
crossings so as to maintain connectivity and allow for unimpeded flow of water
, conduct pre
-
construction special
-
status avian surveys, and avoid and protect any
special
-
status birds nests
identified in pre
-
construction surveys.

No such removal or crossings are
planned, and development in riparian areas
would be

avoided.

The proposed
Project

would also be required to comply with all Gen
e
ral Plan
policies and actions
related to
mitigating effects on
special
-
status
wildlife
species
, including Policies NR
-

1. 1 trhough
NR
-

1. 8
, NR
-

1.1 2, NR
-

1. 13
,
NR
-

1. C
,
NR
-
1 .E
,
NR
-

2.3,
and
NR
-

2.4 .

As such, impacts associated with the
development of the proposed
Project

would be consistent with the analysis in the DNSP EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

The effects
of the proposed Project on special
-
status wildlife species also would be less than significant.

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Riparian

Habitat and Sensitive Natural Communities

Would the project:

Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife

or
United States

Fish and Wildlife Service?

Summary of DNSP EIR Findings

The
DNSP
EIR evaluated whether full buildout of the development contemplated in the DNSP would h
ave a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife
(CDFW)
or United States Fish and Wildlife Service

(USFWS)
and determined there to be
a less than significant impact in this regard.

The DNSP EIR
identified
that t
he
P
lanning
A
rea contains
both stream and riparian habitat, notably Napa Creek and the
Napa River, which flow through and
adjacent to Downtown and may therefore be affected by implementation of the DN SP.

The DNSP

EIR
dete
rmined that conformance to General Plan policies and actions

related to riparian habitats and
sensitive
communities

would reduce impacts to habitat areas and wildlife movement corridors to a less than significant level
. As such
,

the DNSP EIR
identified a less than significant impact related to
riparian habitat
s

or other sensitive natural communit
es.

Proposed Project Analysis and Conclusions

Although the
Project

site is
fully developed, it

is
located nearby
to the Napa Creek riparian area
.

Conformance to Gen
e
ral Plan
Policies
NR
-

1.1 through

NR
-

1. 5
, NR
-

1. 8, NR
-

1. 13
,
NR
-

4.1 through NR
-

4. 7,
and
PR
-

6.3 ,

which protect riparian
habitats

and

enforce setbacks and
the planting of native vegetation,

would ensure the proposed
Project
’s impact on Napa Creek remains
less than significant.

As such, impacts associated with the
development of the proposed
Project

would be consistent with the analysis in the DNSP EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar effects and would not result in a new or more severe adve
rse
riparian habitiat ot other sensitive natural community
impact that was
not previously identified in the DNSP EIR.

Federally Protected Wetlands

Would the project:

Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP would

impact federally protected wetlands
and determined there to be a less than significant impact in this regard.

The
DNSP EIR identified no federally protected wetlands within the P
lanning
A
rea
;

however
,

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Napa Creek and
the
Napa River both
border or run through the
P
lanning
A
rea, and in
-
stream
wetlands

may occur in these waters.

The DNSP EIR determined that t
he implementation of the
DNSP
EIR

would be required to adhere to General Plan policies
NR
-

1.1 , NR
-

1.4,
NR
-

1.5,
NR
-

1.8,
NR
-

1.13 ,

NR
-

1. A,
NR
-

1.D,

NR
-

4.1 through NR 4.7,

and
PR
-

6.3 ,
which
relate to the protection of wetlands
,
Napa Creek, and
the
Napa River
,

which would reduce impacts to wetlands, streams, or riparian habitat to a less than significant level.

Proposed Project Analysis and Conclusions

The
Project

site does not contain any
federally
protected wetlands
;

however Napa Creek runs
outside of but
adjacent to the
Project

site
.

As such, t
he
proposed
Project

would be required t
o comply with all applicable General Plan policies and actions related to the
prot
ection of
the
Napa River, Napa Creek, and their associated wetlands
, which would
reduce
potential impacts on wetland areas to less than significant levels.

As such, impacts associated
with the development of the proposed
Project

would be consistent with the analysis in the DNSP EIR
and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar effects and would
not result in a new or more severe adverse
wetlands
impact that was not previously identified in the
DNSP EIR.

d
)

Fish or Wildlife Movement

and Nursery Sites

Would the project:

Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of wildlife nursery sites?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP would i
nterfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of wildlife nursery sites

and determined there to be a less than significant impact in this regard.

T
he DNSP EIR
determined that,
w
hile most of the
P
lanning
A
rea is developed and lacks habitat value,
the
Napa
River
,

Napa Creek, and landscaped areas within the vicinity provide a wildlife corridor for fish, waterfowl, other birds, bats, and mammals. Development facilitated under the DNSP
, such as the
pedestrian trail improvements and railroad and road crossings, are not anticipated to substantially modify established migration or dispersal corridors; however ,

because some projects would be
located near, on, and over Napa Creek and

the

Napa River, impacts as a result of these projects may
occur.

As such
, in addition to compliance with
all applicable General Plan policies

relating to riparian
habitat
s and wildlife corridors
, the DNSP EIR
implemented M
M

4. C
-
1a and MM 4.C
-
1b to furt
her
reduce the effects on
wildlife corridors. As such, impacts on fish and wildlife movement

and nursery
sites
were found to be less than significant.

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Proposed Project Analysis and Conclusions

The
Project

site
is
fully developed and is
located in a
n urban environment
, as such the presence of wildlife corridors on the
Project

site is
unlikely. The proposed
Project

would
be required to conduct
pre
-
construction special
-
status avian
surveys

as per MM

4.C
-
1b
, as well as
to
comply with all Gen
e
ral Plan policies and actions
related to
the preservation of wildlife corridors. As such, impacts related to wildlife corridors and nursury sites would be less than significant.

As such, impacts associated with the development of the proposed Project

would be consistent with the analys
is in the DNSP EIR and the proposed
Project

would not
result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar effects and would not result in a new or more severe adverse impact
to fish and wildlife movement and nursery sites
that was not previously
identified in the DNSP EIR.

Conflict with Local Policies or Ordinances

Would the project:

Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

Summary of DNSP EIR Findings

The
DNSP
EIR evaluated whether full buildout of the development contemplated in the DNSP would c
onflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance
,

and determined there to be a less than significant impact in this regard.

The DNSP EIR
determined that t
he
P
lanning
A
rea is covered by the City of Napa Municipal
Code, and the
City’s
General Plan. Development facilitated by the
DNSP

would not fundamentally
conflict with any part of the M
unicipal Code or General Plan. Further, the
P
lanning
A
rea is not within
any habitat conservation or natural community conservation plan and ,

therefore, no conflict with any
habitat conservation or natural community conservation plan w ould

result
. As such, the DNSP EIR
found impacts to be less than significant.

Proposed Project Analysis and Conclusions

The proposed
Project

is within the
P
lan
n
ing
A
rea of the DNSP

and therefore is governed by the same
policies and ordinances as the DNSP. The
proposed
Project

would be required to comply with all
policies
found in the General Plan and
regulating

City’s Municipal Code, a
nd the
Project

site is not within
any habitat conservation or natural
community conservation plan
.

Therefore
, impacts related to conflicts with local policies and
ordinances would be less than significant.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the DNSP EIR and the proposed Project

would not result in any
significant
impacts. Therefore, the proposed
Project

would not result in any
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peculiar effects and would not result in a new or more severe adverse biologocal resource
impact that
was not previously identified in the DNSP EIR.

Habitat Conservation Plan/Natural Community Conservation Plan

Would the project:

Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or
State Habitat Conservation P
lan?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP would c
onflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance
and determined there to be a less than significant impact in this regard.

The DNSP EIR determined that t
he
P
lanning
A
rea is covered by the City of Napa Municipal
Code, and the
City’s
General Plan. Development facilitated by the
DNSP

would not fundamentally
conflict with any part of the Municipal
Code or General Plan. Further, the
P
lanning
A
rea is not within
any
Habitat Conservation

P
lan

and
,

therefore, no conflict with any
Habitat Conservation Pla
n w
ould

result
. As such, the DNSP EIR found impacts to be less than significant.

Proposed Project Analysis and Conclusions

The proposed
Project

is within the
P
lan
n
ing
A
rea of the DNSP and
,

therefore
,

is governed by the same policies and ordinances as the DNSP. The proposed
Project

would be required to comply with all
policies
found in the General Plan and
regulat
ions

City’s Municipal Code
, and the
Project

site is not within
any
Habitat Conservation Pl
an
. As
such, impacts related to conflicts with
adopted habitat conservation plans

would be less than
significant.

As such, impacts associated with the development of the proposed Project

would be
consistent with the analysis in the DNSP EIR and the proposed Project

would not result in any
significant
impacts. Therefore, the proposed
Project

would not result in any peculiar effects and would
not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Relevant
DNSP
EIR

Mitigation Measures

4.C
-
1a

The City shall ensure that the
p
roject
-
specific and
Specific Plan design guidelines
and development standards incorporate the following measures to reduce or avoid impacts to fish species:

•

Avoid, reduce, or compensate for indirect impacts to fish species; for example, removal of riparian vegetation would require compensatory shade plantings.

•

Design creek and river crossings so as to maintain connectivity and allow for unimpeded flow of water, and if at all possible avoid building piers or footings within the channel.

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4.C
-
1b

Pre
-
Construction Special
-
Status Avian Surveys. No more
than two weeks in advance
of any tree or shrub pruning, removal, or ground
-
disturbing activity that will
commence during the breeding season (February 1 through August 31), a qualified wildlife biologist will conduct pre
-
construction surveys of all potenti
al special
-
status
bird nesting habitat in the vicinity of the planned activity. Pre -
construction surveys are
not required for construction activities scheduled to occur during the non breeding

season (August 31 through January 31). Construction activities c ommencing during
the non
breeding

season and continuing into the breeding season do not require surveys (as it is assumed that any breeding birds taking up nests would be acclimated to project
-
related activities already under way). Nests initiated during construction activities would be p
resumed to be unaffected by the activity, and a
buffer zone around such nests would not be necessary. However, a nest initiated during construction cannot be moved or altered.

If pre
-
construction surveys indicate that no
nests of special
-
status birds are present
or that nests are inactive or potential habitat is unoccupied:

no further mitigation is
required.

If active nests of special
-
status birds are found during the surveys:
implement
Mitigation Measure 4.C
-
1c.

MM 4.C
-
1c

Avoidance of active nests. If active nests of special
-
status birds or other birds are
found during surveys, the results of the surveys would be discussed with the California Department of Fish and Game and avoidance procedures will be adopted, if necessary
, on a case
-
by
-
case basis. In the event that a special
-
status bird or
protected nest is found, construction would be stopped until either the bird leaves the area or avoidance measures are adopted. Avoidance measures can include construction buf
fer areas (up to several hundred feet in the case of raptors), relocation of birds, or seasonal avoidance. If buffers are created, a no disturbance zone will be created around active nests during the breeding season or until a qualified biologist determine
s that all young have fledged. The size of the buffer
zones and types of construction activities restricted will take into account factors such as the following:

1. Noise and human disturbance levels at the Plan area and the nesting site at the time of the survey and the noise and disturbance expected during the construction activity
;

2. Distance and amount of vegetation or other screening between the Plan area and the nest; and sensitivity of individual nesting species and behaviors of the nesting birds
.

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Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With
regard to Biological Resources t
he proposed Project would not result in new significant biological resources

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would
not result in an increase in the severity of a previously

identified significant

biological resources

impact.

There is no new information of substantial importance showing that significant biological
resources

impacts described in the DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
5 Cultural and Tribal
Cultural Resources

Would the project:

Cause a substantial
adverse change in
the significance of a
historical resource as
pursuant to

Section
15064.5?

L
ess than
significant

impact
with
mitigation

incorporated

4.D
-
1 b)

Cause a substantial
adverse change in
the significance of an
archaeological
resource pursuant to
Section
15064.5?

Less than
significant
impact with
mitigation
incorporated

4.D
-
2a

4.D
-
2 b

c
)

Disturb any human
remains, including
those
interred
outside of formal
cemeteries?

Less than
significant
impact with
mitigation
incorporated

4.D
-
4 Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code
Section
21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe
, and that is:

d
)

Listed or eligible for
listing in the
California Register of
Historical Resources,
or in a local register
of
historical
resources as defined
in Public Resources
Code Section
5020.1(k), or

Less than
significant
impact with
mitigation
incorporated

None

4.D
-
2a
,
MM

4.D
-
2 b,
MM

4.D
-
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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

e
)

A resource
determined by the
lead agency, in its
discretion and
supported by
substantial evidence,
to be significant
pursuant to criteria
set forth in
subdivision (c)
of
Public Resources
Code Section
5024.1.

In applying
the criteria set forth
i
n

subdivision
(c)
of
Public Resource
Code Section
5024.1, the lead
agency shall
consider the
significance of the
resource to a
California Native
American
Tribe
.

Less than
significant
impact with
mitigation
incorporated

None

4.D
-
2a
,
MM

4.D
-
2 b,
MM

4.D
-
4 Discussion

Historical Resources

Would the project:

Cause a substantial adverse change in the significance of a historical resource as pursuant to
Section
15064.5?

Summary of DNSP EIR Findings

The D
NSP
EIR determined that development facilitated by the DNSP could potentially have a significant impact on historic architectural resources.

The D
NSP
EIR identified and mapped historic
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resources within the DNSP area.

The
Downtown

commercial core is surrounded by several historic
residential neighborhoods that contain historic architectural resources, including the Oxbow area located to the northeast.

Implementation of the DNSP could potentially result in the alteration or demolition of recorded historic resources in
D
owntown.

The DNSP EIR also found that new
development under the DNSP could result in development pressure at or adjacent to historic resources, which could indirectly alter i
ntegrity through demolition or incompatible adjacent new construction.

The City General Plan contains policies to protect historic resources.

Policies HR
-

1.1 through HR
-

1.20 provide the framework that the City uses to protect historic resources.

Individual projects must
demonstrate general consistency with the policies.

In addition, the DNSP contains further
design
guidelines that must be consulted for any project involving a listed property or adjacent to a historic
property

(Appendix A)
.

The DNSP EIR determined that the implementation of City General Plan policies ,

in combination with
guideline compliance
,

would reduce impacts to less than significant levels.

However, because the
guidelines are not regulatory requirements, in order to avoid potential impacts, MM 4.D -
1, which
mandates that any future development under the DNSP meet the intent and goals of the guidelines, was required.

The DNSP EIR determined that impacts to historic resources are considered less than significant with the imp
lementation of applicable General Plan policies and MM 4.D -

1. Proposed Project Analysis and Conclusions

The
City's
Past
F
inder

database was consulted, as required by DNSP MM 4D
-
2a, which also requires
incorporating the recommendation of the Past
F
inder database. The results from the database
indicated that the
P
roject

site is located in a high
ly

sensitive area

for cultural resources
.

The database
indicates that the Project site has been previously surveyed and reco
mmendations from the survey
report
on file be consulted.

In order

to o
btain
this survey report

(S
tate File No. 08856; 1986 Archaeological Reconnaissance of the Napa
Transit Project)
, a

records search at the Northwest Information Center (NWIC) was conducted on March 27,

2025,

that

also
inculded, a
review of
re
corded resources and reports

to
determine the existence of previously documented
historical

resources

within the Project site and 0.5

mile surrounding it
. The results of the record search indicates that 34 historic resources have been

recorded within a
0 .5
-
mile
radius
of the project site
.

The closest

historic resource (P
-
28 -

001295
,
Bridge No.

21C
-
97 ) partially addresses the
Project

site.

Although the bridge
is

recorded

partially
within the Project boundaries, it has been

previously

evaluated for

significan
c
e on

the
National
Register of Historic Places (
NRHP
)

and
California Register of Histo
rical
Resources (
CRHR
)

and

was

determined to
be
ineligible
.

Additionally, the proposed Project would not impact the Napa Creek Corridor, including the bridge.

Th
erefore,

the
bridge
(P
-
28 -
001295, Bridge No. 21C
-
97)

would

not
be
impacted by the proposed Pro
ject.

The analysis under the DNSP EIR remains accurate with respect to the proposed
Project
, which would be developed with mixed uses in accordance with the provisions of the DNSP and would occur within the area previously evaluated in the DNSP EIR.

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The proposed
Project

is located in Downtown Napa and is adjacent to the Gordon Building ,

a known
historic commercial building
, and the
First National Bank

bu
ilding
. The proposed
Project

would be
required to follow
the City of Napa Downtown Historic Design
Guidelines

(outlined below)

and
consistent with
MM 4.D
-
1 , which would reduce any potential impacts on the Gordon Building and the
F
irst National Bank

building
to less than significant levels by preserving the building s

and matching
the design of new buildings to the design standards of the Gordon Building

and the First National
Bank

building

(
Exhibit
7 and
Exhibit
8 )
.

Historic Resources Design Guidelines:

New Construction Adjacent to Historic Resources:

•

Consider how the style, massing, rhythm, setbacks, and materials of new construction may affect the character of adjacent historic resources
.

•

New construction near historic residential properties should be set back from the streetand should preserve the open space and rhythm between residences .

•

New construction near historic commercial buildings can abut adjacent buildings to create a
solid block face unless otherwise specified
.

•

If an addition or new construction is under consideration, reference the information for adjacent historic resources to verify that the proposed change is compatible with both the subject property and the adjacent historic resources.

•

Because these Guidelines are not a regulatory document, the building code and zoning code should be consulted in addition to this document to confirm applicable development regulations for each property.

Secretary of the Interior’s Standards of Historic Properties:

1. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the hist oric materials, features,
size, scale and proportion, and massing to protect the integrity of the property and its environment.

2. New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the
futu
r
e
, the essential form and integrity of the historic property and its environment would be unimpaired.

Additions Adjacent to New Construction:

•

Opportunities for adjacent new development may exist at the rear of the Gordon Building, currently a service alley and non
-
historic department store. The Gordon Building has a strong street presence, and therefore there are no height limitations relative t o historic resources on
adjacent new construction, except as otherwise prescribed by the D N
SP Development
Standards.

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61450001 • 04/2025 | 7_project_diagrams.cdr
Exhibit 7
Project Diagrams

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: RIOS. 10SB. April 2025.

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Exhibit 8
Project Design Features

CITY OF NAPA

FIRST STREET NAPA PHASE II PROJECT

ADDENDUM TO THE DOWNTOWN NAPA SPECIFIC PLAN ENVIRONMENTAL IMPACT REPORT Source: RIOS. 10SB. April 2025.

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•

The Brown Street

Mall
space
should remain
open
space, or through street could be introduced.

This building was

historically

on a p
rominent corner, and new construction should therefore be not abut the Brown Street Mall façade.

•

The First National Bank building
, within the Brown Street Mall,

has a strong street presence
and would not be threatened by new construction
. O
pportunities for new development
may
exist at
non
-
historic building and surface parking lot to the east and north.

Adjacent new construction to the east may be up to three stories in height immediately adjacent to the subject building
, but could step up higher
toward

the northeast corner.

No limitation on height or detail of new construction on the surface parking lot to the north of
the subject building.

The
project
-
specific Design Guidelines incorporate

the applicable Historic Resource Design
Guidelines for the Gordon Building and the First National Bank building. Impacts on historical resources would therefore be less than significant. As such, impacts associated with the development of the proposed Pro
ject would be consistent with the analysis in the DNSP EIR and the proposed Project would not result in any impacts that would not be mitigated to a less than significant level.

Therefore, the proposed Project would not result in any peculiar effects and w ould not result in a new
or more severe adverse impact that was not previously identified in the DNSP EIR.

Archaeological Resources

Would the project:

Cause a substantial adverse change in the significance of an archaeological resource pursuant to
Section
15064.5?

Summary of DNSP EIR Findings

The
DNSP

EIR determined that archaeological resources

have not been previously recorded in the
P
lanning
A
rea.

However, remnants of Native American civilization have been discovered all along Napa Creek and its tributaries, both outside of the
P
lanning
A
rea and within portions of the
P
lanning
A
rea with moderate and high sensitivity for archaeological resources. Additionally, while historic period development within the
P
lanning
A
rea may have covered and/or disturbed prehistoric
archaeological materials, there is potential for obscured or deeply buried archaeological resources.

In
certifyin the

DNSP EIR
the City required implementation of

4.D
-
2a

and MM

4.D
-
2 b, which require
review of the City’s
Past
F
inder

database and adherence to standard procedures in the event human or archaeological remains are discovered during construction activities.

The City found that
a
dherence to these mitigations measures would reduce the DNSP’s impact on archaeological
resource
s to less than significant levels.

Proposed Project Analysis and Conclusions

As noted above, t
he

City's
Past
F
inder

archaeological database

was consulted
,

as required by DNSP
MM 4D
-
2a,
which also requires incorporating the recommendation
s

of the Past
F
inder database.

The
results from the database indicated that the
Project

site i
s located in a
n area of high

archaeological
sensiti
vity
;

however
,

archaeological evaluation determined that
no archaeological
resources are present within the proposed
p
roject

boundaries
.

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The database
also stated that the recommendations of the archaeological evaluation should be consulted
and implemented where applicable to the proposed
Project
.

To obtain the
archaeological
evaluation noted in the PastFinder

report
, along with any
other supporting

information
,

sub
s
e
q
u
ent
records search at the
NWIC

was conducted on
March 27,2025

(Appendix
E
)
,
to determine the

existence of previously documented
archaeological resources. The results of the record search indicates that
, in addition to the

34 histori
c resources noted above, o
ne pre
-
contact

archaeological
resource

has been
recorded within a 0.5

mile of the
Project

site
.

No archaeological resources have
been recorded witin the
P
roject site.

The proposed
P
roject would require earthmoving activities during construction that may uncover or disturb previously
unknown
subsurface
archaeological resource
s.

MM 4.D
-
2a has been partially
satisfied through the preparation of the City’s
Past
F
inder

archaeological database and the NWIC
record search.

Consistent with MM 4.D
-
2a, which calls

for the
site
-
specific
recommendations
of

the
previous archaeological evaluation
report
identified

in the

City's
Past
F
inder

archaeological database

(S
-
008856)

to be impl
e
mented,
a qualified
A
rchaeologist should be present to monitor any
construction activities which would
result in subsurface earth movement.

With the impl
e
m
entation of

4.D
-
2 b as outlined in the DNSP EIR,
and
Implementation Measure (I
M
)

CUL
-
1 , which
details the
full
-
time monitoring requirement
as recommended
by the report,
impacts
to archaeological resources
associated with the development of the proposed
Project

would be
mitigated to a less than significant
level
,

consistent with the analysis
and findings

in the DNSP EIR
.

c
)

Human Remains

Would the project:

Disturb any human remains, including those interred outside of formal cemeteries?

Summary of DNSP EIR Findings

The

DNSP EIR identified a less than siginificant impact related to disturbing human remains.

Although
unlikely to occur, development facilitated by the proposed DNSP

could disturb any human remains,
including those interred outside of formal cemeteries, as such remains could exist anywhere in Downtown.

The DNSP EIR implemented MM

4.D
-
4 , which ensures that
treatment of any human
remains and associated or unassociated funerary objects discovered during soil -
disturbing activities
comply with applicable State laws
.

As such, impacts were found to be less than significant with mitigation.

Proposed Project Analysis and Conclusions

The results of the

the City’s
Past
F
inder

archaeological database, the NWIC records search results determined the
Project

sit
e

and the surrounding area is highly sensitive for archaeological resourc e
s
.

While it is unlikely that the presence of human
remains exists within or near the
Project

site, there is al
ways the possibility that subsurface
construction activities associated with the proposed
Project

could potentially damage or destroy
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previously undiscovered human remains.

With implementation of MM

4.D
-
4 , impacts related to
disturbance of human remains would be less than significant.

Listed or Eligible Tribal Cultural Resources

Would the project:

Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size

and scope of the
landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as

defined in Public Resources Code Section
5020.1(k)?

Summary of DNSP EIR Findings

Since the preparation of the
DNSP

EIR, Assembly Bill (AB) 52 was signed into law on September 25, 2014, and provides that any public or private “project with an effect that may cause a substantial adverse change in the significance of a Tribal Cultural Resource (TCR) is a project that may

have a
significant effect on the environment.” TCRs include “[s]ites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American T
ribe that are eligible
for inclus
ion in the CR or included in a local register of historical

resources.” Under prior law,
TCRs
were typically addressed under the umbrella of “cultural resources,” as discussed above. AB 52 formally added the category of “tribal cultural resources” to CEQA and extends the consultation and confidentiality requirements to all projects, rather tha n just projects subject to Senate Bill (SB) 18.

SB 18 (Government Code § 65352.3) incorporates the protection of California traditional T
ribal
cultural places into land use planning for cities, counties, and agencies by establishing responsibilities for local governments to contact, refer plans to, and consult with California Native American T
ribes as
part of the adoption or amendment of any general or specific plan proposed on or after March 1, 2005. SB 18 requires public notice to be sent to
T
ribes listed on the NAHC SB 18 Tribal Consultation
list with
in the geographical areas affected by the proposed changes. Tribes must respond to a local government notice within 90 days (unless a shorter time frame has been agreed upon by the
T
ribe),
indicating whether they want to consult with the local government. Consultations are for the purpose of preserving or mitigating impacts to places, features, and objects described in Sections 5097.9 and 5097.993 of the Public Resources Code that may

be affected by the proposed adoption or
amendment to a general or specific plan.

