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EX B – CEQA Findings including Statement of Overriding Considerations

Napa City Council
September 15, 2026

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EX B – CEQA Findings including Statement of Overriding Considerations
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September 15, 2026
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CEQA FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS

CEQA FINDINGS OF FACT
The California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) (CEQA) requires that public agencies shall not approve or carry out a project for which an environmental impact report (EIR) has been certified that identifies one or more significant adverse environmental effects of a project unless the public agency makes one or more written Findings for each of those significant effects, accompanied by a brief explanation of the rationale for each Finding (State CEQA Guidelines [Cal. Code Regs., tit. 14, § 15000 et seq.], § 15091). This document presents the CEQA Findings of Fact made by the City of Napa (City), in its capacity as the CEQA lead agency, regarding the Five-Way Intersection Improvements Project (Project), evaluated in the Draft Environmental Impact Report (“Draft EIR”) and Final Environmental Impact Report (Final EIR) for the Project (SCH #2024071257).

Section I.

Introduction
Public Resources Code section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” Pursuant to section 21081 of the Public Resources Code, a public agency may only approve or carry out a project for which an EIR has been completed that identifies any significant environmental effects if the agency makes one or more of the following written finding(s) for each of those significant effects accompanied by a brief explanation of the rationale for each finding:

1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.

2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency.

3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.

As indicated above, section 21002 requires an agency to “avoid or substantially lessen” significant adverse environmental impacts. Thus, mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoided, satisfy section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 [“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”]; Las Virgenes Homeowners Fed., Inc. v. County of Los Angeles (1986) 177 Cal. App. 3d 300, 309 [“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”].) While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (Pub. Resources Code, § 21002.1(c) [if “economic, social, or other conditions make it infeasible to mitigate one or more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agency”]; see also State CEQA Guidelines, § 15126.6(a) [an “EIR is not required to consider alternatives which are infeasible”].) CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” (Pub. Resources Code, § 21061.1.) The State CEQA Guidelines add “legal” considerations as another indicia of feasibility. (State CEQA Guidelines, § 15364.) Project objectives also inform the determination of “feasibility.” (Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828-829.) “‘[F]easibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) “Broader considerations of policy thus come into play when the decision making body is considering actual feasibility[.]” (Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 (“Native Plant”); see also Pub. Resources Code, § 21081(a)(3) [“economic, legal, social, technological, or other considerations” may justify rejecting mitigation and alternatives as infeasible] (emphasis added).) Environmental impacts that are less than significant do not require the imposition of mitigation measures. (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.) The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project’s environmental alternatives is not required; rather, the requirement is that sufficient information be produced “to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” Outside agencies (including courts) are not to “impose unreasonable extremes or to interject [themselves] within the area of discretion as to the choice of the action to be taken.” (Residents Ad Hoc Stadium Com. v. Board of Trustees (1979) 89 Cal.App.3d 274, 287.) Section II.

Impacts That Are Less Then Significant Level With Mitigation Incorporated Noise
Threshold: Would the Project generate excessive groundborne vibration or groundborne noise levels? Finding: Less than significant with mitigation. (Draft EIR, pp. 105-106, 147.) Explanation:

Traffic, including heavy trucks traveling on a highway, rarely generates vibration amplitudes high enough to cause structural or cosmetic damage. Therefore, the Project would not result in generation of excessive vibration during operation. Demolition and construction activities required for construction often generate perceptible vibration levels and levels that could affect nearby structures when heavy equipment or impact tools (e.g., jackhammers, hoe rams) are used in the vicinity of nearby sensitive land uses. The Project would not require pile-driving, which can cause excessive vibration.

Construction activities with the greatest potential of generating perceptible vibration levels would include the removal of pavement and soil, the dropping of heavy objects, and the movement of heavy tracked equipment. Table 2.16-6 presents typical vibration levels that could be expected from representative construction equipment at a reference distance of 25 feet and calculated vibration levels at distances of 50 feet and 100 feet. Vibration levels are highest close to the source and attenuate with increasing distance depending on soil conditions.

