Sacred Lands File Search
Concurrently with the request for the Tribal Consultation List in August 2024, a request was sent to the NAHC for a Sacred Lands File search. The NAHC reported on August 30, 2024, that the result of the Sacred Lands File search was negative.
4.16.2 STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impacts to tribal resources if it would:
1. Cause a substantial adverse change in the significance of a TCR, defined in PRC Section 21074 as either a site, feature, place, or 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 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Tribe, and that is: (i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or (ii) 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 PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of the PRC Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance to a California Native American tribe.
2. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to TCRs.
4.16.3 IMPACT DISCUSSION
As described in Chapter 4.0, Environmental Analysis, of this Draft EIR, some proposed General Plan 2050 policies and actions are required as a means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable at the discretion of the decision maker through permit conditions, agreements, or other legally binding instruments. These mitigating policies and actions use the imperative “shall,” include performance criteria, and are marked with an asterisk (*). Note that all actions are required to be implemented by the City and therefore the imperative “shall,” if not explicitly stated, is implied.
TCR-1 Implementation of the proposed project could cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074 as either a site, feature, place, or 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: (i) Listed or eligible for listing in the California; (ii) Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or (iii) 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 Resource Code Section 5024.1. In applying the criteria set forth in subdivision (c) of the Public Resource Code Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance to a California Native American tribe.
As previously described in Section 4.16.1.1, Regulatory Framework, CEQA defines a TCR as a site, feature, place, or cultural landscape that is geographically defined in terms of size and scope, sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register or included in a local register of historical resources, or if the City of Santa Rosa, acting as the lead agency, supported by substantial evidence, chooses at its discretion to treat SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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the resource as a TCR.9 Through the consultation process described in Section 4.16.1.2, Existing Conditions, no California Native American Tribe has identified the presence of TCRs in the EIR Study Area.
However, there is the potential for TCRs to be identified as part of project-specific development over the course of the implementation of the proposed project.
As described in Section 4.16.1.2, Existing Conditions, as part of the consultation process, some requests were made by the tribes. Table 4.16-1, Tribal Consultation Requests and City Responses, shows the requests presented to the City during the tribal consultation process completed to date and how the request has been responded to as part of the proposed General Plan 2050.
TABLE 4.16-1 TRIBAL CONSULTATION REQUESTS AND CITY RESPONSES Request Response
Work to develop a better communication system for the required SB 18 and AB 52 consultation between City staff and tribes.
Proposed General Plan 2050 Policy 4-2.2, *Action 4-2.1, and *Action 4-2.2 require the review of projects, consultation with Native American Tribes as required by State law, and
collaboration with the most likely descendants, as identified by the Native American Heritage Commission.
Tribal acknowledgment to be added to the Housing Element and to be carried forward in the comprehensive General Plan.
The Housing Element 2023-2031, adopted on February 14,
2023, includes the Tribal Acknowledgement in Chapter 1, Introduction, on page 1-1. The proposed General Plan 2050 includes the Tribal Acknowledgement in Chapter 1,
Introduction, on page 1-6.
Consider Phase 1 archaeological survey for all projects that involve ground disturbance: allowing potential exceptions where the ground has already been disturbed.
Proposed General Plan 2050 *Action 4-2.1 requires
preliminary review of development projects with the California Historical Resources Information System, Northwest
Information Center, at Sonoma State University to determine whether project areas contain known archaeological
resources, including TCRs. Proposed
*Action 4-2.2 requires the
review of projects with site-specific investigations.
Develop a threshold for when ministerial projects with ground disturbance can include consultation.
No threshold has been determined as part of the proposed General Plan 2050 project. The City acknowledges this request and will continue to work with the tribes.
Expand consideration of projects along waterways to include historical locations and trajectories.
The proposed General Plan 2050 includes policies and actions to protect historic and cultural resources, including waterways as Native American archaeological sites tend to be located near waterways and these locations may hold prehistoric resources. Proposed General Plan 2050 Policy 4-1.1, Policy 3-
5.7, and *Action 3-5.20 require the preservation and
enhancement of the city’s natural waterways, require
construction adjacent to creek channels to be sensitive to the natural environment, and require ecological buffer zones between the waterway and development. These policies and actions protect both natural and cultural resources near waterways in the EIR Study Area.
9 Public Resources Code Sections 21074(a)(1) and (2).
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TABLE 4.16-1 TRIBAL CONSULTATION REQUESTS AND CITY RESPONSES Request Response
Ensure the plan includes adequate goals, policies, and actions related to resilience.
The proposed General Plan 2050 includes an update to the State-required safety element, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities. The Climate Resilience section addresses
agricultural and
ecosystem pests and diseases, droughts, extreme heat and warm nights, other climate-influenced health risks, severe winds and storms, wildfires.
While no TCRs have been acknowledged as part of the consultation process or otherwise, there is the potential to unearth archeological resources or human remains, which could be identified as TCRs upon discovery. The proposed General Plan 2050 Chapter 2, Land Use and Economic Development; Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction; and Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture, contains goals, policies, and actions that require local planning and development decisions to consider impacts to TCRs and archaeological resources, which have the potential to be identified as TCRs upon discovery archaeological resources. The following goals, policies, and actions would minimize impacts to TCRs and archaeological resources:
Goal 2-2: Promote city-centered growth and investment with a neighborhood-focused approach to create complete and connected communities that provide community members' daily needs within easy walking or biking distance.
Policy 2-2.2: Encourage a compact, rather than a scattered, development pattern for new development proposals, particularly in Areas of Change. Goal 3-5: Protect, expand, maintain, and restore natural resources, open space, and the limited remaining agricultural land.
Policy 3-5.2: Preserve, enhance, and expand a connected network of open spaces for recreation, natural and cultural resource protection, and mobility of species by way of critical linkages between open space lands.
Action 3-5.4: Collaborate with regional agencies and private landowners to link inaccessible open spaces to benefit the protection of special environments and ecosystems, such as wetlands, plant communities, wildlife habitats and corridors, historic resources, and tribal and cultural resources.
Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
Policy 3-5.5: Maintain, restore, and protect the city’s waterways. Policy 3-5.7: Ensure that construction adjacent to creek channels is sensitive to the natural environment, preserves topography and vegetation along the creek, does not disrupt or pollute the waterway, and provides an adequate setback buffer .
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*Action 3-5.19: Require new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for multiuse trails and recreation.
*Action 3-5.20: Require new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans to meet restoration and enhancement goals.
Goal 4-2: Protect tribal cultural resources in Santa Rosa and enrich the sense of place and understanding of the city’s history and prehistory.
Policy 4-2.1: Protect Native American heritage, honor the early stewards of this land, and treat Native American remains and resources with sensitivity. *Action 4-2.1: Continue to review proposed developments in conjunction with the California Historical Resources Information System, Northwest Information Center, at Sonoma State University to determine whether project areas contain known archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources, or if they have the potential to hold such resources and if so, implement mitigation to protect the resource. *Action 4-2.2: Work in good faith with interested communities to evaluate proposed development sites for the presence of subsurface historic, archaeological, and tribal cultural resources. These efforts may include:
Consideration of existing reports and studies.
Consultation with Native American tribes as required by State law. Appropriate site-specific investigative actions.
On-site monitoring during excavation if appropriate.
*Action 4-2.3: Continue to require that project areas found to contain significant archaeological resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation.
Policy 4-2.2: Collaborate with the most likely descendants, as identified by the Native American Heritage Commission.
*Action 4-2.4: If tribal cultural resources are encountered during development, halt work to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative (if appropriate) have evaluated the situation and recorded identified tribal cultural resources—which may include animals, structures, landscapes, or plants—and determined suitable mitigation measures.
As described under impact discussion CUL-3 in Chapter 4.5, Cultural Resources, of this Draft EIR, compliance with the mandatory regulatory procedures described and the proposed General Plan 2050 goals, policies, and actions, potential impacts related to the potential discovery or disturbance of any human remains accidently unearthed during construction activities associated with future development in the EIR Study Area would be less than significant. However, as described under impact discussion CUL-2 in Chapter 4.5 of this Draft EIR, because future development under the proposed General Plan 2050 may occur where there is the potential for archeological resources, known and unknown, which could be SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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identified as TCRs upon discovery, impacts from the proposed General Plan 2050 are potentially significant.
Impact TCR-1: Impacts to unknown tribal cultural resources (TCR) could occur from potential future development under the proposed General Plan 2050.
Significance with Mitigation: Less than significant. The proposed General Plan 2050 includes goals, policies, and actions that require local planning and development decisions to reduce impacts to archaeological resources that could qualify as TCRs and to conduct consultation with Native American tribes as required by State law. Specifically, proposed Policy 2-2.2 encourages infill development in Areas of Change, which reduces opportunities to unearth potential TCRs and Action 3-5.4 requires the City to collaborate with regional agencies to expand open space that would protect historic and TCRs.
Proposed *Action 4-2.1 and *Action 4-2.2 requires the City to continue to review proposed developments to determine if TCRs are present and evaluate proposed development sites for TCRs through consultation with local Native American tribes. Additionally, proposed *Action 4-2.4 requires that if TCRs are encountered during development, work is halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative have evaluated the situation, and recorded identified cultural resources, which may include animals, structures, landscapes, and plants and determined suitable site-specific mitigation measures.
The proposed General Plan 2050 also includes policies and actions to protect historic and cultural resources, including waterways as Native American archaeological sites tend to be located near waterways and these locations may hold prehistoric resources. As listed under impact discussion CUL- 1 in Chapter 4.5, Cultural Resources, of this Draft EIR, proposed General Plan 2050 Policy 4-1.1 requires the preservation and enhancement of the city’s natural waterways and landscapes; Policy 3-
5.7 requires that construction adjacent to creek channels is sensitive to the natural environment, preserves topography and vegetation along the creek, does not disrupt or pollute the waterway, and provides an adequate setback buffer; and *Action 3-5.19 and *Action 3-5.20 require new development along channelized waterways to establish an ecological buffer zone between the waterway and development.
Compliance with federal and State laws, as described in Section 4.16.1.1, Regulatory Framework, and the proposed General Plan 2050 goals, policies, and actions would protect unrecorded TCRs in the EIR Study Area by providing for the early detection of potential conflicts between development and resource protection, and by preventing or minimizing the material impairment of the ability of archaeological deposits to convey their significance through excavation or preservation. Therefore, impacts to TCRs would be less than significant.
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TCR-2 Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, would not result in less- than-significant cumulative impacts with respect to tribal cultural resources.
Cumulative impacts to TCRs occur when a series of actions leads to adverse effects on local Native American tribes or tribal lands. No TCRs have been identified in the EIR Study Area. Further, in association with CEQA review, future AB 52 consultations with Native American tribes to identify TCRs would be required for projects that have the potential to cause significant impacts to TCRs.
Future development planned for under the proposed project would be primarily within the developed portions of the EIR Study Area (Areas of Change). This, in conjunction with buildout of the city and the region, has the potential to cumulatively impact TCRs impacts. Impacts to TCRs that may be identified as part of project-specific development over the course of the implementation of the proposed project would be less than significant with implementation of the proposed General Plan 2050 goals, policies, and actions. As previously discussed, impacts to TCRs in the EIR Study Area would be less than significant with implementation of the proposed General Plan 2050 goals, policies, and actions described in impact discussion TCR-1 and, with respect to archeological resources that have the potential to be identified as TCRs once unearthed, in impact discussions CUL-1 through CUL-3 in Chapter 4.5, Cultural Resources, of this Draft EIR. Additionally, the existing federal, state, and local regulations and the proposed General Plan 2050 goals, policies, and actions described throughout this chapter serve to protect TCRs and archeological resources in the EIR Study Area. Continued compliance with these regulations substantially decreases potential impacts to TCRs to the maximum extent practicable and cumulative impacts would be less than significant in this regard.
Significance with Mitigation: Less than significant.
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4.17 UTILITIES AND SERVICE SYSTEMS
This chapter of the Draft Environmental Impact Report (EIR) describes the potential impacts to utilities and service systems associated with the adoption and implementation of the proposed project. This includes impacts on utilities and service systems, including water supply and demand, wastewater (sewage) conveyance and treatment, solid waste collection and disposal systems, storm drainage systems, and energy infrastructure. In each section of this chapter, a summary of the relevant regulatory framework and existing conditions is followed by a discussion of project impacts and cumulative impacts from implementation of the proposed project.
4.17.1 WATER
ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
Safe Drinking Water Act
The Safe Drinking Water Act, the principal federal law intended to ensure safe drinking water to the public, was enacted in 1974 and has been amended several times. The Safe Drinking Water Act authorizes the United States Environmental Protection Agency (USEPA) to set national standards for drinking water, called the National Primary Drinking Water Regulations, to protect against both naturally occurring and human-made contaminants. These standards set enforceable maximum contaminant levels in drinking water and require all water providers in the United States to treat water to remove contaminants, except for private wells serving fewer than 25 people. In California, the State Water Resources Control Board (SWRCB) conducts most enforcement activities. If a water system does not meet standards, it is the water supplier’s responsibility to notify its customers.
America’s Water Infrastructure Act of 2018
America's Water Infrastructure Act (AWIA), signed into law on October 23, 2018, authorizes federal funding for water infrastructure projects, expands water storage capabilities, assists local communities in complying with the Safe Drinking Water Act and Clean Water Act (CWA), reduces flooding risks for rural, western, and coastal communities, and addresses significant water infrastructure needs in tribal communities.
1 Additionally, the AWIA requires that drinking water systems that serve more than 3,300 people develop or update risk assessments and emergency response plans. Risk assessments and emergency response plans must be certified by the USEPA within the deadline specified by the AWIA.
1 John Barasso, October 10, 2018, Congress Passes America’s Water Infrastructure Act, https://www.barrasso.senate.gov/public/index.cfm/2018/10/congress-passes-america-s-water-infrastructure-act.
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State Regulations
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act, which was passed in California in 1969 and amended in 2013, is the basic water quality control law for California. Under this Act, the SWRCB has authority over State water rights and water quality policy. This Act divided the state into nine regional basins, each under the jurisdiction of a Regional Water Quality Control Board (RWQCB) to oversee water quality on a day-to- day basis at the local and regional level. RWQCBs engage in a number of water quality functions in their respective regions. RWQCBs regulate all pollutant or nuisance discharges that may affect either surface water or groundwater . The EIR Study Area is within the jurisdiction of the North Coast RWQCB (Region 1).
SWRCB Division of Drinking Water
The California Division of Drinking Water regulates public water systems within California; oversees water recycling projects; permits water treatment devices; and supports and promotes water system security.
The Division of Financial Assistance provides funding opportunities for drinking water system improvements; provides support for small water systems and for improving technical, managerial, and financial capacity; and certifies drinking water treatment and distribution operators. The Field Operations Branch of the Division of Drinking Water is responsible for the enforcement of the federal and California Safe Drinking Water Acts and the regulatory oversight of approximately 7,500 public water systems to ensure the delivery of safe drinking water to all Californians. In this capacity, Field Operations Branch staff perform field inspections, issue operating permits, review plans and specifications for new facilities, take enforcement actions for noncompliance with laws and regulations, review water quality monitoring results, and support and promote water system security.
Urban Water Management Planning Act (Senate Bills 610 and 221) The California Urban Water Management Planning Act and Section 10620 of the Water Code require that all urban water suppliers in California that provide water to more than 3,000 customers or supply more than 3,000 acre-feet per year (AFY)2 prepare and adopt an Urban Water Management Plan (UWMP) and update it every five years. The act is intended to support efficient use of urban water supplies. It requires the UWMP to 1) compare water supply and demand over the next 20 years for normal years, single dry years, and multiple dry years, 2) describe demand management measures in a water shortage contingency plan as an appendix, 3) report progress toward meeting a 20 percent reduction in per-capita urban water consumption by 2020, and 4) determine current and potential recycled water uses.
The City of Santa Rosa’s most recent UWMP was adopted by the City Council on June 8, 2021, and the Amended 2020 Water Shortage Contingency Plan was adopted by the City Council on November 30, 2021
3. The next UWMP is due to the DWR by July 1, 2026.
2 One acre-foot is the amount of water required to cover one acre of ground (43,560 square feet) to a depth of one foot. 3 City of Santa Rosa Urban Water Contingency Plan, https://www.srcity.org/856/Water-Supply-Planning, accessed August 16, 2024.
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Senate Bill (SB) 610 and SB 221 were enacted to 1) ensure better coordination between local water supply and land use decisions and 2) confirm that there is an adequate water supply for new development. The following projects that are subject to the California Environmental Quality Act are required to prepare a Water Supply Assessment (WSA):
Residential developments consisting of more than 500 dwelling units. Shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space.
Commercial office buildings employing more than 1,000 persons or having more than 250,000 square feet of floor space.
Hotel or motel, or both, having more than 500 rooms.
Industrial, manufacturing, or processing plant or industrial park planned to employ more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area.
Mixed-use project that includes one or more of the projects specified above. Project that would demand an amount of water equivalent to, or greater than, the amount of water required for 500 dwelling units.
SB 221 requires written verification that there is sufficient water supply available for new residential subdivisions that include over 500 dwelling units. The verification must be provided before commencement of construction for the project.
Sustainable Groundwater Management Act of 2014
In the midst of a major drought in 2014, a three-bill legislative package was signed into law, collectively known as the Sustainable Groundwater Management Act (SGMA). The Governor’s signing message states “a central feature of these bills is the recognition that groundwater management in California is best accomplished locally.” Under SGMA, local and regional agencies in groundwater basins that are designated as medium and high priority must form groundwater sustainability agencies (GSA) that oversee the preparation and implementation of groundwater sustainability plans (GSP).
Most of the EIR Study Area is within the Santa Rosa Plain Groundwater Subbasin, which is one of three subbasins within the larger Santa Rosa Valley Groundwater Basin. The two other groundwater subbasins in the EIR Study Area along the eastern edge of the city are the Santa Rosa Valley–Rincon Valley Subbasin and the Kenwood Valley Subbasin. These subbasins are designated as very low priority and are not required to prepare a GSP .