A
ccording to the
DNSP

EIR, the City completed the

T
ribal
consultation process in accordance with
SB 18

prior to the adoption of the
DNSP

an
d certification of
the
DNSP

EIR.

Proposed Project Analysis and Conclusions

A review of the City’s
Past
F
inder

archaeological database
, the NWIC records search
results

determined the
Project

sit
e

and the surrounding area

is highly sensitive for archaeological
resourc
e
s,
however

the records search
es

failed to identify
any listed or eligible for list
i
ng TCRs that may be
a
dversely affected by the proposed
Project

Furthermore,
the results from the Native

American
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Heritage Commission (NAHC) Sacred Land File (SFL)
search
results
conducted on March 28, 2025,
were positive
for TCRs
within the Project boundaries. As such, no eligible or potentially eligible TCRs will

be adversely
be affected by the
proposed Project
. In the event that
undiscovered
TCRs, are
encountered during
Project
-
related gorund disturbance
, the proposed
Project

would be required to
implement MM

4.D
-
2 b,

4.D
-
4 , and
I
M CUL
-
1 in order to reduce potential adverse effects to less
than significant levels.

As such, impacts associated with the development of the proposed Project

would be consistent with the analysis in the DNSP EIR and the proposed Project

would not result in
any impacts that would not be mitigated to a less than significant level. Therefore, the proposed Project

would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Lead Agency Determined Tribal Cultural Resources

Would the project:

and scope of the
landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to cri
teria set forth in subdivision
(c)

of
Public Resources Code Section 5024.1?

Summary of DNSP EIR Findings

After the preparation of the
DNSP

EIR, AB 52 amended CEQA to identify an additional category of resources to be considered under CEQA
identified as

“tribal cultural resources” and added Public
Resources Code Section 21074 which further defines TCRs , as described above
. However,
according to the
DNSP

EIR, the City completed the
T
ribal consultation process in accordance with
State law prior to the adoption of the
DNSP

and certification of the
DNSP

EIR.

Proposed Project Analysis and Conclusions

Consultation under AB 52 applies when a lead agency prepares an EIR or ND
. It is not applicable to
the preparation of a checklist or addendum. The analysis under the DNSP EIR remains accurate with respect to the proposed
Project
, which would be developed with mixed uses in accordance with the provisions of the DNSP and would occur within the area previously evaluated in the DNSP EIR.

The City has not identified any significant TCR on the
Project

site.

As previously mentioned above,
the results of the NAHC
SLF search

were positive for TCRs within the
Project boundaries.

A
lthough

the PastFinder
and NWIC record search results
failed to identify
TCRs w
ithin the Project site
,

t
he
proposed
Project

would still be required to im
plement

MM 4.D
-
2b, MM 4.D
-
4 , and IM CUL
-
1 in order
to reduce potential adverse effects to less than significant levels. As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the DNSP EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

Therefore, the proposed
Project

would not result in any peculiar effects and would
not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

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Relevant DNSP EIR Mitigation Measures

MM 4.D
-
1 The City shall require that any future development under the Specific Plan meets the
intent and goals of the City of Napa Downtown Historic Design Guidelines. This includes any project that would alter historic resources or would be constructed adjacent to a historic resource.

MM 4.D
-
2a

When specific projects are proposed under the Specific Plan that involves ground -
disturbing activity into native soils, the City's "Past F
inder" archaeological database
shall be consulted. Recommendations provided by the "Past F
inder" database shall
be implemented based on a parcel’s archaeological sensitivity. In those cases where a site
-
specific cultural resources study is necessary, it shall be performed by qualified cultural resources professional. The study will include an u pdated records searc
h,
pedestrian survey of the project area, development of a historic context, sensitivity assessment for buried prehistoric and historic

period deposits, and preparation of a
technical report that meets federal and State requirements. If significant resources are identified and cannot be avoided, treatment plans will be developed in consultation with the City and Native American representat ives to mitigate potential
impacts to less than significant.

MM 4.D
-
2b

Should any archaeological artifacts be found during construction in the Planning Area, all construction activities within 50 feet shall immediately halt and the City must be notified. A qualified
A
rchaeologist shall inspect the findings within 24 hours of the discovery. If the site is determined to contain significant cultural resources, funding will be provided to identify, record, report, evaluate, and recover the resources as necessary. Construct
ion within the area of the find shall not recomme
nce until
impacts on the historical or unique archaeological resource are mitigated.

Additionally, Public Resources Code
Section

5097.993 stipulates that a project
sponsor must inform project personnel that collection of any Native American artifact is prohibited by law.

MM 4.D
-
4 The treatment of any human remains and associated or unassociated funerary objects discovered during soil
-
disturbing activities shall comply with applicable State laws. Such treatment would include immediate notification of the Napa County Coroner. In the
event of the coroner’s determination that the human remains are Native American, the coroner shall notify of the Native American Heritage Commission, which would appoint a Most Likely Descendant (MLD) (PRC § 5097.98). The archaeological consultant
, the Event Authority, and MLD shall make all
reasonable efforts to develop an agreement for the treatment, with appropriate dignity, of any human remains and associated or unassociated funerary objects (CEQA Guidelines § 15064.5[d]). The agreement would t
ake into consideration the
appropriate excavation, removal, recordation, analysis, custodianship, curation, and final disposition of the human remains and associated or unassociated funerary objects. The PRC allows 48 hours to reach agreement on these matt ers. If the MLD
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and the other parties could not agree on the reburial method, the Event Authority shall follow Section 5097.98(b) of the PRC, which states that “the landowner or his or her authorized representative shall reinter the human remains and items associated with

Native American burials with appropriate dignity on the property in a location not subject to further subsurface disturbance.”

Project
-
s
pecific Implementation Measures

In order to implement MM 4.D
-
1,
MM

4.D
-
2b and
MM

4.D
-
4 the
proposed
P
roject should implement
the following
P
roject
-
specific
IM

(MM 4D
-
3 is discussed in Section 4.7(f), below):

IM CUL
-
1 Archaeological Monitoring

qualified
Archaeological Monitor reporting to the qualified
Project
Archaeologist
shall be present during
all

initial

Project
-
related ground
disturbance
, which includes
but is not limited to,
clearing, grubbing, trenching, and grading

to check for the
inadvertent discovery of archaeological resources or human remains.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in the DNSP EIR.

With regard to Cultural Resources and Tribal Cultural Resources, t he proposed Project would
not result in new significant
cultural

resources impacts that were not evaluated in the DNSP EIR. The proposed Project would not result in an increase in the severity of a previously identified significant cultural

resources impact. There is no new information of substantial importance showing that significant
cultural

resources impacts described in the DNSP EIR could be substantially reduced by adopting new or different mitigation measures or alternatives.

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E
nvironmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
6 Energy

Would the project:

Result in potentially
significant
environmental impact
due to wasteful,
inefficient, or
unnecessary
consumption of
energy resources,
during project
construction or
operation?

Less than
significant

impact

MM 4.B
-
1 b)

Conflict with or
obstruct a State or
local plan for
renewable energy or
energy efficiency?

Less than
significant

impact

MM 4.B
-
1 Discussion

The impacts of energy use were analyzed in the DNSP EIR in the context of criteria air pollutant and greenhouse gas
(GHG)
emissions resulting from the project.

Energy Use

Would the project:

Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?

Summary of DNSP EIR Findings

As disclosed in the DNSP EIR, new development under the DNSP
would result in the commitment of
existing and planned sources of energy, which would be necessary for the operation of the proposed hotel development. However, the
DNSP

incorporates energy
-
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High
-
Performance Building Ordinance
,

which provides for 15 percent higher energy efficiency than Title 24 for new development. The
DNSP

also incorporates sustainable construction policies and features where feasible or as otherwise required by law that would strive to meet the

Leadership in
Energy and Environmental Design

(
LEED
®
)

Program over the long
-
term, resulting in a more energy
-
efficient development and reduced consumption using local materials and labor.

As such, impacts on
energy use resulting from the DNSP were found to be less than significant.

Proposed Project Analysis and Conclusions

Construction

PG
&E

provides electricity
and natural gas
service to the
proposed
Project

site.

The construction of
the proposed
Project

would include grading, excavation, site preparation
,

and construction of the
proposed mixed
-
use development.

The construction phase would require energy for the manufacture and transportation of building materials, pre
paratio
n of the
Project

site (e.g., site clearing and
grading), and the actual construction of the building. Petroleum -
based fuels
,

such as diesel fuel and
gasoline
,

would b
e the primary sources of energy for these tasks.

Th
e types of on
-
site equipment
used during construction
of the
proposed
Project

could include gasoline
-

and diesel
-
powered
construction and transportation equipment, including trucks,

excavators,

forklifts, and
pavers
.

The overall construction schedule and process is already designed to be efficient in order to avoid excess monetary costs. For example, equipment and fuel are not typically used wastefully due to the added expense associated with renting the equipment, mai ntaining it, and fueling it. Therefore, the
opportunities for future efficiency gains during construction are limited.

However, the proposed
Project

does include several measures that would improve the efficiency of the construction process.

Implementation

of the BAAQMD
BMPs
would restrict equipment idling times to

5 minutes or less and
would require the applicant to post signs on the
Project

site reminding workers to shut off idle
equipment.

Thus
, it is anticipated that the construction phase
of the
proposed
Project

would not result
in wasteful, inefficient, and unnecessary consumption of energy. Construction -
related energy impacts
would be less than significant.

Operation

The proposed
Project

would consume energy as part of building operations and transportation activities

The proposed
Project

would incorporate energy
-
efficient

features to comply with the City’s
adopted High
-
Performance Building Ordinance. The proposed green building measures ensure the proposed
Project

would not use energy in an inefficient or wasteful manner. The proposed
Project

would incorporate the following green building measures:

•

Bicycle parking to reduce vehicular load

•

charging

•

Light pollution reduction

•

E
nergy
-
efficient standards per code

•

Cool roof design

•

Reduced indoor/outdoor water use

•

Increased daylighting thru design

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•

Building
and

material design to improve longevity of materials and prevent water intrusion

•

Construction waste and recycling plan

•

Building operations plan for recycling and waste reduction

•

Building operations plan for energy
-
efficient operation and monitoring

•

Building material selection to reduce pollutants and improve indoor air quality

As previously discussed, the proposed
Project

would be considered to result in a potentially
significant impact if it would result in wasteful, inefficient, or unnecessary consumption of energy resources. Considering the guidance provided by Appendix F of the CEQA Guidelines and the Appellate Court de
cision in
League to Save Lake Tahoe Mountain etc. v. County of Placer

(2022) 75
Cal.App.5th

63, 164
–
168, the p
roposed

Project

would be considered to result in wasteful, inefficient, or unnecessary consumption of energy resources if it would conflict with the following energy
conservation goals:

•

Decreasing overall per capita energy consumption;

•

Decreasing reliance on fossil fuels such as coal, natural gas, or oil; and

•

Increasing reliance on renewable energy sources.

Decreasing Overall Per Capita Energy Consumption

T
he proposed
Project
’s

buildings would be designed and constructed in accordance with CALGreen energy efficiency standards of Title 24. Title 24 standards include a broad set of energy conservation requirements that apply to the structural, mechanical, electrical, and plumbing systems in a building.

For example, the Title 24 Lighting Power Density requirements define the maximum wattage of lighting that can be used in a building based on its square footage. Title 24 standards, widely regarded as the most ad
vanced energy efficiency standards, would help
to
reduce the amount of
energy required for lighting, water heating, and heating and air conditioning in buildings and would
promote energy conservation. Moreover, the

propos
ed
Project

would
be constructed according to the
City’s

High
-
Performance Building Ordinance
, which includes numerous

energy
-
efficient
and
green
building features

as
described above.

Theref
ore, th
e proposed
Project

would be consistent with this
criterion.

The decreasing reliance on fossil fu
els and increasing use of renewable energy discussed
below would also reduce per capita energy consumption for the proposed Project
.

Decreasing Reliance on Fossil Fuels

T
he proposed
Project

would
incorporate elements from
the
High
-
Performance Building Ordinanc
e,
and the

California Green Building Standards Code
.

These

Project

design features would reduce the
amount of electricity used
by the
proposed
Project

during operation and, consequently, the amount of
fossil fuels needed to
generate power to meet this demand. For example, low water demand landscaping would reduce the amount of water that would nee d to be

conveyed to the
Project

site.

Increasing Reliance on Renewable Energy Sources

As previously discussed, the proposed
Project

would include the installation of EV charging

which
would accelerate the region's and p
roposed

Project
’s
adoption of EVs and allow the future
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renewable energy sources. As s
uch, th
e proposed
Project

would facilitate a greater dependence on
renewable energy sources for building and transportation energy demands . There
fore, the proposed
Project

would be consistent with this criterion.

Overall

As discussed above, the proposed
Project
’s

energy consumption would not result in the wasteful,
inefficient, or unnecessary consumption of energy resources, consistent with the guidance derived from Appendix F of the CEQA Guidelines and the Appellate Court decision in League to Save Lake
Tahoe Mountain etc. v. County of Placer

(2022) 75 Cal.App.5th

63, 164
–
168. The construction
-
related
and operation
-
related impacts related to electricity, natural gas, and fuel consumption would be less than significant. Therefore, the proposed
Project

would not introduce new significant environmental
impacts or substantially increase the severity of previously analyzed significant effects under any scenario. No additional analysis is required, and impacts would remain less than significant.

Thus,
impacts associated with the development of the proposed Project

would be consistent with the
analysis in the DNSP EIR and the proposed
Project

would not result in any
significant

impacts
due to
the

application of design features and/or BMPs
. Therefore, the proposed
Project

would not result in
any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Energy Efficiency and Renewable Energy Standards Consistency

Would the project:

Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?

Summary of DNSP EIR Findings

The DNSP includes

policies to encourage energy efficiency and green building techniques for project -
level implementation.

Buildout of the DNSP is subject to the regulations in the City’s High
-
Performance Building Ordinance and Title 24
. As such, the DNSP EIR determined a less than
significant impact relating to consistency with a

State or local plan for renewable energy or energy
efficiency
.

Proposed Project Analysis and Conclusions

The proposed
Project
would be required to
comply with all DNSP policies relating to energy efficiency, as well as the City’s High
-
Performance
Building Ordinance and Title 24
.

The proposed
Project

would utilize electricity and natural gas from
PG&E
. According to
PG&E
,
approximately
100

percent of its electricity is currently obtained from
zero
-
emission sources

and
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approximately 33 percent
is
from
renewable energy sources.
12 Therefore, the proposed
Project
’s
electricity provider meets the State’s current objective of 33 percent renewable energy. The proposed Project
’s
electricity provider would also be required to meet the State’s future objective of 60 percent of in
-
State
electricity sales being generated from renewable energy sources by 2030.

The proposed buildings would also be compliant with Title 24 Standards , the City’s
High
-
Performance
Building Ordinance,

and would adhere to the energy efficiency, water efficiency, and material conservation requirements. Therefore, the proposed
Project

would be consistent with all applicable
energy policies and plans, and this impact would be less than significant.

Therefore, the proposed
Project
would be consistent with all applicable energy efficiency plans.

As
such, impacts associated with the development of the proposed Project

would be consistent with the
analysis in the DNSP EIR and the proposed
Project

would not result in any
significant
impacts.

Therefore, the proposed
Project

would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Relevant DNSP EIR Mitigation Measures

Non
e
.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to
Energy, t
he proposed Project would not result in new significant energy

resources
impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in an
increase in the severity of a previously

identified significant

energy

resources

impact.

There is no new
information of substantial importance showing that significant

energy

resources
impacts described in
the DNSP EIR cou
ld be substantially reduced by adopting new or

different mitigation measures or
alternatives.

12 Pacific Gas and Electric

Company (PG&E)
. 2024.

Electric Power Generation Mix.

Website:

https://www.pge.com/assets/pge/docs/account/alternate
-
energy
-
providers/PCE_ElectricPowerGenerationMix.pdf
.

Accessed
April 25, 2025
.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
7 Geology and Soils

Would the project:

Directly or indirectly cause

potential substantial adverse effects, including the risk of loss, injury ,

or
death involving:

Refer to Division
of Mines and
Geology Special
Publication 42?

Less than
significant

impact

None

ii)

Strong seismic
ground shaking?

Less than
significant

impact

None

iii)

Seismic
-
related
ground failure,
including
liquefaction?

Less than
significant

impact

None

iv)

Landslides?

No impact

None

Result in substantial
soil erosion or the
loss of topsoil?

Less than
significant

impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

Be located on a
geologic unit or soil
that is unstable, or
that would become
unstable as a result
of the project, and
potentially result in
on
-

or off
-
site
landslide, lateral
spreading,
subsidence,
liquefaction or
collapse?

Less than
significant

impact

None

Be located on
expansive soil, as
defined in Table 18
-
1 -
B of the Uniform
Building Code
(1994), creating
substantial direct or
indirect risks to life
or property?

Less than
significant

impact

None

Have soils
incapable of
adequately
supporting the use
of septic tanks or
alternative
wastewater disposal
systems where
sewers are not
available for the
disposal of
wastewater?

Less than
significant

impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

Directly or indirectly
destroy a unique
paleontological
resource or site or
unique geologic
feature?

Less than
significant

impact
with
mitigation

incorporated

MM 4.D
-
3 Discussion

Earthquake Hazards

Would the project:

Directly or indirectly cause

potential substantial adverse effects,
including the risk of loss, injury or death involving: (i)

Rupture of a
known earthquake fault, as delineated on the most recent Alquist
-
Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; (ii) Strong Seismic Ground Shaking; (iii) Seismic
-
related ground
failure, including liquefaction; (iv) Landslides
.

Fault Rupture

Summary of DNSP EIR Findings

The

DNSP EIR

evaluated whether full buildout of the development contemplated under

the
DNSP

would expose people or structures to potential substantial adverse effects involving rupture of a known earthquake fault as delineated on the Alquist
-
Priolo Earthquake Fault Zoning Map and
determined there would be a less than significant impact because th e
DNSP

P
lanning
A
rea
is not
located within an Alquist
-
Priolo Fault

Rupture Hazard Zone.
13 The
West Napa Fault Zone
, which is
the nearest active fault,

lies

appro
ximately

1.4 mile
s

west of the
DNSP

P
lanning
A
rea.

Proposed Project Analysis and Conclusions

The analysis under the

DNSP EIR

remains accurate with respect to the proposed
Project
,

which
would
result in the
construct
ion of

a mixed
-
use development in accordance with the
DNSP

and the
areas previously evaluated by the
DNSP

EIR.

13 C
alifornia Department of Conservation

(DOC)
.
2024.

Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
. Accessed October 30, 2024.

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The
Project

site is also not located within an
Alquist
-
Priolo
Earthquake
Fault Zone
,

and
there are no
known faults that cross the
Project

site.
14 The
West Napa Fault zone
, which is the nearest active fault,

lies approximately 1.4 miles to the
we
st of the
Project

site.

Compliance with the California Building

Standards

Code (CBC)
would further
reduce impacts related to fault rupture.

As such, impacts
associated with the development of the proposed
Project

within

the
DNSP

P
lanning
A
rea
would be
consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any
significant impacts
associated with fault rupture.

ii)

Ground Shaking

Summary of DNSP EIR Findings

The

DNSP EIR

evaluated whether full buildout of the development contemplated under

the
DNSP

would

directly or indirectly cause potential substantial adverse impacts involving strong seismic ground shaking and determined these impacts would be less than significant .

The
DNSP

EIR

indicated

that the

West Napa Fault
lies

within the City
, approximately
1 mile outside the
P
lanning
A
rea
of the
DNSP
, while
the
Green Valley
-
Concord

Fault lies within 10 miles of the City
.

Several active
faults with the potential to
g
enerate strong ground shaking in the City

are within 50 miles of the City
.

The
DNSP

EIR determined that compliance with

the CBC and with

policies laid out in the General
Plan
related

to earthquake safety would reduce
the
potential damage and personal injury that would
result from ground shaking
. Therefore, the DNSP EIR concluded that impacts related to seismic ground shaking would be less than significant.

Proposed Project Analysis and Conclusions

As stated above, t
he proposed
Project

is no
t

within any
Alquist
-
Priolo Fault Zone
s
;
however
,

the
abundance of active faults within a 50
-
mile radius of the City would
subject

the
Project

site

to seismic
ground shaking due to its proximity and potential earthquake magnitude of these faults.

Compliance
with building regulations outlined in the CBC
,
DNSP
,
and General Plan would reduce the im
pact of

potential damage and personal injury
caused by seismic ground shaking.

As such, impacts
associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any significant impacts in this regard.

iii)

Ground Failure

Summary of DNSP EIR Findings

The DNSP EIR found that a major earthquake in the region may cause seismic -
related ground failure
that could potentially cause damage, destruction, or injury to development and persons resulting from development facilitated by the DNSP.

The DNSP EIR determined that impacts would be less than significant.

As discussed in (ii), the San Francisco Bay Area is likely to experience at least one major earthquake within the next 30 years.

However, development standards require proper engineering that minimizes

14 California Department of Conservation

(DOC)
. 2024. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/EQZApp/app/. Accessed October 30, 2024.

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seismic hazards through industry standard geotechnical practices and structural design.

The City’s
Building Code addresses ground failure that may damage buildings.

The code requires new
construction to incorporate measures and materials that meet minimum performance standards.

The
City’s General Plan policies further reduce the risk of ground failures.

Policies HS
-

1.1 through 1.6
generally restrict development in high hazard areas or require geotechnical investigations.

Development may be permitted if special construction features are incorporated in project

design.

While damage and injury cannot be completely avoided, the General Plan policies and City Building Code reduce the potential for damage and personal injury.

Therefore, the DNSP EIR determined that
impacts would be less than significant.

Proposed Project Analysis and Conclusions

The proposed
Project

site is not within a known liquefaction zone
identified by the
California
Geological Survey (CGS)
.
15 Areas in close proximity to
the
Napa River were identified in the
DNSP

EIR as being susceptible to liquefaction.

The
Project

site is
approximately
504

feet away from
the
Napa River
;

however
, as stated above,
new construction which follows the building regulations outlined in the CBC would red
uce the potential impacts of liquefaction on development.

As such,
impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would not result in any significant impacts in this
regard.

iv)

Landslides

Summary of DNSP EIR Findings

The
DNSP
EIR
determined that the

buildout of the
DNSP

would result in
no impacts related to
landslides
. According to the
DNSP

EIR,

the
P
lanning
A
rea contains slopes that are less than 15
percent in grade and
are
not considered susceptible to landslides or slope failure. The gentle sloping topography of the area
results in
a very low
potential for landslides or slope failure to affect any new
development in the DNSP
P
lanning
A
rea
.

Proposed Project Analysis and Conclusions

The proposed
Project

is
in a flat
, urban area
and is not within a known landslide zone identified by the CGS
.
16 As such
,
impacts associated with the development of the proposed Project

would be
consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any
significant impacts
related to landslides.

15 California Department of Conservation

(DOC)
. 2024. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
.

Accessed
October 30
,

2024.

16 California Department of
Conservation (DOC). 2024. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/EQZApp/app/. Accessed October 30, 2024.

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Erosion

Would the project:

Result in substantial soil erosion or the loss of topsoil?

Summary of DNSP EIR Findings

The
DNSP
EIR

determined

that the buildout of the
DNSP

would result in a less than significant impact
relating to erosion

and loss of topsoil. According to the
DNSP

EIR,
e
very construction project in the
State of California that causes a disturbance of one acre or more of soil through grading, clearing, and or excavation is subject to the General Construction Stormwater Permit ( Construction General
Permit), adopted by the
California
State Water Resources Control Board (
S
t
ate Water Board
). In
order to complete the
Construction
Gene
ral Permit application, the applicant must first submit a Notice of Intent (NOI) to obtain coverage under the
Construction
General Permit. This
Construction
General Permit requires dischargers to develop and implement a Storm Water Pollution Prevention Plan (SWPPP), which specifies the B
MPs
that would prevent construction pollutants, including
sediment, from reaching storm drains, with the intent of keeping all products of erosion from moving off
-
site into receiving waters. Furthermore, the SWPPP would also

include BMPs to control erosion
associated with grading, trenching, and other ground surface -
disturbing activities
.

Therefore, the
DNSP

EIR determined that c
ompliance with requirements in the
Construction
General Permit

during
the DNSP buildout

would reduce
the impacts of

erosion and topsoil loss to less than significant
.

Proposed Project Analysis and Conclusions

The
Project

site is in a heavily urbanized area

that

is predominantly covered by paved surfaces
;
however
,

grading and construction of the proposed
Project

would
expose the
Project

site to the
effects of wind and water.

The proposed
Project
’s development would exceed the one acre
minimum
and

would be subject to the requirements in the

Construction

General Permit.

Therefore,

the
proposed
Project

would be required to
develop and implement a SWPPP
,

which would reduce the
potential impacts of erosion and topsoil loss
to less than significant levels.

As such, impacts
associated with the development of the proposed
P
roject

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any significant impacts
related to erosion or
topsoil loss.

Unstable Soils or Geologic Units

Would the project:

Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on
-

or off
-
site landsliding, lateral spreading, subsidence,
liquefaction, or collapse?

Summary of DNSP EIR Findings

The DNSP EIR evaluated
whether development facilitated by the DNSP could potentially be subjected to geologic hazards, including unstable geology.