Caltrans identifies a vibration limit of 0.5 in/sec PPV as the threshold at which there is a potential risk of damage to new residential and modern commercial/industrial structures, 0.3 in/sec PPV for older residential structures, and a conservative limit of 0.25 in/sec PPV for historic and some old buildings. Distances to exceedances of the vibration limits for various structure types are shown in Table 2.16-7.

Based on a review of the City of Napa’s historic resource inventories/mapping, for the purpose of vibration analysis, there are 23 historical structures located within 500 feet of the Project vicinity, as shown Figure 2.16-10. Of these identified structures, only eight are located within 200 feet of the Project limits. Vibration levels were calculated for each of these eight structures assuming each piece of equipment would operate along the nearest Project boundary closest to each historical building. An additional historic building at 801 Silverado Trail is located within the project limits, however, it would be demolished as part of the Project and therefore, would not be affected by construction vibration.

Vibration levels generated by vibratory rollers and the dropping of heavy objects would exceed the 0.25 in/sec PPV and 0.3 in/sec PPV thresholds at the following historical buildings and older residences, respectively, shown in Figure 2.16-11. • 406 3rd Street (historical building)
• 1031 Evans Avenue (historical building)
• Garage at 802 Juarez Street (older residence)
• 5 Hennessey Drive (older residence)
• 607 Silverado Trail (older residence)
• Barn at 1017 East Avenue (older residence)
• 36 Coombsville Road (older residence
Additionally, vibration levels generated by vibratory rollers, hoe rams, large bulldozers, caisson drilling, and the dropping of heavy objects would exceed the 0.5 in/sec PPV threshold at the following commercial buildings shown in Figure 2.16-12. • El Rancho Grande at 891 Silverado Trail
• Posh Motors at 800 Silverado Trail
• Napa Tires & Wheels at 713 Silverado Trail
Level of Significance Before Mitigation: Potentially Significant Mitigation Measures:

MM NOI-2.1: Avoid the use of vibratory rollers within 25 feet of structures. Static mode compaction shall be used when construction activities are less than 25 feet from structures.

MM NOI-2.2: Avoid dropping heavy objects or equipment within 25 feet of structures.

MM NOI-2.3: Avoid the use of hoe rams, large bulldozers, and caisson drilling equipment within 15 feet of structures. If vibratory rollers must be used within 25 feet and all other equipment must be used within 15 feet of structures, the following measures will be required:

Contractor must perform vibration monitoring, crack monitoring and photo/video documentation of the effected facilities during construction. The requirements to perform vibration monitoring, crack monitoring and photo/video documentation will be included in the Project's construction specifications as part of the construction contract documents.

Level of Significance After Mitigation: Less then Significant.

Implementation of mitigation measures MM NOI-2.1 through MM NOI-2.3 would reduce the construction vibrations of the Project to a less than significant level. (DEIR, p. 147.) Section III.

Impacts That Cannot Be Fully Mitigated to a Less Than Significant Level The City hereby finds that, pursuant to State CEQA Guidelines section 15091(a)(3), despite the incorporation of Mitigation Measures identified in the EIR and in these Findings, the following environmental impacts cannot be fully mitigated to a less than significant level:

Cultural Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to in §15064.5? Finding: Significant and Unavoidable. (Draft EIR, pp. 133-143.)

Explanation:

As described in Section 2.9 Cultural Resources, the Project would demolish the existing residence at 801 Silverado Trail. The residence is currently listed on the City’s HRI as a contributor to the East Napa Historic District.

Therefore, the residence would be considered a historical resource pursuant to CEQA Guidelines Section 15064.5. According to CEQA Guidelines Section 15064.5(b), a “project with an effect that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” Substantial adverse change is defined as: “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.” The Project design team considered the feasibility of relocating the residential structure as part of the Project, however, given the style of construction and foundation type it was determined the structure could not feasibly be moved. The Project would demolish the existing residence at 801 Silverado Trail, making the property no longer eligible for listing in the City’s HRI and impacting the integrity of the East Napa Historic District by removing one of its contributing properties. Therefore, the Project would result in a significant impact on historical resources according to CEQA Guidelines Section 15064.5. MM CULT-1.1 would require the Project sponsor to document the historical resource to be demolished which would lessen the significant cultural resources impact; however, the impact after mitigation would remain significant and unavoidable.