The City of Santa Rosa formed a GSA with Sonoma County Water Agency (Sonoma Water); Sonoma County; the cities of Cotati, Rohnert Park, and Sebastopol; the town of Windsor; Gold Ridge Resources Conservation District; Sonoma Resource Conservation District; and an organized group of mutual water SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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and public utilities regulated companies (known as Independent Water Systems). The GSP was prepared in December 2021 and was approved by the Department of Water Resources (DWR) in January 2023.4 Water Conservation Act of 2009
The Water Conservation Act of 2009 (SB X7-7) requires all urban retail water suppliers to increase water use efficiency. The legislation sets an overall goal of reducing per capita water use by 20 percent by 2020, with an interim goal of a 10 percent reduction in per capita water use by 2015. Effective in 2016, urban retail water suppliers who do not meet the water conservation requirements established by this bill are not eligible for State water grants or loans. The SB X7-7 requires that urban water retail suppliers determine baseline water use and set reduction targets according to specified standards. Demonstration of compliance with this regulation is a required component of each urban water supplier’s UWMP. The City of Santa Rosa is in compliance with its target reduction. 2018 Water Conservation Legislation
In 2018, the California Legislature enacted two policy bills (SB 606 and Assembly Bill [AB] 1668) to establish a regulatory framework for “Making Conservation a California Way of Life.” The framework addresses both urban and agricultural water use and seeks to implement state-wide, long-term improvements in water conservation and drought planning to adapt to climate change and longer and more intense droughts in California.
5 Overall, the framework is intended to ensure California is resilient to a hotter and drier climate with anticipated periods of water scarcity, and lessen the need for emergency water use reductions that have been previously enacted by SWRCB during periods of drought.
Specific to urban retail water suppliers, DWR and SWRCB were tasked with establishing new water use efficiency standards for:
Indoor residential water use;
Outdoor residential water use;
Commercial, industrial, and institutional water use for landscape irrigation with dedicated meters; and Water loss.
The indoor residential water use standard was set in statute with the passage of SB 1157 in 2022. As a result, California Water Code defines a 55-gallon-per-person daily standard for indoor residential use until 2025, at which time it decreases to 47 gallons, and further decreases to 42 gallons by 2030. The outdoor residential water use standard and outdoor commercial water use standard, established as landscape efficiency factors, become progressively more efficient across three timesteps as presented in Table 4.17- 1, Outdoor Water Use Standards for Residential and Commercial Accounts. The water loss standard is the maximum allowable “real” water loss measured in gallons per connection per day for each supply system
4 Santa Rosa Plain Groundwater Sustainability Agency, Groundwater Sustainability Plan, https://santarosaplaingroundwater.org/gsp/, accessed August 12, 2023. 5 California Department of Water Resources, 2021, 2018 Water Conservation Legislation, https://water.ca.gov/Programs/Water-Use-And-Efficiency/2018-Water-Conservation-Legislation, accessed August 23, 2023.
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in an urban water supplier’s service area. Real losses are defined as the volume of annual leakage due to physical water leakage in a supplier’s distribution system.
TABLE 4.17-1 OUTDOOR WATER USE STANDARDS FOR RESIDENTIAL AND COMMERCIAL ACCOUNTS Year Residential Landscape Efficiency Factors Commercial Landscape Efficiency Factors Present – 6/30/2035 a 0.80 0.80
7/01/2035 – 6/30/2040 0.63 0.63
7/01/2040 – Onward 0.55 0.45
Note:
a. The outdoor commercial water use standard becomes effective July 1, 2028. Prior to this date, the outdoor commercial water budget is equal to actual annual deliveries made to all accounts with dedicated irrigation meters.
Source: California Department of Water Resources, 2021, 2018 Water Conservation Legislation, https://water.ca.gov/Programs/Water-Use-And- Efficiency/2018-Water-Conservation-Legislation, accessed August 23, 2023.
Collectively, the water use efficiency standards and local service are characteristics (such as population and landscape area) that establish individual Urban Water Use Objectives (UWUOs) per urban retail water supplier that cannot be exceeded on an annual basis. Urban retail water suppliers are required to calculate and report their UWUOs alongside their actual usage in an annual water use report. The first reports were due to the SWRCB on January 1, 2024, and are required every January 1 thereafter . The final proposed “Making Conservation a California Way of Life” regulation was published by the SWRCB on July 26, 2024, and is anticipated to become effective January 1, 2025.
The legislation also includes changes to UWMP preparation requirements. These changes include additional requirements for Water Shortage Contingency Plans (WSCPs), expansion of dry year supply reliability assessments to a five-year drought period, and establishment of annual drought risk assessment procedures and reporting.
Mandatory Water Conservation
Following the declaration of a state of emergency on July 15, 2014, due to drought conditions, the SWRCB adopted Resolution No. 2014-0038 for emergency regulation of statewide water conservation efforts.
These regulations, which went into effect on August 1, 2014, were intended to reduce outdoor urban water use and have all California households voluntarily reduce their water consumption by 20 percent.
Urban water suppliers with 3,000 or more service connections were required to report monthly water consumption to the SWRCB.
In January of 2022, following the Governor’s proclamation of a drought state of emergency for all counties, the SWRCB adopted the prohibited wasteful water uses emergency regulations. These include the prohibition of the following wasteful water use practices: 1) the application of potable water to outdoor landscapes in a manner that causes excess runoff; 2) the washing of vehicles without an automatic shut-off nozzle; 3) the application of potable water to driveways and sidewalks; 4) the use of potable water in nonrecirculating ornamental fountains; and 5) the application of potable water to outdoor landscapes during and within 48 hours after at least 0.25 inch of rainfall. In June of 2022 additional emergency water conservation regulations were enacted prohibiting the irrigation of non- functional turf at commercial, industrial, and institutional accounts, and the implementation of SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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conservation actions under Level 2 of urban water suppliers’ Water Shortage Contingency Plans. As of June 5, 2024, the emergency regulations expired.
In October of 2023, AB 1572 was signed into law by the Governor, prohibiting the irrigation of non- functional turf at commercial, industrial, and institutional sites (with exceptions for areas irrigated with recycled water or harvested rainwater). The irrigation prohibitions become effective in stages between 2027 and 2031, beginning with state and local government facilities. Under the law, urban water suppliers must adopt the same irrigation prohibitions into their local regulations.
Water Conservation in Landscaping Act of 2006
The Water Conservation in Landscaping Act (AB 1881) requires cities and counties to adopt the State of California’s Model Water Efficient Landscape Ordinance (MWELO) or a comparable landscape water conservation ordinance that is at least as effective as the State’s MWELO in conserving water.
The MWELO was revised in July 2015 via Executive Order B-29-15 to address the ongoing drought and to build resiliency for future droughts. The 2015 revisions to the MWELO increased water efficiency standards for new and retrofitted landscapes through more efficient irrigation systems, greywater usage, and on-site stormwater capture and by limiting the portion of landscapes that can be covered in turf. Each city and county is required to submit annual reports to DWR that document how the agency is achieving compliance with the State MWELO and how many projects were subject to the ordinance during the annual reporting period. Recently, MWELO went through a round of revisions in 2024 to reduce ambiguity and improve clarity of the requirements as well as reorganize the content to better adhere to the landscape design process. The 2024 revisions did not modify or add new requirements to MWELO.
The City of Santa Rosa adopts its own ordinance in Santa Rosa City Code (SRCC) Title 14, Chapter 14-30, Water Efficient Landscape. The ordinance applies to all new and rehabilitated landscape projects that require a building or grading permit, plan check, design review, or utilities certificate.
California Water Code
The Water Code states that the water resources of the State must be put to beneficial use and that waste or unreasonable use of water must be prevented. The code is divided into several sections for provisions regarding water quality, formation of irrigation districts and water districts, safe drinking water, and water supply and infrastructure improvements.
California Plumbing Code
The latest version of the California Plumbing Code was issued in 2022 and became effective as of January 1, 2023. The code is updated on a three-year cycle. It specifies technical standards for the design, materials, workmanship, and maintenance of plumbing systems. One of the purposes of the plumbing code is to prevent conflicting plumbing codes within local jurisdictions. Among many topics covered in the code are water fixtures, potable and nonpotable water systems, and recycled water systems. The City of Santa Rosa adopts the California Plumbing Code under SRCC Section 18-24.010, Citation of California Plumbing Code.
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California Building Code: CALGreen
The California Building Standards Commission adopted the nation’s first green building standards in July 2008, the California Green Building Standards Code, also known as CALGreen. CALGreen applies to the planning, design, operation, construction, use, and occupancy of every newly constructed building or structure in California. The code establishes building standards for sustainable site development, including water efficiency and water conservation measures that typically reduce water consumption by 20 percent.
CALGreen is updated every three years to allow for consideration and possible incorporation of new low flow plumbing fixtures and water efficient appliances. The mandatory provisions of CALGreen became effective January 1, 2011, and the latest 2022 version became effective on January 1, 2023. The building efficiency standards are enforced through the local building permit process. The City of Santa Rosa has regularly adopted each new CALGreen update under SRCC Section 18-42.010, Citation of California Green Building Standards Code.
California Health and Safety Code
A portion of the State Health and Safety Code is dedicated to water issues, including testing and maintenance of backflow prevention devices, coloring of pipes carrying recycled water, and programs addressing cross-connection control by water users.
Regional Regulations
Santa Rosa Plain Su
bbasin Groundwater Sustainability Plan
Santa Rosa is within the Santa Rosa Plain Subbasin, which has been designated as a medium-priority groundwater basin and is not in critical overdraft.
6 The City of Santa Rosa formed a GSA with Sonoma
Water, which prepared the GSP; Sonoma County; the cities of Cotati, Rohnert Park, and Sebastopol; the town of Windsor; Gold Ridge Resources Conservation District; Sonoma Resource Conservation District; and an organized group of mutual water and public utilities regulated companies (known as Independent Water Systems). The GSP was prepared in December 2021 and was approved by the DWR in January 2023.
7 The GSP establishes a standard for sustainability of groundwater management and use and lays out a management process for how the basin will achieve this standard by 2042.8
6 Department of Water Resources, SGMA Data Viewer,
https://sgma.water.ca.gov/webgis/?appid=SGMADataViewer#currentconditions, accessed April 5, 2023. 7 Santa Rosa Plain Groundwater Sustainability Agency, Groundwater Sustainability Plan, https://santarosaplaingroundwater.org/gsp/, accessed August 12, 2023. 8 Santa Rosa Plain Groundwater Sustainability Agency and Sonoma Water, December 2021, Groundwater Sustainability Plan:
Santa Rosa Plain Groundwater Subbasin, http://santarosaplaingroundwater.org/wp-content/ uploads/000_Santa_Rosa_GSP_508.pdf, accessed April 5, 2023.
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Sonoma Water
Sonoma Water, previously known as the Sonoma County Water Agency, provides water supply, wastewater management, and flood protection to Sonoma County. Sonoma Water is a special district that provides wholesale water supply to several cities and water districts within Sonoma and Marin Counties.
Sonoma Water mostly depends on the Russian River for water supply, with groundwater from the Santa Rosa Plain Subbasin as a secondary source (during drought conditions or when supplies from the Russian River are constrained). Sonoma Water delivers water to Santa Rosa under the provisions of the Restructured Agreement for Water Supply (Restructured Agreement), which was executed in June 2006.
Sonoma Water has water rights to extract an annual maximum of 75,000 acre-feet from the Russian River, and an annual maximum of about 3,870 acre-feet per year from three groundwater wells in the Santa Rosa Plain. Of this total available supply, Santa Rosa is currently entitled to receive a total annual volume of up to 29,100 acre-feet. This amount of water makes the City the largest consumer of water in the Sonoma Water service area.
9 In the 2020 UWMP , Sonoma Water states that there will be sufficient water supplies available to meet the demand of its water retailers for normal years and multiple dry years through 2045, with a potential shortage of water starting in 2030 for single dry years due to low water levels in Lake Sonoma and Lake Mendocino.
10 Local Regulations
Santa Rosa City Code
The SRCC includes various directives to ensure the efficient use of water in Santa Rosa. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to water supply and conservation are in Title 14, Potable and Recycled Water, and Title 18, Buildings and Construction, as follows:
Charter Chapter 26, Water and Sewer Rates, Connection/Demand Fees; and Miscellaneous Fees and Charges. The City Council is able to establish water and sewer rate changes as well as rates for connections to the City’s utility system. All funds that are collected must be used for providing services and maintenance of the City’s water and sewer systems. Chapter 14-04, Potable Water and Recycled Water Service. This chapter outlines the water services in the City and establishes the water shortage rate structure. The water shortage rate structure is how a water shortage emergency is declared and how emergency charges are implemented.
9 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
10 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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Chapter 14-08, Potable Water Rates. This chapter establishes the rates for the delivery of potable water and recycled water as well as the fixed monthly charges. This chapter also specifies the fire line protection service charge for lines that connect to the City’s potable water system. Chapter 14-12, Wells. This chapter provides procedures and regulations for the construction, placement, and destruction of existing and abandoned water wells, test wells, test holes, and excavations. Permits are required for these activities. In addition, all developed parcels in zones of groundwater contamination are required to connect to the City’s potable water supply system.
Chapter 14-25, Recycled Water Regulations. This chapter states that all areas served by potable water service within the Recycled Water Project Area are eligible for recycled water service, and the City reserves the right to require customers to use recycled water in lieu of potable water for approved uses. The City maintains and updates a Recycled Water User’s Guide that details the requirements and rules for the City’s recycled water system. The City also issues a Recycled Water Use Permit to each site, which grants permission to use recycled water in accordance with the rules, regulations, and standards.
Chapter 14-30, Water Efficient Landscape. This chapter establishes the City’s Water Efficient Landscape Ordinance (WELO) as required by California’s Government Code Section 65591, which requires local agencies to adopt water efficient landscape regulations. The WELO, which initially went into effect January 2010 was most recently updated in 2016. The chapter applies to all new public and private projects with landscaping that require a building or grading permit, plan check, design review, or utilities certificate. This includes office, commercial, industrial, and institutional landscaping; park and greenbelt landscaping; multiple-family residential; and single-family residential developments. Chapter 18-24, California Plumbing Code. This chapter adopts the California Plumbing Code which specifies technical standards for the design, materials, workmanship, and maintenance of plumbing systems, including requirements for water conservation systems. Chapter 18-42, California Green Building Standards Code. This chapter adopts by reference, with the additions, insertions, deletions and changes listed throughout, the California Green Building Standards Code which establishes building standards for sustainable site development, including water efficiency and water conservation measures that typically reduce water consumption by 20 percent.
Santa Rosa 2020 Water Master Plan Update
The 2020 Water Master Plan (WMP) Update is an update to the 2014 WMP and was triggered by the events during the 2017 Tubbs Fire. The goal of the WMP Update is to develop and implement water reliability measures to minimize loss of service and improve recovery times under emergency operating conditions. The report includes a systemwide fire flow evaluation and methods to improve system reliability in the upper pressure zones, such as the Fountaingrove area, with pump supply and interties between pressure zones. Also included are recommendations for filling the Proctor Heights tanks more quickly. Finally, the Supervisory Control and Data Acquisition reliability and redundancy evaluation provided options for increasing the reliability and response of the system during emergency situations.
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Priorities and recommendations for system improvements are provided in Chapter 9.0 of the WMP, Recommendations and Costs.11
Santa Rosa 2020 Urban Water Management Plan
The City of Santa Rosa adopted its current 2020 UWMP in June 2021 in compliance with the Urban Water Management Planning Act, the Water Conservation Act of 2009, and Sections 10610 to 10656 of the California Water Code.12 All urban water suppliers are required to prepare, adopt, and file a UWMP with the DWR every five years.
The 2020 UWMP describes water demands, water supply sources, and supply reliability for its service area in five-year increments for normal years, single dry years, and multiple dry years. The UWMP also provides water supply contingency planning in case of shortage emergencies, demand management measures to increase water use efficiency, and current and planned water conservation efforts. The UWMP states that there will be sufficient supplies to meet existing and future demands through 2045 for normal years, but that there could be a shortage of water supplies in single-dry years and multiple-dry years under the worst-case scenario.
The City 2020 UWMP has been prepared in accordance with the Urban Water Management Planning Act.
13 The 2020 UWMP addresses the City’s water system and includes a description of the water supply sources, historical and projected water use, and a comparison of water supply to water demands during normal, single-dry, and multiple-dry years. The 2020 UWMP describes water demands, available water supply sources, and supply reliability for its service area in five-year increments for normal years, single- dry years, and multiple-dry years up to year 2045. The 2020 UWMP also provides a water shortage contingency plan, demand management measures to increase water use efficiency, and current and planned water conservation efforts.
The Water Conservation Act of 2009, also known as SBX7-7, requires that urban water suppliers reduce their per capita water use by 20 percent by 2020. As reported in the UWMP , the City met this goal in 2020 with a per capita water demand of 99 gallons per capita per day (gpcd) as compared to the target goal of 126 gpcd.
14 11 Santa Rosa Water, February 7, 2022, 2020 Water Master Plan Update: Water System Reliability Study, https://www.srcity.org/DocumentCenter/View/34912/2020-Water-Master-Plan-Update---Water-System-Reliability -Study, accessed August 24, 2023.
12 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
13 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pd, accessed August 9, 2023f.
14 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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Water Shortage Contingency Plan
The WSCP was adopted as part of the 2020 UWMP in June 2021 and amended in November 2021 to update the Excess Use Penalty structure and revise the demand offset requirements for new construction, which are described in further detail below. The revised requirement is a 1:1 ratio of water demand offset when Stages 5 through 8 of the WSCP are implemented.
The WSCP describes eight shortage levels and the corresponding demand reduction actions which would be taken to reduce water usage by a range from 10 percent to more than 50 percent. Measures include restrictions and prohibitions on end users, increased marketing and outreach to customers, water waste prevention and enforcement, rate structure changes, and aggressive promotion of existing and temporary water conservation programs, incentives, and enhancements to help customers conserve water . These measures have successfully helped the community conserve water during previous droughts, achieving on average 20 to 25 percent reduction in water use. The City has also implemented an Excess Use Penalties program to penalize usage of individual accounts that exceed water allocations. Together, these actions are anticipated to adequately reduce projected demands in a single-dry year scenario to match available supplies.
Water Demand Offset Policy
The water demand offset (WDO) policy was adopted by the City in March 2022 and applies when Stages 5 through 8 of the WSCP are implemented. It requires new construction to offset its water demand to achieve a net zero impact and applies to all new projects that will increase water demand and be subject to new or increased water connection fees. The provisions of the policy apply at the time that an application for a building permit is submitted.
15 All construction projects must complete and submit to the City a WDO application and pay the WDO Fee, which is based on the type of residential or commercial, industrial, or institutional development. The applicant can also propose an alternative compliance method with a detailed description of how the water demand offsets would be achieved and submit supporting studies, plans, reports, and/or analyses.