Geologic materials vary within the DNSP
area, which may contain geologic hazards such as compressed fill materials with differential settlement characteristics.

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rock outcrop.

Placing development in areas known to contain unstable geological units could cause significant damage to structural foundations if not properly engineered.

The following General Plan policies would help to ensure that any new development would be built to appropriate standards:

Policy HS
-

2.1 The City shall seek to minimize grading and impermeable surfaces in high -
erosion
areas.

If grading or impermeable surfaces are necessary, they shall be properly engineered and drained to reduce runoff and erosion.

Policy HS
-

2.2 The City shall consider natural landform contours and geologic conditions in the development of roadways and individual project design.

Policy HS
-

2.3 The City shall continue to regulate development on hillsides to reduce the hazards posed by soil erosion and landslides.

Policy HS
-

2.4 The City shall require that an erosion control plan be prepared and approved for development on slopes of 15 percent or greater.

The plan should include limitations
on vegetation removal, revegetation, and installation of other erosion and sedimentation control measures.

The City General Plan and Building Code require new construction to incorporate measures that reduce risk from geologic hazards.

Policy HS
-

1.3, combined with building code requirements, would
require detailed investigations of subsurface materials and require mitigation, if necessary, as a condition of approval.

The results of that investigation would help develop project engineering and methods to mitigate geologic hazards.

Therefore, impacts resulting from the DNSP were determined to be less than signific
ant.

Proposed Project Analysis and Conclusions

The pro
posed
Project

would be required to comply with all building standards outlined in the City’s General Plan, as well as in the Building Division and CBC.

The
Project

site is located in a
flat,
urbanized area and
,

a
ccording to the CGS, is outside of any liquefaction

or landslide zones.
17 As such
the proposed
Project
’s impacts on
liquefaction,
landslides
,

or lateral spreading as a result of unstable
soils would be less than significant.

Compliance with General Plan policies related to seismic hazards as well as building standards outlined by the Building D i
vision

and the CBC would reduce
the effects
of subsidence and
collapse due to unstable soils to less than significant levels.

As such, impacts
associated with the development of the proposed
Project

would be less than significant
;

consistent
with the analysis in the
DNSP

EIR
;

and the proposed
Project

woul
d not result in any significant
impacts in this regard. No
Project
-
specific or site
-
specific mitigation is necessary for the proposed
Project
.

17 California Department of Conservation

(DOC)
. 2024. Earthquake Zones of Required Investigation. Website:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
.

Accessed October 30, 2024.

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Expansive Soils

Would the project:

Be located on expansive soil, creating substantial
direct or indirect
risks to life or property?

Summary of DNSP EIR Findings

The DNSP EIR evaluated whether development facilitated by the DNSP could potentially be subjected to geologic hazards, including expansive soils.

Geologic materials vary within the DNSP
area, which may
contain geologic hazards such as compressed fill materials with differential settlement characteristics.

Placing development on unstable soils could cause significant damage to structural foundations if not properly engineered.

Only site
-
specific testing could identify the presence of expansive soils.

However, the soil survey
prepared for the DNSP EIR identified a variety of soils, predominantly silt and clay loams.

Therefore,
it is very likely that the DNSP area contains some expansive soils.

General Plan policies would help to ensure that any new development would be built to appropriate standards.

The City General Plan and Building Code require new construction to incorporate measures that reduce risk from geologic hazards.

Policy HS
-

1.3, above, combined with building code
requirements would require detailed investigations of subsurface materials.

The results of that
investigation would help develop project engineering and methods to mitigate geologic hazards.

T
he

DNSP EIR found this impact wo
uld to be less than significant.

Proposed
P
roject

Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would

include a
mixed
-
use

development in accordance with the City’s General Plan, Building Division, and CBC
, in order to reduce potential impacts related to expansive soils.

The
proposed
Project

also
would be required to conduct a
site
-
specific

geological investigation prior to construction
to

determine the potential presence of any
evidence of expansive soils

in accordance

with all
applicable
State
and local requirements, including building code requirements.

As such, impacts
associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any significant impacts. Therefore, the proposed
Project

would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified the DNSP

EIR.

Septic Tanks

Would the project:

Have soils incapable of supporting the use of septic tanks or other alternative wastewater disposal systems where sewers are not available?

Summary of DNSP EIR Findings

The
DNSP

EIR

determined that
all
new development in the
DNSP

P
lanning
A
rea would be served by
existing municipal wastewater
infrastructure
;

therefore
,

no impacts

on soils

related to the use of septic
tanks

or alternative wastewater systems

would occur.

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Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with
mixed

uses in accordance with the provisions of
t
he
DNSP

and

would occur
within the area previously evaluated in the
DNSP

EIR.

Consistent with the
DNSP

EIR, the proposed
Project

would not include any use of septic tanks or alternative wastewater systems and

would
connect directly to ex
isting municipal wastewater systems
on the
Project

site.

As such, impacts
associated with the development of
the proposed
Project

within
the
DNSP

area would be consistent
with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any significant
impacts.

Destruction of Paleontological Resource or

Unique
Geologic Feature

Would the project:

Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

Summary of DNSP EIR Findings

The
DNSP

EIR states that the City is generally underlain by Pleistocene

alluvium which has high
paleontological potential,
therefore

subsurface excavations beyond previously disturbed soils could disturb or destroy paleontological resources. Therefore, impacts

from the
buildout of the DNSP on

paleontological resources would be potentially significant .

The
DNSP

EIR
provided M
M

4.D
-
3 which
would require trainin
g earthmoving crews on

the

appearance of fossils, procedures to follow if any are
discovered, and ensuring t
hat a
P
aleontologist assess
es

the significance of any fossil find, and
recovers it, if appropriate.

With implementation of
MM 4.D
-
3 , impacts on p
aleontological

resources

would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The
Project

site is in an urban area with

no
known unique geological features.

Since the
DNSP

P
lanning
A
rea

is
generally underlain

by
geology
with high paleontological potential, the

effects of the proposed
Project

on
paleontological resources
would be potentially sig
nificant
.

As evaluated in the DNSP EIR, and required in the MMRP for the Specific Plan
,

i
mplementation of
M
M

4.D
-
3 would reduce
the Project’s
potential impacts on
p
aleontological resources to
less than significant levels. No additional analysis required.

Relevant
DNSP
EIR

Mitigation Measures

MM 4.D
-
3 Prior to the start of any subsurface excavations that would extend beyond previously disturbed soils, all construction forepersons and field supervisors shall receive training by a qualified professional
P
aleontologist, as defined by the Society of
Vertebrate Paleontology (SVP), who is experienced in teaching non -
specialists, to
ensure they can recognize fossil materials and will follow proper notification procedures in the event any are uncovered during co
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find and notifying a qualified
P
aleontologist, who will evaluate its significance.

Training on paleontological resources will also be provided to all other construction workers but may involve using a videotape of the initial training and/or written materials rather than in
-
person traini
ng by a
P
aleontologist. If a fossil is determined to
be significant and avoidance is not feasible, the
P
aleontologist will develop and
implement an excavation and salvage plan in accordance with SVP standards

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Geology and Soils, t
he proposed Project would not result in new significant geology and soils

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not
result in an increase in the severity of a previously

identified significant

geology and soils

impact.

There is no new information of substantial importance showing that significant geology and soils

impacts described in th
e DNSP EIR could be substantially reduced by adopting new or

different
mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstance
s Involving
New or More
Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
8 Greenhouse Gas Emissions

Would the project:

Generate
greenhouse gas
emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?

Significant and
unavoidable
impact

MM 4
.B
-
1 and

MM 4.B
-
4 b)

Conflict with any
applicable plan,
policy or regulation
of an agency
adopted for the
purpose of reducing
the emissions of
greenhouse gases?

Significant and
unavoidable
impact

MM 4.B
-
1 and

MM 4.B
-
4 Discussion

Greenhouse Gas Emissions

Would the project:

Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

Summary of DNSP EIR Findings

The

DNSP EIR

identified a significant and unavoidable impact related to the impact of greenhouse
gas (
GHG
)

emissions on the environment.

Using the BAAQMD GHG Model, the DNSP EIR
determined that the per capita emission rate generated by the implementation of the DNSP would be

7.7 metric tons per service population per year
, which exceeds the BAAQMD adopted threshold of 6.6
metric tons per service population per year
.

Therefore, GHG emissions of development facilitated by
the
DNSP

would have a significant impact using the methodology and significance criteria of the BAAQMD, the air quality regulatory agency with jurisdiction over the P
lanning

A
rea
. The DNSP EIR
implemented MM 4.B
-
5, which imposes Green Building and Development Measures on new development projects and requires them to
demonstrate that GHG emissions from operation would
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be reduced by 30 percent from business
-
as
-
usual 2020 emissions levels
. According to the DNSP
EIR, i
mplementation of
MM

4.B
-
5 would reduce GHG emissions associated development facilitated by the
DNSP
. However, even with mitigation, emissions
-
related development facilitated by the
DNSP

would remain cumulatively significant because of the large size of the development and related substantial GHG emissions.

Proposed Project Analysis and Conclusions

The DNSP EIR utilized
BAAQMD thresholds of significance for evaluating potential GHG impacts

which (at the time) were based on meeting State
-
mandated GHG reduction targets for the year 2030
.

Since the
time of the
publication of the DNSP EIR, the BAAQMD has updated the recommended thresholds

in the
2022 CEQA Air Quality Guidelines

to address State
-
mandated GHG reduction
targets for years beyond 2030
.

The new thresholds state that, if a project would contribute its “fair share” of what will be required to ach
ieve California’s long
-
term climate goal of carbon neutrality by
2045, then a reviewing agency can find that the impact will not be significant because the project will help to solve the problem of global climate change. The thresholds for new land use pro jects require
projects to meet either of one of two enumerated Criteria “A” or “B” as shown below

(Table 6)
. If a
land use development project cannot demonstrate consistency with Criterion A or Criterion B, then that project would result in a potentially significant impact related to the generation of direct and indirect GHG emissions.

Table
6 : BAAQMD Thresholds for Land Use Projects

Thresholds for Land Use Projects

Projects must include, at a minimum, the following project design elements:

1. Buildings

The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).

The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the CEQA Guidelines.

2. Transportation

Achieve a reduction in project
-
generated Vehicle Miles Traveled (VMT) below the
regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target,
reflecting the recommendations provided in the Governor’s Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA:

Residential projects: 15 percent below the existing VMT per capita

ii.

Office
projects: 15 percent below the existing VMT per employee

iii.

Retail projects: no net increase in existing VMT

Achieve compliance with off
-
street electric vehicle
(EV)
requirements in the most
recently adopted version of CALGreen Tier 2.

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Thresholds for Land Use Projects

Projects must be
consistent with a local GHG reduction strategy that meets the criteria under CEQA Guidelines Section 15183.5(b).

Notes:

CEQA = California Environmental Quality Act

CALGreen = California Green Building Standards Code

Projects must be consistent with either Criterion A or Criterion B.

Source: Bay Area Air Quality Management District (BAAQMD). 2022. CEQA Guidelines. April 20.

Project consistency with Criteria A is based on incorporating project design criteria based on key attributes consistent with the 2022 Scoping Plan and long -
term carbon neutrality goals. Projects
incorporating these elements would be contributing their “fa ir share” of what will be required to
achieve California’s long
-
term climate goal of carbon neutrality by 2045. These include criteria for building energy design (elimination of natural gas) as well as criteria related to reduction in transportation emissi
ons via VMT reductions and installation of EV charging infrastructure.

The City does not have a GHG reduction plan or C
lean Air Plan

for evaluation against Criteria B.

Therefore, the proposed
Project

was

evaluated against Criteria A
,

as outlined above.

Construction

BAAQMD does not have thresholds of significance for construction -
related GHG emissions. GHG
emissions from construction activities are one
-
time, short
-
term emissions and therefore would not
significantly contribute to long
-
term cumulative GHG emissions imp
acts of the proposed
Project
.

Therefore, construction emissions would be less than significant.

Operation

As previously discussed, the BAAQMD’s proposed 2022 GHG significance thresholds represent a method for determining whether the proposed
Project

would be cumulatively considerable or whether
the proposed
Project

contributes to solving the cumulative problem of climate change, taking into consideration the State’s long
-
term climate goal of carbon neutrality by 2045.

The
proposed
Project

is evaluated against the design elements in Criterion A of BAAQMD’s 2022 GHG Significance thresholds

as follows
:

•

All
-
electric design
:

The proposed project
is
not committed to being all
-
electric in design, and
therefore the

proposed
Project

would
not

comply with this
design element
.

•

Energy efficiency
:

Electricity

providers supplying electricity to the proposed
Project

are
required to comply with both the
Renewable Portfolio Standard (
RPS
)

and SB 350 and will
meet these standards. PG&E
, the electricity provider in Napa,

is ahead of the SB 350 target
with 50 percent of its base energy supply presently coming from renewable sources.

Furthermore, the proposed
Project

would
compl
y

with all relevant Energy Code and CALGreen
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requirements which would ensure energy efficiency. Therefore, the proposed Project

is
consistent with this design element.

•

VMT impact
:

According to BAAQMD thresholds, projects that achieve a reduction in project -
generated VMT below the regional average

would meet this criteria. Residential projects are
defined as 15 percent below the existing VMT per capita, and retail projects are defined as no net increase in VMT.

The Association of Bay Area Governments (ABAG) Vehicle Miles Traveled Screening Map indicates a less than significant impact for the proposed Project
.

The proposed
Project
is in a transit priority area and is at lea
st 15
percent

below
the regional average (and
Countywide average).
18 In addition, the Draft VMT and Trip Generation Assessment conducted by
W-
Trans for the proposed Project assessed the anticipated VMT and vehicular trip generation characteristics of the proposed Project, and found that VMT would have less than significant impacts for the residential, hotel and retail components of the proposed Project.

Therefore, the proposed
Project

is consistent with this design element.

•

Tier 2 EV Charging Infrastructure
: The last design element relates to implementation of
CALGreen Tier 2 level of EV charging infrastructure, which is beyond the mandatory CALGreen requirement of EV charging spaces. MM 4.B
-
1 requires the installation of charging
units for
EVs

at residences and businesses, and the development of incentives for businesses to include preferential parking for electric and/or hybrid vehicles. However, MM 4.B -
1 lacks the
level of specificity needed to ensure the charging units for electric vehicle at residences and businesses would meet Tier 2 requirements.

Therefore, even

with implementation of MM

4.B
-1
,
the proposed
Project

would not be consistent with this design element.

In summary, the proposed
Project

would satisfy
two of the four design elements as outlined in the
BAAQMD GHG threshold Criterion A.

Construction and operation of the proposed
Project

would be
required to comply with all federal, State, and local regulations related to GHG emissions. The proposed
Project

would also implement MM 4.B
-
5 through compliance with the City’s High
-
Performance Building Regulations and CALGreen standards, which have been updated since the adoption of the DNSP.

The proposed Project would also

implement MM 4.B
-
1, MM 4.B
-
4, and MM

4.B
-
5, which

would serve to further reduce GHG emissions. However, because the proposed

Project
would not satisfy all design elements outlined in the BAAQMD thresholds of significance, the

proposed
Project

would result in a significant impact related to GHG emissions.

The DNSP EIR
concluded that
, even with mitigation,
GHG
emissions
-
related development facilitated by the
DNSP

would remain cumulatively significant because of the large size of the development and related substantial GHG emissions.

As such, impacts associated with the development of the proposed Project

would be consistent with the analysis in the

DNSP EIR

and the proposed
Project

would not
result in any peculiar
GHG

emission
effects and would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

18 Association of Bay Area Governments

(ABAG)
.

VMT Screening Map. Website:
https://mtc.maps.arcgis.com/apps/dashboards/6ff269ac90784909939f5ed8813ac5de . Accessed April 25, 2025.

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Greenhouse Gas Emissions Reduction Plan Conflict

Would the project:

Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases?

Summary of DNSP EIR Findings

The

DNSP EIR

identified a significant

and unavoidable

impact related to conflict with a GHG
emissions reduction plan.

Even with the implementation of MM 4.B
-
5, which is intended to reduce
GHGs on a project
-
by
-
project basis, the DNSP EIR determined that the impact relating to conflicts with
a GHG emissions reduction plan

would be significant and unavoidable.

With respect to consistency with

AB
32 and its Climate Change Scoping Plan, this analysis
acknowledges that BAAQMD derived the per

capita efficiency threshold from emission
levels required
to be met to achieve AB

32 goals. Therefore, these quantitative thresholds
were

used to assess
whether the
DNSP
would conflict with AB

32. Because development facilitated by the
DNSP

would
emit GHGs that exceed the service population
-
based efficiency thresholds of the BAAQMD which
were derived based on AB

32 attainment goals, implementation of the
DNSP

would also conflict with
AB

32 and its associated planning efforts. The City
’s
General Plan
, at the time th
e

document was
published, did

not
include policies explicitly designed to address

GHG
emissions and climate change.

However, the Draft Napa Countywide Community Climate Action Plan include d

aggressive reduction
measures to achieve 1990 GHG levels by 2020. Based on the substantial reductions required by these measures and the changing regulatory environment pertaining to GHGs, it was

not clear
whether the GHG reduction strategies described in the Draft Climate Action Plan were

feasible for the
DNSP
. Thus, the
DNSP

could conflict with the goa
ls identified in the Draft Napa Countywide
Community Climate Action Plan.

Proposed Project Analysis and Conclusions

The consistency of the proposed
Project

with respect to ARB’s 2022 Scoping Plan is discussed
below.

2022 Scoping Plan

The ARB 2022 Scoping Plan for Achieving Carbon Neutrality was approved in December 2022 and expands on prior scoping plans and recent legislation, such as AB 1279, by outlining a technologically feasible, cost
-
effective, and equity
-
focused path to achieve
the State’s climate target of reducing
anthropogenic GHG emissions to 85 percent below 1990 levels and achieving carbon neutrality by 2045 or sooner. To achieve carbon neutrality by 2045, the 2022 Scoping Plan contains GHG emissions reductions, technology,

and clean energy mandated by statutes; reduction of short -
lived
climate pollutants; and mechanical
carbon dioxide
(
CO
2 )
capture and sequestration actions.

The 2022
Scoping Plan identifies three priority areas where emissions reductions are targeted to achieve its long
-
term goal of carbon neutrality. Those priority areas include transportation electrification ,

VMT
reduction
,

and building decarbonization.

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•

Building decarbonization:

As previously discussed
, the proposed
Project

has not committed
to

an all
-
electric design and would therefore
be

inconsistent

with this key priority area.

•

VMT impact
:

As discussed in Impact GHG
-
1, the proposed
Project
would have less than
significant VMT impacts.

T
herefore, the proposed
Project

is
consistent

with this
key priority
area
.

•

Transportation Electrification
:

As discussed previously, MM 4.B
-
1 would
require
implementation of
charging units for
EVs
, as well as the development of incentives for
businesses to include preferential parking for electric and/or hybrid vehicles. Therefore, the proposed
Project
is consistent with this
key priority area
.

cannot be assured that the

proposed
Project would
be all
-
electric in design, and therefore the

proposed
Project

would
be inconsistent with the 2022 Scoping Plan, which would

result in a
significant impact related to conflicts with GHG emissions reduction plans.

The proposed
Project
would be required to comply with all federal, State, and local regulations regarding GHG emissions reduction goals and would implement MM 4.B
-
1 and MM 4.B
-
4 to reduce GHG emissions.

However
,
impacts associated with the development of the proposed Project

would
remain

significant. The
DNSP EIR concluded that
, even with mitigation,
GHG
emissions
-
related development facilitated by
the
DNSP

would remain cumulatively significant because of the large size of the development and related substantial GHG emissions.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the

DNSP EIR

and the proposed
Project

would not result in any peculiar effects
in conflict with any applicable plan, policy or regulation, and
woul
d not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

Relevant
DNSP
EIR Mitigation Measures

MM 4.B
-
1 In order to be consistent with the MSM A
-
1 and MSM A
-
2 T
ransportation Control
Measures (TCMs), the City shall require that the following measures be included as potential Transportation Demand Management (TDM) strategies to be implemented by individual project applicants, where feasible and appropriate:

•

Install charging units for electric vehicles at residences and businesses.

•

4.B
-
4 Implement
Mitigation Measure 4.B
-
1 to ensure consistency with the BAAQMD TCMs
to promote clean, fuel efficient and zero
-
emission vehicles.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to
GHG
emissions
, t
he proposed Project would not result in new significant GHG

emission

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in
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an increase in the severity of a previously

identified significant

GHG

emission

impact.

There is no
new information of substantial importance showing that significant

GHG

emission

impacts described
in the DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or
alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
9 Hazards and Hazardous Materials

Would the project:

Create a significant
hazard to the public
or the environment
through the routine
transport, use, or
disposal of
hazardous materials?

Less than
significant

impact

None

Create a significant
hazard to the public
or the environment
through reasonably
foreseeable upset
and accident
conditions involving
the release of
hazardous materials
into the
environment?

Less than
significant

impact

None

Emit hazardous
emissions or handle
hazardous or acutely
hazardous materials,
substances, or waste
within one
-
quarter
mile of an existing or
proposed school?

Not A
ddressed

None

Be located on a site
which is included on
a list of hazardous
materials sites
compiled pursuant to
Government Code
Less than
significant
impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

Section 65962.5 and,
as a result, would it
create a significant
hazard to the public
or the environment?

For a project located
within an airport land
use plan or, where
such a plan has not
been adopted, within
two miles of a public
airport or public use
airport, would the
project result in a
safety hazard
or
excessive noise
for
people residing or
working in the project
area?

Not Addressed

None

f
)

Impair
implementation of or
physically interfere
with an adopted
emergency response
plan or emergency
evacuation plan?

Not Addressed

None

g
)

Expose people or
structures
, either
directly or
indirectly

to a significant risk of
loss, injury or death
involving wildland
fires?

Not Addressed

None

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Discussion

Routine Transport, Use, or Disposal of Hazardous Materials

Would the project:

Create a significant hazard to the public or the
environment through
the routine transport, use, or disposal of hazardous materials?

Summary of DNSP EIR Findings

The DNSP EIR evaluated whether development facilitated by the DNSP would include increased commercial, retail, and hotel land uses that could involve the transportation, use, or storage of hazardous materials that could cause a potential impact to public h ealth and/or safety risks to facility
workers, residents, and visitors, and the surrounding area.

Proposed development would be expected
to increase the use of chemical products considered hazardous materials or waste.

The DNSP does
not propose industrial
uses that may use or transport hazardous materials.

Projects that involve the handling, using, or transporting of hazardous materials would be required to follow applicable laws and regulations.

As described in the DNSP EIR, the City would require future development to comply with
all applicable
State
and local
regulatory requirements,
including building
code requirements, and
coupled with the County’s Hazardous Materials Management Plan which avoid or minimize the potential impacts.

In addition, transportation routes would be identified and regulated by Cal
trans to minimize impacts.

Therefore, impacts would be less than significant.

Proposed Project Analysis and Conclusions

The proposed
Project

would include the
construction of a hotel, as
w
ell as retail and residential uses
,
which could involve the transport, use, and disposal of hazardous materials.

Development of the
proposed
Project

would also include the
temporary transport, use, or disposal of typical hazardous materials (e.g., diesel fuels, lubricants, solvents, asphalt, pesticides, and fertilizers) during the proposed
Project
’s construction phase.

D
uring construction

and operation
, the proposed
Project

would be require
d to comply with all applicable federal, State, and local laws and regulations related to the safe transport, use, and disposal of hazardous materials,

as well as
General Plan

policies
HS
-

7.1 through HS
-

7.3 as described above
,

which would ensure impacts remain less than significant.

T
he proposed
Project

would not result in any peculiar
hazardous materials
effects and would not
result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As
such, impacts associated with t
he development of the proposed
Project

would be consistent with the
analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any
significant

impacts.

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Risk of Upset

Would the project:

Create a
significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

Summary of DNSP EIR Findings

The DNSP EIR evaluated whether construction facilitated by the DNSP could potentially create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials.

Construction activities associated
with development may involve the transport and use of hazardous materials; however, they would be used in limited quantities and only temporarily stored on -
site.

As discussed in the Hydrology and Water Quality discussion, the City would require construction projects to develop and implement a SWPPP, which contains measures to prevent and contain hazardous materials from spreading off
-
site.

Furthermore, as discussed in (a) above, hazardous
materials generated by demolition activities would be disposed of according to applicable laws and regulations.

Compliance with existing regulations would address potential upsets and accidents, and ,

therefore, impacts were found t
o be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with
mixed

uses in accordance with the provisions of
t
he
DNSP

and

would occur
within the area previously evaluated in the
DNSP

EIR.

The
proposed
Project

would be required to
comply with all applicable
federal, State, and local

laws and regulations that relate to
the safe
transport, use, and disposal of hazardous materials
.

The proposed
Project

would also be required to
comply with
the
National Pol
lutant Discharge
Elimination System (
NPDES
)

Construction General
Permit
,

w
hich requires the
preparation and implementation of a SWPPP for construction activities .

Impacts related to spills of hazardous materials would be mitigated by the SWPPP and would be
reduced to less than significant levels.