Level of Significance Before Mitigation: Potentially Significant Mitigation Measure:

CULT-1.1: Historic Resource Preservation: Following construction, the Project Sponsor will prepare, in consultation with the State Historic Preservation Officer (SHPO), an evaluation of the East Napa Historic District for eligibility to the National Register of Historic Places. In consultation with Section 106 stakeholders and the SHPO, Caltrans and the City of Napa will implement mitigation measures specific to the effects to the East Napa Historic District, including, but not limited to, installation of identification signs and interpretive materials providing information on the history of the neighborhood and recordation of 801 Silverado Trail consistent with the Historic American Building Survey (HABS) standards maintained in local repositories. These mitigation measures are captured in a Memorandum of Agreement between Caltrans as the NEPA lead agency, the stakeholders, and the SHPO.

Level of Significance After Mitigation: Significant and Unavoidable Section IV.

Findings Regarding Significant Irreversible Environmental Change Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the Project be implemented. Generally, a Project would result in significant irreversible environmental changes if any of the following would occur:

The Project would involve a large commitment of non-renewable resources; The primary and secondary impacts of the Project would generally commit future generations to similar uses; The Project involves uses in which irreversible damage could result from any potential environmental accidents; or The proposed consumption of resources is not justified.

This Project does not present and environmental impacts that would cause significant irreversible environmental changes.

Section V.

Growth-Inducing Impacts
The information in this section is based primarily on a technical Community Impact Memorandum (August 2024) prepared for the Project. This study is incorporated into this Draft EIR/EA by reference. A copy of this study is available for review at the locations listed inside the front cover of this document.

The Project is limited to improvements to an existing intersection and would not change land use patterns or density. The Project is located within, and is intended to serve, an urbanized and mostly-developed area of Napa. The Project would not open additional areas to development.

The Project is intended to reduce traffic congestion and vehicle delay and improve safety conditions. Existing traffic conditions are the result of growth that has already occurred in the area in accordance with land uses identified in the City’s adopted General Plan. One result of reducing congestion and improving safety can be to increase accessibility, which can in turn affect the timing and location of growth elsewhere. However, due to the urban location of this intersection, the Project is not expected to drive growth in unplanned areas or areas where growth is not currently foreseeable, therefore, the Project would not result in an unplanned population increase.

The Project purpose is limited to serving the local urbanized area. To the extent that a reduction in congestion makes the area more attractive for development, the Project could facilitate growth in the area. The General Plan contains policies that ensure that the future capacity of services (e.g., schools, utilities, police and fire protection, libraries, parks, etc.) would be adequate to serve that planned growth. Therefore, any growth indirectly facilitated by the Project would not substantially affect resources of concern.

Section VI.

Alternatives
Background
The Draft EIR analyzed three alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Program’s significant environmental effects while also meeting the majority of the Project’s objectives. The City finds that it has considered and rejected as infeasible the alternatives identified in the EIR and described below. This section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the Project objectives, as required by CEQA.

Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Subsection 15126.6(b) states the purpose of the alternatives analysis:

Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:

The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Program. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Program. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Program.

The alternatives analyzed in the FEIR were developed with the goal of being at least potentially feasible, given Project objectives and site constraints, while avoiding or reducing the Project’s identified environmental effects. The following are evaluated as alternatives to the proposed Project:

No Build Alternative
Five-Legged Roundabout Alternative
Two Roundabout Alternative
Project Objectives
The purpose of the Project is to improve the operations of the intersection that will result in reduced driver delay, reduced congestion, and, therefore, an overall improvement to intersection operations. Additionally, the purpose of the Project is to improve the safety and accessibility for all users of the intersection. The secondary objectives of this Project are to improve bicycle and pedestrian facilities at the intersection as well as meet Americans with Disabilities Act (ADA) requirements Alternatives Considered But Rejected From Detailed Analysis Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic Project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts.