The City will provide a WDO Agreement that must be notarized and recorded in the Official Records of Sonoma County. Any WDO Fees collected by the City will be used to implement projects or programs to achieve the required water demand offsets, such as bathroom conversions, high efficiency residential clothes washer upgrades, or rebates for ornamental turf conversions at multi-family units or commercial, industrial, or institutional land uses.
Santa Rosa Groundwater Master Plan
The City’s Groundwater Master Plan (GMP) was prepared in 2013 prior to enactment and implementation of the SGMA and the preparation of the GSP for the Santa Rosa Plan Subbasin. However, it still provides a comprehensive resource that describes the operation of the City’s two production wells, three emergency
15 City of Santa Rosa, 2022, Water Demand Offset Policy.
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supply wells, and one landscape irrigation well.16 The GMP also provides the framework for developing a monitoring well network, development of a groundwater database, and recommended projects and programs to provide emergency groundwater supplies.
Santa Rosa Water Distribution Standard Specifications
Revised in October 2018, the Water Distribution Standard Specifications include construction specifications, standard plans, and the regulations for separation between water mains and non-potable pipelines. Also, the Water Distribution Standard Specifications include distribution system design standards for water mains, connections to water mains, sizing criteria, soil cover, valves, laterals, meters, fire hydrants, and pressure requirements.
17 Established to assist developers and their engineers, the Water Distribution Standard Specifications provides guidelines for the design of water mains, laterals, and connections, and establishes the minimum acceptable design criteria. More stringent requirements may be imposed by Santa Rosa Water based on specific project conditions.
Recycled Water Standards
Revised in October 2018, the Recycled Water Standards include design standards, standard plans, construction specifications, and an engineer’s list of approved items. 18 Established to assist developers
and their engineers, the Recycled Water Standards provide procedures and guidelines for the design and construction of recycled water mains and connections and establishes the minimum acceptable design criteria. More stringent requirements may be imposed by Santa Rosa Water based on specific project conditions.
Capital Improvement Program
The Capital Projects Engineering Division is responsible for the design and construction of projects to rehabilitate, upgrade, and expand the City’s infrastructure, including sewer collection system projects and Laguna Treatment Plant projects. The capital projects are funded primarily through sewer and water rates, development fees, and grants. The City’s Capital Improvement Program (CIP) is a five-year financial plan for the maintenance and expansion of the City’s infrastructure. The CIP identifies public facility improvements that are needed, provides a design and construction schedule, and identifies funding for these projects.
19 Some of the CIP programs that have currently been approved and are in the planning or construction phase include the following water infrastructure projects:
16 City of Santa Rosa, September 2013, Groundwater Master Plan, https://www.srcity.org/DocumentCenter/View/14031/Groundwater---2013-Master-Plan, accessed August 23, 2023. 17 City of Santa Rosa, October 18, 2018, Water Distribution Standard Specifications, https://www.srcity.org/DocumentCenter/View/18370/Water-Design-Standards, accessed August 24, 2023. 18 City of Santa Rosa, October 18, 2018, Recycled Water Standards, https://www.srcity.org/DocumentCenter/View/17624/Recycled-Water-Design-Standards, accessed August 24, 2023. 19 City of Santa Rosa, 2023, Capital Improvement Program, https://www.srcity.org/690/ Capital-Improvement-Program, accessed August 29, 2023.
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Cobblestone Drive Zone R2-R4 Water Main Connection: To improve fire protection in Cobblestone neighborhood.
Cleveland Avenue and St. Rose District Sewer and Water Improvements. Emergency Well Pump Station—A Place to Play: Convert existing test well to emergency groundwater well along with design and construction of a well pump station. Geysers-Delta Pond Connection Improvements: Upsize water main to allow higher flows of recycled water to be delivered to Delta Pond.
Slater Street and Lewrosa Way Sewer and Water Main Replacement Project. Terra Linda and Buena Vista Sewer and Water Replacement. Emergency Groundwater Supply Development.
North Trunk Sewer Replacement and Water Main Upgrade. Albany, Clement and Malano Sewer and Water Improvements. E. Haven Drive Sewer and Water Improvements in Grace neighborhood. Controller and Radio Upgrades at Water Pump Stations. Emergency Groundwater Wells at Oakmont Treatment Plant and Speers Roads. Seismic Upgrades and Improvements at Reservoirs F9A and R16 and Fire Pump Additions. Backup Generators at Water and Wastewater Facilities. Dotti Farm Recycled Water Pipeline Improvements.
Existing Conditions
Santa Rosa Water is the urban water supplier for the EIR Study Area. Sonoma Water is the wholesale water provider to the City and supplies primarily surface water from the Russian River . The GSAs, including the City and Sonoma Water, have the responsibility and authority to manage groundwater in the EIR Study Area. Santa Rosa Water also coordinates and conducts water conservation programs within the City’s service area. A WSA has been prepared for the proposed General Plan 2050 on July 10, 2023, by Santa Rosa Water and is provided in Appendix D, Water Supply Assessment, of this Draft EIR. However, information in this section has been updated slightly to reflect minor changes in conditions, Water Distribution System
Santa Rosa Water operates and maintains a potable water distribution system within the EIR Study Area that consists of 20 booster pump stations, 624 miles of water mains, 24 aboveground reservoirs (tanks), 6 groundwater wells, a well treatment facility, and over 54,000 service connections. The existing water distribution system is shown on Figure 4.17-1, Water Distribution System.
Santa Rosa Water also owns, maintains, and operates a recycled water distribution system that provides nonpotable water for landscape irrigation to 32 connections, including multi-family residences, commercial, and institutional/governmental customers.
20 The City’s water distribution system is divided
into 18 major pressure zones and serviced by 624 miles of water mains ranging in size from 4 to 24 inches.
20 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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Most connections are served by laterals that branch from 6-inch- to 12-inch diameter-water mains. Pipe materials consist of asbestos cement, polyvinyl chloride (PVC), high-density polyethylene (HDPE), ductile iron, and cement mortar lined and coated steel. Water is delivered to Santa Rosa Water through a transmission and delivery system owned and operated by Sonoma Water, as shown previously on Figure
4.17-1. There are several Sonoma Water aqueducts and pipelines that traverse the EIR Study Area and connect to Santa Rosa Water through a series of turnouts, check valves, and direct connections serving City pump stations. There are 59 physical connections between the City’s distribution system and Sonoma Water’s system, including 39 pressure-reducing valves, 16 check valves, and 4 pumping stations.21 The 2014 WMP provided a hydraulic model of the existing distribution infrastructure and recommended improvements needed for future buildout and to meet fire flow requirements. Many of these improvements have since been implemented through the City’s CIP . An update to the WMP was prepared in 2020 and evaluates fire flow performance, system reliability, water quality, and Supervisory Control and Data Acquisition reliability and redundancy.
22 The recommendations include fire flow improvements in areas where the fire flow goals of 1,500 gallons per minute (gpm) at pressures of 20 pounds per square inch for a duration of two hours cannot currently be met and include fire flow facility improvements for tanks and pump stations to meet fire flow goals in four pressure zones. Also included are opportunities to increase the reliability of the distribution system by adding pumps, interties between pressure zones, and utilizing the Proctor Heights Tanks.
Water Supply Sources
Santa Rosa Water currently has three sources of water supply: 1) potable water from Sonoma Water (a regional water wholesaler); 2) groundwater from the City’s wells, and 3) non-potable water (recycled water) from the Santa Rosa Regional Water Reuse System for urban landscape irrigation. 23 Approximately 93 percent of the City’s potable water supply is purchased from Sonoma Water under the provisions of the Restructured Agreement for Water Supply, which was executed in June 2006. Sonoma Water obtains almost all of its water supplies as surface water from the Russian River (approximately 99 percent). The rest of the water supplied by Sonoma Water is pumped from three groundwater wells in the Santa Rosa Plain Subbasin. However, none of the groundwater is delivered to Santa Rosa; it feeds into the Cotati Aqueduct.
21 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
22 Santa Rosa Water, February 7, 2022, 2020 Water Master Plan Update: Water System Reliability Study, https://www.srcity.org/DocumentCenter/View/34912/2020-Water-Master-Plan-Update---Water-System-Reliability -Study, accessed August 24, 2023.
23 City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
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Figure 4.17-1
Water Distribution System
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024. 0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
SCWA Aqueduct
City Pipelines
≤ 8-inch diameter
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UTILITIES AND SERVICE SYSTEMS
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Santa Rosa Water produces approximately seven percent of its potable water supply from six groundwater wells. Two of the wells are actively pumped (Farmers Lane Wells Nos. W4-1 and W4-2 and three (Carley, Peter Springs, and Leete) are emergency potable supply wells that are operated to provide landscape irrigation to an adjacent park and school landscaping, and augment supplies in Lake Ralphine (Howarth Park). These wells are available and approved by the California Division of Drinking Water to be on standby for emergency potable use. One well (Farmers Lane Well No. 3) is operated to provide minor amounts of landscape irrigation only. A summary of the wells and their status is provided in Table 4.17-2, Santa Rosa Municipal Groundwater Wells.
TABLE 4.17-2 SANTA ROSA MUNICIPAL GROUNDWATER WELLS
Well Name/Number Well Status
Farmers Lane (W4-1) Active
Farmers Lane (W4-2) Active
Farmers Lane (W4-3) Not connected to City’s potable water distribution system; used strictly for minor landscape irrigation Carley (W2-1) Used for landscape irrigation and on standby for emergency potable water supply Peter Springs (W2-2) Used for landscape irrigation and on standby for emergency potable water supply Leete (W1) Used for landscape irrigation and on standby for emergency potable water supply Source: City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
Santa Rosa Water also has two additional municipal wells that are either out of service or inactive. The Freeway Well (W3) is out of service due to groundwater contamination and the Sharon Park Well (W6) is inactive due to severe sanding. A state funded study of the Freeway Well contamination issue recommended that the well be formally abandoned to reduce the risk of the well acting as a “conduit” for migration of the contaminant plume. A capital project is proceeding to properly abandon this well consistent with county well ordinance standards. For the past three years, the City has pumped between 1,126 and 1,323 acre-feet per year (AFY) of groundwater for its municipal water supply. The California Division of Drinking Water has permitted the City’s groundwater wells for production of up to 2,300 AFY of potable water supply.
24 Additionally, the City owns and operates the Laguna Treatment Plant Regional System, which provides high quality tertiary treated water that is approved for irrigation of urban landscapes, playgrounds, golf course, public parks, agricultural crops, and vineyards. Most of the recycled water is piped to Sebastopol and Rohnert Park as well as to the Geysers Recharge Project and to farmlands and vineyards outside of the city limits of Santa Rosa. In 2020, the City used approximately 108 AFY of recycled water within its service area and the projected future use of recycled water through 2045 is expected to be about 140 AFY , accounting for less than 1 percent of urban water use.
A summary of the existing and future sources of water for the City is provided in Table 4.17-3, City of Santa Rosa Existing and Future Water Supplies (acre-feet).
24 City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
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TABLE 4.17-3 CITY OF SANTA ROSA EXISTING AND FUTURE WATER SUPPLIES (ACRE-FEET) Water Supply Sources 2020 2025 2030 2035 2040 2045
Surface Water (from Sonoma Water) 18,024 29,100 29,100 29,100 29,100 29,100 Groundwater (from City wells) 1,253 2,300 2,300 2,300 2,300 2,300 Recycled Water (for urban use only) 110 140 140 140 140 140 Total 19,387 31,540 31,540 31,540 31,540 31,540
Source: City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
In addition to the existing water supply, in October 2023, the City completed an adaptive Water Supply Alternatives Plan.25 The first objective identified in the Water Supply Alternatives Plan was to establish a water supply resiliency and reliability goal for Santa Rosa’s future, informed by discussions with the City’s Water Department staff, an external group of community leaders, the community at large, and the Board of Public Utilities. The City created a goal of expanding and diversifying its potable water supply portfolio to enhance its resiliency and mitigate the potential impacts of future water supply shortages caused by severe and/or prolonged droughts or catastrophic service interruptions. New supplies could augment existing City groundwater production capacity (approximately 1,300 AFY , with an average of 2 million gallons per day over approximately 6.5 months per year). This is an ongoing project that has not been fully studied as of the release of this Draft EIR.
Existing Water Demand
Table 4.17-4, Santa Rosa 2020 Existing Water Demand, presents the water demand for 2020, as presented in the 2020 UWMP for the EIR Study Area. Single-family homes represent over half of the 2020 total demand at 51 percent. Multifamily homes account for about 17 percent of the total demand. Commercial, industrial, and institutional/governmental represent a combined 14 percent of total demand. 26 Water
losses account for approximately 7 percent of the water demand and the other category includes billed uses, such as fire lines, construction meters, and municipal yard meters, and unbilled uses, such as firefighting and hydrant flushing. In addition, the City of Santa Rosa used 110 acre-feet of recycled water in 2020 for urban irrigation uses.
TABLE 4.17-4 SANTA ROSA EXISTING WATER DEMAND
Land Use AFY
Single Family 9,863
Multi-Family 3,309
Commercial 2,020
Industrial 304
Institutional/Governmental 308
25 City of Santa Rosa, Our Water Future, www.srcity.org/OurWaterFuture, accessed June 2024. 26 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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TABLE 4.17-4 SANTA ROSA EXISTING WATER DEMAND
Land Use AFY
Landscape 1,991
Losses 1,284
Other 198
Recycled Water 110
Total 19,387
Note: AFY = Acre-feet per year
Source: Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
Water agencies must also demonstrate compliance with their established water use targets, pursuant to SB X7-7. The calculated water use target for Santa Rosa is 126 gpcd. The actual 2020 demand was 99 gpcd. Thus, the City successfully met the 2020 target.27 Water Supply Reliability
As reported in the 2020 UWMP , Table 4.17-5, Santa Rosa Projected Normal, Dry, and Multiple Dry Year Supply and Demand (AFY), provides the project water demand and supply in the Santa Rosa Water service area for a normal year, single dry year, and multiple dry years from 2025 through 2045.
TABLE 4.17-5 SANTA ROSA PROJECTED NORMAL, DRY, AND MULTIPLE DRY YEAR SUPPLY AND DEMAND (AFY) 2025 2030 2035 2040 2045
Normal Year
Supply Total 31,540 31,540 31,540 31,540 31,540
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 9,880 8,457 7,888 7,211 6,443
Single Dry Year a
Supply Total 22,660 20,639 20,937 20,978 21,689
Demand Total 21,660 20,639 20,937 20,978 21,689
Difference 1,000 0 0 0 0
Multiple Dry Years a
First Year
Supply Total 22,660 24,083 24,652 25,329 26,097
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 1,000 1,000 1,000 1,000 1,000
Second Year
Supply Total 22,660 24,083 24,652 25,329 26,097
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 1,000 1,000 1,000 1,000 1,000
27 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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TABLE 4.17-5 SANTA ROSA PROJECTED NORMAL, DRY, AND MULTIPLE DRY YEAR SUPPLY AND DEMAND (AFY) 2025 2030 2035 2040 2045
Third Year
Supply Total 22,660 24,083 24,652 25,329 26,097
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 1,000 1,000 1,000 1,000 1,000
Fourth Year
Supply Total 22,660 24,083 24,652 25,329 26,097
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 1,000 1,000 1,000 1,000 1,000
Fifth Year
Supply Total 22,660 24,083 24,652 25,329 26,097
Demand Total 21,660 23,083 23,652 24,329 25,097
Difference 1,000 1,000 1,000 1,000 1,000
Note: AFY = Acre-feet per year.
a. Single and multiple dry years assume implementation of WSCP Stage 1 reductions of 10 percent.
Source: Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
As shown in Table 4.17-5, there will be a surplus of water available during normal years, with Sonoma Water supplying 29,100 AFY , the City pumping up to 2,300 AFY of groundwater, and a recycled water supply of 140 AFY . During a single-dry year, Sonoma Water projects that Santa Rosa’s water allotment could be reduced by 16 to 19 percent. However, the City would implement the WSCP to reduce customer demands to match available supplies for the years 2030 through 2045. Sonoma Water’s 2020 UWMP does not anticipate a reduction in supplies to its retail customers for multiple dry years. Therefore, the City’s water supply would not exceed demand and there would be surplus water available through 2045 for multiple dry year events.
28 STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impact to water supply if it would:
1. Require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects.
2. Not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.
3. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to water supply.
28 Sonoma Water, 2021, 2020 Urban Water Management Plan, https://www.sonomawater.org/ media/PDF/Water%20Resources/Water%20Supply/UWMP/Sonoma%20Water%202020%20UWMP_June%202021-ADA.pdf, accessed August 9, 2023.
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IMPACT DISCUSSION
USS-1 Implementation of the proposed project would not require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects.
Implementation of the proposed project would have a significant impact if it would result in the construction of new water treatment facilities or the expansion of existing facilities that would have a significant effect on the environment. With implementation of the proposed project water demand would increase throughout the EIR Study Area due to increases in population and employment.
The current and projected water demands from the 2020 UWMP are provided in Tables 4.17-3 and
4.17-4. Buildout under the proposed project would result in increases in single-family and multifamily residences as well as new retail, commercial, office, industrial, and public/institutional land uses. The net increase in housing units and commercial/industrial/institutional square feet associated with the proposed General Plan 2050 is provided in Table 4.17-6, Proposed General Plan 2050 Buildout. The City subsequently prepared a WSA based on the information provided in this table to evaluate the water demand and available supplies with implementation of this project, as discussed in the following section.
The WSA is provided in Appendix D, Water Supply Assessment, of this Draft EIR.
TABLE 4.17-6 PROPOSED GENERAL PLAN 2050 BUILDOUT
Land Use Net Increase Units
Detached Residential 11,810 Dwelling Units
Attached Residential 12,280 Dwelling Units
Retail 945,000 Square Feet
Office 2,100,000 Square Feet
Industrial 1,500,000 Square Feet
Public/Institutional 727,000 Square Feet
Park/Public Landscape 3,092,760 Square Feet
Hotels 69 Rooms
Education 4,797 Students
Source: City of Santa Rosa, Planning & Economic Development, 2023.
Water Demand Analysis
The proposed increase in water demand is summarized in Table 4.17-7, Water Demand Increase: Proposed General Plan 2050. The detailed discussion and calculations are provided in Appendix D, Water Supply Assessment, of this Draft EIR. The City uses a Residential Equivalency Factor (REF) consistent with the land uses provided in Table 4.17-7. One REF is equivalent to the average water use of one detached residential unit per year, which is estimated to be 65,345 gallons per year . Attached residential water use requires minimal landscape irrigation and averages to be about 70 percent of the detached residential water use.