T
he proposed
Project

would not result in any peculiar
release
of hazardous materials
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associate
d with the development of the
proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

Exposure of Schools to Hazardous Materials or Emissions

Would the project:

Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one
-
quarter mile
of an existing or proposed school?

Summary of DNSP EIR Findings

T
he
DNSP

EIR determined that no impacts would occur related to
e
mit
ting

hazardous emissions or
handl
ing

hazardous or acutely hazardous materials, substances, or waste within

0.25 mile of an
existing or proposed school
. The
DNSP

EIR concluded that
there are no current or proposed
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industrial uses in the
P
lanning
A
rea and
,

therefore, the proposed uses in the
P
lanning
A
rea would not
include any hazardous emissions or handle hazardous materials, substances ,

or waste such that it
would put occupants of the school at risk
.

As a result
,

no
impact

would occur.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The nearest school

to the proposed
Project
,
Blue Oak Elementary School,

is
approximately

0.18 mile
west of the
Project

site.

However,

industrial
uses would

not

be included in the proposed
Project
. T
herefore
,

the proposed
Project

would not

include any hazardous emissions or handle hazardous materials

within a quarter mile of a school
.

T
he proposed
Project

would not result in any peculiar
hazardous materials
effects and would not
result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As
such, impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be
mitigated to a less than significant level.

d
)

Hazardous Materials Sites

Would the project:

Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

Summary of DNSP EIR Findings

The DNSP EIR evaluated whether development facilitated by the DNSP on land previously impacted by
release of hazardous materials could potentially expose residents or workers to hazardous materials or wastes.

The EIR identified previously developed lots that may contain underground storage tanks.

The tanks could pose a risk from leaked petroleum hydrocarbons or other chemical constituents.

As a result, exposing residents was considered a potentially significant impact.

As summarized in the DNSP EIR, a number of sites were listed on regulatory agency databases.

The
DNSP EIR identified all properties listed on the State
Water Board

GeoTracker database within the
DNSP area.

To address potential impacts, the DNSP EIR discusses City General Plan policies and the County’s Certified Unified Program Agency.

Policy HS
-

7.1 requires continued
participation in the Unified
Program.

The Program evaluates risks and remediation efforts on contaminated sites.

Other existing
requirements include preparing Phase I
Environmental Site Assessmen
ts
(ESAs)
which evaluate
historical uses and evaluate sub
-
surfaces for possible contamination.

If necessary, a project would
undertake investigations and remediation efforts with oversight by several agencies.

This includes the
County’s Department of Environmental Management, the
Regional Water Quality Control Board
(
RWQCB
)
, and the California Department of Toxic Substances Control

(DTSC)
.

The DNSP EIR
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concluded that because completion of cleanup activities with agency oversight would be completed prior to construction (as a condition of approval), impacts would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

T
he
Project

site is not
included
on a list of
hazardous materials sites compiled pursuant to Government Code Section 65962.5 , nor
does
it

contain any

known

underground storage tanks.
19 Accordingly, the policies
identified in the DNSP EIR
related to contaminated sites are not applicable to the proposed Project
.

The
Project

site currently
contains
a
vacant

Kohl’s department store, three restaurants, the Dwight Murray Plaza, and a shared parking lot,
while the Public Realm Parcel include
s

an existing City parking lot, the 9/11 Memorial
Garden, and a pedestrian corridor
.

T
he proposed
Project

would not
be located on a hazardous
materials site and would not
result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As such, impacts
associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would no
t result in any
significant
impacts.

Airports

Would the project:

For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or
excessive noise

for people residing or working in the project area?

Summary of DNSP EIR Findings

The

DNSP

EIR identified that no impacts would
occur related to

airport
-
related safety hazards for
people residing or working in the
P
lanning
A
rea
.

According to the
DNSP

EIR, t
he closest airstrip or
airport to the
P
lanning
A
rea is the Napa County Airport located approximately 5
.41

miles south, well
outside of the Airport Land Use Plan. Therefore, there would be no

potential impacts to any airports.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
. The
nearest airport

to the
Project

site
, Napa
County Airport,

is located

5.41 miles south of the
Project

site
, placing it outside of the boundary of the
Airport Land Use Plan
. Therefore
, no impacts would occur related to

airport
-
related safety hazards for
people resid
ing or working in the
P
lanning
A
rea
.

T
he proposed
Project

would not
be located within an
airport land use plan and would not
result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As such, impacts

19 California Environmental Protection Agency

(Cal
/
EPA)
. 2024. Cortese List Data Results. Website:
https://calepa.ca.gov/sitecleanup/corteselist/
. Accessed October 31, 2024.

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associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any
significant
impacts.

Emergency Response and Evacuation

Would the project:

Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan and determined there would be no impact.

The
DNSP

EIR determined
that the buildout of the DNSP
could result in an increased resident, employee
,

and visitor population
in the
P
lanning
A
rea
, and although the buildout of the
DNSP

would alter the existing street network by
removing the one
-
way coupl
ets and forming two
-
way flow, it would comply with all emergency vehicle
access requirements as a condition of construction
. It was determined by the
DNSP

EIR that the
buildout of the
DNSP

would not impede an established emergency access route or interfere with emergency response requirements and would not result in permanent road closures. Therefore, no impacts to emergency response or evacuation plans

would occur.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

The
proposed
Project

would not result in any
road closures and would employ a fire access plan which would provide adequate emergency access
to the
Project

site.

Fire access would be provided via Main Street through the Main Street drop -
off/loading loop. Adequate turnaround distance would be provided for emergency vehicles through a turnaround area in a portion of the Brown Street
C
orridor adjacent to the drop
-
off/loading loop
.

Therefore,

the proposed
Project

would not conflict with the
implementation of or physically interfere
with an adopted emergency response plan or emergency evacuation plan .

No impacts would occur.

T
he proposed
Project

would not result in any peculiar effects

to
an adopted emergency response plan
or emergency evacuation plan

and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

g
)

Wildland Fires

Would the project:

Expose people or structures, either directly or indirectly to a significant risk of loss, injury or death involving wildland fires?

Summary of DNSP EIR Finding
s

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

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emergency evacuation plan and determined there would be no impact.

The

DNSP

EIR
determined
that the
DNSP

P
lanning
A
rea is located within an urbanized area that is not immediately adjacent to any wildlands
, and a
ll construction that might be associated with the
DNSP

would be required to
adhere to Building Fire Codes that are designed to minimize the potential for uncontrolled fires.

Therefore, implementation of the
DNSP

would not expose people or structures to significant risk of wildland fires
.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR. The proposed
Project

is within an urbanized
area

and is outside of any Fire Hazard Severity Zones (FHSZs) .
20 As such
the proposed
Project

would not expose people or structures, either directly or indirectly ,

to a significant risk of loss, injury
,

or
death involving wildland fires
.

Therefore, the Project would not result in any

new or more severe
impacts with respect to
wildland fires

that were not previously analyzed and disclosed in

the D
N
SP
EIR

and no further environmental analysis is required
.

Relevant
DNSP
EIR Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to
Hazards and Hazardous Materials, t
he proposed Project would not result in new
significant
hazards and hazardous materials

impacts that were not

evaluated in the DNSP EIR.

The
proposed Project would not result in an increase in the severity of a previously

identified significant

hazards and hazardous materials

impact.

There is no new information of substantial importance
showing that significant

hazards and hazardous materials

impacts described in the DNSP EIR could
be substantially reduced by adopting new or

different mitigation measures or alternatives.

20 California Department of Forestry and Fire Protection (CAL FIRE) . 2024. Fire
Hazard
Severity Zones in State
Responsibility Area. Website:
https://calfire
-
forestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d89597ab693d008 . Accessed October
31, 2024.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 0

Hydrology and Water Quality

Would the
project:

Violate any water
quality standards or
waste discharge
requirements

or
otherwise
substantially degrade
surface or
groundwater quality
?

Less than
significant
impact

None

Substantially
decrease

groundwater supplies
or interfere
substantially with
groundwater
recharge such that
the project may
impede sustainable
groundwater
management of the
basin
?

No impact

None

Substantially alter the
existing drainage
pattern
of the site or

area, including
through the alteration
of the course of a
stream or river

or
through the addition
of impervious
surfaces
, in a
manner which would
:

Less than
significant
impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

(i)

result in
substantial
erosion or siltation
on
-

or off
-
site;

Less than
significant
impact

None

(ii)

substantially
increase the rate
or amount of
surface runoff in a
manner which
would result in
flooding on
-

or off
-
site;

Less than
significant
impact

None

(iii)

create or
contribute runoff
water which would
exceed the
capacity of
existing or
planned
stormwater
drainage systems
or provide
substantial
additional sources
of polluted runoff;
or

Less than
significant
impact

None

(iv)

impede or redirect
flood flows?

Less than
significant

impact

None

In flood hazard,
tsunami, or seiche
zones, risk release of
pollutants due to
project inundation?

No impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

Conflict with or
obstruct
implementation of a
water quality control
plan or sustainable
groundwater
management plan?

Not Addressed

None

Discussion

a
)

Water Quality

Would the project:

Violate any water quality standards or waste discharge
requirements or
otherwise substantially degrade surface or
groundwater quality?

Summary of DNSP EIR Findings

The DNSP EIR considered the potential for development facilitated by the DNSP to violate water quality standards, violate waste discharge requirements, or otherwise degrade water quality by increasing nonpoint source pollutants in stormwater runoff.

The DNSP EIR identified the potential for pollutants to wash into local waterways during storm events.

Pollutants include oils, fuels, heavy metals, pesticides, and other contaminants common to City
streets and parking lots.

Sediments may pollute local waterways caused by erosion from construction activities and urban uses such as landscaping maintenance and litter.

The pollutants
could ultimately wash into the Napa River and Napa Creek, already identified as impaired waters.

Therefore, the development faci
litated by the DNSP could create a potentially significant impact.

However, development facilitated by the DNSP would be subject to City guidelines, ordinances, and
permitting requirements.

As described in the DNSP EIR, the RWQCB prepared the San Francisco Bay Basin Water Quality Control Plan, which provides regulations and measures that apply to development contemplated in the DNSP.

Future projects would comply with applicable regulations and implement control measures through construction permits to ensure protection of municipal water sources, wildlife and aquatic habitat, and recreational resources.

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The City is required to develop a Stormwater Management Plan and obtain a permit that allows for stormwater discharge.

The Stormwater Management Plan describes BMPs, measurable goals, and timetables to achieve water quality goals.

The plan and subsequent permits include educational
components, apply to construction sites, and require operational measures to avoid or minimize pollutants from entering waterways.

The City also developed a Stormwater Runoff Pollution and Control Ordinance.

The ordinance is
intended to protect water resources an
d

improve water quality.

The City adopted standards for off
-
site
and on
-
site stormwater management practices, prohibit
ed

deliberate discharges, establishe
d

authority to manage and control pollutant sources,
and
adopted requirements for project site design
that
apply to project construction and operational phases.

Therefore, impacts were found to be less
than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would be required to
comply with all applicable federal,
S
tate, and local
laws and regulations governing water quality and
stormwater quality standards. The proposed
Project

would be required to
create and implement a
SWPPP that would further redu
ce potential impact related to stormwater quality.

The proposed
Project

would also include design features
that would increase stormwater retention and filtration, like permeable pavers and stormwater planters.

T
he proposed
Project

would not result in any peculiar
water quality
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in

the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

Groundwater

Would the project:

Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

Summary of DNSP EIR Findings

The
DNSP

EIR

evaluated whether full buildout of the development contemplated in the DNSP

would
s
ubstantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
proposed
project may impede sustainable groundwater management of the basin

and
determined there to be
no
impact in this regard.

The
DNSP

EIR
determined that the
underlying
groundwater aquifer in the
P
lanning
A
rea is not used for water supply purposes

and n
o groundwater
extraction beyond minor temporary d
ewatering activities that may be required for construction would be facilitated by the
DNSP
. The
DNSP

includes stormwater management guidelines encouraging
design features that would increase pervious surfaces and, as a result, groundwater recharge.

Therefore,
DNSP

EIR determined that
there
was

no adverse potential impact associated with
development facilitated by the
DNSP

relative to the depletion of groundwater supplies.

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Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would not include any
groundwater extraction infrastructure and would include pervious surfaces and bioretention area that
would facilitate groundwater infiltration. The
proposed development is consistent with the
development foreseen in the
DNSP
, and the proposed
Project

would connect directly to existing water
supply infrastructure on the
Project

site.

T
he proposed
Project

would not result in any peculiar
groundwater
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to

a less than significant level.

c
)

Drainage

Would the project:

Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

result in substantial erosion or siltation on
-

or off
-
site;

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP

would

substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would

result in substantial erosion

and determined there to be a less than significant impact in this regard.

The
DNSP

EIR determined that adherence to the City’s
Storm Water Management Plan and
Stormwater Runoff

Pollution Control Ordinance

would require
erosion and sedimentation control
measures for construction and operation
;
therefore
,

potential impacts related to erosion on or off
-
site
would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would be required to
develop and implement a SWPPP which would include measures to reduce the potential
effects of
erosion on
-

or off
-
site

to less than significant levels
.

T
he proposed
Project

would not result in any
peculiar
erosion or siltation
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of
the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

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(ii)

substantially increase the rate or amount of surface runoff in a manner which would res
ult in flooding on
-

or off
-
site;

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP

would

substantially increase the rate or amount of surface runoff in a manner which would result in flooding on
-

or off
-
site
and determined there to be a less than significant impact in this regard.

The
DNSP

EIR
determined that although the
P
lanning
A
rea is

largely developed and covered
primarily by
impervious surfaces such as roads, buildings, and parking lots ,

the development under the
DNSP

would

include design features that incorporate stormwater management guidelines

such as
permeable pavers

and st
ormwater retention areas
.

The
DNSP

EIR also determined that adherence to
the City’s
Storm Water Management Plan and Stormwater Runoff Pollution Control Ordinance

would
require source controls of stormwater volumes eit
her through detention or local infiltration, as

well as
generally improve
drainage facilities over existing conditions
.

As such, impacts on surface runoff from
the buildout of the
DNSP

were found to be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would be required to
develop and implement a SWPPP
,

which would include measures to reduce the potential effects of surface runoff

to less than significant levels
. Design features
,

such as permeable paver, planter strips,
and bioretention areas
,

would help
control runoff fr
om the
Project

site and would facilitate infiltration
to reduce the effects of on or
off
-
site

flooding.

T
he proposed
Project

would not result in any peculiar
surface runoff
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a le ss than significant level.

(iii)

create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff;

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP

would
substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water whic
h would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff

and
determined there to be a

less than significant impact in this regard.

The
DNSP

EIR determined that
adherence to the City’s

Storm Water Management Plan and Stormwater Runoff Pollution Control Ordinance,
as well as the incorporation of stormwater management design features ,

would
generally
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improve drainage facilities over existing
conditions

and

would

limit the amount of runoff that would be
directed off
-
site and could even reduce volumes over existing conditions.

As such
,

the buildout of the
DNSP

was found to have a less than significant impact
of stormwater
on
existing drainage systems.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

includes
stormwater
management design features
,

such as

permeable pavers

and

planter strips,
which would reduce the
amount of runoff that would be directed off
-
site

and increase infiltration on the
Project

site. The
proposed
Project

would also be
required to develop and implement a SWPPP which would
contain
measures to reduce the effects of stormwater runoff and reduce potential strain on local drainage systems.

T
he proposed
Project

would not result in any peculiar
stormwater capacity or pollution
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed Project

would
be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any
impacts that would not be mitigated to a less than significant level.

(iv)

impede or redirect flood flows?

Summary of DNSP EIR Findings

The
DNSP

EIR

evaluated whether full buildout of the development contemplated in the DNSP

would
substantially

alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would

impede or redirect flood flows

and determined there to be a less than significant impact in this regard.

The
DNSP

EIR
determined that the buildout of the
DNSP

would alter flood flows
through new
development

on previously vacant sites, but the
introduction of design
features that incorporate
stormwater management guidelines would likely result in a net reduction in stormwater flows off -
site
through the addition of pervious surfaces
.

As such the impact on flood flows was found to be

less
than significant
.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would include design
features that incorporate stormwater management guidelines , as well as incorporate a SWPPP which
would reduce the level of stormwater
directed off
-
site.

T
he proposed
Project

would not result in any
peculiar
flood flow
effects and would not result in a new or more severe adverse impact that was not previously i
dentified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

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Risk of Pollutant Release Due to Inundation

Would the project:

In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP

would,
i
n flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation

and
determined there to be a less than significant impact in this regard.

The
DNSP

EIR determined that
the
P
lanning
A
rea was located outside of any
areas at risk of tsunamis, seiches, or mudflows and that there would be no impacts related
to these hazards.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
P
roject
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
P
roject

is within
the
DNSP

P
lanning
A
rea
,

which is located outside of any areas at risk of tsunamis, seiches, or mudflows.

A
portion of the
Project

site is designated as an area of

0.2 percent

Annual Chance Flood Hazard
.
21 Adherence to General Plan policies and actions related to flood

hazards as well as the City’s
Floodplain Management Ordinance

would reduce
the proposed
Project
’s impacts on flood hazards on
the
Project

site
.

T
he proposed
Project

would not result in any peculiar
inundation
-
caused pollutant
release
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not
result in any impacts that would not be mitigated to a less than significant level.

Water Quality Control or Sustainable Groundwater Management Plans Consistency

Would the project:

Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

Summary of DNSP EIR Findings

The
DNSP

EIR

did not identify a significant impact related to conflict or obstruction of

implementation
of a water quality control plan or sustainable groundwater management plan.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The
proposed

Project

would adhere to all local,
State, and federal laws and regulations related to water quality and groundwater ,
as well as
all
General Plan and
DNSP

policies
related to groundwater conservation and infiltration
.

Additionally, the

21 Federal Emergency Management Agency (
FEMA
)
. 2024.

FEMA Flood Map Service Center
. Website:
https://msc.fema.gov/portal/search?AddressQuery=napap%20ca . Accessed
March 14, 2025
.

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proposed
Project

would develop and implement a SWPPP
,

which would contain measures to

maintain groundwater quality standards.

T
he proposed
Project

would not
conflict
with
or obstruct any
water quality and groundwater
plans and would not
result in any peculiar effects and would not result
in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

As such
,

the proposed
Project

would not interfere with the implementation of any adopted water quality control plan.

I
mpacts associated with the development of the proposed
Project

would be consistent with the
analysis in
the

DNSP EIR
, and the proposed
Project

would not result in any impacts that would not be
than significant.

Relevant
DNSP
EIR Mitigation Measures

None.

Conclusion

The proposed
Project

is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Hydrology and Water Quality, t
he proposed
Project

would not result in new
significant
hydrology and water quality

impacts that were not

evaluated in the DNSP EIR.

The
proposed
Project

would not result in an increase in the severity of a previously

identified significant

hydrology and water quality

impact.

There is no new information of substantial importance showing that significant
hydrology and water quality

impacts described in the DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 1

Land Use and Planning

Would the project:

Physically divide an
established
community?

Less than
significant

impact

None

Cause a significant
environmental impact
due to a conflict with
any land use plan,
policy, or regulation
adopted for the
purpose of
avoiding or
mitigating an
environmental effect?

Less than
significant

impact

None

Discussion

Division of an Established Community

Would the project:

Physically divide an established community?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

would physically divide an established community and identified a less than significant impact.

The
DNSP

EIR determined that the
buildout of the
DNSP

would not include any major planned roadways,
such as freeways that would divide Downtown or individual neighborhoods or subareas . The
DNSP

EIR also determined that the
DNSP

would include
objectives to
increase circulation throughout the
P
lanning
A
rea,
including new

and

improved

pedestrian
and bicycle
pathways

and
converting streets
from one
-
way to two
-
way
.

The
DNSP

also includes
new land use designations to
provide for sensitive
transition to adjacent residential areas that surround the P
lanning
A
rea
, like D
MU

and Downtown
Residential. As such, the
DNSP

EIR determined that the
buildout of the
DNSP

would have a less than
significant impact related to physically dividing an established community.

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Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would
develop mixed

uses in accordance with
DNSP

with
in
the Focus A
rea previously evaluated by
the
DNSP

EIR.

The proposed
Project

is located in
the most dense

urban area
of Napa
and is
surrounded by
commercial

and retail uses on all sides of the
Project

site. The
proposed
Project

does
not include any
development that would block roadways or cut off circulation through the C
ity.

Instead, the proposed Project’s
New
Pl
aza
would

restore the urban grid
and
re
-
establish connections
and circulation.

Construction of the proposed
Project

would not require the
permanent
closing of any
roadways and would be consistent with
urban

land use in the surrounding area.

Th
e proposed
Project

does include many updates to circulation through the
Project

site, such as the reactivation of the
Brown Street Corridor, as well as the addition of a
new

pedestrian
corridor extension
that would
provide a connection from

Coombs Street to
the existing 9/11 memorial

as part of the proposed
Public Realm improvements
.

T
he proposed
Project

would not result in any peculiar effects
that would
physically divide an established community
and would not result in a new or more severe adverse
impact
that was not previously identified in the

DNSP EIR
.

As such, impacts associated with the
development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR

and the
proposed
Project

would have a less than significant impact.

Conflict with Applicable Land Use Plans, Policies, or Regulations

Would the project:

Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

Summary of DNSP EIR Findings

The DNSP EIR considered whether development facilitated by the DNSP could potentially conflict with applicable land use plan, policy, or regulation of an agency with jurisdiction over the proposed
project (including, but not limited to
a

general plan, specific plan, local coastal program, or zoning ordinance) that was adopted for the purpose of avoiding or mitigating an environmental effect.

The
DNSP EIR notes that a policy inconsistency is considered a significant adverse impact only if the
inconsistency would result in a significant adverse physical impact based on the established significance criterion.

The proposed DNSP land use districts would not represent a substantial departure from the existing controls such that incompatible land uses would be developed.

In general, it is anticipated that future
development allowed by these new districts would result in a more cohesive D CC

area that
transitions to mixed

uses.

The DNSP would provide development guidelines to guard surrounding neighborhoods from incompatible densities.

Subsequent actions required for implementation of the
DNSP include amendments to th
e City General Plan and Land Use Map and amendments to the City Zoning Code and maps to ensure consistency.

Therefore, the DNSP EIR determined that the DNSP
would not conflict with any applicable land use policies adopted for the purpose of avoiding or mitigating an environmental effect.

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Proposed Project Analysis and Conclusions

The DNSP Land Use Designation for the
Project

site, including Dwight Murray Plaza, is DCC,
Downtown Core Commercial with the Parking Lot Parcel designated DMU . The
proposed
P
roject
does not conflict with such land use designations and related polic i
es.

For the most part, the Napa
2040 General Plan Update copied the land use designations throughout the DNSP boundary.

However, the General Plan Land Use Diagram (2040 General Plan Update, Figure 2 -
3) depicts
Dwight Murray Plaza as “Open Space and Parks” whic
h is consistent with the City’s Parks plan listing
of Dwight Murray Plaza as a “Civic Space” (2040 General Plan Update, Table 4 -
4). Under the 2040
General Plan Update, “Civic Sp
aces” include small, landscaped spaces and gathering areas.

Generally smaller than one acre in size and easily traversed on foot, C
ivic
S
paces provide social
space that is often supported by amenities such as benches, tables, landscaping, public art, water features, or other amenities for community events. These spaces are typically located within Downtown districts, high
-
density urban area
s, and transit stations, but are community
-
wide assets.

Civic Spaces can provide for the day
-
to
-
day open space needs of

nearby residents and employees,
as well as shoppers, transit users, and people attending community events. They help balance high -
density development and communicate neighborhood character. The City currently provides nine Civic Spaces for a total of 4.3
acres. (See 2040 General Plan Update §4.6)

The proposed
Project

would replace and increase the size of Dwight Murray Plaza, which would be relocated to the
New Pla
za on the
Project

site.

The PD Overlay and Development Agreement
regulate the development and public use of the required New Plaz
a. Under
Napa Municipal Code

17.42.020, Planned Development Overlay Districts may be combined with any principal zoning district consistent with the purpose and provisions of the district. Here the DCC, DMU and Parks designations will be combined with the PD
Overlay
designation.

The specific purposes of the
P
lanned
Development Overlay Di
strict under
Napa Municipal Code

17.42.010 are to encourage high quality,
innovative and creative development design, and possibilities for varied or mixed uses and to provide a mechanism for preservation of open space, natural or historic features while continuing to permit efficient use

of land.

Through the use of the proposed Project’s PD Overlay, high quality, innovative and creative development design and preservation of Civic Spaces is accomplished with the Project’s New Plaza

relocated on the
Project

site with a larger public area t
hat connects the pedestrian corridor
at the Shops on First Street to the 9
/
11 Memorial area.

The plaza relocation further supports the
implementation of the DNSP Town Center Focus Area.

The DNSP Entertainment Overlay District Map also would be amended to include the entirety of the Project

site.

Portions of the
Project

site are currently within the Entertainment Overlay District.

Including the entire site would provide the proposed
Project

a uninform permitting standard to
implement entertainment uses and activities allowed by the DNSP.