Thirteen conceptual build alternatives were originally designed for the Project, which were narrowed into three build alternatives during the Project Initiation Document (PID) phase, and one build alternative during the Project Approval & Environmental Document (PA&ED) phase. Alternatives were eliminated prior to and during the PID Phase primarily based on their ability to meet the Project’s Purpose and Need, excessive costs, unacceptable traffic operations, and imposed access restrictions.

All previously developed concepts were considered for their ability to avoid Section 4(f) protected properties. Six alternatives were moved forward within the Section 4(f) analysis to determine if these alternatives were feasible and prudent avoidance alternatives to avoid the use of the historic district. The potential alternatives were further reviewed to determine if they were feasible as a matter of sound engineering judgment and prudent as described for each alternative below. Out of the six alternatives, two alternatives were determined to be redundant as they had similar designs to two of the other alternatives. Therefore, the six alternatives were narrowed down to four alternatives by combining the alternatives that otherwise would have been considered redundant. Additionally, the No-Build Alternative would avoid the Section 4(f) protected property (i.e., the historic district).

Evaluation of Alternatives Selected for Analysis
A. No Build Alternative
Description of Alternative: The No Build Alternative leaves the existing lane geometrics and intersection controls in place, without any roundabouts. Under existing conditions, the intersection of SR 121/Third Street/Coombsville Road/East Avenue remains signalized.

Comparison of Environmental Impacts: The No Build Alternative would avoid all the identified significant impacts of the project, namely cultural resources and noise.

Finding: The No Build Alternative would not meet any of the project objectives. The No Build Alternative would be inconsistent with the City of Napa General Plan policies 1) TE 2-6, which requires the study and design of future improvements for all modes of transportation along Silverado Trail between Trancas Street and Soscol Avenue, and 2) TE 5-4, which requires that acceptable traffic flow be maintained along Silverado Trail from Soscol Avenue to Trancas Street. Traffic conditions at the Project intersection would worsen over time under the No Build Alternative. Therefore, this alternative is rejected.

B. Five-Legged Roundabout Alternative
Description of Alternative: The Five-Legged Roundabout Alternative would replace the existing intersection with a single, five-legged roundabout. The single roundabout would be centered slightly east of the existing intersection and incorporate all of the adjoining roadways. The Five-Legged Roundabout Alternative would result in a full acquisition of three commercial properties and full acquisition of a residential property, potentially resulting in social and economic impacts to the local community. The potential right-of-way impacts are summarized below:

Napa Marble & Granite Works (9 Coombsville Road) is a monument and grave marker business. The property would be completely within the footprint of the roundabout and would require full acquisition.

Posh Motors is a used car dealership which uses the parking lot on their property to store and display inventory. This alternative may eliminate both existing driveways for the Posh Motors (800 Silverado Trail) property. If both driveways are eliminated, full acquisition of the property would be required.

Napa Tire & Wheels (713 Silverado Trail) is an automobile service business. The southbound SR 121 exit from the five-legged roundabout would impact the existing overhang/carport structure on the property. Both existing driveways would be impacted, and there may not be a suitable location to provide a new driveway that gives sufficient distance from the roundabout. Discussion with the business owners will determine if full acquisition is required. Additionally, due to the nature of the business, contaminated soils are likely present in the area. 1010 East Avenue is a multi-family residential property with two residences that would be directly impacted by this alternative. The main residence is within the alignment for East Avenue and would require demolition. An additional residence is directly adjacent to the improvements and a new driveway access to the property may be infeasible, requiring full acquisition of the property.

Comparison of Environmental Impacts:

Aesthetics
This alternative would result in more visual changes to the Project area because it would require full acquisition of several commercial and residential properties and demolition of existing structures. Similar to the Build Alternative, this alternative would also result in tree removals, reconfiguration of the existing intersection, and new sources of lighting.