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Non-residential land use categories were converted to REFs based on land use and equivalent water use per the California Water Code 10912(a).
TABLE 4.17-7 WATER DEMAND INCREASE: PROPOSED GENERAL PLAN 2050 Land Use DUs Square Feet Rooms/Students
REF Conversion
Factor REFs
Detached Residential 11,810 - - 1 REF/unit 11,810
Attached Residential 12,280 - - 0.7 REF/unit 8,575
Retail - 945,000 - 1 REF/1000 SF 945
Office - 2,100,000 - 1 REF/500 SF 4,200
Industrial - 1,500,000 - 1 REF/1,300 SF 1,154
Public/Institutional - 727,000 - I REF/500 SF 1,454
Hotel - - 69 0.75 REF/room 52
Education - - 4,797 0.11 REF/student 536
Total 24,090 8,364,760 - - 29,823
Total - AFY 6,484
Notes: AFY = Acre-feet per year; REF = Residential Equivalency Factor.
Source: City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
The proposed project would result in a water demand increase of 29,823 REFs x 65,345 gallons per REF, for a total of approximately 5,980 AFY of additional demand. The project water demand should also include non-revenue water, which historically accounts for about 7 percent of total water sales and a small adjustment of 0.8 percent to account for other miscellaneous water sales. Nonrevenue water includes water used for fire protection and training, water system flushing, sewer cleaning, system leaks, and water used by unauthorized connections and meter inaccuracies. Miscellaneous water sales occur through municipal yard meters and temporary water meters (primarily for construction sites). The addition of nonrevenue water (454 AFY) and other sales (50 AFY) increased demand by 504 AFY , bringing the total project demand to 6,484 AFY . Table 4.17-8, Total Water Demand, 2050, provides the baseline water demand plus the net increase for buildout of the proposed project to generate the total water demand in 2050.
TABLE 4.17-8 TOTAL WATER DEMAND, 2050
Land Use AFY
Baseline Water Demand (2019) 17,832
General Plan – Net Increase 6,484
Total 2050 Water Demand 24,316
Note: AFY = Acre-feet per year.
Source: City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
The projected water demand in 2050 with buildout of the proposed project of 24,316 AFY is less than the projected water demand in the 2020 UWMP of 25,097 AFY for the year 2045 under normal conditions.
Therefore, the projected increases in population, housing units, and building construction have been accounted for in the 2020 UWMP . However, to determine long-term reliability of water supplies, the analysis must also consider single dry years and multiple dry years. A detailed analysis of the normal year, SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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single dry year, and multiple dry year scenarios is presented in the City’s WSA, which is provided in Appendix D, Water Supply Assessment, of this Draft EIR, and summarized in Table 4.17-9, Water Supply and Demand with Proposed General Plan 2050 Buildout (AFY).
TABLE 4.17-9 WATER SUPPLY AND DEMAND WITH PROPOSED GENERAL PLAN 2050 BUILDOUT (AFY) 2028 2033 2038 2043
Normal Year
Supply Total 31,540 31,540 31,540 31,540
Demand Total 20,032 21,269 22,796 24,316
Difference 11,508 10171 8,744 7,224
Single Dry Year
Supply Total 21,447 20,818 20,962 21,405
Demand Total 20,032 21,369 22,796 24,316
Difference 1,415 -552 -1,834 -2,911
Multiple Dry Years
Supply Total 23,514 24,424 25,058 25,790
Demand Total 20,032 21,369 22,796 24,316
Difference 3,481 3,055 2,263 1,474
Note: AFY = Acre-feet per year
Source: City of Santa Rosa, July 10, 2023, SB 610 Water Supply Assessment (WSA) for the Santa Rosa General Plan 2050. See Appendix D, Water Supply Assessment, of this Draft EIR. Note that information summarized here from the WSA has been updated slightly to reflect minor changes in conditions.
While no shortage of water supplies would occur under normal years or a consecutive five-year drought, a shortage is expected to occur under a single dry year scenario beginning in 2031. Water shortages would range from about 3 percent to 12 percent of the water supplies and would easily be addressed by implementing the City’s WSCP . Shortage Levels of 1 to 3 would result in a reduction of water use between 10 and 20 percent, which would account for the potential shortage of water supplies in a single dry yea r.
The City may also implement the WDO policy for new construction and the Excess Use Penalties program for excessive water usage. These actions are anticipated to reduce projected demands in a single-dry year scenario to match available supplies. The WSA concludes that the City has adequate existing water supplies to meet the demands of the proposed project plus existing demands with implementation of demand management measures as needed during dry years.
The surface water that the City purchases from Sonoma Water is of high quality and does not require treatment other than the addition of chlorine for residual disinfection and sodium hydroxide to adjust the pH. Sonoma Water pumps water from the Russian River in a process called riverbank filtration. Six collector wells are located beneath the riverbed at depths of about 100 feet below ground surface, and the water is pumped through natural sands and gravels that act as a filtering system. In addition to Sonoma Water’s sampling program, Santa Rosa Water collects weekly water quality samples from the City’s distribution system for testing. The water supplied to Santa Rosa Water customers meets or exceeds all state and federal drinking water standards.
There are no water treatment plants that supply water to Sonoma Water or Santa Rosa Water; therefore, implementation of the proposed project would not require new water treatment facilities. Also, Sonoma Water and Santa Rosa Water’s current water transmission and distribution systems are adequate for meeting the existing and future needs of their respective service areas. In addition, both water providers have robust CIPs to expand and upgrade their distribution systems to accommodate potential future SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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development. Accordingly, no new water treatment or distribution facilities would be needed, and Santa Rosa Water would monitor and upgrade the water distribution system with projects described in the CIP to accommodate potential future development. As such, no significant impact would occur .
In addition, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050 contains goals, policies, and actions that require planning and development decisions to consider impacts to water supplies and resources. The following goal, policies, and actions would serve to minimize potential adverse impacts to water supplies with future development:
Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.1: Ensure water quality, water service delivery, and wastewater treatment are sufficient to meet the needs of current and future residents.
Action 5-9.1: Continue to use high-quality water from the Sonoma Water aqueduct system as the primary water supply.
Action 5-9.2: Continue to require that water supply capacity and infrastructure are in place prior to occupancy of new development.
Action 5-9.3: Maintain water, wastewater, and recycled water system integrity and capacity by continuing to prioritize maintenance and preserve funding for maintenance, rehabilitation, and replacement of existing infrastructure.
Action 5-9.4: Evaluate cost and other implications of new initiatives to avoid impacting funding and resources needed for proper management of existing infrastructure. Action 5-9.5: Ensure that new programs and infrastructure do not impact funding of existing infrastructure maintenance, rehabilitation, and replacement. Action 5-9.6: Study the impacts of potential future annexations on water delivery and on the collection and treatment of wastewater .
Action 5-9.7: Decline requests for extension of water beyond the Urban Growth Boundary, except in cases of existing documented health hazards and in areas where the City has entered into prior contractual agreements to provide services, in collaboration with the County and Local Agency Formation Commission (LAFCO).
Action 5-9.8: Evaluate the City’s long-term water supply strategies, including development of new sources of water supply, enhanced water-efficiency programs, and implementation of appropriate growth-control measures, if deemed necessary by the City. Action 5-9.9: Work with State agencies to identify water quality issues and apply for remediation funds, as needed.
Action 5-9.10: Implement the Water Supply Alternatives Plan to mitigate potential impacts of climate change, drought, and natural or human-caused catastrophic events by enhancing water supply resiliency and reliability.
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Action 5-9.11: Continue working with the Santa Rosa Plain Groundwater Sustainability Agency to implement the Groundwater Sustainability Plan and achieve sustainability of local groundwater resources.
Policy 5-9.2: Maintain water quality and encourage Santa Rosa Water customers to save water. Action 5-9.12: Regularly monitor water quality to maintain high levels of water quality for human consumption and for other life systems in the region. Action 5-9.13: Require new development projects to provide water-efficient landscaping in accordance with the City’s Water Efficient Landscape Ordinance. Action 5-9.14: Continue to comply with statewide regulations for long- term urban water use efficiency.
Action 5-9.15: Promote water efficiency through public education, incentives, rebates, technical assistance, and information about indoor and outdoor water use efficiency measures.
Action 5-9.16: Provide information and explore incentive opportunities to encourage property owners to install catchment, graywater systems, and other water recycling systems; remove paving; and install low-impact development features, such as permeable pavers, bioswales, and other green infrastructure components.
Policy 5-9.3: Ensure that water distribution lines are adequate for existing and future populations. Action 5-9.17: Continue to require that developers improve water distribution infrastructure if needed to serve the demands of new development.
Action 5-9.18: Continue to identify funding sources for water infrastructure projects on the Capital Improvement Program list.
Action 5-9.19: Evaluate both the upfront (capital) and ongoing maintenance cost commitments of new projects and/or programs prior to approval. Action 5-9.20: Evaluate costs and benefits of new and existing water projects before diverting funding/resources needed for proper management of existing infrastructure. Action 5-9.21: Actively maintain an inventory of existing infrastructure and operations and maintenance requirements (staffing and budget) in addition to capital, operations, and maintenance needs of planned infrastructure.
Policy 5-9.4: Ensure that adequate wastewater capacity is available to serve existing and future needs of the city.
Action 5-9.28: Improve stormwater management to increase infiltration, provide treatment, promote groundwater recharge, reduce flood risk, capture trash, and enhance the environment.
Action 5-9.29: Implement mitigation measures to mimic the pre-development water balance through infiltration, evapotranspiration, and capture and reuse of stormwater .
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Action 5-9.30: Evaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks. Action 5-9.32: Employ a multi-benefit “one-water” approach for new capital projects to include stormwater quality (low-impact development features) on a large scale, flood mitigation, creek restoration, and increased groundwater recharge. Policy 5-9.6: Identify and work with partners to address impacts from groundwater threats and solid waste.
Action 5-9.39: Consult with appropriate regional, State, and federal agencies to monitor water quality and address local sources of groundwater and soil contamination, including underground storage tanks, septic tanks, and industrial uses, as necessary, to achieve State and federal water quality standards.
Action 5-9.41: Identify solid waste and hazardous waste facilities that do not comply with standards for preventing contamination of air, water, and soil with hazardous waste, and work with owners to upgrade those facilities to meet those standards, prioritizing facilities in Equity Priority Areas.
In summary, because no new water treatment or distribution facilities would be needed to accommodate potential future development, and compliance with the City’s requirements for new construction, water- efficient landscaping, and the proposed General Plan 2050 goal, policies, and actions listed above, impacts would be less than significant with respect to the need for new and/or expanded water facilities.
Significance without Mitigation: Less than significant.
USS-2 Implementation of the proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years.
As previously shown in Table 4.17-8, the water demand for implementation of the proposed project was estimated to be an additional 6,484 AFY . Adding this increase to the existing demand results in a water demand of 24,316 AFY in 2050. This is less than the projected water demand presented in the 2020 UWMP of 24,957 AFY for the year 2045.
To ensure that there would be sufficient water available for implementation of the proposed project, Santa Rosa Water also prepared a WSA, which is provided in Appendix D, Water Supply Assessment, of this Draft EIR. The WSA concluded that the City has adequate water supplies to meet existing demands plus the additional demand associated with the proposed project, with the implementation of demand management measures as needed during dry years.
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As described under impact discussion USS-1, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider impacts to water supplies and resources. The same proposed General Plan 2050 goal, policies, and actions listed under impact discussion USS-1 would also contribute to ensuring sufficient water supplies to serve the proposed project.
Additionally, potential future development over the buildout horizon of the proposed project would be required to implement the water-efficient requirements of the California Plumbing Code (SRCC Chapter 18-24) and CALGreen (SRCC Chapter 18-42) as well as the MWELO (SRCC Chapter 14-30) requirements for water efficient landscaping. Future projects that meet the criteria under California Water Code Section 10912 would be required to prepare a WSA that demonstrates that project water demands would not exceed water supplies. In addition, residential, commercial, and industrial water usage can be expected to decrease in the future as a result of the implementation of water conservation practices. In the case of a water shortage, the City would implement the WSCP , as outlined in the 2020 UWMP. This includes enacting the WDO Policy for new construction when water shortages are at Stages 5 through 8 and Excess Use Penalties for customers that use more than their allocation. The City would continue to implement conservation efforts, demand management measures, and water use restrictions as per the WSCP.
Compliance with the SRCC and proposed General Plan 2050 goals, policies and actions, implementation of the WSCP during dry periods, and continued water conservation efforts would reduce water demand with respect to water supplies. In summary, buildout associated with the proposed project would not result in a shortage of water supplies and impacts would be less than significant.
Significance without Mitigation: Less than significant.
USS-3 Implementation of the proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to water supply.
The area considered for cumulative water supply impacts is the service areas of Sonoma Water and Santa Rosa Water . Future projects within these service areas would result in increases in water demand.
However, cumulative water demands would not require building new water treatment facilities. The surface water supplied by Sonoma Water to its retail water purveyors does not require treatment other than chlorination and the addition of sodium hydroxide for pH adjustment.
All new development projects that meet the SB 610 criteria, such as residential projects with more than 500 dwelling units, would be required to prepare WSAs. The water purveyors would review such projects for adequacy of water supply and the water purveyors would update their respective UWMPs every five years to ensure that there are adequate water supplies and contingency plans for future residents and customers. All new developments would require the implementation of water efficiency and water conservation measures, pursuant to CALGreen (SRCC Chapter 18-42) and City’s WELO (SRCC Chapter 14- 30) irrigation requirements. Water supply deficits in dry years would be met by implementing the WSCPs and other water conservation efforts.
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All cumulative projects would require compliance with Sonoma County and City ordinances as well as local, State, and federal regulatory requirements. Existing and future regulations would result in a reduction in per capita water use over time, which would ensure that cumulative impacts with respect to water supply would be less than significant.
Significance without Mitigation: Less than significant.
4.17.2 WASTEWATER
ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
Clean Water Act
The CWA of 1972 regulates the discharge of pollutants into watersheds throughout the nation. It is the primary federal law that governs water pollution and is implemented by the USEPA. Under the CWA, the USEPA sets wastewater standards and makes it unlawful to discharge pollutants from a point source into any navigable waters without obtaining a permit. Point sources include any conveyances, such as pipes and man-made drainage channels, from which pollutants may be discharged.
National Pollutant Discharge Elimination System
The National Pollutant Discharge Elimination System (NPDES) permit program was established as part of the CWA to regulate municipal and industrial discharges to surface waters of the United States. Federal NPDES permit regulations have been established for broad categories of discharges, including point- source municipal waste discharges and nonpoint-source stormwater runoff. NPDES permits generally identify effluent and receiving water limits on allowable connections and/or mass emissions of pollutants contained in the discharge; prohibitions on discharges not specifically allowed under the permit; and provisions that describe required actions by the discharger, including industrial pretreatment, pollution prevention, self-monitoring, and other activities. Wastewater discharge is regulated under the NPDES permit program for direct discharges into receiving waters and by the National Pretreatment Program for indirect discharges to a wastewater (sewage) treatment plant.
State Regulations
State Water Resources Control Board
On May 2, 2006 the SWRCB adopted Statewide General Waste Discharge Requirements ([WDRs] Order No. 2006-0003) and a monitoring and reporting program (Order No. WQ-2013-0058-EXEC) for all publicly owned sanitary sewer collection systems in California with more than one mile of sewer pipes. The order provides a consistent statewide approach to reducing sanitary sewer overflows (SSO). The WDRs require public agencies that own or operate sanitary sewer systems to develop and implement sewer system
4.17.2.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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management plans (SSMP) and report all SSOs to the SWRCB’s online reporting system. The SWRCB has delegated authority to nine RWQCBs to enforce these requirements within their regions. 2021 Winery Order
The SWRCB recently developed general WDRs for winery process water for activities that generate winery waste and discharge it to land for reuse or disposal. Winery Order No. WQ 2021-002-DWQ was adopted in January 2021 and is applicable statewide. Facilities that produce wine or grape juice and generate between 10,000 and 15 million gallons of process water per year that is discharged to land for irrigation or through a septic-subsurface disposal system are required to enroll in the Winery Order . Applicants are required to submit to the SWRCB an electronic Notice of Intent that contains information on winery effluent flows and process water generation, treatment, reuse, and disposal. Applicants must also pay an application fee and an annual fee, based on process water flow rates.
Regional Regulations
North Coast Regional Water Quality Control Board
The North Coast RWQCB (Region 1) issues and enforces NPDES permits in the EIR Study Area, which includes permits for wastewater treatment plants (WWTP) and industrial waste discharges. NPDES permits allow the RWQCB to regulate where and how waste is disposed, including the discharge volume and effluent limits of waste and the monitoring and reporting responsibilities of the discharger . The RWQCB is also charged with conducting inspections of permitted discharges and monitoring permit compliance. The North Coast RWQCB reissued an NPDES permit in 2020 (Order No. R1-2020-0012) for the Santa Rosa Regional Water Reuse System and the Laguna Treatment Plant.
RWQCB Water Quality Trading Framework for Laguna de Santa Rosa Watershed The North Coast RWQCB adopted Resolution No. R1-2018-0025 in 2018 approving the Water Quality Trading Framework for the Laguna de Santa Rosa Watershed. This resolution replaces the previous Santa Rosa Nutrient Offset Program, which was established in 2008, and is available for both the City of Santa Rosa and the Town of Windsor as an approved method for complying with the “no net loading” effluent limitations for total phosphorus in the NPDES permit. This allows the City to implement ecologically beneficial projects within the watershed that offset the potential phosphorus loading from discharge for the Laguna Treatment Plant. These offset projects must be completed in advance of any discharge and have a specified life and credit time period. The recent revision to the NPDES permit (Order No. R1-2021- 0041) clarifies that credits from projects where ecological uplift is provided on permanently protected lands are no longer subject to expiration.
Local Regulations
Santa Rosa
City Code
The SRCC includes various directives that pertain to wastewater in Santa Rosa. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to wastewater are in Title 15, Sewers, and Title 20, Zoning, as follows:
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Chapter 26, Water and Sewer Rates, Connection/Demand Fees; and Miscellaneous Fees and Charges.
The City Council is able to establish water and sewer rate changes as well as rates for connections to the City’s utility system. All funds that are collected must be used for providing services and maintenance of the City’s water and sewer systems.