The relocation of the Civic Space on
-
site does not conflict with the General Plan Map designation or the Napa 2040 General Plan or DNSP because relocating the

Civic Space’s Parks
designated area
would not remove the plaza from the site; instead the
New Pl
aza would not reduce the number of
Civic Spaces and would increase the size and quality of Civic Spaces in furtherance of 2040 General Plan Update Goals and Policies: Goal LUCD
-
1, Goal LUCD
-
2, Goal LUCD
-
3, LUCD 3.4, LUCD 3.4,
Goal LUCD 20, Goal LUCD 21, Go
a
l LUCD 22, Goal CSPR
-
9, CSPR9
-
12, and CSPR 10.1. Because
the relocation of the plaza through the PD

Overlay

and Development Agreement does not affect
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goals, policies, or other adopted portions of the General Plan as described above, the PD Overlay’s
relocation of the Civic Space on
-
site is not considered a General Plan Amendment under Section 1.9 of the 2040 General Plan.

With respect to the DNSP Entertainment Zone Map amendment, the change makes the site cohesive as contemplated in the DNSP Focus Area and would not introduce new uses or environmental impacts.

The
remaining land use
analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which would
develop mixed

uses in accordance with
the
DNSP

with
in
the Focus

A
rea
previously evaluated by the
DNSP

EIR.

The proposed
Project

would include a
Zoning

A
mendment
which would designate the entire
Project

site under the
PD
Overlay
.

The PD Overlay w
ould
establish
specific use provisions, intensity and density, maximum floor area, and maximum height, along with other development standards that w
ould

be required as part of the future design review for the proposed
P
roject.

The PD
Overlay
also establishes
p
roject
-
specific Design Guidelines

prepared to
facilitate creating a blend of dense residential and commercial uses, plazas and promenades, and natural areas that w
ould

advance some of the key goals for the Downtown Napa Specific Plan Town Center Focus Area
.

The proposed
Project

would be required to comply with all land use regulations established by the PD

Overlay
,
as well as any General
Plan policies or actions regarding land use that

would result in
adverse effects to the environment if not
followed.

The proposed PD
Overlay
designation contains
site
-
specific regulations and development standards consistent with the DNSP, which provides a height limit of 75 feet for the entire property and densities that do not exceed the co m
bined density of
the existing DCC and DMU designations. The PD
Overlay
designation, entertainment zone
expansion
,

and Design Guidelines would not represent a substanti
al departure from the existing use
regulations and development
standards
in the DNSP
,

and they further implement the DNSP Focus
Area. The changes proposed would still be within the inter est

of development contemplated for the
DMU and DCC districts within
Downtown

I and II and applicable to the site as evaluated in the DNSP EIR.

T
he proposed
Project

would not result in any peculiar
land use planning
effects and would not
result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As
such, impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would have a less than significant impact.

Relevant DNSP EIR Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Land Use and Planning, t
he proposed Project would not result in new significant land use and planning

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would
not result in an increase in the severity of a previously

identified significant

land use and planning

impact.

There is no new information of substantial importance showing that significant land use and
planning

impacts described in the DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 2

Mineral Resources

Would the project:

Result in the loss of
availability of a
known mineral
resource that would
be of
value to the
region and the
residents of the
State?

No
i
mpact

None

Result in the loss of
availability of a
locally

important
mineral resource
recovery site
delineated on a local
general plan, specific
plan or other land
use plan?

No
i
mpact

None

Discussion

a, b)

Loss of Minerals Resources o
f Statewide or Local Importance

Would the project:

Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State
?

Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?

Summary of DNSP EIR Findings

T
he
DNSP

EIR identified no impacts related to mineral resources. According to the DNSP

EIR, t
he
DNSP
P
lanning
A
rea is located in a developed urban area that has no known existing mineral resources

and
is mapped by the California Department of Mines and Geology as MRZ -
1, an area
where adequate information indicates a low likelihood of significant mineral resources .

Therefore,
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implementation of the
DNSP

would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the S
tate and would not result in the loss of
availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan
,

or other land use plan. Implementation of the
DNSP

would have no impact on mineral
resources.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

is located within the
P
lanning
A
rea of the
DNSP

and therefore is mapped by the California Department of Mines and Geology as MRZ
-
1, which would classify the
Project

site as an area
where adequate information
indicates a low likelihood of significa
nt mineral resources
. There are also no known mineral recovery
sites within the
P
lanning
A
rea of the
DNSP
;
therefore
,

the development of the proposed
Project

would
not have an impact in this regard.

T
he proposed
Project

would not result in any peculiar
mineral
resource
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not
result in any impacts that would not be mitigated to a less than significant level.

Relevant
DNSP
EIR Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Mineral Resources
, t
he proposed Project would not result in new significant mineral resources

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not
result in an increase in the severity of a previously

identified significant

mineral resources

impact.

There is no new information of substantial importance showing that significant mineral resources

impacts described in the DNSP EIR could be substantially reduced by adopting new or

different
mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 3

Noise

Would the project:

Generation of a
substantial temporary
or permanent increase
in ambient noise levels
in the vicinity of the
project in excess of
standards established
in the local or noise
ordinance, or
applicable standards
of other agencies?

Less than
significant
impact
with
mitigation

incorporated

MM 4.I
-
1a,

MM 4.I
-
1b,

MM 4.I
-
1c

Generation of
excessive
groundborne vibration
or groundborne noise
levels?

Less than
significant
impact with
mitigation
incorporated

MM 4.I
-
3 c)

For a
project located
within the vicinity of a
private airstrip or an
airport land use plan
or, where such a plan
has not been adopted,
within two miles of a
public airport or public
use airport, would the
project expose people
residing or working in
the project

area to
excessive noise
levels?

No impact

None

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Discussion

Noise Levels in Excess of Adopted Standards

Would the project

R
esult in

Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in
excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

Summary of DNSP EIR Findings

The D
NSP

EIR

evaluated whether full buildout of the development under the DNSP could generate a temporary increase in ambient noise level in the City during construction periods.

The
DNSP

EIR
identified Mitigation Measures

MM 4.I
-
1a, MM 4.I
-
1b, and MM 4.I
-
1c

to reduce construction
-
related
noise impacts
.

These measures require implementation of best available noise control technologies (e.g., upgraded mufflers, acoustical shielding), restricted hours of operation for construction activities and equipment servicing,
use of quieter construction methods where feasible (e.g., hydraulic tools), installation of temporary sound barriers for high
-
noise activities such as pile driving, and posting of
on
-
site notices outlining noise control requirements
.

Additionally, the
DNSP

EIR provides the City with
authority to require adjustments to construction methods in response to noise complaints.

Impl
ementation of these measures
was
found to reduce construction
-
related

noise impacts to less
than significant levels.

T
he EIR
also
evaluated
whether
operational
noise

from both
stationary and mobile sources

would
result in a significant permanent increase in ambient noise levels .

Stationary
noise
sources, such as
mechanical ventilation

(HVAC) systems, were determined to be subject to compliance with the City’s General Plan policies and Municipal Code
N
oise
O
rdinance
.

The City of Napa Noise Ordinance
(Municipal Code Chapter 8.08) limits exterior noise levels from mechanical equipment to 50 dBA at nearby residential property lines during nighttime hours (9:00 p.m. to 7:00 a.m.) and estab
lishes
an
interior noise standard of 45 dBA.

These standards are intended to protect sensitive receptors from operational noise. Based on this regulatory framework, the DNSP

EIR concluded that stationary
operational noise would be less than significant with compliance. Mobile sources associated with increased traffic volumes were also analyzed. Although some roadways were projected to exceed 65 dBA Ldn, the
DNSP

EIR concluded that noise increases resulting from
the
Specific Plan buildout
would not exce
ed
the
3 dBA

threshold for a perceptible

change in
ambient

noise

and

would therefore
be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the DNSP EIR remains accurate with respect to the proposed P
roject, which
would be developed with mixed uses in accordance with the provisions of the DNSP and would occur within the area previously evaluated in the DNSP EIR.

The

proposed

P
roject would implement
Mitigation Measures 4.I
-
1a through 4.I
-
1c identified in the
DNSP

EIR to reduce construction
-
related
noise impacts. These measures require incorporation of noise control best practices, restricted construction hours,
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City’s authority to enforce compliance. Implementation of these measures would ensure that construction noise impacts remain less than significant.

During long
-
term operations, the
Project

would include mechanical
heating, ventilation, and air
conditioning
(
HVAC
)

systems typical of
a

mixed
-
use development
. These stationary sources would be
required to comply with
Napa Municipal Code Chapter 8.08, which
establishes performance
standards for mechanical equipment. Specifically, mechanical systems must not exceed 50 dBA L eq

at
the nearest residential property line during nighttime hours

(9
:00

p.m
. to
7:00

a.m.)

and interior noise
levels

must not exceed 45 dBA CNEL.

Based on the traffic study prepared for the Project,
o
perational
traffic generated by the
Project

would
generate
48 fewer average daily trips than the trips
generated
by the existing land uses
.

Therefore,
Project traffic would not

result in any
perceptible

increases in
ambient noise levels
and
would
clearly

not exceed the 3 dBA
increase
significance threshold.

As
such
, operational noise impacts from stationary and mobile sources would be less than significant, and no additional mitigation would be required.

The
refore, the proposed P
roject would not result in any peculiar
ambient noise level
environmental
effects related to noise, and no new mitigation measures are warranted.

I
mpacts associated with the
development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the
proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level
.

Groundborne Vibration

Would the project

result in
:

Generation of excessive
groundborne vibration or
groundborne noise levels?

Summary of DNSP EIR Findings

The

DNSP EIR

evaluated whether full buildout of the
Specific Plan

would
generate excessive
groundborne vibration or groundborne noise levels

and
concluded that impacts would
be less than
significant
with mitigation.

The EIR
identified

that conformance
with

General Plan policies related to
development, construction activities, and noise regulation would reduce construction
-
related
groundborne
vibration

impacts

to less than significant.

However,
the analysis
identified that

implementation

of the
DNSP

could result in the placement of

sensitive receptors
in proximity to

known

source of ongoing operational groundborne vibration
–
the
Napa Valley

Wine Train
rail line.

To address this
,
the EIR

includes
MM

4.I
-
3 ,

whic
h
requires residential
development

within 200 feet of the rail station
or

mainline track
to
undergo a detailed
site
-
specific
vibration analysis
conducted by a qualified acoustical consultant. Where
necessary, design
modifications such as vibration isolation techniques would be required to ensure compliance with applicable thresholds.

Implementation of this measure would
reduce potential

groundborne
vibration

impacts
to

less than significant

levels
.

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Proposed Project Analysis and Conclusions

The
refore, the

proposed
Project

would be
required to conform to all applicable General Plan policies and actions relating to City development, construction activities, and noise regulation
s, including
MM 4.I
-
1a, MM 4.I
-
1b, and MM 4.I
-
1c
, which
would reduce potential construction vibration impacts to less than sign ificant, similar to the findings of
the DNSP EIR.

The proposed
Project

includes a mixed
-
use development consisting of residential, retail, and hotel uses.

Therefore, the proposed
Project
would not be a source of on
going

groundborne vibration. In
addition, t
he
Project
site
is not located within 200 feet of the rail station

or mainline track
and

therefore,
MM

4.I
-
3 of the DNSP EIR
does not apply

and no design modifications would be
necessary
. The
Project

would not introduce new sensitive receptors within the
Federal Transit
Administration (
FTA
)

defined screening distance,
nor would it
introduce

any new
conditions that
would
result in significant vibration impact
s.

No new or more severe vibration impacts would occur, and no additional mitigation measures are
necessary.

As such, groundborne vibration impacts would be
consistent with the conclusions of the DNSP EIR and would remain less than significant.

Airport

or
Private Airstrip

Noise

Would the project

result in
:

F
or a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the pr
oject area to excessive noise levels?

Summary of DNSP EIR Findings

The
DNSP EIR determined that no impact would occur relating to airport or private airstrip noise as a result of the buildout of the DNSP. T
here are no airport land use plans, public or private airports ,

o
r

airstrips within
5 miles of the
P
lanning
A
rea
; as such, no impacts would occur.

Proposed Project Analysis and Conclusions

The analysis under the

DNSP EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the S
pecific
Plan

and within the
s
a
me
geographic
area evaluated in the
EIR
.

The
Project

site

is
not located within the vicinity of a private
airstrip. The

closest
airport

to the
Project

site is
the

Napa County Airport,
located approximately 5.41
miles
south

the
Project
site.

Therefore, implementation of the proposed
Project

would not expose
persons residing or working in the
Project

vicinit
y to noise levels from airport activity that would be in excess of normally acceptable standards for the proposed land use development, and no impact would occur.

As such,
potential vi
bration
impacts associated with the development of the proposed Project

would
be consistent with the analysis in the

DNSP EIR

and the proposed
Project

would not result in any
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impacts. Therefore, the proposed
Project

would not result in any peculiar
airport
-
related
effects and
would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

Relevant
DNSP
EIR Mitigation Measures

4.I
-
1a

Construction contractors for subsequent development projects within the Planning Area shall utilize the best available noise control
techniques (e.g., improved mufflers,
equipment redesign, use of intake silencers, ducts, engine enclosures, and acoustically
-
attenuating shields or shrouds, etc.) when within 400 feet of sensitive receptor locations. Additional techniques shall include, bu t not be limited to the
following noise control elements:

•

Non
residential

construction project activities (Monday through Friday) shall be limited to the hours of 7:00 a.m. to 7:00 p.m. with no startup of machines or equipment prior to 8 a.m. No delivery of materials nor equipment shall occur prior to 7:30 a.m. or after 5:00 p.
m. No cleaning of machines or equipment shall occur
after 6:00 p.m. No servicing of equipment shall occur past 6:45 p.m. Construction of weekends and holidays shall be limited to the hours of 8:00 a.m. to 4:00 p.m., unless a permit allows oth
erwise.

•

Impact tools (e.g., jack hammers, pavement breakers, and rock drills) used for construction shall be hydraulically or electrically powered wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools. However, wh
ere use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used; this muffler shall achieve lower noise levels from the exhaust by approximately 10 dBA. External jackets on the tools themselves shall be used where
feasible in order to achieve a reduction of 5 dBA.

Quieter procedures shall be used, such as drills rather than impact equipment, whenever
feasible.

•

All construction equipment shall not be placed adjacent to developed areas unless said equipment is provided with acoustical shielding.

•

Signs shall be posted at all construction site entrances to the property upon commencement of project construction, for the purposes of informing all contractors and subcontractors, their employees, agents, materialmen, and all other persons at the constru
ction site, of the basic requirements of Mitigation
Measures 4.1
-
a through 4.1
-
c.

M
M

4.I
-
1b

Should pile

driving be necessary for a proposed project, the project sponsor would require that the construction contractor limit pile driving activity to the least disturbing hours of the day. To further mitigate pile driving and/or other extreme noise -
generating con
struction impacts, a set of site
-
specific noise attenuation measures
shall be completed under the supervision of a qualified acoustical consultant. No extreme noise
-
generating activities shall be allowed on weekends and holidays.

Tec
hniques included may include but not be limited to the following:

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•

Erect temporary plywood noise barriers around the construction site,

•

Implement “quiet” pile

driving technology (such as pre
-
drilling of piles and the use
of more than one pile driver to shorten the total pile driving duration), where feasible, in consideration of geotechnical and structural requirements and conditions;

•

Use noise control blankets on building structures as buildings are erected to reduce noise emission from the site; Evaluate the feasibility of noise control at the receivers by temporarily improving the noise reduction capability of adjacent buildings; and

•

Monitor the effectiveness of noise attenuation measures by taking noise measurements.

MM 4.I
-
1c

The City shall condition approval of projects in the Planning Area near receptors sensitive to construction noise, such as residences and schools, such that, in the event of a justified complaint regarding construction noise, the City would have the abilit
y to require changes in the construction practices to address the noise complaints.

Conclusion

The
proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Noise, t
he proposed Project would not result in new
noise

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in an increase in the severity of a previously

identified significant

noise

impact.

There is no new information of substantial importance
showing that significant

noise

impacts described in the DNSP EIR could be substantially reduced by adopting new or

dif
ferent mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 4

Population and Housing

Would the project:

Induce substantial
unplanned population
growth in an area,
either directly (for
example, by
proposing new
homes and
businesses) or
indirectly (for
example, through
extension of roads or
other infrastructure)?

Less than
significant

impact

None

Displace substantial
numbers of existing
people or housing,
necessitating the
construction of
replacement housing
elsewhere?

Less than
significant

impact

None

Discussion

Growth Inducement

Would the project:

Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other
infrastructure)?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

would induce substantial unplanned population growth in an area, either directly or indirectly, and determined there would be a less than significant impact in this regard.

According to the
DNSP

EIR,
ABAG

projects that

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from 77,800 to 84,600 (an increase of approximately 8.7 percent), at the approximate buildout year for the
DNSP

(2035). It is assumed that some of this increase in population would occur in the City’s Downtown. More specifically, within the
DNSP
P
lanning
A
rea, the rezoning would accommodate an
additional 627 net new housing units, which would generate approximately 1,379 net new residents within the
P
lanning
A
rea. This figure is based on the assumption that each housing unit would generate approximately 2.2

residents. The rezoning would, therefore, induce growth within the P
lanning
A
rea. However, this growth would amount to less than
1 percent

of total
c
itywide
growth
anticipated in 2035 and is already expected given that the P
lanning
A
rea is the City’s Downtown,
where higher
-
density housing is encouraged by the General Plan.

Ne
w housing that would be
constructed under implementation of the
DNSP

would be consistent with
the General

Plan
,

which
aims to encourage higher
-
density mixed
-
use developments within Downtown
.

Thus, while the
DNSP

would introduce new population to the Downtown, the projected housing development would not be expected to result directly in subs
tantial unanticipated
population growth.

As such,
the impact

would
be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

The proposed
Project

would consist of a
mixed
-
use

development with residential, retail, and hotel uses. The proposed Project

c
ould be
expected to introduce
up to
201

new residents to the
P
lanning
A
rea

(transient or permanent)
, which i
s
less than but
consistent with

the anticipated growth level in the
DNSP
.
22 The DNSP anticipated
approximately
1 ,
37 9

new residents
within the DNSP Planning Area
.

The proposed
Project

would also
be consistent with the goals of the
G
eneral
P
lan to
introduce high
-
density mixed

uses to the
Downtown
area
.

T
he proposed
Project

would not result in any peculiar
population growth
effects and
would not result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As such, impacts associated with the development of the proposed Project

would be
consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any
impacts that would not be mitigated to a less than significant level.

Displacement of Persons or Housing

Would the project:

Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

Summary of DNSP EIR Findings

The
DNSP

EIR did not identify a significant impact related to the displacement of existing people or housing, necessitating the construction of replacement housing elsewhere.

According to the
DNSP

EIR, t
he
DNSP

proposed to establish housing in
the
P
lanning
A
rea

in three zoning districts:

D
MU
,
Downtown Neighborhood
, and
D
CC
.

S
ince areas appropriate for housing have already been
identified and planned for, the
DNSP

would not displace housing or people such that construction of

22 United States Census Bureau. 202
5 . Napa, California Quick Facts. Website:
https://www.census.gov/quickfacts/fact/table/napacitycalifornia/PST040223 . Accessed
March 21, 2025.

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replacement housing would be required elsewhere. Moreover, more units would be built than would be demolished.

B
ecause the
DNSP

proposes substantially more residential development than currently exists within the
P
lanning
A
rea or than could be displaced, none of the residents within the existing housing in the area would be expected to be permanently displaced by future redevelopment, since residents would likely be able to occupy new housing added to the area.

full buildout, the
DNSP

would add a net of
627 new housing units to the area.

As such
,

the
DNSP

EIR determined that
the implementation of the
DNSP

would not
result in the substantial displacement of residences of housing units, and

impacts

would therefore be considered less than significant
.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

The
Project

site currently contains
Kohl’s
department store

(recently closed)
, three restaurants, the Dwight Murray Plaza,

and
a shared parking
lot, while the Public Realm Parcel include
s

an existing City parking lot, the 9/11 Memorial Garden, and a pedestrian corridor
. Therefore,
the proposed
Proj
ect

would not require
the removal of
any
existing housing from the area. The proposed
Project

consists of a mixed
-
use development
containing residential, retail, and hotel uses and would therefore add new housing to the area.

T
he
proposed
Project

would not result in any peculiar
population displacement
effects and would not
result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As
such, impacts associated with the development of the proposed Project

would be consis
tent with the
analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be
mitigated to a less than significant level.

Relevant
DNSP
EIR Mitigation Measures

None.

Conclusion

The proposed Project is within the
scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to
Population and Housing, t
he proposed Project would not result in new significant population and housing

impacts that were not

evaluated in the DNSP EIR.

The proposed Project
would not result in an increase in the severity of a previously

identified significant

population and
housing

impact.

There is no new information of substantial importance showing that significant population and housing

impacts described in the DNSP EIR coul
d be substantially reduced by
adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
1 5

Public Services

Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significa nt environmental
impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

Fire protection?

Less than
significant impact

None

Police protection?

Less than
significant impact

None

Schools?

Less than
significant impact

None

Parks?

Less than
significant impact

None

Other public
facilities?

Less than
significant impact

None

Discussion

Fire Protection

Would the project:

Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, need
for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other perform
ance objectives for any of the public
services: Fire protection?

Summary of DNSP EIR Findings

The DNSP EIR evaluated whether development facilitated by the DNSP would result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities

or the

need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times
,

or other performance objectives for fire protection.

Development facilitated by the
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DNSP would increase demand for fire protection and result in an increased number of calls for service received in the
Downtown

area and regulatory oversight to serve the increased residential and employment population.

The City may require additional fire department staff to maintain response times and/or the construction or expansion of facilities in the DNSP area.

However, the increased demand for fire
protection services would be
gradual and incremental over the 20
-
year time
frame of the DNSP.

The
City would conduct review and determine if construction of new fire station becomes necessary over the course of implementing the DNSP
,

d
uring which time, the City would review individual projects and assess potential deficiencies.

Key to fire protection is capacity of water system to provide sufficient flow for firefighting purposes.

The DNSP EIR evaluated the City’s water distribution system.

As discussed in the Utilities and
Service Systems chapter of the DNSP EIR, the City continually identifies infrastructure improvement projects and funding to address
Downtown
’s water needs, including adequate water flow for
firefighting purposes.

The current system meets fire flow demand
,

but future buildout of the DNSP
would require approximat
ely 50 percent of the existing water pipes w
ould

require an upgrade.

The
DNSP EIR also considered General Plan policies that apply to future development and infrastructure improvements.

Policies CS
-

1.2 and 1.3 would ensure adequate public services through the City’s development review process.

Policy CS
-

1.4 requires that new development fund its fair share of construction for new or expanded public facilities.

Therefore, impacts were found to be less than
significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

Fire protection services
for the
Project

site
would be provided by
t
he Napa Fire Department

(NFD)
.

The nearest station to the
Project

site
is Fire
Station No. 1
,

which is

approximately

0. 28 mile southwest of the
Project

site.

As of 202
4 ,
NFD
operates out of five stations and has a
staffing ratio
of

one on duty fire fighter per
4,37
5 residents
.
23 Overall, NFD response time for all priority incidents was within 6 minutes, 24 seconds 90

percent

of
the time.
24 The proposed
Project

is consistent with the proposed development analyzed in the DNSP

EIR
,

and there is nothing peculiar about the proposed
Project

or the
Project

site that would result in
potential environmental effects not previously addressed in the DNSP

EIR related to staffing

response times.

According

to
the DNSP EIR,
the
existing water distribution system

will require upgrades to adequately
serve the buildout of the DNSP,
with approximately 50 percent of the existing water pipes requiring
upgrades
.

As a result, t
he proposed
Project

would be required to pay its fair share in water system

23 City of Napa. 2023. Napa Fire Department Annual Report. Website:
https://www.cityofnapa.org/DocumentCenter/View/
14000/2024
-
Annual
-
Report
-
PDF
. Accessed November 4, 2024.

24 City of Napa Fire Department

(NFD)
. 2023. Organizational and Operational Analysis. Website:
https://www.cityofnapa.org/DocumentCenter/View/10761/Napa -
Fire
-
Service
-
Analysis
. Accessed November 4, 2024.

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improvements
, to facilitate the required upgrades of the
Downtown water system
.

Furthermore, the
proposed
Project

would be required to adhere to all goals and policies outlined in

the General Plan
and
DNSP

that relate to infrastructure improvements and fire safety.

T
he proposed
Project

would not
result in any peculiar
fire protection
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the
development of the
proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the
proposed
Project

would not result in any impacts that would not be less than significant.

Police Protection

Would the project:

Result in substantial adverse physical impacts
associated with the
provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service

ratios, response
times or other performance objectives for any of the public services: Police protection?

Summary of DNSP EIR Findings

a
need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times
,

or other performance objectives for police protection.

Development facilitated by the
DNSP
w
ould increase demand for police protection and increase the number of calls for service received in
D
owntown as well as regulatory oversight to serve the increased residential and employment population.

The City may require additional police department staff to maintain response times and/or the construction or expansion of facilities in the DNSP area.

The increased demand for police protection
services would be gradual and incremental over the 20
-
year time
frame of the DNSP.

The City would
review individual projects and assess potential deficiencies.

Therefore, impacts to police services
were found to be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The Napa Police Department

(NPD)

is located

0.26 mile southwest of the
Project

site.

The NPD is organized in
to two main divisions: Operations and
Administration/Support Services.

The Operations Division is home to most of
the NPD’s

sworn
personnel and includes Patrol Officers, Detectives, Youth Services Bureau, Traffic Officers, and Homeless Outreach Services.