Air Quality
Similar to the Build Alternative, this alternative would not increase vehicle trips through the intersection or otherwise result in permanent air quality impacts. Construction air quality emissions would be greater than the Build Alternative because several more structures would need to be demolished during the construction phase.

Biological Resources
This alternative would impact the same habitat types as the Build Alternative and would result in a comparable number of tree removals. The Five-Legged Roundabout Alternative would result in a similar level of impacts to biological resources as the Build Alternative.

Cultural Resources
This alternative would result in a similar level of potential impacts to archaeological resources during project construction. However, the alternative would avoid demolition of the residence at 801 Silverado Trail and, therefore, would not result in a significant impact to the East Napa Historic District. For this reason, the Five-Legged Roundabout Alternative would result in a lesser level of impact on cultural resources. The properties that would be demolished for construction of this alternative were found not to be eligible for listing on the CRHR or NRHP.

Energy
This alternative would result in comparable levels of energy consumption as the Build Alternative during both the construction and operational phases.

Geology and Soils
This alternative would result in similar impacts associated with geology and soils because it would be constructed in the same location as the Build Alternative.

Hazards and Hazardous Materials
This alternative would result in similar impacts associated with hazards and hazardous materials because it would be a similar project type constructed in generally the same location as the Build Alternative. Additional soil remediation and monitoring may be required due to the acquisition of the Napa Tire & Wheels property but it would not significantly increase impacts from the Project.

Hydrology and Water Quality
Similar to the Build Alternative, the Five-Legged Roundabout Alternative would likely result in a net increase in impervious surfaces on-site and would be partially located within a flood hazard zone but impacts to water quality would be less than significant through compliance with the MS4 Permit.

Land Use and Planning
Similar to the Build Alternative, the Five-Legged Roundabout Alternative would not divide an existing community and would be consistent with the City’s goals and policies to improve traffic circulation and bicycle and pedestrian facilities. However, this alternative would also result in the demolition of at least one residential structure. Additionally, the Five-Legged Roundabout Alternative would require full acquisition of three commercial properties and the demolition of several commercial structures occupied by existing businesses.

Noise
Similar to the Build Alternative, the Five-Legged Roundabout Alternative would not increase traffic in the Project area but it would alter the existing geometry of the intersection. This alternative would not substantially increase ambient noise at nearby receptors. This alternative would result in similar construction noise and vibration impacts as the Build Alternative and would require mitigation to reduce impacts to a less than significant level.

Population and Housing
Similar to the Build Alternative, this alternative would not induce population growth. The Five-Legged Roundabout Alternative would displace residents due to the full acquisition of one residential property. This would be a similar impact to the Build Alternative, which would demolish one residence.

Public Services
Similar to the Build Alternative, this alternative would not result in any permanent impacts to public services. A TDM would still be prepared to ensure adequate emergency access is provided throughout construction.

Transportation
Similar to the Build Alternative, the Five-Legged Roundabout Alternative would not result in any changes in VMT and would incorporate bicycle and pedestrian facilities into the roundabouts. A TMP would be prepared to ensure adequate emergency access is provided throughout construction. This alternative would not introduce any incompatible uses and would be designed in accordance with current highway and roundabout design standards.

Tribal Cultural Resources
This alternative would result in a similar level of potential impacts to tribal cultural resources during project construction.

Utilities and Service Systems
Similar to the Build Alternative, this alternative would not result in a substantial increase in demand on utility services. The only utility usage associated with the Build Alternative would be landscape irrigation and electricity for lighting. Similar to the Build Alternative, the Five-Legged Roundabout Alternative would likely require the relocation of existing utilities to accommodate the proposed roundabout.

Wildfire
Similar to the Build Alternative, the Five-Legged Roundabout Alternative would not exacerbate wildfire risk.

Finding: Although the Five-Legged Roundabout Alternative would provide accessibility for all users and improve operations over existing conditions, the implementation of cumulative projects in the area would result in operational deficiencies on Third Street (LOS E). The Five-Legged Roundabout Alternative would also avoid demolishing the residence at 801 Silverado Trail and, therefore, would avoid a significant impact to the East Napa Historic District; however, the City finds this alternative would not meet the project objectives to improve intersection operations and reduce vehicle delay and congestion to the same extent as the Build Alternative and, therefore, is rejected.