Chapter 15-04, Administration. This chapter describes the responsibilities of the City to maintain the wastewater collection system and the responsibilities of property owners to maintain the sewer service laterals, cleanouts, and backflow devices that connect to the City’s collection system. It also states that the owner of any parcel with a private sewage system that is within 200 feet of the City’s sewer system is required to connect to the City’s sewer system. Chapter 15-06, General and Pretreatment Enforcement. This chapter describes the enforcement mechanisms and process for undertaking enforcement actions for violators of wastewater discharge permits or pretreatment requirements. The chapter also outlines the fees for wastewater discharge permit applicants, monitoring and inspection procedures, and reviewing and responding to accidental discharges and construction.
Chapter 15-08, Pretreatment. This chapter provides a classification system for users that need to submit a wastewater discharge permit to the City based on each user’s waste quality and flow rate and provides a basis for sewer use charges. The chapter incorporates pretreatment standards in accordance with federal and State standards and local limits. The Director of Utilities may require a permit holder to prepare a slug control plan if deemed necessary.
Chapter 15-16, Sewer Connections. This chapter specifies the design criteria and standard plans and specifications that must be followed for constructing sewer service laterals or connections to the City’s sewer system. The chapter specifies connection fees and non-residential and industrial demand factors, which are the basis of the connection fees, also known as sewer demand fees.
Chapter 15-20, Sewer Charges. This chapter states that sewer charges will be levied in order to operate and maintain the existing sewer system and to provide for the expansion of the system with future development. The amounts and rate schedules for fees and charges are determined by the Board of Public Utilities and may include construction charges, connection or demand fees, sewer use permit fees, and fixed monthly service charges for sewer users. The collected fees are deposited into the wastewater capital recovery fund and the sewer utility fund for the operation, maintenance, and expansion of the City’s wastewater collection system.
Chapter 15-28, Private Sewage Systems. Construction of a private sewage system requires a permit from the Sonoma County Permit and Resources Management Department and must be on a property that is at least two acres in size with less than 30 percent slope for the leach field and must not be within close proximity to a City sewer line. Permits applications and plans must be submitted to the County Environmental Health Department and conform with County Health Department standards.
Chapter 20-30, Standards for All Development and Land Uses. Article 10.20.100, Septic Tank Area Requirements, states that a septic tank may be allowed where no public sanitary sewer is accessible or within 500 feet, if the parcel is more than two acres and meets County Health Department standards.
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NPDES Permit for Regional Water Reuse System and Laguna Treatment Plant The North Coast RWQCB reissued an NPDES permit in 2020 (Order No. R1-2020-0012) for the Santa Rosa Regional Water Reuse System and the Laguna Treatment Plant located at 4300 Llano Road in Santa Rosa.
The City of Santa Rosa conveys wastewater from within the EIR Study Area to the WWTP and also accepts wastewater from the cities of Cotati, Rohnert Park, and Sebastopol and unincorporated areas of Sonoma County. The permit establishes an average dry weather flow of 21.34.9 million gallons per day (MGD). 29 The facility is permitted to discharge tertiary treated wastewater to Santa Rosa Creek, an unnamed ditch tributary to Laguna de Santa Rosa, and Laguna de Santa Rosa from October 1 through May 14 but is limited to no more than 5 percent of the flow of the receiving water, as measured at the Hacienda Bridge (USGS Guage). During the dry season, tertiary treated recycled water is distributed for irrigation on authorized use sites and for recharging the steam fields at the Geysers Recharge Project. The NPDES permit includes effluent limitations, water recycling specifications and requirements, and receiving water limitations. A monitoring and reporting program is also included as part of the NPDES permit. The permit was amended in 2021 (Order . No. R1-2021-0041) to revise the Water Quality Training Framework for Laguna de Santa Rosa and clarify that the credits for long-term and multi-benefit projects do not expire.
Santa Rosa Sewer System Management Plan
The latest Santa Rosa SSMP was certified in April 2019 and revised in July 2019.30 The purpose of the SSMP is to properly manage, operate, and maintain all parts of the sanitary sewer system in order to minimize the number of SSOs and mitigate any SSOs that do occur . The SSMP describes how the sanitary sewer system is operated and maintained, efforts to minimize infiltration and inflow, design and performance standards, overflow emergency response plan, a fats, oil and grease control program, and monitoring and audit requirements. As required by law, the SSMP must be updated every five years and must be developed in compliance with the requirements of the SWRCB Waste Discharge Requirements Order No. 2006-003-DWQ, Amended Monitoring and Reporting Program Order No. WQ 2008-002-EXEC, and Order No. WQ 2013-0058-EXEC.
Santa Rosa Sanitary Sewer System Master Plan Update
Most recently updated in August 2023, the Sanitary Sewer System Master Plan (Sanitary SSMP) is used to support ongoing wastewater collection system capital improvement projects as well as management and operation of the sanitary sewer system.31 The Sanitary SSMP provides a description of the model used to estimate dry weather and wet weather wastewater flows in the City’s existing sewer collection system and calculate future wastewater flow rates based on project population and employment increases.
Additionally, the Sanitary SSMP provides a summary of areas that should be prioritized over the next
29 To go up to 25.9 MGD, Santa Rosa Water would have to show that the needed capacity improvements have been made to support this higher flow without increasing discharge. (Mike Prinz, Deputy Director of Water Reuse Operations, Santa Rosa Water, August 6, 2024)
30 Santa Rosa Water, revised July 3, 2019, Sewer System Management Plan (SSMP), https://www.srcity.org/DocumentCenter/View/24182/Santa-Rosa-Water-Sewer-System-Management-Plan-PDF, accessed August 28, 2023.
31 City of Santa Rosa, October 2014, Sanitary Serwer System Master Plan Update, https://www.srcity.org/DocumentCenter/View/13828/Sewer---2014-Master-Plan, accessed August 28, 2023.
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several CIP cycles. A condition assessment was completed and identified sections of Llano and Robles Trunk Sewers as the highest priorities and rankings for the likelihood of failure (LOF) and consequence of failure (COF) in the sewer system. Los Alamos Trunk Sewer, the Cross Town Trunk Sewer, and the Airport Trunk Sewer were also identified for recommended size upgrades for several sewer pipelines.
Santa Rosa Regional Water Reuse System Master Plan
The Regional Water Reuse System Master Plan, prepared in February 2018, provides a description, capacity, and condition of the Laguna Treatment Plant and environmental laboratory, biosolids management facilities, and recycled water distribution and discharge system. The report also identifies opportunities to meet future needs through long term planning and major projects and programs as well as recommended capital improvement projects and a 20-year investment program. 32 Incremental Recycled Water Program and Master Plan
The August 2007 update to the Recycled Water Master Plan (RWMP) was prepared to assist the City in deciding how to manage additional wastewater flows into the City’s Regional Water Reuse System. 33 The
RWMP also describes methods for managing current and future flows that are discharged. The sum of these flows is the incremental flow to be addressed by the Incremental Recycled Water Program (IRWP).
The RWMP formulates a course of actions for implementing facilities under the IRWP to manage the incremental flow. The primary objectives of the IRWP are to provide wastewater treatment, recycling, and disposal for the Santa Rosa Regional Water Reuse System to accommodate projected growth; develop and operate the wastewater treatment and disposal system; and maintain a system and components that are economically feasible and continue to be successfully financed.
Sewer Design Standards
Adopted in October 2018, the Sanitary Sewer Standard Specifications includes sanitary sewer system design standards, standard plans, construction specifications, and an engineer’s list of approved items. 34 Established to assist developers and their engineers, the Sanitary Sewer Standard Specifications provides guidelines for the design of sewer utilities projects and establishes the minimum acceptable design criteria. More stringent requirements may be imposed by the Director of Santa Rosa Water based on specific project conditions.
32 City of Santa Rosa, February 2018, Regional Water Reuse System Master Plan, https://www.srcity.org/DocumentCenter/View/37627/Regional-Water-Reuse-Master-Plan---2018, accessed August 28, 2023. 33 City of Santa Rosa, July 2007, Incremental Recycled Water Program: August 2007 Update to the Recycled Water Master Plan, https://www.srcity.org/DocumentCenter/View/13970/Incremental-Recycled-Water-Program ---2007-Master-Plan, accessed April 5, 2023.
34 City of Santa Rosa, October 18, 2018, Sanitary Sewer Standard Specifications, https://www.srcity.org/DocumentCenter/View/18368/Sewer-Design-Standards, accessed April 7, 2023.
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Capital Improvement Program
The Capital Projects Engineering Division is responsible for the design and construction of projects to rehabilitate, upgrade, and expand the City’s infrastructure, including sewer collection system projects and Laguna Treatment Plant projects. The capital projects are funded primarily through sewer and water rates, development fees, and grants. The City’s CIP is a five-year financial plan for the maintenance and expansion of the City’s infrastructure. The CIP identifies public facility improvements that are needed, provides a design and construction schedule, and identifies funding for these projects. 35 Some of the CIP
programs that have currently been approved and are in the planning or construction phase include the following sewer and wastewater infrastructure projects:
North Trunk Sewer Replacement– Mendocino Avenue to Terra Linda Drive. Albany, Clement and Malano Sewer and Water Improvements. Laguna Treatment Plan Disinfection Improvements: Replace the existing UV system. Terra Linda and Buena Vista Sewer and Water Replacement. Mendocino Avenue Easement South of Dawson Road Sewer Main Replacement. E. Haven Drive Sewer and Water Improvements in Grace neighborhood. Los Alamos Trunk Sewer Replacement: Streamside Drive to Elaine Drive. Los Alamos Trunk Sewer Replacement: Elaine Drive to Melita Road at Santa Rosa Creek. Laguna Treatment Plant Waste Gas Burner Replacement.
Cleveland Avenue and St. Rose District Sewer and Water Improvements. Controller and Radio Upgrades at Water Pump Stations and Sewer Lift Stations. Robles Trunk Lining.
Fulton Road Sewer Main Improvements.
Laguna Treatment Plant Emergency Generator Fuel Tank and Fleet Fueling Station Replacement. Backup Generators: Water and Wastewater Facilities.
Llano Trunk Rehabilitation.
Cross Town Trunk Lining.
Slater Street and Lewrosa Way Sewer and Water Main Replacement.
Existing Conditions
Wastewater Collection
The City of Santa Rosa’s sewer collection system serves a population of approximately 175,300 people with 50,512 connections. It consists of 587 miles of gravity sewer pipelines, 6.4 miles of force mains, and 17 lift stations. The location of the sewer pipelines within the EIR Study Area are shown on Figure 4.17-2, City of Santa Rosa Sewer Collection System. The sewer pipes range in size from 4 to 66 inches and are of various ages, dating back to the 1970s. Collected wastewater is conveyed to the Laguna Treatment Plant and is treated to tertiary (recycled) water standards.
35 City of Santa Rosa, 2023, Capital Improvement Program, https://www.srcity.org/690/ Capital-Improvement-Program, accessed August 29, 2023.
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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The Santa Rosa Water Department, Operations Division, operates and maintains the sewer collection system within the EIR Study Area. This includes the following tasks:36 Perform regularly scheduled collection system maintenance, including hydroflushing, rodding, cleaning, closed circuit television (CCTV), and smoke testing. Minimize Inflow/Infiltration using data collected from flow monitors to determine the sources of inflow/infiltration and regularly inspect sources with the aid of smoke testing and CCTV. Minimize the number and impacts of SSOs and provide emergency response, cleanup, notification, and follow up for all SSOs in accordance with the Overflow Emergency Response Plan. Provide education to residents and businesses about the impact of fats, oil, and grease in the collection system.
The City is in the process of upsizing and replacing portions of the sewer collection system, as recommended in the 2014 Sanitary SSMP. Most notably, the prioritized projects focus on trunk line replacement in several areas to limit the inflow of stormwater into the sewer system. Also, the City is optimizing the use of both City and the Laguna Treatment Plant’s wet weather storage ponds via flow meters to prevent surcharging during future storm events.
There also are several satellite wastewater collection systems operated and maintained by the cities of Cotati, Rohnert Park, and Sebastopol that convey wastewater to the Laguna Treatment Plant. The City of Santa Rosa maintains the sewer collection system of South Park County Sanitation District under contract.
Each city and sanitation district is responsible for compliance with the State and local waste discharge requirements.
Wastewater Treatment
The Laguna Treatment Plant, also known as the Santa Rosa Regional Water Reuse System, is owned and operated by the City of Santa Rosa. The Laguna Treatment Plan is at 4300 Llano Road in Santa Rosa and provides tertiary treated effluent (recycled water) using primary sedimentation, biological secondary treatment (activated sludge) with alum coagulation, flocculation, and clarification, followed by tertiary filtration and ultraviolet light (UV) disinfection.
Tertiary treated effluent is discharged to an effluent pond system with a maximum capacity of 1.65 million gallons prior to entering either the recycled water distribution system or prior to discharge to Santa Rosa Creek and/or Laguna de Santa Rosa during the permitted discharge period from October 1 to May 14. The effluent pond system allows the City to control the timing, location, and volume of discharge to protect beneficial uses of the receiving waters and provide a source of recycled water during the discharge
36 Santa Rosa Water, revised July 3, 2019, Sewer System Management Plan (SSMP), https://www.srcity.org/DocumentCenter/View/24182/Santa-Rosa-Water-Sewer-System-Management-Plan-PDF, accessed August 28, 2023.
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prohibition period.37 Nearly 100 percent of the recycled water produced by the facility is used for landscape and agricultural irrigation and recharge of the Geyser’s geothermal steam field.
Biosolids produced during the treatment process are thickened, anaerobically digested, and dewatered.
Approximately one-third of the biosolids are transported to the Lystek facility in Fairfield, where it is processed using thermal hydrolysis and transformed into a Class A biosolids fertilizer product. The remainder of the biosolids are applied to agricultural land.
As previously discussed, the Laguna Treatment Plant also accepts wastewater from the cities of Cotati, Rohnert Park, and Sebastopol, as well as the South Park County Sanitation District. The facility also accepts hauled waste, including domestic septage, chemical toilet waste, grease trap waste, non-hazardous commercial and industrial waste, groundwater, grey water, and landfill leachate. Liquid wastes such as septage, greywater, and rinse water directly enter the liquid stream in the Laguna Treatment Plant. High strength wastes, such as kitchen grease from restaurants, food processing facility wastes, and wastes from breweries and wineries, are offloaded into dedicated tanks and pumped directly to the anaerobic digesters for treatment.
The Laguna Treatment Plant is permitted to treat 21.34 MGD as an average daily dry weather flow and is designed with a peak wet weather flow of 64 MGD. The average dry weather flow in 2022 was 13.1 MGD.
No discharge to receiving waters occurred in 2022.
38 Wastewater flows from the City of Santa Rosa have
ranged between 72 percent and 73.5 percent of the total wastewater flow for the past six years. For fiscal year 2021/2022, Santa Rosa’s flows to the Laguna Treatment Plant were 4,388.95 MG, with total flows to the Laguna Treatment Plant being 6,008.68 MG, representing 73.04 percent of flows for that year . Santa Rosa’s contribution to the wastewater flow to the plant in 2022 was calculated to be about 10.6 MGD.
STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant wastewater related impact if it would:
4. Require or result in the relocation or construction of new or expanded wastewater treatment or facilities, the construction or relocation of which could cause significant environmental effects.
5. 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.
6. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to wastewater facilities.
37 North Coast Regional Water Quality Control Board, 2020, Waste Discharge Requirements and Water Recycling Requirements for the City of Santa Rosa, Santa Rosa, Regional Water Reuse System, Laguna Treatment Plant, Sonoma County, Order No. R1-2020-0012.
38 City of Santa Rosa, February 24, 2023, 2022 Annual Report: Regional Water Reuse System – Laguna Treatment Plant, https://www.srcity.org/DocumentCenter/View/31637/2022-Santa-Rosa-Regional-Water-Reuse-System-Annual-Report, accessed September 7, 2023.
4.17.2.2 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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UTILITIES AND SERVICE SYSTEMS
4.17-36 OCTOBER 2024
IMPACT DISCUSSION
USS-4 Implementation of the proposed project would not require or result in the relocation or construction of new or expanded wastewater treatment or facilities, the construction or relocation of which could cause significant environmental effects.
Buildout of the proposed project would result in an increase in wastewater, which includes liquid and solids, with the addition of 24,090 new housing units and 8,364,760 square feet of non-residential land use. Wastewater collected in the EIR Study Area would be conveyed to the Regional Water Reuse System/Laguna Treatment Plant for treatment. Other cities (Cotati, Rohnert Park, and Sebastopol) and the South Park County Sanitation District also convey wastewater to this facility and are included in this analysis.
An estimate of the amount of additional wastewater generated by the proposed project was determined, as shown in Table 4.17-10, Wastewater Demand Increase, Proposed General Plan 2050. The wastewater demand factors were derived in consultation with the City of Santa Rosa and assumed that 80 percent of the total water demand consisted of indoor water use and that 100 percent of the indoor water use became wastewater.
TABLE 4.17-10 WASTEWATER DEMAND INCREASE, PROPOSED GENERAL PLAN 2050 Category Amount Units
Water Demand 5,339,136 GPD
Wastewater Factor 0.8
Wastewater Demand 4,271,309 GPD
Wastewater Demand Increase with General Plan 2050 4.27 MGD
Existing Wastewater Demand 13.1 MGD
Increase for Santa Rosa with GP Buildout 4.27 MGD
Increase for Other Contributors 0.6 MGD
Total 17.97 MGD
Notes:
a. Assumes 80 percent of total water demand is indoor water and that 100 percent of indoor water becomes wastewater. b. GPD = gallons per day; MGD = million gallons per day. c. Existing wastewater demand from 2022 Regional Water Reuse System Annual Report. d. Projected 2035 wastewater flows for Cotati, Rohnert Park, and Sebastopol from 2014 Sanitary Sewer System Master Plan Update.
Sources: City of Santa Rosa, 2023; PlaceWorks, 2023.
The increase in wastewater demand with buildout of the proposed project is estimated to be approximately 4.27 MGD. Combined with the existing average daily flow of 13.1 MGD and the increase with other contributors to the Laguna Treatment Plant flow rates, the estimated total wastewater flow rate in 2050 is estimated to be approximately 18 MGD.
The Laguna Treatment Plant is currently permitted for an average daily flow rate of 21.34 MGD. As noted previously, capacity up to 25.9 MGD ADWF is permitted if the City can show the improvements necessary to achieve that flow. In addition, the facility has an effluent pond system with a maximum capacity of 1.65
4.17.2.3 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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PLACEWORKS 4.17-37
million gallons that can control surges in volume during wet weather conditions and the facility also recycles approximately 6.6 billion gallons of wastewater per year . Also, the treatment plant is undergoing system upgrades as part of the CIP .