T
he Administration/Support Division is home to professional staff and includes
the

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Communications Center.

The NPD has
approximately 76 sworn personnel, and 71 professional
staff.
25 The proposed
Project

would add approximately 20
1 new residents to the area
,

which would increase
demand
for

police services.
26 However,
the proposed
Project

would be
consistent with the proposed
development analyzed in the
DNSP

EIR
,

and there is nothing peculiar about the proposed
Project

or
the
Project

site that would result in potential environmental effects not previously addressed in the DNSP

EIR

related to staffing, response times, or the need for additional police
facilities.

T
he
proposed
Project

would not result in any peculiar
police protection
effects and would not result in a
new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

As such,
impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR

and the proposed
Project

would not result in any significant impacts in this
regard.

Schools

Would the project:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause signific
ant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Schools?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

would result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities

need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, and determined there would be a less than significant impact
in this regard.

According to the
DNSP

EIR, p
rojects facilitated by the
DNSP

would increase the
numb
er of residential units and employees within Downtown, thereby potentially increasing student enrollment at local schools. The rezoning would accommodate an additional 627 net new housing units, which would

generate approximately 84 school
-
aged children at buildout. These new students
would be added to the district
-
wide enrollment incrementally over the entirety of the 20 -
year
time
frame of the
DNSP
.

Additionally, new students would be distributed among the schools both within and near Downtown, thereby reducing substantial enrollment impacts at any one school. A portion of new students would
also be expected to attend private schools in Downtown and other areas.

The
DNSP

EIR also states
that
,

p
ursuant to the Leroy F. Greene School Facilities Act of 1998, or SB 50
, applicants for individual

25 City of Napa. 2025.

About the Department. Website:
https://www.cityofnapa.org/323/Police
-
Department
. Accessed March
21, 2025.

26 United States Census Bureau. 202
5 . Napa, California Quick Facts. Website:
https://www.census.gov/quickfacts/fact/table/napacitycalifornia/PST040223 . Accessed
March 21, 2025

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development projects facilitated by the
DNSP

would be required to pay school impact fees
established to offset potential impacts from new development on school facilities.

Local jurisdictions
are precluded under
S
tate law (SB 50) from imposing school enrollment
-
related mitigation beyond the
school development fees. The collection of these fees, therefore, is considered under SB 50 to fully mitigate any potential effects associated with additional development that c ould result from
implementation of the

DNSP
. As such, the
DNSP

EIR determined that impacts on school facilities
would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR
.

The proposed
Project

would be served by the
Napa Valley Unified School District (NVUSD)
.

T
he

proposed
Project

could
add 78 housing units
and
an estimated 20
1 residents
—
including
10 students
27 ,
28 —
to the Downtown area, which is consistent
with the
growth

Project
ed

in the
DNSP
.

In accordance with SB 50, the proposed
Project

would also be
required to
pay school impact fees
to offset any potential effects
resulting from its development

in
accordance with Government Code Section
65996
.

T
he proposed
Project

would not result in any
peculiar
school
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

d, e)

Parks and Other Public Services

Would the project:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause signific
ant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Parks?

Other public services?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the
DNSP

would result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities

need for new or physically altered park facilities, the construction of which could cause significant environmental impacts, and determined there would be a less than significant impact in this regard.

At the time the document was published,
the City
had

approximately 11 acres of
parkland per 1,0
00 residents, which is just below the standard of 12 acres per 1,000 residents listed in the General Plan.

According to the
DNSP

EIR, d
evelopment under the
DNSP

was

estimated to

27 City of Napa. 2012. Downtown Napa Specific Plan Program Environmental Impact Report. March.

28 84

new

student
s (DNSP EIR)/627 new dwelling units (DNSP EIR)

= 0.13397;

0.13397 X 78 dwelling units in the proposed
p
roject

=
10 new students as a result of the proposed
p
roject
.

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generate approximately 1,379 new residents over the course of 20 years. Therefore, growth related to the
DNSP

would minimally reduce this ratio in 20 years to about 10.4 acres per 1,000 residents.

Although no new park facilities
were proposed in the
DNSP
, a
s stated in
Section 5.16 of this
Addendum, several new park facilities had been proposed by the City, unrelated
to

the
DNSP
.

The
DNSP

EIR
,

other parks and recreation areas currently planned for the P
lanning
A
rea, as well as
dedication of parkland/in

lieu
fees required of future residential development would reduce the increased

demand for parks

generated
by the buildout of the
DNSP
;

therefore
,

impacts resulting from
new
park facilities would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

wo
uld include a
mixed
-
use

development with residential, retail, and hotel uses.

The proposed
Project

would also include
improvements to pedestrian and bicycle corridors, such as the Brown Street Corridor , as well as
the

addition of a

new
pedestrian corridor as part of the Public Realm improvements , that would connect
Coombs Street to the existing
9/11 memorial
. Development of
these areas

as part of the proposed
Project

would be required to comply with all
S
tate, regional, and local laws and regulations, as well as all applicable General Plan policies related to the construction of public
facilities.

As me
ntioned in
Section 5.14, Population and Housing, the proposed
Project

would not result in a significant increase
in population compared to the existing and proposed population as it is consistent with the buildout Project
ions
of the
DNSP
.

T
he proposed
Project

would not result in any peculiar
park or other public
service
effects and would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

As such, impacts associated with the development of the proposed Proje
ct

would be consistent with the analysis in the
DNSP

EIR

and the proposed
Project

would not
result in any significant impacts in this regard.

Relevant
DNSP
EIR Mitigation Measures

None
.

Conclusion

The proposed Project is within the scope of the DNSP
development program evaluated in

the DNSP
EIR.

With regard to Public Services, t
he proposed Project would not result in new significant public
services

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in
an increase in the severity of a previously

identified significant

public services

impact.

There is no
new information of substantial importance showing that significant public services

impacts described
in the DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or
alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
1 6

Recreation

Would the project:

Would the project
increase the use of
existing
neighborhood and
regional parks or
other recreational
facilities such that
substantial physical
deterioration of the
facility would
occur
or be accelerated?

Less than
significant

impact

None

Does the project
include recreational
facilities or require
the construction or
expansion of
recreational
facilities, which
might have an
adverse physical
effect on the
environment?

Less than
significant

impact

None

Discussion

a, b)

Existing Neighborhood and Regional Parks and Recreational Facilities

Would the project:

increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or

Does the project:

include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?

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Summary of DNSP EIR Findings

The
DNSP

EIR

evaluated whether full buildout of the development contemplated in the DNSP

would
increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated

or require

construction
or expansion of recreational facilities, which might have an adverse physical effect on the environment
,

and

determined there to be a less than significant impact in this regard.

At the time the

DNSP EIR

was
published,
the City
had

approximately 11 acres of parkland per 1,000 residents, which is just below the standard of 12 acres per 1,000 residents listed in the General Plan. Development under the
DNSP

was

estimated to generate approximately 1,379 new residents over the course of 20 years. Therefore, growth related to the
DNSP

would minimally reduce this ratio in 20 years to about

10.4 acres per 1,000 residents.

Although no specific parks or recreational facilities are proposed by the DNSP
, other parks and open
space improvements
were

proposed or planned in Downtown

at the time the
DNSP

EIR was
published

that would serve residents of
DNSP
-
related developments. The most prominent of these
projects
was

the multi
-
purpose Oxbow Commons. This project
was

a planned flood protection bypass
channel funded by the federal government and local sales tax (Measure A) and managed by Napa County Flood Control and Water Conservati
on District that would also serve as a park when not
utilized for flood protection purposes. A series of trails would provide an alternative pedestrian/bicycle connection under Soscol Avenue from the Oxbow Commons area to First Street and Pearl Street in t
he
Downtown

core. In addition, the currently fenced
-
off China Point Park
would

be replaced by the
mouth of the bypass and a new park
would

be constructed at the southwest corner of Soscol Avenue and First Street called China Point Overlook.

Additionally, another park began construction in 2011 at the southwest corner of Third Street and Soscol Avenue (Riverfront Green)

which has since been completed

after the DNSP was
published
.

Another planned improvement
was

the riverfront trail, which would provide a north
–
south pedestrian
route along the Napa River and include additional recreation facilities. Other parks noted in the Specific Plan include the relocation of the Skate Park potentially to Solomon Park, the potential replacement of the surfac
e parking lot at the southwest corner of Main and Pearl streets with a 0.5
-
acre park following replacement of the parking spaces
,

and the expansion of the remainder of
Heritage Park to create a linear parkway along the top of the banks of Napa Creek in the block bounded by Pearl/Coombs/Clinton/Main streets.

A
lthough no specific parks are proposed by the
DNSP
, other parks and recreation areas planned for the Planning Area

by the City
, as well as
dedication of parkland/in

lieu fees required of future resident
ial development would reduce the
increased demand for parks generated by new residents living in Downtown. Additional residents
would also be anticipated to

utilize other parks in the immediate vicinity of the
P
lanning
A
rea,
including the 9.5
-
acre Fuller Park and the 12.7
-
acre Oxbow Preserve. Therefore,
the
DNSP

EIR
determined that
impacts regarding parks and recreation would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
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within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

includes a
mixed
-
use

development with residential, hotel, and retail uses. The proposed Project

could
be expected to
add
approximately
2 0
1 new residents to the City.
29 This is consistent with the
Project
ed growth
in the
DNSP
, and therefore new residents would be adequately served by existing or proposed recreational facilities

in the City

as discussed in the DNSP EIR
. The proposed
Project

would also include
improvements to pedestrian and bicycle corridors
, such as the Brown Street Corridor

as well as the
addition of a new pedestrian corridor as part of the Public Realm improvements, that would connect Coombs Street to the existing 9/11 memorial
.

Although the existing Dwight Murray Plaza
would

be
displaced, the
New Plaza

would
be relocated on the Project site with a
n enhanced

public area that
connects the pedestrian corridor at the Shops on First Street to the 911 memorial area .

Development
of

these

areas as part of

the proposed
Project

would be
required to comply with all
S
tate,
regional,
and local laws and regulations, as well as all applicable General Plan policies related to the construction of
public
facilities.

T
he proposed
Project

would not
result in any peculiar
displacement of
recreation
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

Relevant

DNSP EIR
Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Recreation, t
he proposed Project would not result in new significant recreation

impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not result in an
increase in the severity of a previously

identified significant

recreation

impact.

There is no new
information of substantial importance showing that significant recreation

impacts described in the
DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or
alternatives.

29 U
nited States

Census Bureau. 202
5 .

Napa, C
alifornia

Quick Facts. Website:
https://www.census.gov/quickfacts/fact/table/napacitycalifornia/PST040223 . Accessed
March 21, 2025
.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New Analysis
or
Verification?

Mitigation
Measures

4 .
1 7

Transportation

Would the project:

Conflict with a

program

plan,
ordinance or policy of
the circulation system,
including transit,
roadway, bicycle and
pedestrian facilities?

Significant and
unavoidable
impact

None

Would the project
conflict or be
inconsistent with
CEQA Guidelines
Section 15064.3,
subdivision (b)
?

Not

A
ddressed

None

c
)

Substantially increase
hazards due to a
geometric
design
feature (e.g., sharp
curves or dangerous
intersections) or
incompatible uses
(e.g., farm
equipment)?

Less than
significant

impact

None

d
)

Result in inadequate
emergency access?

Less than
significant

impact

None

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Discussion

a
)

Affect to Circulation System

Would the
project:

Conflict with a

program

plan, ordinance or policy of the circulation
system,
including transit, roadway, bicycle and pedestrian
facilities?

Summary of DNSP EIR Findings

The

DNSP EIR

evaluated the potential traffic conditions and the effects of the buildout of the DNSP

to
determine whether the City’s planned circulation system would be able to accommodate future traffic demands associated with buildout.

The
E
xisting
P
lus Project scenario was developed by adding the
net new trips generated by the buildout of the
DNSP

land use projections to
the
existing traffic
volume
.

Because the
DNSP

includes the conversion of the existing one
-
way segments of First Street,
Second Street, Third Street
,

and Fourth Street to two
-
way travel, the existing baseline traffic volumes
were first adjusted to reflect two
-
way circulation. It is assumed that the two
-
way reconfiguration would
not require any major modifications to study intersections, such as constru ction of new medians or
expansion of right
-
of
-
way for new turn pockets or travel lanes, apart from the Jefferson Street/First Street intersection, where a southbound left turn lane would need to be constructed.

A
ll study
intersections in the Existing
P
lus
Project scenario would continue to operate at acceptable levels of service, except the unsignalized intersection of SR
-
29 northbound off
-
ramp/First Street, which would
continue to operate at
Level of Service (
LOS
)

F for the AM and PM peak
-
hours. Although this
intersection already operates at LOS F under existing conditions, development under the DNSP

would add at least 50 peak
-
hour trips to the intersection, which
would
contribute to continuing
operational failure.

For the intersection to operate at an acce
ptable
LOS
, the intersection should be
signalized.

Because the intersection operates at LOS F and meets peak -
hour signal warrants under existing
conditions, it is considered an existing deficiency. While development under the DNSP

would not
cause the impact, it adds at least 50 peak
-
hour trips to the intersection and exacerbates the
unacceptable operation. The intersection would operate at acceptable LOS B or better if signalized; however, the City of Napa, as
L
ead
A
gency, could not implement this improvement without the approval of Caltrans. Further, the intersection is near the City’s intersection of California Boulevard
and First Streets, which is being considered for a roundabout. The operation of the two intersections would conflict, as stacking and queu
eing

could intrude into the opposing

intersections.

The DNSP EIR
implemented MM 4.L
-
1a, which requires the City to continue to work with Caltrans to install a traffic
signal at the intersection of SR
-
29 northbound off
-
ramp/First Street or identify other acceptable
alternatives to the signal.

However,
previous discussions with Caltrans indicate that this improvem ent
would be difficult to approve, as installation of a traffic signal would require a design exception due to the close spacing (approximately 350 feet) to the California Boulevard/First Street intersection to the east, which is unlikely to be granted.

For these reasons,

the DNSP EIR determined that the

implementation of the
DNSP

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SR
-
29 northbound
o
ff
-
ramp/First Street.

Subsequent to the DNSP adoption, the City improved this intersection with an unsignalized round
about

system.

Proposed Project Analysis and Conclusions

Roadway Access and Circulation

The analysis under the

DNSP EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the

DNSP EIR
.

According to the VMT and
Trip Generation
Assessment

prepared for the proposed
Project

by W
-
Trans, attached as Appendix
F
,
the proposed
Project

is expected to generate an average of 2,539 trips per day, including 138 trips during the AM

peak hour and
205

during the
PM

peak hour. Compared to conditions
with Kohl’s

and other
retail/restaurant uses to be
removed, the
proposed
Project

would be expected to generate

48 fewer
trips on a daily basis,
79 more trips during the morning peak
-
hour, and

17 more

trip
s

during the
evening peak
-
hou
r
.

As explained further in Appendix F,

to present a holistic trip generation
comparison
,

the
estimates
were developed
using
four broad land use types
,

as well as consistent
assumptions pertaining to the percentage of internally
-
captured trips. Note that for the proposed
P
roject
,

this approach leads to a less
-
detailed trip generation but allows a clearer
comparison when
considering the differences among scenarios for the entire DNSP area .
30 This means that the
share of
trips consumed by development in the DNSP would decrease with the proposed
P
roject as compared
to existing conditions. This is
attributed to
the net decrease in retail square footage resulting from the proposed P
roject’s demolition of
the former
Kohl’s and other retail uses on the
Project Site
.
31 Table 3
in the
VMT and Trip Generation Assessment

(Appendix F), provides a comparison
of trip generation
for different
stages of DNSP buildout
,

along with the addition of the proposed Project.

According to
the assessment, the

development of

proposed
Project
, combined with all built and entitled projects
under the DNSP thus far, would
constitute
29 percent of the total anticipated DNSP growth in daily trips.

The
refore, the

proposed
Project

would be consistent with the expected
LOS

increase in the
DNSP, and no major modifications to existing roads are proposed.

The construction of the proposed
Project

would not result in any road closures.

Therefore, the
proposed
Project

would not result in a significant number of new trips compared to existing uses and proposed
Project

traffic would not significantly impact roadways surrounding the site. Furthermore, pr
oposed

driveways would be constructed in accordance with all City standards.

Pedestrian Access and Circulation

Pedestrians
would

have a variety of routes to circulate through the
Project

site. This includes

the

Brown Street

Corridor

and
i
nterior
p
edestrian
c
orridors
,

as well as pathway connections t
o

Napa
Creek. The design
is intended to

foster linkages to and between public gathering places, parks and the Napa River for people to explore Downtown.

As part of the public realm improvements, the

30 W
-
Trans.
2025.

First Street Napa Phase II VMT and Trip
Generation Assessment
.

May 1.

31 The p
roposed
p
roject adds 30,000 square feet of new retail and demolishes 76,000 square feet of existing retail; the net decrease of 46,000 square feet, when combined with the 11,430 square feet of retail growth since adoption of the Downtown Napa
S
pecific Plan (
DNSP
)
, results in an overall decrease of 34,570 square feet within the DNSP .

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proposed
Project

would also include a pedestrian plaza that connects Main Street to Coombs Street and intersects with the Brown Street Corridor. The proposed Project

would also include a new
crosswalk on Main Street to facilitate pedestrian access from the east, which would use

Rectangular
Rapid Flashing Beacons

that flash

to alert drivers of a crossing.

Therefore,

the proposed Project
would have a less than significant impact with regard to pedestrian access and circulation.

Bicycle Access and Circulation

There
is a
northbound
Class II

Bike Route along Coom
bs Street
between First Street and Pearl
Street
. The DNSP also plans to install

Class
I Bike Route
s

along the Brown Street Corridor

and
Pearl
Street
.

There are no existing or proposed bicycle facilities along First Street (Coombs St reet

to Main
St
reet
) or along Main St
reet

(First St
reet

to Pearl St
reet
), but the
DNSP
include
s

a proposed
bike
/
ped
estrian

crossing of Main Street midblock between First St
reet

and Pearl St
reet

to connect the
existing Class I facility in the Oxbow Commons to the proposed Class I facility along the Brown Street Corridor.

Bicycle access to the
Project

site would be provided via Main Street and Coombs Street through pedestrian crossings. Circulation through the
Project

site would be provided

via

Class I
Bike
Routes

within the project site along the Brown Street Corridor and along Pearl Street connecting to Coombs St
reet
. Therefore, the proposed
Project

would not conflict with the City’s adopted plans and
policies as it relates to bicycle facilities.

Transit Facilities

The
Project site is not directly served by any transit services .

The closest bus stop to the Project site,
Third Street at Brown Street, is located approximately 0.17 mile to the south
.

Located

approximately

0.37 mile
east of the

Project site,

the Soscol Gateway Transit Center provides a connection between the City and the greater Bay Area.

Transit facilities would be accessed via existing
pedestrian facilities
along Brown Street,
First
Street, Main Street,
Third
Street, and Lawrence Street.

As such,
the

proposed Project would not impact existing
or future

transit facilities,
and

would
not interfere with
a

program
,

plan, ordinance
,

or policy

as it relates to
transit facilities.

Conclusion

In conclusion
, impacts associated with the development of the proposed Project

would be consistent
with the analysis in the

DNSP EIR
,

and the proposed
Project

would not result in any impacts that
would not be mitigated to a less than significant level. Therefore, the proposed Project

would not
result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

b
)

CEQA Guidelines Section 15064.3

Would the project:

Would the project
conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision (b)?

Summary of DNSP EIR Findings

This CEQA checklist question specifically addresses the new transportation metric of V
MT
, and
whether a land use project would exceed an applicable threshold of significance.

At the time the
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DNSP EIR was published, CEQA

Guidelines Section 15064.3

was not in effect; as such, the DNSP
EIR did not address consistency with this section.

Proposed Project Analysis and Conclusions

The proposed
Project

is located approximately

0.37 mile

from the
Soscol Gateway Transit Center
,

at
which
local and regional transit routes can be accessed
.

According to the

VMT and
Trip Generation
Assessment

(A
ppendix
F
),
r
esidential VMT was calculated to be 9.37 VMT per capita, while hotel employee VMT was calculated to be 16.70 VMT per
employee
.

The City’s adopted threshold of
significance for
residential and office projects states that
a
proposed project exceeding a level of 15
percent below existing regional VMT per capita may indicate a significant transportation impact

(

14. 70
VMT per capita for residential uses and 22.87 VMT per employee

for employees)
.
32 33

As such
,

VMT
impacts related to the
expected reside
nts and hotel employees

were

found to be less than significant
.

Thresholds for land use types other than residential, employment ,

or retail are determined on a case
-
by
-
case basis

and

typically
take

guidance from the
Technical Advisory

on Evaluating Transportation
Impacts in CEQA

(Technical Advisory)
.
34 Neither
the City
’s adopted VMT significance thresholds nor
the

T
echnical
Advisory
address how hotel and lodging type uses should be assessed. Over the five years since VMT became a mandatory component of transportation CEQA analyses, the most common approach to assessing hotel VMT has been to treat the land use similarly

to retail,
qualitatively analyzing the potential to increase total VMT at the regional level.

As such, the threshold
of significance
for hotel uses used in the
VMT
and Trip Generation Assessment

states that
a
net
increase in total VMT may indicate a significant transport ation impact
.

The assessment determined
that
the

addition of a new hotel in
Downtown

Napa would not directly increase the total amount of
lodging demand in the region.

of December 2024, the six
-
month moving average hotel occupancy
rate in the City was 65 percent
,
35 and based on an article in the North Bay Business Journal, hotel occupancy rates during the August 2024 peak season were approximately 71 percent in Napa County as a whole
.
36 These occupancy rates indicate that there is not an untapped demand such that adding new lodging would by itself generate new vehicular travel to the area.

Additionally, the proposed
Project proposes to further enhance pedestrian circulation by adding a new crosswalk on Main Street and renovating the Brown Street
C
orridor to provide enhanced pedestrian and streetscape amenities.

Th
e existing and
expanded

availability of non
-
auto travel
facilities in the
Project

vicinity and
Downtown

would be expected to reduce the level of auto travel and VMT generated by hotel guests,

32 The
City’s
significance threshold for
residential uses
is 14.70
Vehicle Miles Traveled
(
VMT
)

per capita, which is 1
5 percent below the countywide average of

17.30 VMT per capita.

33 The
City’s
significance threshold for
e
mployee

VMT
is

22.87 VMT per employee, which is 15 percent
below the
countywide average of 26.90 VMT per employee.

34 State of California.
2018.

Technical Advisory

on Evaluating Transportation Impacts in CEQA
. April. Website:
https://lci.ca.gov/docs/20180416
-
743_Technical_Advisory_4.16.18.pdf
. Accessed
April 24, 2025.

35 City of Napa.
2025.

Economic Development Dashboard. Website:
https://www.cityofnapa.org/1172/Economic
-
Development
-
Dashboard
. A
ccessed March 24, 2025

36 Cheryl Sarfaty. North Bay Business Journal. 2024. Visit Napa Valley Reports

Record Tourism Spending Last Year.

Website:
https://www.northbaybusinessjournal.com/article/industrynews/visit -
napa
-
valley
-
spending
-
tourism/#:~:text=Hotel%20occupancy%20in%20Napa%20County,up%204.8%25%20from%20August%202023 .

A
ccessed March 24, 2025

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particularly the short

mid
-
length
trips
that hotel guests often make during the day
. As such
,

VMT
impacts related to the addition of

the proposed hotel would be less than significant.

The City’s adopted threshold of significance for
retail projects states that
a

net increase in total VMT
may indicate a significant transportation impact
.

VMT associated with the proposed
Project
’s retail
uses was assessed in consideration
of
guidance set forth in the
Technical Advisory
.
37 Because the
proposed retail uses are less than 50,000 square feet and ,

more importantly, would be oriented
toward
Downtown

Napa visitors, employees, and lodging residents, such uses were
considered

local
-
serving and presumed to have a less

than

significant VMT impact.

As shown in

the
VMT and Trip
Generation Assessment
,
the proposed
Project

would

not
reach or exceed
the established significance
thresholds for residential
, hotel, or retail uses.

As such
,

VMT impacts
would
be
less than significant.

c
)

Roadway Safety Hazards

Would the project:

Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

Summary of DNSP EIR Findings

The

DNSP EIR

d
etermined that the buildout of the DNSP would not result in significant impacts related to roadway safety hazards resulting from geometric design features or incompatible uses.

Implementation of the
DNSP

would facilitate development throughout the
DNSP

area. The locations
and/or specific design elements of these developments
were

not know
n when the document was
published
. Therefore, it
was

beyond the scope of
the

DNSP EIR

to determine
whether

the
proposed
project

would adversely affect traffic

safety. However, considering that each individual development would be required to be consistent with appropriate regulations and design standards in effect at the time
,

the DNSP

would cause a less

than s
ignificant impact on safety for motor vehicles, bicycles, and pedestrians.

The DNSP does include modifications to
the roadway network in the
P
lanning
A
rea by
converting existing one
-
way couplets to two
-
way traffic
. According to the DNSP EIR, t
he ultimate
implementation of the two
-
way street conversion would require a detailed engineering and traffic operations assessment, including
,

but not limited to, an evaluation of the needed improvements to intersection geometry, striping, signage and traffic control a t the existing signalized and unsignalized
intersections along the streets recommended for two
-
way conversion.