C. Two Roundabout Alternative
Description of Alternative: The Two Roundabout Alternative would replace the existing intersection with two, single-lane roundabouts. Unlike the Build Alternative, this alternative would align Third Street to the southern roundabout along with Coombsville Road and SR 121. The northern roundabout would be a three-legged roundabout with SR 121 and East Avenue. The Two Roundabout Alternative would result in a full acquisition of three commercial properties and a major or full acquisition of a fourth commercial property, potentially resulting in social and economic impacts to the local community. The potential right-of-way impacts are summarized below:

Posh Motors is a used car dealership which uses the parking lot on their property to store and display inventory. This alternative would require acquisition of a significant portion of the parking area, which eliminates the commercial viability of the property as a car dealership. A full acquisition would be anticipated.

Third Street would be realigned through the center of the Napa Tire & Wheels property, and a full acquisition would be required. Due to the nature of the business, contaminated soils are likely present in the area.

Both existing driveways to the Napa Marble & Granite Works property would be eliminated and there are no viable locations to provide a new driveway. A full acquisition would be required.

The commercial center on the southeast corner of Third Street and Juarez Street includes multiple businesses, including an appliance store, plumbing showroom, and children’s event venue. Third Street would be realigned through the property, requiring demolition of a portion of the existing building. Some commercial utility of the remaining unused property may be possible, and an existing driveway onto Juarez Street would remain. Major acquisition would be anticipated, though full acquisition may be required depending on discussions with the property owners.

The residential property at 1010 East Avenue would require partial acquisition and may require driveway realignment.

Comparison of Environmental Impacts:

Aesthetics
This alternative would result in more visual changes to the Project area because it would require full acquisition of several commercial properties and demolition of existing structures. Similar to the Build Alternative, this alternative would also result in tree removals, reconfiguration of the existing intersection, and new sources of lighting.

Air Quality
Similar to the Build Alternative, this alternative would not increase vehicle trips through the intersection or otherwise result in permanent air quality impacts. Construction air quality emissions would be greater than the Build Alternative because several more structures would need to be demolished during the construction phase.

Biological Resources
This alternative would impact the same habitat types as the Build Alternative and would result in a comparable number of tree removals. The Two Roundabout Alternative would result in a similar level of impacts to biological resources as the Build Alternative.

Cultural Resources
This alternative would result in a similar level of potential impacts to archaeological resources during project construction. However, the alternative would avoid demolition of the residence at 801 Silverado Trail and, therefore, would not result in a significant impact to the East Napa Historic District. For this reason, the Two Roundabout Alternative would result in a lesser level of impact on cultural resources. The commercial properties that would be demolished for construction of this alternative were found not to be eligible for listing on the CRHR or NRHP.

Energy
This alternative would result in comparable levels of energy consumption as the Build Alternative during both the construction and operational phases.

Geology and Soils
This alternative would result in similar impacts associated with geology and soils because it would be constructed in the same location as the Build Alternative.

Greenhouse Gas Emissions
Similar to the Build Alternative, this alternative would not increase vehicle trips through the intersection or otherwise result in a permanent increase in GHG emissions. Construction GHG emissions would be comparable to the Build Alternative.

Hazards and Hazardous Materials
This alternative would result in similar impacts associated with hazards and hazardous materials because it would be a similar project type constructed in generally the same location as the Build Alternative. Additional soil remediation and monitoring may be required due to the acquisition of the Napa Tire & Wheels property but it would not significantly increase impacts from the Project.

Hydrology and Water Quality
Similar to the Build Alternative, the Two Roundabout Alternative would likely result in a net increase in impervious surfaces on-site and would be partially located within a flood hazard zone but impacts to water quality would be less than significant through compliance with the MS4 Permit.