Therefore, the Laguna Treatment Plant will be able to accommodate the future wastewater flows from Santa Rosa and the other contributors to the facility’s wastewater flow rates. In addition, the assumptions used in calculating future wastewater flow are conservative (i.e., they represent a “worst case scenario”), as wastewater flows to WWTPs continue to decline with water conservation efforts. 39 In conjunction with upgrades to the Laguna Treatment Plant, the City of Santa Rosa is also implementing sewer collection improvement projects as recommended in the 2014 Sanitary SSMP. The goal is to replace portions of the sewer infrastructure with larger pipe sizes to accommodate future growth, improve wet weather capacity, and reduce inflow/infiltration. Completion of the Laguna Treatment Plant and sewer system upgrades should minimize the potential for future SSOs and the wastewater system will be able to accommodate the increases in wastewater flows with buildout of the EIR Study Area.
In addition, sewer demand fees (i.e., connection fees) are imposed on all new developments to recover a proportionate share of costs for existing and future wastewater system facilities and new or expanded connections to the City’s wastewater system. Property owners are also required to pay monthly sewer service charges. These fees are also used to fund wastewater collection and treatment system improvements designated in the CIP and routine repair and maintenance by the Santa Rosa Water Department.
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050 contains goals, policies, and actions that require planning and development decisions to consider impacts to wastewater collections systems and treatment facilities. In addition to the goals, policies, and actions listed under impact discussion USS-1, the following goal, policy, and actions would serve to minimize potential adverse impacts to wastewater infrastructure with future development:
Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.4: Ensure that adequate wastewater capacity is available to serve existing and future needs of the city.
Action 5-9.22: Maintain existing levels of wastewater service by preserving and improving infrastructure, including replacing sewer mains, as necessary. Action 5-9.23: Decline requests for extension of sewer services beyond the Urban Growth Boundary.
Action 5-9.24: Implement the Sewer Master Plan via projects identified in the Capital Improvement Program.
Action 5-9.25: Regularly review wastewater treatment and biosolids management strategies to accommodate growth over the life of the General Plan.
39 California Water Environment Association, 2023, Dealing with Declining Wastewater Flows, https://www.cwea.org/news/dealing-with-declining-flows/, accessed on August 31, 2023.
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Action 5-9.26: Work with regional partners (notably the Cities of Rohnert Park, Cotati, and Sebastopol, and Sonoma Water) to build consensus on maintenance, rehabilitation, modernization, and resilience improvements for facilities that provide service to them, such as the Laguna Treatment Plant.
Implementation of the proposed project would not require the construction or expansion of the Laguna Treatment Plant or sewer collection system beyond what is already planned or under construction.
Adherence to the City’s municipal code requirements as well as the proposed General Plan 2050 goals, policies, and action would reduce wastewater generation rates over time, and therefore impacts associated with the sewer collection and treatment systems would be less than significant.
Significance without Mitigation: Less than significant.
USS-5 Implementation of the proposed project would not 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.
As described under impact discussion USS-4, the City’s Laguna Treatment Plant is currently permitted to treat up to 21.34 MGD. The City’s contribution to an increase in wastewater demand in 2050 is estimated to be 4.27 MGD, as shown in Table 4.17-10. Including increases by other wastewater contributors, the total wastewater flow rate to the treatment plant is estimated to be about 18 MGD. This is well below the permitted capacity of the Laguna Treatment Plant of 21.34 MGD. Capacity up to 25.9 MGD is permitted if the City can show the improvements necessary to achieve that flow.
The estimated increase in wastewater flows is conservative because there likely will be declining rates of wastewater generation over time because new projects would be required to comply with the California Plumbing Code and CALGreen and implement active and passive water conservation measures. This would also reduce the amount of wastewater produced per dwelling unit or building. Future development would also be required to undergo City review. Furthermore, as described under impact discussion USS-4, the proposed General Plan 2050, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, contains goals, policy, and actions that require local planning and development decisions to consider impacts to wastewater collections systems and treatment facilities. The same proposed General Plan 2050 goals, policies, and actions identified under impact discussion USS-4 would ensure that potential future development would minimize impacts to wastewater collection and treatment capacity.
With continued compliance with applicable regulations wastewater generated by the proposed project would not exceed the capacity of the Laguna Treatment Plant. In addition, implementation of the proposed General Plan 2050 goals, policies, and actions would further reduce demand. Therefore, the proposed project would not result in a determination by the wastewater treatment provider that there is not adequate capacity to serve the EIR Study Area’s projected demand in addition to the demands of other wastewater dischargers. Impacts would be less than significant.
Significance without Mitigation: Less than significant.
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USS-6 Implementation of the proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulative impact to wastewater facilities.
The context used for the cumulative assessment is the service area of Santa Rosa’s Laguna Treatment Plant. In addition to wastewater discharged to the treatment plant by the City, there are other dischargers, including the cities of Cotati, Rohnert Park, and Sebastopol, and the South Park Community Sanitation District.
As described under impact discussion USS-4, the existing and future wastewater flows to the City’s Laguna Treatment Plant were calculated for all dischargers, as shown in Table 4.17-10. The facility currently has the capacity to treat 25.9 MGD and would still have a residual average annual dry weather capacity of
7.9 MGD.
Also, the City has committed to implementing improvements to the Laguna Treatment Plant and sewer collection system, as described in the CIP. The other dischargers to the treatment plant also have sewer collection system improvement programs. Future development within the city would require compliance with all applicable regulations and ordinances. Project applicants would have to pay wastewater demand (connection) fees and property owners are required to pay monthly sewer service charges, which funds continued improvements to the wastewater collection and treatment systems.
Therefore, with continued compliance with applicable regulations and future reductions in wastewater demands with water conservative efforts, cumulative development would not exceed wastewater collection or treatment capacities. Accordingly, the proposed project would not result in a cumulatively considerable impact related to wastewater, and cumulative impacts would be less than significant.
Significance without Mitigation: Less than significant.
4.17.3 STORMWATER
ENVIRONMENTAL SETTING
Regulatory Framework
The regulatory framework for stormwater is described in detail in Chapter 4.10, Hydrology and Water Quality, of this Draft EIR. The regulatory requirements that pertain solely to storm drain systems are repeated below.
Federal Regulations
National Pollutant Discharge Elimination System
Under the NPDES program, all facilities that discharge pollutants into waters of the U.S. are required to obtain an NPDES permit. Requirements for stormwater discharges are also regulated under this program.
In California, the NPDES permit program is administered by the SWRCB through the nine RWQCBs. The
4.17.3.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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4.17-40 OCTOBER 2024
City of Santa Rosa lies within the jurisdiction of North Coast RWQCB (Region 1) and is subject to the waste discharge requirements of the Phase I MS4 Permit (Order No. R1-2014-0030; NPDES No. CA0025054) that regulates stormwater discharges from the City of Santa Rosa, portions of unincorporated Sonoma County, Sonoma Water, the cities of Cotati, Cloverdale, Healdsburg, Rohnert Park, Sebastopol, Ukiah and the Town of Windsor.
State Regulations
SWRCB G
eneral Construction Permit
Construction activities that disturb one or more acres of land that could impact hydrologic resources must comply with the requirements of the SWRCB Construction General Permit (Order WQ 2022-0057-DWQ; NPDES No. CAS000002), which was adopted on September 8, 2022, and becomes effective on September 1, 2023. Under the terms of the permit, applicants must file Permit Registration Documents (PRD) with the SWRCB prior to the start of construction. The PRDs include a Notice of Intent, risk assessment, site map, Stormwater Pollution Prevention Plan (SWPPP), annual fee, and a signed certification statement. The PRDs are submitted electronically to the SWRCB via the Stormwater Multiple Application and Report Tracking System (SMARTS) website.
Applicants must also demonstrate conformance with applicable best management practices (BMP) and prepare a SWPPP containing a site map that shows the construction site perimeter, existing and proposed buildings, lots, roadways, stormwater collection and discharge points, general topography both before and after construction, and drainage patterns across the project site. The SWPPP must list BMPs that would be implemented to prevent soil erosion and discharge of other construction-related pollutants that could contaminate nearby water resources. Additionally, the SWPPP must contain a weekly visual monitoring program and BMP inspections prior to, during, and after qualifying precipitation events. Water quality monitoring is also required with a schedule based on the risk level of the site.
SWRCB
Industrial General Permit
The Statewide General Permit for Stormwater Discharges Associated with Industrial Activities, Order No. 2014-0057-DWQ and amended by 2015-0122-DWQ (2018), implements the federally required stormwater regulations in California for stormwater associated with industrial activities that discharge to waters of the United States. This regulation covers facilities that are required by federal regulations or by the RWQCBs to obtain an NPDES permit. Dischargers are required to eliminate non-stormwater discharges, develop SWPPPs that include BMPs, conduct monitoring of stormwater runoff, and submit all compliance documents via the SWRCB’s SMARTS program.
SWRCB Tras h Amendment
On April 7, 2015, the SWQCB adopted an amendment to The Water Quality Control Plan for Ocean Waters of California to control trash. In addition, the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California added Part 1, Trash Provisions. Together, they are collectively referred to as "the Trash Amendments." The Trash Amendments apply to all surface waters of California and include a land-use-based compliance approach to focus trash controls on areas with high trash- SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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generation rates. Areas such as high density residential, industrial, commercial, mixed urban, and public transportation stations are considered priority land uses.
The Trash Amendments apply to all Phase I and II permittees under the NPDES MS4 permits. The Trash Amendments require municipalities to install certified trash control systems, such as filters, on all catch basins no later than December 2, 2030.40
Sonoma Water
Sonoma Water has recently revised its Flood Management Design Manual, which is to be used by public agencies and private entities in Sonoma County that are designing, constructing, or maintaining waterways, channels, closed conduits, or culverts. It is applicable for drainage designs, plans, or improvements that are subject to review by Sonoma Water . It provides the methodology and criteria for analyzing storm drain systems and facilities that are necessary to convey stormwater runoff from large storm events. It replaces the previous Sonoma Water Flood Control Design Criteria. 41 The Santa Rosa
Storm Drain Design Standards uses this methodology for the hydrologic and hydraulic design of storm drains within the city.
Local Regulations
Santa Rosa C ity Code
The SRCC includes various directives that pertain to stormwater in Santa Rosa. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions are in Title 16, Storm Water Enterprise; Title 17, Environmental Protection; and Title 20, Zoning:
Section 14-30.055, Grading Design Plan. This chapter states that when slopes are greater than 10 percent, a grading plan is needed that clearly identifies drainage patterns and storm water retention improvements.
Chapter 16-12, Establishment of Storm Water Enterprise. This chapter creates the Storm Drainage and Flood Control Management Enterprise which operates the City’s surface water, storm water, storm drainage, and flood control management efforts.
Chapter 17-12, Storm Water. This chapter is broken up into two articles that give an overview of drainage areas and storm water quality.
Article I. Drainage. This article establishes requirements for driveway culverts, permits, and violations associated with stormwater .
40 State Water Resources Quality Control Board, September 2022, Storm Water Program: Trash Implementation Program, https://www.waterboards.ca.gov/water_issues/programs/stormwater/trash_implementation.html, accessed April 4, 2023. 41 Sonoma Water, 2020, Flood Management Design Manual,
https://www.sonomawater.org/media/PDF/Water%20Resources/Flood%20Protection/Flood%20Management%20Design%20Ma nual/FMDM_Main_Body_Mar2020_ADA%20v2.pdf, accessed August 4, 2023.
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Article II. Storm Water Quality. This article’s purpose is to limit the amount of spills and dumping or disposal of materials other than storm water in the City’s storm water system and to reduce pollutants in storm water discharge to the highest degree possible. Chapter 20-30.040, Creekside Development. This section provides minimum setbacks from waterways to provide protection for owners of riparian property and the public from the hazards of stream bank failures and flooding. In general, the setback area on either side of a natural or modified waterway shall be 50 feet from the top of the highest bank for new structures.
Storm Water Low Impact Development Technical Design Manual Recently revised in 2020 and applicable for all new development in Santa Rosa, the Storm Water Low Impact Development (LID) Technical Design Manual provides technical guidance for project designs that require the implementation of permanent stormwater BMPs intended to satisfy NPDES permit requirements.
42 The intention of the Stormwater LID Technical Design Manual is to promote LID goals of minimizing adverse impacts from storm water runoff; minimizing the percentage of impervious surfaces on land development projects and implementing mitigation measures to mimic the pre-development water balance; minimizing pollutant loadings from impervious surfaces such as roof tops, parking lots, and roadways; and properly selecting, designing and maintaining treatment control BMPs and Hydromodification Control BMPs.
Storm Drain Standards
The City of Santa Rosa has established Storm Drain Design Standards to assist developers and their engineers in the design of storm drain facilities within the City.43 The Storm Drain Design Standards provides the methodology for determining stormwater runoff rates and the hydraulic design criteria to be used in sizing storm drains. In general, drainage systems must be designed to accommodate flows from storms with recurrence intervals ranging from 10 to 100 years, depending on the waterway classification to which it discharges. Open channels that will be maintained by Sonoma Water must be designed as specified in the 2020 Sonoma Water Flood Management Design Manual.
Storm Water Assessment Funding
The City of Santa Rosa has established a funding program dedicated to mitigating storm water impacts to the storm drain system, as well as downstream creeks and waterways. The Storm Water Assessment is a charge placed on each city parcel and is used to fund such projects as mapping and evaluating the storm drain system, flood control improvements, responses to flooding issues and creek restoration. 44 42 Cities of Cloverdale, Cotati, Healdsburg, Rohnert Park, Santa Rosa, Sebastopol, and Ukiah, County of Sonoma, Sonoma Water, and Town of Windsor, revised December 2020, Storm Water Low Impact Development Technical Design Manual, https://www.srcity.org/DocumentCenter/View/14974/2017-Storm-Water-Technical-Design-Manual-Narrative -revised-1621, accessed April 5, 2023.
43 City of Santa Rosa, April 26, 2005, Public Storm Drain Standards, https://www.srcity.org/DocumentCenter/View/17627/Storm-Drain-Standards, accessed September 7, 2023. 44 City of Santa Rosa, 2023, Storm Water Assessment, https://www.srcity.org/2909/ Storm-Water-Assessment, accessed September 5, 2023.
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Existing Conditions
Stormwater Collection System
The City’s storm drain system consists of 320 miles of storm drain lines and 75 miles of open channels and ditches. These facilities are part of an integrated system of roadside gutters, drainage ditches, pipelines, and creeks that are used to collect and convey the stormwater runoff to creeks within the City and ultimately into Laguna de Santa Rosa. The existing stormwater system is shown on Figure 4.17-3, City of Santa Rosa Stormwater System. The City’s storm drain system also makes use of stormwater detention facilities used to attenuate peak flows and allow for the settlement of sediment from the stormwater flows before continuing downstream. The Public Works Department works year-round cleaning silt, trash, and other pollutants out of the City’s catch basins and storm drains, using a large vacuum truck. Sonoma Water’s Stream Maintenance crews are responsible for removing sediment and vegetation in the creeks that flow through the City of Santa Rosa. The City is in the process of developing a Storm Drain Master Plan to evaluate the capacity of the existing storm drain facilities, identify areas of deficiencies, and recommend upgrades to the system.
The City is continually upgrading its stormwater infrastructure through the CIP , which is a five-year financial plan for maintenance and expansion of public infrastructure. The prioritized capital improvement projects involving stormwater infrastructure focus on pumping improvements at wet weather storage basins, new bio-retention facilities, creek restoration, and various citywide improvements to storm drainage pipes, catch basins, ditches and bank stabilization. 45 Some of the CIP programs that have currently been approved and are in the planning or construction phase include the following stormwater infrastructure projects:
Lower Colgan Creek Restoration: Restore channel into a natural creek and improve retention. Parker Hill Rd and Paulin Creek Erosion Repair: Improvements to drainage area to prevent erosion. 3rd Street Storm Drain Pump Coupling Replacement.
Storm Water Creek Restoration Projects: Improvement to habitat and water quality in creeks and waterways.
Preparation of the Storm Drain Master Plan.
Stormwater Discharge
Runoff generated in Santa Rosa drains through nine subwatershed areas that ultimately discharge into Laguna de Santa Rosa. Numerous major creeks and various tributaries convey the stormwater between the city’s runoff-generating sources and the Laguna de Santa Rosa.
Santa Rosa Creek is a part of the city’s largest drainage basin and flows westward through the City, collecting runoff from the east-central portion of the city as well as the downtown area. The northeastern section of the City is drained by Brush Creek and its tributaries, which connect to Santa Rosa Creek.
45 City of Santa Rosa, 2023, Capital Improvement Program, https://www.srcity.org/690/Capital-Improvement-Program, accessed August 29, 2023.
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City of Santa Rosa Stormwater System
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Portions of the Oakmont Creek subwatershed drain into Oakmont Creek, which connects to Santa Rosa Creek, while other creeks in the area drain east toward Sonoma Creek and eventually into San Pablo Bay.
Matanzas Creek and Spring Creek are within the Matanzas Creek watershed and collect runoff from the southcentral portion of the city, eventually connecting to Santa Rosa Creek. Piner Creek and Paulin Creek collect runoff from the northern portion of the city and are also tributaries to Santa Rosa Creek. The Southern Santa Rosa Creeks subwatershed, which includes Roseland Creek, Kawana Springs Creek, and Colgan Creek, conveys runoff directly to Laguna de Santa Rosa. The Western Creeks watershed includes Gravenstein and Naval Creeks and also discharges directly into Laguna de Santa Rosa. Todd Creek also provides drainage for the far southern portion of the City and connects to Laguna de Santa Rosa via the Bellevue-Wilfred Channel.
STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in a significant stormwater impact if it would:
7. Require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects.
8. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to stormwater facilities.
IMPACT DISCUSSION
USS-7 Implementation of the proposed project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects.
Potential future new development and/or redevelopment in the EIR Study Area would result in an increase in impervious surfaces, which in turn could result in an increase in stormwater runoff, higher peak discharges to drainage channels, and the potential to cause nuisance flooding in areas without adequate drainage facilities. However, much of the city is already built out and future development and redevelopment sites may replace existing land uses that already contain impervious surfaces and pavement. Therefore, new development on these sites should not create a significant increase in impervious surfaces.