Implementation of the policy
provisions to maintain roadways and improve traffic flow in the DNSP, specifically Policies TR
-

1.2 through TR
-

1.7 , in conjunction with enforcement of modern design standards in the construction of new roadway facilities, would ensure that construction or conversion of roadway facilities associated with the
DNSP

would not result in unacceptable safety conflicts. Therefor e,
the DNSP
EIR concluded
that
impacts
would be less

than significant
.

37 State of California. 2018.

Technical Advisory

on Evaluating Transportation Impacts in CEQA
. April. Website:
https://lci.ca.gov/docs/20180416
-
743_Technical_Advisory_4.16.18.pdf
. Accessed April 24, 2025.

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Proposed Project Analysis and Conclusions

The analysis under the

DNSP EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the

DNSP EIR
.

The proposed
Project

would include a new
Main Street
pedestrian c
rossing as part of its public realm improvements, to provide safe connectivity between on
-
site pedestrian areas and the Napa Creek and Oxbow Commons pedestrian pathways to the east of the
Project

site, which would be constructed to City standards.

The proposed p
roject
would be required to be developed consistent with the City of Napa Municipal Code and City of Napa Standard Specifications and Standard Plans

with respect to roadway safety
.

As such, impacts
associated with the development of the proposed
Project

would be consistent with the analysis in the

DNSP EIR
,

and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar
road safety
hazard
effects and would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

d
)

Emergency Access

Would the project:

Result in inadequate emergency access?

Summary of DNSP EIR Findings

The

DNSP EIR

states that the implementation of

the

DNSP

is not anticipated to result in inadequate
emergency access.

Implementation of the
DNSP

would convert the one
-
way couplets in Downtown to
two
-
way traffic, but this circulation modification would not adversely affect travel times of emergency vehicles. The City’s Fire Code and Subdivision regulations contain detailed standards and mitigation requirements relating to dead
-
end streets and emergency vehicle access. The adequacy of emergency vehicle access w
ould

be eva
luated for each individual development in the
DNSP

area.

Considering that each individual development is expected to be consistent with the City’s Fire Code, Subdivision
,

and other regulations in effect at the time, the
DNSP

would cause a less

than significant
impact on emergency access.

Proposed Project Analysis and Conclusions

The analysis under the

DNSP EIR

remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the

DNSP EIR
.

The proposed
Project

would include adequate
emergency vehicle access to the
Project

site, including adequate emergency vehicle turnaround
areas. Emergency vehicles would be able to access the
Project

site from the north, west, and south
directly from the adjacent stre
ets including Coombs Street, Pearl Street, and First Street. Emergency access from the east would be provided
via Main Street through the Main Street
drop
-
off
/loading loop.

Adequate turnaround distance would be provided for emergency vehicles through a turnaround area in a portion of the Brown Street
C
orridor adjacent to the drop off/loading loop
. All project driveways
and access areas would be consistent with NFD standards.

As such, impacts associated with the
development of the proposed
Project

would be c
onsistent with the analysis in the

DNSP EIR
,
and the
proposed
Project

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level. Therefore, the proposed
Project

would not result in any peculiar
emergency access
effects and
would not result in a new or more severe adverse impact that was not previously identified in the

DNSP EIR
.

Relevant
DNSP
EIR Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Transportation, t
he proposed Project would not result in new significant transportation
impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not
result in an increase in the severity of a previously

identified significant

transportation

impact.

There is
no new information of substantial importance showing that significant transportation
impacts
described in the DNSP EIR c
ould be substantially reduced by adopting new or

different mitigation
measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .
1 8

Utilities and Service Systems

Would the project:

a
)

Require or result in
the
relocation or

construction of new
or
expanded

water
,

wastewater treatment
or
stormwater

drainage, electric
power, natural gas, or
telecommunications

facilities, the
construction
or
relocation

of which
could cause
significant
environmental effects?

Less than
significant

impact

None

b
)

Have sufficient water
supplies available to
serve the project
and
reasonably
foreseeable future
development during
normal, dry and
multiple dry years
?

Less than
significant
impact

None

c
)

Result in a
determination by the
wastewater treatment
provider which serves
or may serve the
project that it has
adequate capacity to
serve the project’s
projected demand in
addition to the
Less than
significant
impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

provider’s existing
commitments?

d
)

Generate solid waste
in excess of State or
local standards, or in
excess of the capacity
of local infrastructure,
or otherwise impair
the attainment of solid
waste reduction
goals?

Less than
significant
impact

None

e
)

Comply with federal,
State, and local
management and
reduction

statutes and
regulations related to
solid waste?

Less than
significant
impact

None

Discussion

Water, Wastewater, and Stormwater Facilities

Would the project:

Require or
result in the relocation or construction of new or
expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental eff
ects?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP area

would require or result in the relocation or construction of new or expanded water, wastewater treatment
,

or stormwater drainage

facilities
, the construction or relocation of which could cause
significant environmental
effects
, and

determined there to be a less than significant impact in this regard.

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Water and Wastewater Treatment

The DNSP EIR determined that the buildout of the DNSP would exceed the capacity of the existing wastewater system
operated by
NapaSan
. The DNSP EIR found that the

NapaSan

collection system
has adequate dry
-
weather capacity to support the level of growth anticipated by the City’s General Plan but has inadequate capacity to accommodate existing wet -
weather peak flows caused by high
infiltration and inflow in many areas of th
e City, including the Downtown area.

Any new wastewater
facilities would be required to comply with all federal, State, and local laws and regulations, as well as all applicable policies and actions related to wastewater facilities in the General Plan, the refore the
DNSP EIR determined that impacts on new development of wastewater facilities would be less than significant.

Stormwater Drainage

The DNSP EIR determined that the DNSP would include sustainable measures, which would encourage infrastructure improvements to reduce stormwater runoff and water use.

Electricity, Natural Gas, and Telecommunications

The DNSP EIR found that PG&E is the main energy utility provider for the City and County and that the residential sector was the largest user of electricity in the County in 2003, with commercial use being the second largest. Downtown Napa is served by und erground, three
-
phase primary electric
lines.

The DNSP EIR found that there are no natural gas production wells in the County and that natural gas use has been decreasing.

The DNSP EIR found that Comcast and AT&T are the main providers of cable, phone, and internet services to the City. The DNSP EIR identified that neither provider expects continued growth within the DNSP area to exceed their system’s existing capacity.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would connect to
existing stormwater and wastewater facilities on the
Project

site, and would be served by existing
electric power, natural gas, or telecommunications

facilities.

Although implementation of
the DNSP

could potentially
exceed the cap
acity of the existing wastewater system
operated by the

NapaSan
,
development would be reviewed by the City on a project
-
by
-
project basis to ensure adequate
w
as
te
water facilities

are available.

As such, impacts associated with the development of the proposed Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not
result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar
water, w
astewater treatment
,

stormwater
or other
facility

effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

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Water Supply

Would the project:

Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated in the DNSP

would
h
ave sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry
,

and multiple dry years and determined there to be a less than significant impact in this regard.

The DNSP EIR determined that the
City would have adequate water
supplies to meet demand

during normal, dry
,

and multiple dry years

with the

implementation of long
-
term water conservation BMPs
.

NapaSan also proposed new additions to recycled water systems to reduce City demand. The DNSP EIR noted, however, that 50 percent of existing water pipes in the Downtown demand and distribution system would require upgrades because of the buildout of the DNSP. All new development in the DNSP would be required to comply with all applicable General Plan policies related to infrastructure improvements and would be required to pay its fair share of water system improvements. As such, the DNSP EIR determined a less than significant impact would
occur related to water supply.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would connect to
existing water supply infrastructure on the
Project

site and would be required under the DNSP to pay
its fair share of water system improvements. This, coupled with its compliance to all General Plan policies and actions related t
o water use, would reduce the proposed
Project’
s impacts on water
supply to less than significant levels.

As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar
water supply
effects and would not result in a
new or more severe adverse impact that was not previously identified in the DNSP

EIR.

Wastewater Treatment Capacity

Would the project:

Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the DNSP

would result in a determination by the wastewater treatment provider which serves or may serve the DNSP

that it has adequate capacity to serve the
DNSP
’s projected demand in addition to the
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provider’s existing commitments and determined there would be a less than significant impact in this regard.

The DNSP EIR determined that d
evelopment facilitated by the
DNSP

may require investment
in new or upgraded sanitary sewer infrastructure. The
NapaSan

collection system has adequate dry
-
weather capacity to support the level of growth anticipated by the City’s General Plan but has inadequate capacity to accommodate existing wet
-
weather peak flows caused by high infiltration and
inflow in many areas of
the City, including the Downtown area.

Development facilitated by the
DNSP
would be subject to
all applicable
General Plan policies regarding the provision of public facilities .

New development facilitated by the
DNSP

would be required to pay its fair share of wastewater
system improvements as required by General Plan policies.

The DNSP EIR determined that
d
eveloper
-
driven fees and payments
,

in combination with other existing and proposed sources of funding for water system improvements
,

would reduce potent
ial impacts regarding wastewater
collection and distribution to a less than significant level.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

would connect to
existing sanitary sewer lines on the
Project

site and would be required under the DNSP to pay its fair share of wastewater system improvements. This, coupled with its compliance with all General Plan policies and actions related to wastewater management, would reduce the proposed Project’
s
impacts on wastewater sy
stems to less than significant levels.

As such, impacts associated with the
development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and the
proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level. Therefore, the proposed
Project

would not result in any peculiar
wastewater treatment
effects
and would not result in a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

Solid Waste Reduction Goals Consistency

Would the project:

Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

Summary of DNSP EIR Findings

The
DNSP

EIR evaluated whether full buildout of the development contemplated under the DNSP
would generate solid waste in excess of State or local standards, or in excess of local infrastructure, or otherwise impair the attainment of solid waste reduction goals and determined this impact
would
be less than significant.

The DNSP EIR determined that p
opulation and commercial growth in
the
DNSP area

would generate increased amounts of solid waste

over the 20
-
year buildout time frame of
the DNSP
. Although the i
ncreased residential population and business activities resulting from implementation of the
DNSP

would incrementally increase the total waste generated by the City, the increasing rate of diversion through recycling, composting, and other methods would result in a decreasing share of total waste that would be disposed

in landfills serving the City.

The DNSP EIR
also noted that p
rojects facilitated by the
DNSP

would generate construction

and
demolition
(C&D)
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debris. Most projects would be required to comply with the City’s C&D

debris ordinance (
Municipal
Code
Chapter 15.32) requiring diversion of 50 percent of such waste from landfill disposal. Given this fact and given the long
-
term capacity available at Keller Canyon Landfill through 2030, the DNSP

would not result in landfills exceeding permitted capacities.

As such, the DNSP EIR determined
impacts related to the generation of solid waste would be less than significant.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

includes
a mixed
-
use
development consisting

of
residential, retail, and hotel uses.

The proposed
Project

is consistent with
the buildout projections of the

DNSP
EIR and thus would not generate solid waste in excess of State or local
s
tandards or i
n excess of local infrastructure. Furthermore, the proposed Project

would
adhere to applicable General Plan policies related to solid waste and waste diversion. As such, impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would have less than significant impacts.

Therefore, the proposed
Project

would not result in any peculiar
solid waste capacity
effects and
would not result in a new or more severe adverse impact tha t was not previously identified in the
DNSP

EIR.

Solid Waste Regulations Consistency

Would the project:

Comply with federal, State, and local management and reduction statutes and regulations related to solid waste?

Summary of DNSP EIR Findings

The
DNSP
EIR evaluated whether full buildout of the development contemplated under the DNSP
would comply with federal, State, and local management and reduction statutes and regulations to solid waste

and determined there to be a less than significant impact in this regard .

Chapter

15.32 of
the City’s Municipal Code mandates a 50 percent diversion rate for solid waste from landfill disposal.

According to the DNSP EIR, i
mplementation of the
DNSP

would not impede the ability of the City to
meet waste diversion requirements or cause the City to violate other applicable federal, St
ate, and
local statutes and regulations related to solid waste.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with
mixed
uses in accordance with the provisions of
the DNSP

and would occur
within

the

area previously evaluated in the
DNSP

EIR. The proposed
Project

consists of the
construction of a
mixed
-
use development containing residential, hotel, and retail uses

on an existing
developed site. The
Project

applicant would be required to comply with the requirements of federal, State, and local statutes and

regulations related to solid waste. The proposed
Project

would be
required to adhere to all State and local waste diversion requirements. As such, impacts associated with the development of the proposed
Project

within

the

DNSP
P
lanning

A
rea would be consistent
with the analysis in the
DNSP

EIR and the proposed
Project

would have less than significant impacts.

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Therefore, the proposed
Project

would not result in any peculiar
solid waste management or
reduction
effects and would not result in a new or more severe adverse impact that was not previously identified in the
DNSP

EIR.

Relevant

DNSP EIR
Mitigation Measures

None.

Conclusion

The proposed Project is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Utilities and
Service Systems, t
he proposed Project would not result in new
significant
utility
impacts that were not

evaluated in the DNSP EIR.

The proposed Project would not
result in an increase in the severity of a previously

identified significant

utility

impact
s
.

There is no
new information of substantial importance showing that significant utility
impacts described in the
DNSP EIR could be substantially reduced by adopting new or

different mitigation measures or
alternatives
.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .19

Wildfire

If located in or near State Responsibility Areas or lands classified as V
ery
H
igh
F
ire
H
azard
S
everity
Z
ones, would the project:

Substantially impair an
adopted emergency
response plan or
emergency evacuation
plan?

No impact

None

Due to
slope, prevailing
winds, and other
factors, exacerbate
wildfire risks, and
thereby expose project
occupants to, pollutant
concentrations from a
wildfire or the
uncontrolled spread of
a wildfire?

No impact

None

Require the installation
or maintenance of
associated
infrastructure (such as
roads, fuel breaks,
emergency water
sources, power lines or
other utilities) that may
exacerbate fire risk or
that may result in
temporary or ongoing
impacts to the
environment?

No impact

None

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New or
More Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

Expose people or
structures to significant
risks, including
downslope or
downstream flooding or
landslides, as a result
of runoff, post
-
fire slope
instability, or drainage
changes?

No impact

None

Discussion

Emergency Response/Evacuation Plan Consistency

Would the project:

If located in or near
S
tate
R
esponsibility
A
reas or lands classified as
V
ery
H
igh
F
ire
H
azard
S
everity
Z
ones, substantially impair an
adopted emergency response plan or emergency evacuation plan?

Summary of DNSP EIR
Findings

The
DNSP

EIR

determined
that no impact would occur related to
emergency response plan or
emergency evacuation plan

consistency
due to

the implementation of the
DNSP
. The
P
lanning
A
rea is
outside of any

State Responsibility Areas or lands classified as
FHSZs
, and
the buildout of
the
DNSP

would comply with all emergency vehicle access requirements as a condition of development
.

Overall, the
DNSP

would not impede an established emergency access route or interfere with emergency response requirements and would
not result in permanent road closures. Therefore, the
DNSP

would have no
impact

emergency response or evacuation plans.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

is within the
DNSP

P
lanning
A
rea and therefore is not within a
State Responsibility Area or land classified

as an
FHSZ
.

Construction of the proposed
Project

would not result in any
permanent
road closures and
adequate
fire access would be provided on the
Project

site.

T
he proposed
Project

would not result in any
peculiar
em
ergency response and evacuation
effects and would not result in a new or more severe
adverse impact that was not previously identified in the DNSP

EIR.

As such, impacts associated with
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the development of the proposed
Project

would be consistent with the analysis in the
DNSP

EIR and
the proposed
Project

would not result in any impacts that would not be mitigated to a less than significant level.

b
)

Expose Project Occupants to Pollutant Concentrations from Wildfire

Would the project:

If located in or near
S
tate
R
esponsibility
A
reas or lands classified as

Very High Fire Hazard Severity Zone
s, due to slope, prevailing
winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

Summary of DNSP EIR Findings

The
DNSP

EIR determined
that no impact would occur related to
emergency response plan or
emergency evacuation plan

consistency due to the implementation of the
DNSP
. The
P
lanning
A
rea is
outside of any

State Responsibility Areas or lands classified as
FHSZs
;

as such
,

the
DNSP

EIR
determined that no impacts would occur.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

is within the
DNSP

P
lanning
A
rea and therefore is not within a
State Responsibility Area or land classified

as an FHSZ.

T
he proposed
Project

would not result in any peculiar
wildfire pollutant
effects and would not result in
a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As such,
impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be
mitigated to a less than s
ignificant level.

c
)

Infrastructure
t
hat Exacerbates Fire Risk

Would the project:

If located in or near
S
tate
R
esponsibility
A
reas or lands classified as
Very High Fire Hazard Severity Zon
es, require the installation or
maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environme
nt?

Summary of DNSP EIR Findings

The
DNSP

EIR determined
that no impact would occur related to
emergency response plan or
emergency evacuation plan

consistency due to the implementation of the
DNSP
. The
P
lanning
A
rea is
outside of any

State Responsibility Areas or lands classified as
FHSZs
.

All construction that might be
associated with
the
DNSP

would be required to adhere to Building Fire Codes that are designed to minimize the potential for uncontrolled fires
;

as such
,

the
DNSP

EIR determined that no impacts
would occur.

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Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

is within the
DNSP

P
lanning
A
rea and therefore is not within a
State Responsibility Area or land classified

as an FHSZ.

T
he proposed
Project

would not result in any peculiar
exacerbated fire
effects and would not result in
a new or more severe adverse impact that was not previously identified in the DNSP

EIR.

As such,
impacts associated with the development of the proposed Project

would be consistent with the
analysis in the
DNSP

EIR and the proposed
Project

would not result in any impacts that would not be
mitigated to a less than significant level.

d
)

Flooding and Landslide Hazards Due To Post
-
fire Slope Instability/Drainage
Changes

Would the project:

If located in or near
S
tate
R
esponsibility
A
reas or lands classified as
Very High Fire Hazard Severity Zones
,

expose people or structures
to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post
-
fire slope instability, or
drainage changes?

Summary of DNSP EIR Findings

The
DNSP

EIR determined
that no impact would occur related to
emergency response plan or
emergency evacuation plan

consistency due to the implementation of the
DNSP
. The
P
lanning
A
rea is
outside of any

State Responsibility Areas or lands classified as
FHSZs
;

as such
,

the
DNSP

EIR
determined that no impacts would occur.

Proposed Project Analysis and Conclusions

The analysis under the
DNSP

EIR remains accurate with respect to the proposed
Project
, which
would be developed with mixed uses in accordance with the provisions of the DNSP

and would occur
within the area previously evaluated in the
DNSP

EIR.

The proposed
Project

is within the
DNSP

P
lanning
A
rea, and therefore is not within a
State Responsibility Area or land classified

as an FHSZ.

T
he proposed
Project

would not result in any peculiar
post
-
fire flooding or landslide
effects and would
not result in a new or more severe adverse impact

that was not previously identified in the
DNSP

EIR.

As such, impacts associated with the development of the proposed Project

would be consistent with
the analysis in the
DNSP

EIR
,

and the proposed
Project

would not result in any impacts that would
not be mitigated to a less than significant level.

Relevant

DNSP EIR
Mitigation Measures

None
.

Conclusion

The proposed
Project

is within the scope of the DNSP development program evaluated in

the DNSP
EIR.

With regard to Wildfire, t
he proposed
Project

would not result in new significant
Wildfire

impacts
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that were not

evaluated in the DNSP EIR.

The proposed
Project

would not result in an increase in the
severity of a previously

identified significant

Wildfire

impact.

There is no new information of
substantial importance showing that significant
Wildfire

impacts described in the DNSP EIR could be
substantially reduced by adopting new or

different mitigation measures or alternatives.

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

4 .20

Mandatory Findings of Significance

Does the project have
the potential to
substantially

degrade
the quality of the
environment,
substantially reduce
the habitat of a fish or
wildlife species, cause
a fish or wildlife
population to drop
below self
-
sustaining
levels, threaten to
eliminate a plant or
animal community,

substantially

reduce
the number or restrict
the range of a rare or
endangered plant or
animal, or eliminate
important examples of
the major periods of
California history or
prehistory?

Not Addressed

MM 4.C
-
1a,
MM 4.C
-
1b,
MM 4.C
-
1c
,
MM 4.D
-
1,

MM 4.D
-
2a,
MM 4.D
-
2b,
MM 4.D
-
4,

MM 4.D
-
3 b)

Does the project have
impacts that are
individually limited, but
cumulatively
considerable?

(“Cumulatively
considerable” means
that the incremental
effects of a project are
considerable when
viewed in connection
Not Addressed

MM 4.B
-
1,
MM 4.B
-
2,
MM 4.B
-
3,
MM 4.B
-
4,
MM 4.B
-
5,
MM 4.B
-
6 ,
MM 4.C
-
1a,
MM 4.C
-
1b,
MM 4.C
-
1c,
MM 4.D
-
1,
MM 4.D
-
2a,
MM

4.D
-
2b,
ATTACHMENT 23

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ADDENDUM

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Environmental Issues

DNSP EIR

Determination

Do the
Proposed
Changes
Involve New
or More
Severe
Impacts?

New
Circumstances
Involving New
or More Severe
Impacts?

New
Information
Requiring
New
Analysis or
Verification?

Mitigation
Measures

with the effects of past
projects, the effects of
other current projects,
and the effects of
probable future
projects)?

MM 4.D
-
4,
MM 4.D
-
3,
MM 4.B
-
5,
MM 4.I
-
1a,
MM 4.I
-
1b,
MM 4.I
-
1c

Does the project have
environmental effects,
which will cause
substantial adverse
effects on human
beings, either directly
or indirectly?

Not Addressed

MM 4.B
-
1,
MM 4.B
-
2,
MM 4.B
-
3,
MM 4.B
-
4,
MM 4.B
-
5,
MM 4.B
-
6,
MM 4.C
-
1a,
MM 4.C
-
1b,
MM 4.C
-
1c,
MM 4.D
-
1,
MM 4.D
-
2a,
MM 4.D
-
2b,
MM 4.D
-
4,
MM 4.D
-
3,
MM 4.I
-
1a,
MM 4.I
-
1b,
MM 4.I
-
1c

Discussion

Potential Degradation to
Environment and Examples of California History or
Prehistory

Does the project:

Have the potential to
substantially
degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -
sustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a rare or
endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?

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As described in detail herein and
in
the attached appendices, project
-
level analysis determined that
no new or more severe impacts would occur as a result of the proposed Project
,
and no new
mitigation would be required beyond those applicable measures already identified in the DNSP EIR.

These impacts were already accounted for in the DNSP EIR and are therefore not a peculiar or more severe impact. All
Project
-
specific biological resources impacts were found to be less than significant with

implementation of
MM 4.B
-1
through
MM 4.B
-6.

The DNSP

EIR also determined that any
impacts related to
important
disruption of examples of the major periods of California history or prehistory

would be less than significant with implementation of
MM 4.D
-
1, MM 4.D
-
2a, MM 4.D
-
2b,

MM 4.D
-3
, and
MM 4.D
-4
.

The proposed
Project

would comply with all applicable biological

and
historical

resources mitigation measures and would therefore not degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self
-
sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal community , or
eliminate
important examples of the major periods of California history or prehistory .

The proposed
Project

is within the development assumptions analyzed by the DNSP EIR and therefore would not result in any new or more severe impacts. The conclusions of the DNSP EIR would remain unchanged. As such, the
M
itigation
M
easures included within this Addendum would
mitigate all potential
Project

impacts to a less than significant level or to a level consistent with the findings of the

DNSP EIR. Therefore, the proposed
Project

would not result in any peculiar effects
and would not result in a new or more severe adverse

impact that was not previously identified in the
DNSP EIR.

Cumulatively Considerable Impacts

Does

the project:

Have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

Potential cumulative impacts were thoroughly addressed in the DNSP EIR. As discussed in this Addendum
, the proposed
Project

would not result in any additional or more severe impacts than previously disclosed in the certified EIR. Accordingly, the proposed Project

does not require any
revisions to the cumulative analysis in the DNSP EIR.

T
he
DNSP

EIR identified significant and unavoidable cumulative impacts related to

transportation, air
quality, consistency with the Bay Area 2010 CAP, GHG emissions, and conflicts with applicable plans, policies
,
or regulations

adopted for the purpose of reducing GHG emissions
. According to the DNSP
EIR, these impacts would be mitigated through implementation of MM

4.B
-1
through MM

4.B
-6
and
MM

4.L
-
1a

through MM

4.L
-6
. MM

4.L
-
1a

through MM

4.L
-6
are not applicable to the proposed
Project

as they relate to the installation of a traffic signal

at the intersection of SR
-
29 northbound off
-
ramp/First Street

and
developments under the
DNSP

that would generate substantial multi
modal

trips
crossing at
-
grade railroad crossings
.

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the buildout of the DNSP even with mitigation, but implementation of the applicable measures listed above would reduce
Project
-
level impacts to less than significant levels.

The proposed
Project

would not result in any peculiar effects and would not result in any new or more severe impacts that were not previously identified in the DNSP EIR.