Land Use and Planning
Similar to the Build Alternative, the Two Roundabout Alternative would not divide an existing community and would be consistent with the City’s goals and policies to improve traffic circulation and bicycle and pedestrian facilities. Additionally, this alternative would not require full acquisition of any residential properties or the demolition of any residential structures. However, the Two Roundabout Alternative would require full acquisition of four commercial properties and the demolition of several commercial structures occupied by existing businesses.

Noise
Similar to the Build Alternative, the Two Roundabout Alternative would not increase traffic in the Project area but it would alter the existing geometry of the intersection. This alternative would not substantially increase ambient noise at nearby receptors. This alternative would result in similar construction noise and vibration impacts as the Build Alternative and would require mitigation to reduce impacts to a less than significant level.

Population and Housing
Similar to the Build Alternative, this alternative would not induce population growth. The Two Roundabout Alternative would not displace any people because it would not require full acquisition of any residential properties. This would be a lesser impact than the Build Alternative, which would demolish one residence.

Public Services
Similar to the Build Alternative, this alternative would not result in any permanent impacts to public services. A TDM would still be prepared to ensure adequate emergency access is provided throughout construction.

Transportation
Similar to the Build Alternative, the Two Roundabout Alternative would not result in any changes in VMT and would incorporate bicycle and pedestrian facilities into the roundabouts. A TMP would be prepared to ensure adequate emergency access is provided throughout construction. This alternative would not introduce any incompatible uses and would be designed in accordance with current highway and roundabout design standards.

Tribal Cultural Resources
This alternative would result in a similar level of potential impacts to tribal cultural resources during project construction.

Utilities and Service Systems
Similar to the Build Alternative, this alternative would not result in a substantial increase in demand on utility services. The only utility usage associated with the Build Alternative would be landscape irrigation and electricity for lighting. Similar to the Build Alternative, the Two Roundabout Alternative would likely require the relocation of existing utilities to accommodate the proposed roundabouts.

Wildfire
Similar to the Build Alternative, the Two Roundabout Alternative would not exacerbate wildfire risk.

3. Finding: The Two Roundabout Alternative would result in AM and PM peak hour queues for southbound vehicles on SR 121 entering the southern roundabout that would likely extend more than 150 feet, which is the available distance between the two roundabouts. This would result in the queue spilling back into the northern roundabout, creating significant delay. The Two Roundabout Alternative would avoid demolishing the residence at 801 Silverado Trail and, therefore, would avoid a significant impact to the East Napa Historic District. Because this alternative would result in queuing and significant delays during the AM and PM peak hours, it would not meet the Project objectives to the same extent as the Build Alternative and, therefore, is rejected.

Environmentally Superior Alternative
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives to a proposed Program shall identify an environmentally superior alternative among the alternatives evaluated in an EIR. However, State CEQA Guidelines Section 15126.6(e)(1) states “if the environmentally superior alternative is the ‘no project’ alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” In this case, the No Build Alternative is environmentally superior because it avoids all of the identified impacts of the project. The No Build Alternatives does not, however, meet any of the project objectives.

In addition to the No Build Alternative, the Two Roundabout Alternative would avoid the significant cultural resource impact to the East Napa Historic District and avoid full acquisition of residential property to accommodate the Project. Based on the discussion above, the environmentally superior alternative would be the Two Roundabout Alternative as it would reduce the cultural resource impact of the project and avoid full residential property acquisition. However, the Two Roundabout Alternative would result in significant delay and would not meet the Project objectives. For this reason, the Two Roundabout Alternative is rejected.

Section VII.

Mitigation Monitoring And Reporting Program
Attached to this Resolution as Exhibit 2 and incorporated and adopted as part of this Resolution herein is the Environmental Commitments Record (ECR) that serves as the Mitigation Monitoring and Reporting Program (MMRP) for the Project required under Section 21081.6 of the CEQA Statute and Section 15097(b) of the CEQA Guidelines. The ECR/MMRP identifies impacts of the Project, corresponding mitigation, designation of responsibility for mitigation implementation and the agency responsible for the monitoring action.

Section VIII.