Also, regulated projects that create or replace 10,000 square feet or more of impervious surfaces would trigger the implementation of stormwater treatment and trash collection measures to reduce stormwater runoff, pursuant to the MS4 Permit and the City’s Stormwater LID Technical Design Manual.
Implementation of these stormwater measures will reduce the amount of stormwater runoff that is ultimately discharged to the City’s storm drain system and the creeks that run through Santa Rosa. Prior to the issuance of grading permits, the City will require completion and submittal of a Storm Water LID Determination Worksheet and an Initial and Final Storm Water Low Impact Development Submittal (SWLIDS) report for review and approval to ensure that these requirements are met.
4.17.3.2 4.17.3.3
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The MS4 permit and City also require that all projects that generate runoff from the 1.0-inch, 24-hour storm event must treat stormwater onsite for the pollutants of concern and install trash capture devices.
For all projects that create and/or replace 10,000 square feet of impervious surface or more but less than one acre of impervious surface, any increase in stormwater volume from the 1.0-inch, 24-hour storm event must be captured onsite and trash capture requirements must be implemented. Projects that create and/or replace one acre or more of impervious surfaces must also adhere to the hydromodification requirements of the MS4 permit and demonstrate that 100 percent of the post-project runoff generated by a 1.0-inch, 24-hour storm event is infiltrated and/or retained on-site. This would minimize the amount of stormwater runoff from new development and redevelopment sites within the EIR Study Area.
Also, as part of the permitting process, future development would be required to pay a storm water assessment, pursuant to SRCC Title 16, which is designed to mitigate the impacts of stormwater that is discharged into the creeks and waterways in Santa Rosa. The assessments are used to evaluate and maintain the storm drain system, implement flood control improvements, respond to flooding issues, and restore creeks and habitat.
Additionally, all potential future development in the EIR Study Area would be required to comply with the requirements of the SRCC Section 17-12.010, which requires drainage permits for discharge into the storm drain system and prohibits discharges in violation of the NPDES permit (Section 17-12.150). All development that discharges storm water associated with industrial activity shall also comply with the requirements of the General Industrial Permit (Order No. 2014-0057-DWQ) and amended in 2018 by Order No. 2015-0122-DWQ.
Lastly, the City’s CIP describes planned improvements to the existing storm drains and new stormwater infrastructure (i.e., bio-retention facilities) needed for future development. The construction of new stormwater facilities through the CIP, implementation of best management practices and on-site stormwater control measures, and preparation of the required documents and review by the City would serve to minimize any potential impacts associated with stormwater .
Chapter 3, Circulation, Conservation, and Greenhouse Gas Reduction Element, and Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities Element, of the proposed General Plan 2050 contain goals, policies, and actions that require local planning and development decisions to consider impacts related to storm drain infrastructure. In addition to the goals, policies, and actions listed under impact discussion USS-1, the following goals, policies, and actions would serve to minimize potential adverse impacts related to stormwater discharge:
Goal 3-5: Protect, expand, maintain, and restore natural resources, open space, and the limited remaining agricultural land.
Policy 3-5.5: Maintain, restore, and protect the city’s waterways. Action 3-5.14: Implement the Citywide Creek Master Plan and promote a “one water” approach that teaches preservation and stewardship of local creeks and water resources. Action 3-5.15: Periodically review the status of local creeks and plan for ongoing restoration, planning, and stewardship, as identified in the Citywide Creek Master Plan.
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Action 3-5.16: Seek funding to maintain and restore citywide creeks, including for recreational opportunities linked to creeks as well as for flood control. Action 3-5.17: Implement stormwater pollution prevention outreach to increase community awareness of pollution impacts to creeks and preserve waterways. Policy 3-5.6: Restore channelized waterways and avoid creating additional channelized waterways unless no other alternative is available to protect human health, safety, and welfare. Action 3-5.18: Restore and enhance the ecological function of channelized waterways, consistent with the Citywide Creek Master Plan, and avoid channelizing additional segments of the waterways system.
Goal 5-2: Effectively manage the potential effects of flooding and dam failure. Policy 5-2.6: Manage, maintain, and improve stormwater drainage and capacity. Action 5-2.12: Require dedication, improvement, and ongoing maintenance of stormwater management and retention areas as a condition of development approval. Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for new development.
Action 5-2.14: Require improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks.
Action 5-2.15: Ensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Active Transportation Plan and are incorporated into stormwater improvement projects along creek corridors.
Policy 5-2.7: Provide storm drainage facilities that accommodate increased development and enhanced water quality.
Action 5-2.16: Cooperate with Sonoma Water and the Northern California Regional Water Quality Control Board on assessments of stormwater drainage facilities to ensure adequate capacity to accommodate increases in residential and commercial development.
Action 5-2.17: Require implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system.
Compliance with the MS4 permit and the City’s stormwater design standards and requirements would ensure that potential future development would not result in significant increases in runoff and would not contribute to the construction of new storm drain facilities or expansion of existing facilities that would cause significant environmental impacts. In addition, implementation of the proposed General Plan 2050 goals, policies, and actions would further reduce stormwater demand on the system, and the City would continue to repair, rehabilitate, and upgrade the storm drain system through implementation of the CIP.
Therefore, impacts with respect to stormwater infrastructure would be less than significant.
Significance without Mitigation: Less than significant.
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USS-8 Implementation of the proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to stormwater facilities.
The analysis of cumulative storm drainage impacts considers potential future development within the nine subwatersheds that encompass the EIR Study Area. Cumulative projects could result in an incremental increase in impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities. However, all cumulative projects would be required to comply with the Sonoma County Municipal Code and SRCC as well as the MS4 permit, the City’s Stormwater LID Technical Design Manual, and Sonoma Water’s Water Smart Development Guidebook, which would minimize stormwater runoff.
As discussed previously, future development within the EIR Study Area would require conformance with State and City policies that would reduce hydrology and infrastructure construction impacts to less than significant levels. Any new development within the EIR Study Area would be subject to the proposed General Plan 2050 goals, policies, and actions listed under impact discussion USS-7, SRCC, LID Design Manual, and other applicable City requirements that reduce impacts related to hydrology and stormwater drainage facilities. Therefore, potential changes related to stormwater flows, drainage, impervious surfaces, and flooding would be minimized by the implementation of stormwater control measures, retention, infiltration, and low-impact-development measures and review by Santa Rosa Water to integrate measures to reduce potential stormwater drainage and flooding impacts.
All cumulative projects in unincorporated Sonoma County within the watershed areas would be subject to similar permit requirements and compliance with the MS4 permit. All new development would be required to prepare drainage reports in accordance with the County’s Flood Management Design Manual for review and approval by Permit Sonoma. Sonoma County has also prepared the Water Smart Development Guidebook that serves as a supplementary resource to the City’s Stormwater LID Technical Design Manual to assist developers in incorporating LID storm water features on their project sites. 46 In combination with past, present, and reasonably foreseeable projects, development and redevelopment within the EIR Study Area would not result in a cumulatively considerable impact to stormwater infrastructure within the watersheds, and cumulative impacts would be less than significant.
Significance without Mitigation: Less than significant.
46 Sonoma County Water Agency, December 2013, Water Smart Development Guidebook, accessed September 7, 2023, https://evogov.s3.amazonaws.com/media/185/media/165407.pdf.
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4.17.4 SOLID WASTE
ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
Resource Conservation and Recovery Act of 1976
The Resource Conservation and Recovery Act of 1976 (Title 40 of the Code of Federal Regulations), Part 258, contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs incorporating the federal landfill criteria. The federal regulations address the location, operation, design (liners, leachate collection, run-off control, etc.), groundwater monitoring, and closure of landfills.
State Regulations
Sanitary District Act of 1923
The Sanitary District Act of 1923 (Health and Safety Code Section 6400 et seq.) authorizes the formation of sanitation districts and enforces the sanitation districts to construct, operate, and maintain facilities for the collection, treatment, and disposal of wastewater. This Act was amended in 1949 to allow the sanitation districts to also provide solid waste management and disposal services, including refuse transfer and resource recovery.
Integrated Waste Management Act
The Integrated Solid Waste Management Act of 1989 (AB 939), codified in Public Resources Code 40050 et seq., established an integrated waste-management system that focused on source reduction, recycling, composting, and land disposal of waste. AB 939 required every California city and county to divert 50 percent of its waste from landfills by the year 2000. This act also requires that each city and county prepare a Source Reduction and Recycling Element to be submitted to the Department of Resource Recycling and Recovery (CalRecycle), a department within the California Natural Resources Agency. AB 939 also establishes a goal for all California counties to provide at least 15 years of ongoing landfill capacity.
In 2007, SB 1016 amended AB 939 to establish a per capita disposal measurement system. The per capita disposal measurement system is calculated as a jurisdiction’s reported total disposal of solid waste divided by a jurisdiction’s population. CalRecycle sets a target per capita disposal rate for each jurisdiction. Each jurisdiction must submit an annual report to CalRecycle with an update of its progress in implementing diversion programs and its current per capita disposal rate.
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Mandatory Commercial Recycling Act (AB 341)
AB 341 (Chapter 476, Statutes of 2011) increased the statewide solid waste diversion goal to 75 percent by 2020 and mandates commercial businesses and public entities that generate four cubic years or more of waste per week to have a recycling program in place. In addition, multifamily residential properties with five or more units are also required to develop a recycling program. AB 341 is designed to reduce greenhouse gas (GHG) emissions in the state by 5 million metric tons of carbon dioxide equivalents. In Santa Rosa, businesses and property owners can subscribe to composting and recycling services provided by Recology Sonoma Marin (Recology).
Mandatory Organics Recycling Act (AB 1826)
AB 1826, which was enacted in 2014 and took effect in 2016, mandated organic waste recycling for all businesses and multifamily dwellings that consist of five or more units. Starting in January 2020, all generators of two cubic yards or more of garbage, recycling, and compost combined per week must recycle organic waste. Organic waste includes food scraps, food-soiled paper and cardboard waste, green waste and yard trimmings, landscaping materials, and nonhazardous, untreated wood waste.
California Short-L ived Climate Pollutants Act (SB 1383) SB 1383 focuses on the elimination of methane gas created by organic materials in landfills and establishes goals to reduce the landfill disposal of organics by achieving a 50 percent reduction in the statewide disposal of organic waste by 2020 and a 75 percent reduction by 2025. Organic waste makes up half of what Californians send to landfills. SB 1383 requires all businesses and residents to divert organic materials from landfills. The regulation took effect on January 1, 2022, and requires that organic collection services be provided to all residents and businesses. The collected organic waste must be recycled into new products, such as compost, mulch, biofuel, and electricity. Each city and county has an annual procurement target based on its population. Also, an edible food recovery program must be established by 2025 with the goal of recovering 20 percent of currently disposed edible food that would otherwise be sent to landfills to feed people in need. Mandated food donors and food recovery organizations and services must keep records of the amount and dates of food donations and acceptances.
California Solid Waste Reuse and Recycling Access Act
The California Solid Waste Reuse and Recycling Access Act requires new commercial and multi-family development projects to set aside areas for collecting and loading recyclable materials. This act required CalRecycle to develop a model ordinance for adoption by any local agency that provides adequate areas for the collection and loading of recyclable materials for development projects. Local agencies are required to adopt the model, or an ordinance of their own, that establishes standards including space allocation for the collection and loading of recyclable materials.
CALGreen
The 2022 CALGreen became effective on January 1, 2023. Sections 4.408 and 5.408, Construction Waste Reduction Disposal and Recycling, mandate that, in the absence of a more stringent local ordinance, a minimum of 65 percent of non-hazardous construction and demolition debris must be recycled or SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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salvaged. CALGreen requires developers to prepare and submit a Construction Waste Management Plan, which must:
Identify the materials to be diverted from disposal by recycling, reuse on the project, or salvage for future use or sale.
Specify if materials would be sorted on-site or mixed for transportation to a diversion facility. Identify the diversion facility where the material collected can be taken. Identify construction methods employed to reduce the amount of waste generated. Specify that the amount of materials diverted shall be calculated by weight or by volume but not both.
Regional Regulations
Sonoma County Countywide Integrated Waste Management Plan Prepared in 2003, the Sonoma County Countywide Integrated Waste Management Plan (CoIWMP) complies with the California Integrated Waste Management Act of 1989 and includes the Source Reduction and Recycling Element, Household Hazardous Waste Element, Siting Element, and Non- Disposal Facility Element.
47 The purpose of the CoIWMP is to demonstrate methods and goals for the reduction of solid waste that is disposed of at landfills while demonstrating the long-term ability for Sonoma County to implement waste diversion programs and adequate disposal facilities for local jurisdictions.
Sonoma County Environmental Health Section, Solid Waste Management Program The Sonoma County Environmental Health Section, Solid Waste Management Program enforces state laws and regulations at solid waste sites within the County. Certified by CalRecycle, the agency is the Local Enforcement Agency for the landfills, transfer stations, and composting facilities within Sonoma County and conducts inspections and monitoring of these facilities as well as the franchised waste haulers. The agency also addresses illegal accumulation and investigates storage complaints.48 Zero Waste Sonoma
Zero Waste Sonoma (previously known as Sonoma County Waste Management Agency) is a joint powers authority for nine cities and towns within Sonoma County, including Santa Rosa, and the unincorporated areas of the county.
49 Zero Waste Sonoma provides recycling, composting and household hazardous waste programs and exists to serve and help county residents to reduce, reuse, and recycle materials safely and effectively. Jurisdictions within the county have adopted ordinances to reduce solid waste generation, with a goal of substantially reducing material going to landfills by 2030. Zero Waste Sonoma assists local
47 Sonoma County, October 15, 2003, Sonoma County Countywide Integrated Waste Management Plan, https://zerowastesonoma.gov/uploads/reports/CoIWMP_Combined.pdf, accessed September 1, 2023. 48 County of Sonoma, 2022, Solid Waste, https://sonomacounty.ca.gov/ public-notice-solid-waste-management-program-local-enforcement-agency-(lea) , accessed September 6, 2023. 49 Zero Waste Sonoma, 2023, About Us, https://zerowastesonoma.gov/about, accessed September 6, 2023.
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jurisdictions in meeting statewide waste diversion goals and performs state reporting functions for the jurisdictions within the county.
Local Regulations
Santa Rosa City Cod e
The SRCC includes various directives to ensure the proper handling of and adequate facilities for solid waste. The SRCC is organized by title, chapter, and section, and in some cases, articles. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to solid waste services are in Title 9, Health and Safety; Title 18, Building and Construction; and Title 20, Zoning, as follows:
Chapter 9-10, Waste Reduction Program for Carryout Bags. This chapter states that no retail establishment shall provide single-use carryout bags and may make available for sale to a customer a recycled paper bag at a minimum charge
Chapter 9-12, Refuse and Sanitation. This chapter establishes provision of waste, recycling, and yard trimmings collection services governed by the collection services contract. This chapter also outlines the rates for collection services and the rules associated with them. Chapter 9-14, Construction and Demolition Debris. This chapter requires that any person or entity that provides construction and demolition debris collection service within the city shall be required to enter into a nonexclusive Franchise Agreement with the City and pay a franchise fee to provide such service.
Chapter 9-30, Zero Waste Food Ware. This chapter states that food facilities and retail establishments in Santa Rosa must not sell, procure, distribute, or otherwise give way food ware or food accessories that contain either Per- and Polyfluoroalkyl or Polystyrene, and requires all Dine-In food facilities to only use reusable food ware and reusable food ware accessories. This chapter also describes other restrictions regarding food ware or food accessories and how three-bin waste stream containers are required.
Chapter 18-42, California Green Building Standards Code. This chapter adopts the State Green Building Standards Code by reference. With adoption of the California Green Building Standards Code, 2022 edition, the City requires that all construction projects submit a Construction Waste Management Plan that documents the diversion of construction waste and debris in compliance with the CALGreen requirements.
Section 20-30.120, Solid Waste and Recycling Storage Facilities. The purpose of this section is to provide recycling and waste collection areas within all developments city-wide. Design review approval is required for all waste collection and recycling facilities.
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Santa Rosa Zero Waste Master Plan
Adopted in January 2020, the City of Santa Rosa’s Zero Waste Master Plan guides the community in diverting its waste from landfill disposal and reducing waste at the source.50 The City’s zero waste goal is to reduce landfill disposal to less than one pound per person per day and achieve at least 75 percent diversion of waste from landfill disposal by 2030. The strategy of the Zero Waste Plan is to reduce waste generation at the source, increase the rates of recovery for divertible materials, increase community participation in recycling programs, increase the diversion of construction and demolition materials, and establish the City as a community leader in Zero Waste culture through outreach and education. The City also adopted the Zero Waste Sonoma resolution in 2020 that sets a goal of zero waste by 2030 and reducing the total pounds per person per day by at least 10 percent every year .
Existing Conditions
Solid Waste Collection and Recycling
Recology is the franchise waste hauler for the City of Santa Rosa and provides residential and commercial solid waste collection, composting, and recycling services. Recology provides the following services to residents and businesses in the City:
Weekly curbside collection of waste in three containers: landfill waste in a gray container, recyclables in a blue container, and organics (including yard and food waste) in a green container. Kitchen countertop compost pails to collect food scraps for placement in the compost cart. Curbside pickup of household batteries and motor oil and filters. Two free pickups per year of bulky items, such as old furniture, appliances, or mattresses. Outreach, education, and technical support to help customers divert more materials from landfill disposal and audits for businesses to identify opportunities to increase diversion 15 percent discount on Recology bill offered through the Recology Cares program for eligible households.
Debris boxes for construction and demolition (C&D) waste and transport and recycling of C&D materials, are provided as a separate, non-exclusive service.
All garbage collected in the gray bins from residents and businesses is transported to the Central Landfill in Petaluma, which is operated by Republic Services. The single-stream recycled material collected in the blue bins is transported to Recology’s Materials Recovery Facility in Santa Rosa, where it is sorted and baled for shipment. The organic waste collected in the green bins is transported to various composting facilities outside the County, including Cold Creek Compost, West Contra Costa Sanitary Landfill Organics Processing Facility, and Waste Management’s Earth Care Compost Facility in Novato. Each jurisdiction within Sonoma County receives an allotment of compost as part of the organics processing contracts, and Zero Waste Sonoma also manages a compost rebate program. Santa Rosa received about 1,683 yards of compost in 2022, which is given to residents, schools, nonprofits, gardens, parks, and ranchland. Santa
50 City of Santa Rosa, November 1, 2019, Zero Waste Master Plan, https://www.srcity.org/DocumentCenter/View/26668/Final-Santa-Rosa-Zero-Waste-Plan, accessed September 1, 2023.