The proposed
Project

would
comply with all applicable mitigation measures required to implement the DNSP

to reduce impacts
related to development within the site to the greatest extent feasible , including MM

4.B
-
1 through MM

4.B
-
6 . All other cumulative impacts
and the proposed
Project
’s incremental contribution to such less
than significant

impacts
would be reduced to less than significant levels through compliance with mitigation measures identified by the DNSP EIR. As such, impacts associated with the development of the proposed
Project

would be consistent with the analysis in the DNSP EIR. The proposed Project

is consistent with the development assumptions in the DNSP EIR and therefore would not result in any peculiar
cumulative
effects and
would not result in a new or more severe adverse impact that was not previously identified in the DN
SP EIR.

Adverse Effects on Human Beings?

Does

the project:

Have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly?

As described in detail herein and
in
the attached appendices, the proposed
P
roject

would be
consistent with the proposed development assumptions contained within the DNSP EIR

and would
benefit the City by providing increased housing options . The preceding sections of this Addendum
discuss the various impacts that could have adverse effects on human beings, such as air quality, GHG emissions, hazardous materials, hydrology and water quality, and noise ,

compared to the
findings of the DNSP EIR. All impacts identified in this document have been determined consistent with or less severe than

the impacts identified in the DNSP EIR through the implementation of applicable mitigation measures
including
MM 4.B
-
1 through MM 4.B
-
6, MM 4.C
-
1a

through
MM 4.C
-
1c, MM 4.D
-
1 through MM 4.D
-
4, MM 4.I
-
1a through MM 4.I
-
1c
,
and incorporation of
P
roject

design
features
. As such, impacts associated with the development of the proposed P
roject

would be
consistent with the analysis in the DNSP EIR. Therefore, the proposed P
roject

would not result in any
peculiar effects
on human beings
and would not result in a new or more severe adverse impact that was not previously identified in the DNSP EIR.

Relevant DNSP EIR Mitigation Measures

Implement
MM 4.B
-
1, MM 4.B
-
2, MM 4.B
-
3, MM 4.B
-
4, MM 4.B
-
5, MM 4.B
-
6, MM 4.C
-
1a, MM 4.C
-
1b, MM 4.C
-
1c, MM 4.D
-
1, MM 4.D
-
2a, MM 4.D
-
2b, MM 4.D
-
3, MM 4.D
-
4, MM 4.I
-
1a, MM 4.I
-
1b, and
MM 4.I
-
1c.

Conclusion

With regard to Mandatory Findings of Significance, t
here is no new information of substantial
importance, change in the
proposed
P
roject
, or change in circumstances
in

which it w
ould

be
undertaken identifying new significant effects, nor is there a

substantial increase in the severity of
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previously identified impacts related to mandatory findings.

The proposed
P
roject

is within the scope
of the DNSP EIR, the DNSP EIR adequately describes the proposed P
roject

for purposes of CEQA
and the conclusions from the DNSP EIR remain unchanged when considering the adoption of the proposed
P
roject
.

ATTACHMENT 23
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Addendum

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5 -

Conclusions

Based on this

Initial Study/
Addendum
, the City
hereby makes the
following determinations regarding
the proposed
P
roject
:

•

As
explained in detail below, because the
P
roject

is
consistent with
the development density

established by
existing zoning, community plan, or general plan policies for which an

EIR was
certified
, the proposed
P
roject

would be eligible for
a more

limited environmental review
available under CEQA Guidelines
Section
15183.

Although both CEQA
Guidelines
Section
s

15168 and 15183 apply to the proposed
P
roject
,
the analysis above

focuses on Section 15168.

•

Based on the analyses and conclusions in
Section
4 of this Initial Study/Addendum, and

p
ursuant to Sections 15168(c) and 15162(a) of the CEQA Guidelines, the City has determined that
the proposed
P
roject

will not have any new significant environmental effects

that were not
identified and addressed in the DNSP EIR, or result in a substantial increase in the severity of any
previously identified effects, and the City is not aware of any new information of substantial importance within the meaning of CEQA Guidelines Section 15162(a)(3) .

Therefore
,
the City
hereby
determine
s

that no
additional environmental review is necessary and no
new
environmental document is required.

•

As explained in detail below, the proposed
P
roject

is exempt from further environmental review
because it is an “in
fill

development project” under Section 15332 of the CEQA Guidelines.

•

As explained in detail below,
the proposed
P
roject

is exempt from further environmental review
under the “common sense” exemption set forth in Section 15051(b)(3) of the CEQA Guidelines.

5.1 -

Section 15183 Exemption for
General Plan
Consistency

The
proposed
P
roject

is consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified .

Therefore, the
P
roject

is
eligible for the limited scope of environmental review available under Section 15183 of the CEQA Guidelines.

More specifically, t
he 2040 General Plan Update recognized and supported the land use designations, planning and implementation of the DNSP.

The
proposed
P
roject is consistent with the
policies included in the General Plan

for development in the DNSP
.

It is located within the DNSP
Focus Area and consistent with the DCC/DMU land use designations, which allows hospitality, hotels, residential and retail uses.

As such, the
proposed
P
roject
is consistent with the development density
established by existing zoning

and
general plan policies for which
the
2040 General Plan Update EIR
was certified

on
October 4, 2022
.

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The
2040 General Plan Update EIR recognized the impacts evaluated in the DNSP EIR and provided updated growth projections for the entire City of Napa through 2040.

For the reasons explained in this
Initial Study/
Addendum, the impacts from the
P
roject

are also within and less than the impacts
analyzed for the 2040 General Plan Update program.

As a result, if the City applied the more limited
scope of environmental review available under Section 15183, it would similarly conclude that the
proposed
P
roject

is within the scope of the 2040 General Plan Update EIR impact evaluation, the 2040 General Plan Update EIR adequately describes the proposed P
roject
’s impacts for purposes of
CEQA and that no further CEQA documentation is required.

As explained above, however, the City
elected to perform the more comprehensive environmental review described in Sections 15162(a) and 15168(c) of the CEQA Guidelines.

Accordingly, the City could also determine that no additional environmental review
is
required under
Section 15183 of the
CEQA Guidelines.

5.2 -

In
fill

Development Project, Class 32 Categorical
Exemption

The
prop
osed
P
roject
is
exempt from the provisions of CEQA requiring environmental review under Public Resources Code § 21084 because it is a project that falls within a
Categorical Exemption,
which
includes classes of projects that
have been determined by the State of California not to have a significant effect on the environment.

The
proposed
P
roject

is
exempt from CEQA under the Class 32
Exemption (CEQA Guideline §15332, In
fill

Development Projects) as in
fill

development meeting the
following conditions, as detailed below:

(a)

The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.

The
proposed
P
roject is consistent with the
land use designations and
policies included in the
General Plan.

It is located within the DNSP Focus Area and consistent with the DCC/DMU land use designations, which allows hospitality, hotels, residential and retail uses.

(b)

The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses.

The proposed
Project

site is on less than 5 acres and is wholly within the City limits, surrounded by commercial uses and designations in
Downtown
.

(c)

The project site has no value as habitat for endangered, rare or threatened species.

The site is a
fully developed
site.

No special
-
status plant species have potential to occur in the
P
roject

site and no sensitive plant communities exist on the
P
roject
site.

No Habitat Conservation Plan,
Natural Conservation Community Plan, or other approved local, regional, or State Habitat
Conservation Pl
an occurs on or in the area of the
P
roject

site. The
proposed P
roject
avoids
development impacting Napa Creek.

ATTACHMENT 23

CITY OF NAPA
—

FIRST STREET NAPA PHASE II PROJECT

INITIAL STUDY
/

ADDENDUM TO THE DNSP EIR

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(d)

Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.

As explained in
Sec
tion

4, the
proposed
P
roject would not have any new significant effects relating to traffic, noise, air quality, or water quality.

(e)

The site can be adequately served by all required utilities and public services.

The
Project

site can be adequately served via adjacent existing services.

The
Project

site has
electrical, water, sanitary sewer and other services and utilizes located in Downtown

within or
adjacent the site.

Pursuant to the CEQA Guidelines, the Class 32 Exemption applies so long as an “Exception” set forth
in Section 15300.2
does not disqualify the Exemption.

No such disqualifying exception applies to the
proposed
P
roject and therefore the
proposed
P
roject
is
categorically exempt from CEQA under the
Class 32 Exemption.

5.3 -

Common Sense

Exemption

Based on the analyses in this Initial Study/Addendum, t he
proposed
P
roject

is also
exempt
from
further environmental review
under CEQA Guideline § 15061(b)(3), the “common sense” exemption.

The common sense exemption exists to allow “obviously exempt” types of projects not listed in the categorical exemptions to avoid being required to “needlessly to comply with the requirement s of
CEQA.” Myers v. Board of Supervisors (1976) 58 CA3d.413, 425.

The City could determine, consistent with CEQA Guideline § 15061(b)(3), that
a
p
roject located within
the DNSP Focus Area that is consistent with the DCC/DMU land use designations, which allows hospitality, hotels, residential and retail uses, and is consistent with the policies included in the General Plan for development in the DNSP

is the type of project that is contemplated by CEQA
Guideline § 15061(b)(3) as
interpreted
by the California Courts.

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6 -

LIST OF PREPARERS

FirstCarbon Solutions

2999 Oak Road, Suite 250

Walnut Creek
, CA
94597

Phone:
925.357.2562

Project Director

................................
................................
................................
........................

Mary
Bean

Project Manager

................................
................................
................................
..................

Angela Wolfe

Assistant Project Manager

................................
................................
...............................

Laura Campion

Legal Counsel

................................
................................
................................
.................

Megan Starr, JD

Principal Field
Bio
logist

................................
................................
................................

Dr. Michael Tuma

Director of
Noise

and Air Quality

................................
................................
.............

Phil

Ault, LEED
®

Senior Air Quality Scientist

................................
................................
................................
.

Jackie

Winkel

D
irector of Cultural Resources

................................
................................
.......

Dana

DePietro, PhD, RPA

Senior Archaeologist

................................
................................
................................
.........

Ste
fanie Griffin

Environmental Services
Analyst

................................
................................
........................

David Sall
oum

Senior Managing Editor

................................
................................
................................
........

Susie Harris

Publications
Manager

................................
................................
................................
.............

Alec Harris

Technical Editor

................................
................................
................................
......................

Sarah Vine

Technical
Document
Manager

................................
................................
.......................

Melissa Ramirez

GIS/Graphics

................................
................................
................................
..............

Karlee McCracken

GIS/Graphics

................................
................................
................................
................

Sebastian Macias

Technical Subconsultants

W
-
Trans

Principal

................................
................................
................................
.................

Zachary Matley, AICP

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First Street Napa Phase II Project

Initial Study/
Addendum

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APPENDIX A:

Design Guidelines
ATTACHMENT 23

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ATTACHMENT 23

FIRST STREET NAPA

PHASE II REDEVELOPMENT
1 First Street Napa
Phase II Redevelopment
Design Guidelines
T own Center Focus Area:

Reactivating the Heart of the
City
RIOS
1053
ATTACHMENT 23

CONTENTS

1. FIRST STREET NAPA - DESIGN GUIDELINES OVERVIEW

3 2. S

ITE HISTORY

4 3. EXIS

TING SITE CONDITIONS AND OPPORTUNITIES

5 4. EMB

RACING THE DOWNTOWN FABRIC

7 5. S

PECIFIC PLAN LAND USE DISTRICTS

10 6. D

ESIGN AND STANDARDS

12 LAY

OUTS & IMPROVEMENTS

15 SITE L

AYOUT - ACCESS & CIRCULATION

16 SITE L

AYOUT - PARKING & LOADING AREAS

17 HISTO

RIC INTEGRATION

18 BUILDIN

G ORIENTATION & SCALE

20 DEVEL

OPMENT STANDARDS

21 MASS &

FORM STANDARDS

22 BUILDIN

G FACADE ARTICULATION

24 BUILDIN

G MATERIALS

25 LANDSCAP
E

26 PUBLIC
REALM

27 SUST

AINABLE STRATEGIES

30 LIGHTING,

SIGNAGE & FURNITURE

31 7. D

EMOLITION PLAN

32 “Welcome to Downtown Napa in 2030. Enjoy Downtown’s unique environment where the community comes together to enjoy a vibrant collection of inviting public spaces, attractive streets, distinctive shops and eateries, exciting entertainment venues, creative public art, historic buildings, sustainable new buildings and an array of housing options.” “As the distinctive heart of Napa, Downtown is a welcoming, fun and intimate city center – a place where history, charm, neighborhood and economic vitality come together along the Napa River.”
- Vision for Downtown Napa, Chapter 3, Downtown Specific Plan

FIRST STREET NAPA

PHASE II REDEVELOPMENT
2 RIOS
1053
ATTACHMENT 23

FINAL DOWNTOWN NAPA SPECIFIC PLAN

LAND USE DESIGNATIONS AND ZONING DISTRICTS
83 FIGURE 4.5: Town Center Focus Area
Retail
Retail
and
services
Retail
Retail
Retail
Avia
Hotel
Residential/
ofﬁce/PG&E
Residential/
Retail
Retail/
PG&E
Gordon
Building
Residential
Neighborhoods
Sushi Mambo
historic Napa
Register Building
Retail/
Services/
Opera
House
Historic
Courthouse
Heritage
Park
Parking
Lot
Parking
Lot
Retail
Napa River
Napa Creek

FIRST ST

SECOND ST

THIRD ST

SOSCOL AVE

CLAY ST
A
R
R
O
Y
O

D
R

PEARL ST

POLK ST

CLINTON ST

WEST ST

CALISTOGA AVE

BROWN ST

RANDOLPH ST

COOMBS ST

MAIN ST

FRANKLIN ST
Napa T own Center
Potential
Development
Site
Kohl’s
Potential
Development
Site
Transit Center
(to be relocated)
Merrill’s
Building
Facade
Redesigned
Dwight Murray
Plaza
9/11
Memorial
Garden
Ristorante
Allegria
historic First
National Bank
Downtown Area
Focus Area
Auto/Bicycle/Pedestrian Connection
Pedestrian/Bicycle Trails
Gateway
Proposed/Planned
Downtown Core Commercial
Downtown Mixed-Use
Gathering Space
Historic Resource
Public Restroom
N
0 250ft
500ft
125ft

1. FIRST STREET NAPA - PHASE II REDEVELOPMENT

DESIGN GUIDELINES OVERVIEW
The First Street Napa Phase II Redevelopment Project (“Project”), a mixed use project primarily consisting of 78 units of for sale market rate branded residential multifamily housing units, a 6-story, Upper Upscale hotel with 161 rooms with accessory retail and related amenities, and up to 30,000 sf of ground floor and second floor retail, and public realm improvements, is located within the Downtown Napa Specific Plan Town Center Focus Area.

The Project will be developed through a Planned Development Overlay District. The PD provides the applicable regulations to implement the Project.

The PD also establishes these First Street Napa Phase II Redevelopment Design Guidelines (“Guidelines”). These Project specific Guidelines supersede the Downtown Napa Specific Plan Design Guidelines, Chapter 5. The Guidelines are intended to guide and define the character of the Project within PD Overlay District and to implement the vision and goals of the Specific Plan Focus Area and the PD.

In connection with its review of any Design Review Permit or other Project applications, the City will review the Project consistent with the standards and objectives set forth in these Guidelines.

FINAL DOWNTOWN NAPA SPECIFIC PLAN

FIRST ST

SECOND ST

THIRD ST

SOSCOL AVE

CLAY ST
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PEARL ST

POLK ST

CLINTON ST

WEST ST

CALISTOGA AVE

BROWN ST

RANDOLPH ST

COOMBS ST

MAIN ST

FIRST STREET NAPA

PHASE II REDEVELOPMENT
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ATTACHMENT 23

SITE HISTORY
The First Street Napa Phase II Redevelopment will connect and respect the historical street patterns and architectural heritage of downtown Napa.

The Historic Map (see top right) demonstrates the previously integrated street patterns, particularly along Clay and Brown Street, with more permeable and smaller block patterns. The current Kohl’s development significantly altered this historic configuration. This project will aim to reconnect these key right of ways.

The area has also historically included various two to three story buildings with highly detailed facade frontages. The Sanborne Map (see middle right) demonstrates that the site’s original buildings typically fronted the street. The project will aim to reintroduce this pattern of denser and activated buildings with facades aligned to the street frontage.

First and Main Streets, Early 1970s
Dwight Murray Plaza, circa 1910
First and Coombs Streets, circa 1910
Historic Map
Sanborne Map

JANUARY 17, 2021 | 8

FIRST STREET NAPA PHASE II REDEVELOPMENT

PROJECT BLOCK

2. SITE HISTORY
The First Street Napa Phase II Redevelopment will connect and respect the historical street patterns and architectural heritage of downtown Napa.

The Historic Map (see top right) demonstrates the previously integrated street patterns, particularly along Clay and Brown Street, with more permeable and smaller block patterns. The redevelopment of downtown Napa and the site in the 1970’s signiﬁcantly altered this historic conﬁguration. This project will aim to reconnect these key corridors.

The area has also historically included various two to three story buildings

with highly detailed facade frontages. The Sanborne Map (see middle right) demonstrates that the site’s original buildings typically fronted the street. The project will aim to reintroduce this pattern of denser and activated buildings with facades aligned to the street frontage.
“Another prominent Turton-Newman building was the Migliavacca Building, constructed in 1904 at the corner of Brown and First streets for wine industry pioneer G. Migliavacca. The two-story stone building housed a number of different shops and department stores until it was demolished by the Napa Community Redevelopment Agency in 1973.”
“In 1969, the City Council established a separate redevelopment agency, with its own bylaws and appointed officers. Some citizens were displeased with the Agency and its Urban Redevelopment Plan for the Parkway Plaza Redevelopment Project (adopted December 15, 1969), so they filed a referendum petition which ultimately did not get enough signatures and failed.

”
“In 1970, the City of Napa’s application for the Neighborhood Development Program was approved and funded by the U.S. Department of Urban Development, setting the wheels in motion for the first major phase of redevelopment, which included the First Street beautification project, Brown Street Mall, another new downtown shopping mall, parking garages, new department stores (Mervyns and Carithers), and a one-time public art program. This effort led to the demise of some historic downtown commercial buildings, including the construction of a controversial clock tower and plaza on First Street to replace the Migliavacca Building (1905, demolished 1973), and the demolition of the Behlow Building (1900, demolished 1977) to make way for a new parking garage. Building permits from the 1970s are also on record for the demolition of a handful of buildings on Pearl Street to make way for a parking lot.”
* All quotes from: Heritage Napa, Downtown Napa Historic Context Statement & Survey Report Final
Old Migliavacca Building, location of
Dwight Murry Plaza

FIRST STREET NAPA

PHASE II REDEVELOPMENT
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ATTACHMENT 23

EMBRACING THE DOWNTOWN FABRIC

HERITAGE
PARK
PHASE
II

MAIN ST

PEARL STRET

COOMBS STREET
OPERA
HOUSE
PLAZA
DWIGHT
MURRAY
PLAZA
NAPA
CREEK

RIVERFRONT

PROMENADE

FIRST STREET

NAPA MALL
NAPA
COUNTY
COURT
ARCHER
HOTEL
3RD STREET
1ST STREET
KOHL’S

DEPARTMENT
STORE

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FIRST STREET NAPA PHASE II REDEVELOPMENT

3. SITE CONTEXT
PUBLIC
PUBLIC
REALM
REALM
PUBLIC
PUBLIC
REALM
REALM
PHASE 2 - CITY BLOCK

BUILDING FOOTPRINT

PUBLIC REALM

FIRST STREET NAPA

PHASE II REDEVELOPMENT
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ATTACHMENT 23

EXISTING SITE

CONDITIONS AND OPPORTUNITIES
The site includes various elements to expand upon in creating an enhanced downtown Napa environment. This includes gathering areas in Dwight Murray Plaza, an enhanced mid-block passage along the Brown Street Corridor, the community- centered 9/11 memorial, and opportunities to connect with nature along Napa Creek.

However, various areas remain unactivated and even hostile to pedestrians.

Certain passages are dominated by asphalt and paving—clearly intended to service vehicles rather than people. In multiple locations pedestrians remain exposed to the elements, with extremely limited landscaping and trees along many street segments and limited opportunities for respite (i.e. benches, tables, and alcoves).

Various street frontages remain dominated by blank walls, fences, parking lots, and parking structure entries.

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FIRST STREET NAPA PHASE II REDEVELOPMENT

3. EXISTING SITE

CONDITIONS AND OPPORTUNITIES
Various areas remain unactivated and even hostile to pedestrians within the existing site context. Certain passages are dominated by asphalt and paving—clearly intended to service vehicles rather than people. In multiple locations pedestrians remain exposed to the elements, with extremely limited landscaping and trees along many street segments and limited opportunities for respite (i.e. benches, tables, and alcoves). Various street frontages remain dominated by blank walls, fences, parking lots, and parking structure entries.

The site includes various elements to expand upon in creating an enhanced downtown Napa environment. Dwight Murray Plaza on First Street is a medium- sized urban plaza in a central location. It currently lacks sufficient uses and connections to make it active and vibrant. Additionally, its “sunken” plaza design is dated and is currently not a popular gathering place in Downtown.

Adjacent to Dwight Murray Plaza is the Brown Street Plaza. Brown Street south of Pearl Street to the mid-block south of First Street is closed to vehicular traffic. This area has the potential to become a prominent community gathering place if designed and programmed correctly.
•

Characterizing Downtown as a place
of
social, entertainment, art, cultural,
retail, residential, administrative and
government uses;
•

Emp
hasizing pedestrian orientation with
active streets and open spaces;
•

Promo
ting mixed-use projects as a means
to reduce the need for automobile use and
to support Downtown businesses;
•

Enc
ouraging rehabilitation and re-use of
historic structures;
•

Pro
moting the historic urban form of
Downtown with new buildings compatible
with the heights, street faces and building
massing of older buildings;
•

Enh
ancing public access to Downtown,
including strong linkages to adjacent
residential neighborhoods;
•

Enh
ancing Downtown gateways;
•

Stu
dying access and circulation to and
within the Downtown area;
•

Sup
porting creative parking solutions;
•

Cre
ating incentive programs and
regulatory ordinances that stimulate public
and private investment;
•

Encou
raging specialty retail businesses
catering to visitors and residents, and
discouraging discount stores with high
square footage and parking requirements;
and
•

Pro
moting hotel and conference facilities,
24-hour activity, art and cultural activities.

PLANNING CONTEXT

FIRST STREET NAPA

PHASE II REDEVELOPMENT
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ATTACHMENT 23
Archer Hotel
Spaces Napa Valley
First Street
First Street Napa Mall
Napa Square
The immediate vicinity of the First Street Napa Phase II Redevelopment offers a vibrant downtown setting with an array of hotels, restaurants, businesses, and public plazas. The
Archer Hotel
and
Andaz Hotel
both provide a high-quality
boutique hotel experience for business travelers and Napa Valley tourists. A wide range of cuisines can be experienced in the many restaurants accessed along First Street, including within the
First Street Napa Mall
. Both small businesses and
major corporations have offices located in buildings such as Spaces Napa Valley

and
Napa Square
. The project intends to both complement and expand these opportunities to attract both residents and visitors to Downtown Napa.

EMBRACING THE

DOWNTOWN FABRIC

JANUARY 17, 2021 | 5

FIRST STREET NAPA PHASE II REDEVELOPMENT
Andaz Hotel

4. EMBRACING THE

DOWNTOWN FABRIC
The immediate vicinity of the First Street Napa Phase II Redevelopment offers

a vibrant downtown setting with an array of hotels, restaurants, businesses, and public plazas. The Archer Hotel and Andaz Hotel both provide a high-quality boutique hotel experience for business travelers and Napa Valley tourists. A wide range of cuisines can be experienced in the many restaurants accessed along First Street, including within the First Street Napa Mall. Both small businesses and major corporations have o
ffi
ces l
ocated in buildings such as Spaces Napa Valley and Napa Square that compliment the First Street Mall retail storefronts and various other service oriented commercial spaces. The project intends to both complement and expand these opportunities to attract both residents and visitors to Downtown Napa.

Archer Hotel
Spaces Napa Valley
First Street
First Street Napa Mall
Napa Square
The immediate vicinity of the First Street Napa Phase II Redevelopment offers a vibrant downtown setting with an array of hotels, restaurants, businesses, and public plazas. The
Archer Hotel
and
Andaz Hotel
both provide a high-quality
boutique hotel experience for business travelers and Napa Valley tourists. A wide range of cuisines can be experienced in the many restaurants accessed along First Street, including within the
First Street Napa Mall
. Both small businesses and
major corporations have offices located in buildings such as Spaces Napa Valley

and
Napa Square
. The project intends to both complement and expand these opportunities to attract both residents and visitors to Downtown Napa.

EMBRACING THE

DOWNTOWN FABRIC

JANUARY 17, 2021 | 5

FIRST STREET NAPA PHASE II REDEVELOPMENT
Andaz Hotel

FIRST STREET NAPA

PHASE II REDEVELOPMENT
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ATTACHMENT 23

4. EMBRACING THE

DOWNTOWN FABRIC
The First Street Napa Phase II Redevelopment’s creative blend of dense residential and commercial uses, plazas and promenades, and natural areas will advance some of the key goals of the Downtown Napa Speciﬁc Plan:
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Napa City CouncilJune 24, 2025

Napa City Council
June 24, 2025