No Evidence of New Significant Impacts
No evidence of new significant impacts or any new information of “substantial importance” as defined by State CEQA Guidelines §15088.5, has been received by the City after circulation of the Draft EIR that would require recirculation.

Section VX.

Statement Of Overriding Considerations
Pursuant to State CEQA Guidelines Section 15093(a), the City must balance, as applicable, the economic, legal, social, technological, or other benefits of the Project against its unavoidable environmental risks in determining whether to approve the Project. If the specific benefits of the project outweigh the unavoidable adverse environmental effects, those environmental effects may be considered acceptable.

Having reduced the adverse significant environmental effects of the Project to the extent feasible by adopting the mitigation measures; having considered the entire administrative record on the project; the Town has weighed the benefits of the Project against its unavoidable adverse impacts after mitigation in regards to cultural resources. While recognizing that the unavoidable adverse impacts are significant under CEQA thresholds, the City nonetheless finds that the unavoidable adverse impacts that will result from the Project are acceptable and outweighed by specific social, economic and other benefits of the Project.

In making this determination, the factors and public benefits specified below were considered. Any one of these reasons is sufficient to justify approval of the Project. Thus, even if a court were to conclude that not every reason is supported by substantial evidence, the City would be able to stand by its determination that each individual reason is sufficient. The substantial evidence supporting the various benefits can be found in the preceding findings, which are incorporated by reference into this section, and in the documents found in the Records of Proceeding.

The City therefore finds that for each of the significant impacts which are subject to a finding under CEQA Section 21081(a)(3), that each of the following social, economic, and environmental benefits of the Project, independent of the other benefits, outweigh the potential significant unavoidable adverse impacts and render acceptable each and every one of these unavoidable adverse environmental impacts:

Significant Unavoidable Impacts. With respect to the foregoing findings and in recognition of those facts that are included in the record, the City has determined that the Project will result in significant unmitigated or unavoidable impacts, as set forth above, associated with the residence at 801 Silverado Trail, which is listed on the City’s Historic Resources Inventory as a contributor to the East Napa Historic District.

Overriding Considerations. The City Council specifically adopts and makes this Statement of Overriding Considerations that this Project has eliminated or substantially lessened all significant effects on the environment where feasible, and finds that the remaining significant, unavoidable impacts of the Project are acceptable in light of the economic, legal, environmental, social, technological or other considerations noted below, because the benefits of the Project outweigh its significant adverse environmental impact of the Project. The City Council finds that each of the overriding considerations set forth below constitutes a separate and independent basis for finding that the benefits of the Project outweigh its significant adverse environmental impacts and is an overriding consideration warranting approval of the Project. These matters are supported by evidence in the record that includes, but is not limited to, the City of Napa 2040 General Plan, City of Napa Bicycle Plan, and City of Napa Pedestrian Plan.

Benefits of the Project. The City Council has considered the public record of proceedings on the proposed Project and other written materials presented to the City as well as oral and written testimony at all public hearings related to the Project, and does hereby determine that implementation of the Project as specifically provided in the Project documents would result in the following substantial public benefits:

Intersection Operations Improvement. Consistent with the goals and policies of the City of Napa 2040 General Plan, the Project would address existing operational deficiencies that are anticipated to increase with continued growth in the area. The Project would result in reduced driver delay and congestion at the Project intersection.

Safety and Accessibility Improvements. The Project would address the substandard pedestrian facilities and lack of bicycle facilities at the existing intersection. The Project would improve bicycle and pedestrian facilities at the intersection and meet Americans with Disabilities Act (ADA) requirements to improve safety and accessibility for all modes of travel.

Section X.

LOCATION AND CUSTODIAN OF RECORDS
The documents and other materials that constitute the record of proceedings on which the City Council based the foregoing findings and approval of the Project are located at the City’s Department of Public Works, City of Napa Community Services Building, 1600 First Street, Napa, California, 94559. The City Council hereby designates the City’s Director of Public Works at the Director’s office at 1600 First Street, Napa, California, 94559, as the custodian of documents and records of proceedings on which this decision is based. 2 EXHIBIT B

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