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Rosa recovered approximately 1.4 million pounds of edible food in 2022, which is donated to food recovery organizations and services in Santa Rosa. The majority of the food was delivered to Redwood Empire Food Bank, which serves pantries throughout Sonoma County. 51 Landfills
The City of Santa Rosa is a member of the Sonoma County Waste Management Agency (now known as Zero Waste Sonoma), which is a county-wide Joint Powers Authority organized to provide regional compliance with State solid waste regulations and to act on behalf of its members in reporting disposal and diversion rates to CalRecycle. Therefore, there are no individual landfill disposal rates provided for cities within Sonoma County; they are incorporated in the County statistics.
In 2019, the solid waste that was generated by Sonoma County Waste Management Agency was transported to 26 facilities and landfills for a total disposal rate of 472,841 tons. However, 73 percent of the solid waste from Sonoma County and the majority of the waste from Santa Rosa was delivered to the Central Landfill in Petaluma.
52 The Central Landfill (officially known as the Central Disposal Site) is operated by Republic Services of Sonoma County Inc. and is located at 500 Meacham Road in Petaluma. The landfill has a maximum permitted throughput of 2,500 tons per day, a remaining capacity of 9.2 million cubic yards, and is estimated to close in 2043. Therefore, the landfill has a remaining capacity of more than 15 years as required by AB 939.
53 The Central Landfill information is summarized in Table 4.17-11, Central Landfill Data.
TABLE 4.17-11 CENTRAL LANDFILL DATA
Landfill Name and Location
Maximum Permitted
Throughput,
tons/day
Average
Disposal,
tons/day
Residual Disposal
Capacity,
tons/day
Remaining
Capacity,
cubic yards
Estimated
Closing Year
Central Landfill (Central
Disposal Site), Petaluma, CA 2,500 960 1,540 9,181,519 2043 Source: CalRecycle, 2023, SWIS Facility Details and Landfill Tonnage Reports.
Solid Waste Diversion and Recycling
Compliance with AB 939 is measured by comparing the CalRecycle target disposal rates for residents and employees to actual disposal rates. The CalRecycle target disposal rates for Sonoma County Waste Management Agency, of which the City of Santa Rosa is a member, for 2021 are 7.1 pounds per day (ppd) for residents and 18.3 ppd for employees. The actual disposal rates in 2021 were 4.6 ppd for residents and
51 Sonoma County Waste Management Agency, 2022, Electronic Annual Report to CalRecycle. 52 CalRecycle, 2023, Landfill Tonnage Reports, https://www2.calrecycle.ca.gov/LandfillTipFees/, accessed September 1, 2023.
53 CalRecycle, 2023, SWIS Facility/Site Detail, https://www2.calrecycle.ca.gov/SolidWaste/Site/Details/3621 s, accessed September 2, 2024.
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11.5 ppd for employees.54 Therefore, the solid waste diversion goals for Sonoma County and the City of Santa Rosa have been met.
STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impacts related to solid waste if it would:
9. 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.
10. Comply with federal, State, and local management and reduction statutes and regulations related to solid waste.
11. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to solid waste facilities.
IMPACT DISCUSSION
USS-9 Implementation of the proposed project would not 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.
With implementation of the proposed project, the population is anticipated to increase by 65,760 residents and 14,090 jobs. As shown in Table 4.17-12, Increase in Solid Waste Generation at 2050 Buildout, this level of growth would result in an increase in solid waste of approximately 232 tons per day, or 84,777 tons per year . These numbers are conservative because, with continued recycling and waste reduction programs implemented by the City and Zero Waste Sonoma, the waste generation rates would be reduced over time. The City’s goal is to reduce landfill disposal to less than one pound per person per day and achieve at least a 75 percent diversion rate from landfill disposal by 2030.55 TABLE 4.17-12 INCREASE IN SOLID WASTE GENERATION RATES AT 2050 BUILDOUT Category
Increase in Residents
or Jobs
Solid Waste Generation
Rate (pounds/day)
Increase in Solid Waste
(tons/day)
Increase in Solid Waste
(tons/year)
Residents 65,760 4.6 151 55,206
Jobs 14,090 11.5 81 29,571
Total 232 84,777
Sources: CalRecycle, 2023; PlaceWorks, 2023.
54 CalRecycle, 2023, Countywide, Regionwide, and Statewide Jurisdiction Diversion/Disposal Progress Report, accessed July 27, 2023.
55 City of Santa Rosa, November 1, 2019, Zero Waste Master Plan, https://www.srcity.org/DocumentCenter/View/26668/Final-Santa-Rosa-Zero-Waste-Plan, accessed September 1, 2023.
4.17.4.2 4.17.4.3
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As shown in Table 4.17-12, an increase of 232 tons per day with buildout of the project would be about 15 percent of the current residual capacity of 1,540 tons per day at Central Landfill. In addition, some of the solid waste from the City of Santa Rosa is transported to other landfills in the Bay Area, and Zero Waste Sonoma and the City are working together to divert more waste from landfill disposal through recycling, composting, and edible food redistribution. This estimate conservatively assumes that all of the generated waste is landfilled. The results in Table 4.17-12 show that the proposed project would not generate solid waste in excess of the capacity of the landfills that serve the City and Sonoma County.
Furthermore, all new potential future development in the EIR Study Area would require compliance with CALGreen Sections 4.408 and 5.408, which require that at least 65 percent of nonhazardous construction and demolition waste from residential and nonresidential construction operations be recycled and/or salvaged for reuse. New development and redevelopment would also need to comply with the requirements of AB 341 and SB 1383 that mandates recycling and organics collection for commercial and multifamily residential land uses. In addition, Recology provides recycling and green waste collection for all residents in Santa Rosa. Therefore, solid waste facilities would be able to accommodate project- generated solid waste, and impacts would be less than significant.
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to minimize impacts related to solid waste generation. In addition to the goals, policies, and actions listed under impact discussion USS-1, the following proposed goal, policies, and actions would serve to minimize potential adverse impacts on solid waste generation:
Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.5: Meet the city’s solid waste disposal needs while maximizing opportunities for waste reduction and recycling.
Action 5-9.33: Continue to implement and update the City’s Zero Waste Master Plan and Program.
Action 5-9.34: Continue public education programs about waste reduction, including recycling, composting, yard waste, wood waste, and household hazardous waste. Action 5-9.35: Continue to enforce the City’s Zero-Waste Food Ware Ordinance and share information and resources with food facilities to help facilitate compliance. Action 5-9.36: Continue to implement and update the City’s Environmentally Preferable Purchasing policies and identify opportunities to reduce use of single-use plastics in municipal operations and at City events.
Action 5-9.37: Promote non-plastic packaging alternatives to local businesses. Action 5-9.38: Provide and maintain public drinking fountains and bottle fillers in high traffic and outdoor recreation areas to reduce demand for bottled water . Policy 5-9.6: Identify and work with partners to address impacts from groundwater threats and solid waste.
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Action 5-9.40: Monitor the Solid Waste Information System (SWIS) and Closed, Illegal, and Abandoned (CIA) Disposal Sites Program to identify solid waste sites and facilities that are illegal, abandoned, or have not met the standards for closure, and work with State agencies to investigate and enforce standards for sites, prioritizing sites in and near Equity Priority Areas. Policy 5-9.7: Facilitate residential, commercial, and industrial compliance with the Sonoma County Countywide Integrated Waste Management Plan.
Action 5-9.42: Provide educational materials regarding waste management, control, and recycling, including the Sonoma County Household Hazardous Waste Management Plan.
With continued compliance of the applicable regulations, leading to increased recycling and waste diversion, and adherence to the General Plan 2050 goals, policies, and actions listed above, anticipated rates of solid waste disposal from the project would be less than significant with respect to permitted landfill capacity. In addition, Sonoma County is well below the CalRecycle target disposal rates and meets the regulatory requirements of AB 939. Therefore, implementation of the proposed project would not generate solid waste in excess of State and local standards, or in excess of the capacity of the landfills, or otherwise impair the attainment of solid waste reduction goals and the impact is less than significant.
Significance without Mitigation: Less than significant.
USS-10 Implementation of the proposed project would comply with federal, State, and local management and reduction statutes and regulations related to solid waste.
As discussed under impact discussion USS-8, Recology, which serves the EIR Study Area, complies with all State requirements to reduce the volume of solid waste through recycling and organic waste diversion.
The Zero Waste Sonoma per capita disposal rates of 4.6 ppd per resident and 11.5 ppd per employee are well below the CalRecycle targets of 7.1 ppd for residents and 18.3 ppd for employees. In addition, all potential future development over the buildout horizon of the proposed project would comply with CALGreen Sections 4.408 and 5.408, which require that at least 65 percent of nonhazardous construction and demolition waste from nonresidential construction operations be recycled and/or salvaged for reuse.
Potential future development would also comply with AB 341, which mandates recycling for commercial and multifamily residential land uses as well as schools and school districts. All jurisdictions in California are required to provide organic waste collection services to all residents and businesses, beginning in 2022 and in accordance with SB 1383. Recology and the City currently comply with all applicable federal, State, and local solid waste regulations, and solid waste, recycling, and green waste collection services are available for all residents and commercial businesses. Therefore, the proposed project would comply with all current and future regulatory requirements and solid waste impacts would be less than significant.
Significance without Mitigation: Less than significant.
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USS-11 Implementation of the proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to solid waste facilities.
The area considered for cumulative impacts to solid waste disposal facilities is Sonoma County, which is serviced by Recology. As reported by the California Department of Finance, the total population of Sonoma County is expected to decrease from 488,022 in 2020 to 434,406 by 2050.56 While the proposed project solid waste generation would be 232 tons per day for the City of Santa Rosa, a projected decrease in countywide population would result in an overall reduction in solid waste generation for Sonoma County. As discussed under impact discussion USS-8, conservatively assuming that all of this waste is landfilled, although the current diversion rate by Recology is about 34 percent, the additional waste generated by Santa Rosa with the proposed project at the horizon year of 2050 would only about 15 percent of the daily residual capacity of Central Landfill of 1,540 tons per day.
In addition, new development within the county would comply with CALGreen Sections 4.408 and 5.408, which require that at least 65 percent of nonhazardous construction and demolition waste from residential and nonresidential construction operations be recycled and/or salvaged for reuse. This would also reduce the volume of solid waste transported to the landfills. Continued compliance with the applicable regulations and an increase in recycling and landfill diversion rates would ensure that solid waste cumulative impacts would be less than significant.
Significance without Mitigation: Less than significant.
4.17.5 ENERGY INFRASTRUCTURE
ENVIRONMENTAL SETTING
Regulatory Framework
The regulatory framework for energy is described in detail in Chapter 4.6, Energy, of this Draft EIR. The regulatory requirements that pertain solely to energy infrastructure are repeated below.
Federal Regulations
National Energy Policy
Established in 2001 by the National Energy Policy Development Group, the National Energy Policy is designed to help the private sector, and state and local governments promote dependable, affordable, and environmentally sound production and distribution of energy for the future. Key issues addressed by the energy policy are energy conservation, repair and expansion of energy infrastructure, and ways of increasing energy supplies while protecting the environment.
56 California Department of Finance, 2023, Population Projections, https://dof.ca.gov/forecasting/demographics/projections/, accessed September 6, 2023.
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Energy Policy Act of 2005
Passed by Congress in July 2005, the Energy Policy Act includes a comprehensive set of provisions to address energy issues. This Act includes tax incentives for energy conservation improvements in commercial and residential buildings, fossil fuel production and clean coal facilities, and construction and operation of nuclear power plants, among other things. Subsidies are also included for geothermal, wind energy, and other alternative energy producers.
Energy Independence and Security Act of 2007
Signed into law in December 2007, the Energy Independence and Security Act contains provisions designed to increase energy efficiency and the availability of renewable energy. The Act contains provisions for increasing fuel economy standards for cars and light trucks, while establishing new minimum efficiency standards for lighting as well as residential and commercial appliance equipment.
National G
as Pipeline Safety Act of 1968
The Natural Gas Pipeline Safety Act of 1968 authorizes the United States Department of Transportation to regulate pipeline transportation of flammable, toxic, or corrosive natural gas and other gases as well as the transportation and storage of liquefied natural gas. The Pipeline and Hazardous Materials Safety Administration within the Department of Transportation develops and enforces regulations for the safe, reliable, and environmentally sound operation of the nation's 2.6-million-mile pipeline transportation system. The regulations enacted under this act have been updated several times. The latest revision is dated May 2023 and includes additional safety regulations for gas transmission pipelines, including repair criteria, integrity management improvements, cathodic protection, and other inspection and maintenance procedures. The regulations are encoded in 49 Code of Federal Regulations, Part 192.
State Regulations
Warren-Al
quist Act
Established in 1974, the Warren-Alquist Act created the California Energy Commission (CEC) in response to the energy crisis of the early 1970s and the state’s unsustainable growing demand for energy resources. The CEC’s core responsibilities include advancing State energy policy, encouraging energy efficiency, certifying thermal power plants, investing in energy innovation, developing renewable energy, transforming transportation, and preparing for energy emergencies. The Warren-Alquist Act is updated annually to address current energy needs and issues, and its latest revision is dated January 2023.
California Public Utilities Commission Long Term Energy Efficiency Strategic Plan Adopted in September 2008 and updated in January 2011, the California Public Utilities Commission (CPUC) Long Term Energy Efficiency Strategic Plan provides a framework for energy efficiency in California through the year 2020 and beyond. It articulates a long-term vision, as well as goals for each economic sector, identifying specific near-, mid-, and long-term strategies to assist in achieving these goals. The plan sets forth the following four goals, known as “Big Bold Energy Efficiency Strategies,” to achieve significant reductions in energy demand:
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All new residential construction in California will be zero net energy by 2020. All new commercial construction in California will be zero net energy by 2030. Heating, ventilation, and air conditioning will be transformed to ensure that its energy performance is optimal for California’s climate.
All eligible low-income customers will be given the opportunity to participate in the low-income energy efficiency program by 2020.
The CPUC and CEC have adopted the following goals to achieve zero net energy levels by 2030 in the commercial sector:
Goal 1: New construction will increasingly embrace zero net energy performance (including clean, distributed generation), reaching 100 percent penetration of new starts in 2030. Goal 2: 50 percent of existing buildings will be retrofit to zero net energy by 2030 through achievement of deep levels of energy efficiency and with the addition of clean distributed generation. Goal 3: Transform the commercial lighting market through technological advancement and innovative utility initiatives.
California B
uilding Energy Code: Title 24, Part 6, Energy Efficiency Standards The State of California provides a minimum standard for energy conservation through Title 24, Part 6 California Code of Regulations, commonly referred to as the California Energy Code. The California Energy Code was first adopted by the California Energy Resources Conservation and Development Commission (now the CEC) in June 1977. The standards are updated on a three-year cycle to allow for consideration and possible incorporation of new energy efficiency technologies and methods. In August 2021, the CEC adopted the 2022 California Energy Code, which went into effect on January 1, 2023. The 2022 standards require mixed-fuel single-family homes to be electric ready to accommodate replacement of gas appliances with electric appliances. In addition, the new standards also include prescriptive photovoltaic systems and battery requirements for high-rise, multifamily buildings (i.e., more than three stories) and noncommercial buildings such as hotels, offices, medical offices, restaurants, retail stores, schools, warehouses, theaters, and convention centers.
57 California Bu ilding Code: Title 24, Part 11, Green Building Standards On July 17, 2008, the California Building Standards Commission adopted the nation’s first green building standards. CALGreen (24 California Code of Regulations, Part 11) was adopted as part of the California Building Standards Code. It includes mandatory requirements for new residential and nonresidential buildings throughout California. CALGreen is intended to (1) reduce greenhouse gas (GHG) emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the governor . The latest 2022 CALGreen code became effective on January 1, 2023.
57 California Energy Commission, 2021, Amendments to the Building Energy Efficiency Standards (2022 Energy Code) Draft Environmental Report, CEC-400-2021-077-D.
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CALGreen includes provisions to reduce construction waste, make buildings more efficient in the use of materials and energy, and reduce environmental impact during and after construction. CALGreen contains requirements for construction site selection, stormwater control during construction, construction waste reduction, indoor water use reduction, material selection, natural resource conservation, site irrigation conservation, etc. The code provides for design options, allowing the designer to determine how best to achieve compliance for a given site or building condition. The code also requires building commissioning, which is a process for verifying that all building systems (e.g., heating and cooling equipment and lighting systems) are functioning at their maximum efficiency.
58 Appliance Efficiency Regulations
The Appliance Efficiency Regulations (Title 20, California Code of Regulations Sections 1601 through 1608), combined with federal standards, set minimum efficiency levels for energy and water consumption in products, such as consumer electronics, household appliances, and plumbing equipment. The regulations are continually updated with the latest revisions dated 2023. Eighteen categories of appliances are included in the scope of these regulations. The standards within these regulations apply to appliances that are sold or offered for sale in California, except those sold wholesale in California for final retail sale outside the state, and those designed and sold exclusively for use in recreational vehicles or other mobile equipment. These regulations exceed the standards imposed by all other states and they reduce GHG emissions by reducing energy demand.
California Energy Benchmarking and Disclosure
The Building Energy Benchmarking Program is mandated under AB 802 and requires owners of large commercial and multifamily buildings to report energy use to the CEC by June 1 annually. This program applies to all buildings with more than 50,000 square feet of gross floor area and owners of multifamily residential buildings with more than 50,000 square feet and 17 or more utility accounts. The bill requires each utility, upon the request and authorization of the owner, owner’s agent, or operator of a building covered under the regulation, to deliver or provide aggregated energy usage data for a covered building.
The required energy usage shall be reported to the CEC through the Energy Star Portfolio Manager .
California Ren
ewable Portfolio Standards
A major component of California’s Renewable Energy Program is the renewables portfolio standard established under SB 1078 (Sher) and SB 107 (Simitian). The standard requires that a specified percentage of the electricity that utilities provide comes from renewable resources. Renewable sources of electricity include wind, small hydropower, solar, geothermal, biomass, and biogas. SB 1020, signed into law on September 16, 2022, requires renewable energy and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035 and 95 percent by 2040. Additionally, SB 1020 requires all State agencies to procure 100 percent of electricity from renewable energy and zero-carbon resources by 2035.
58 California Building Standards Commission, 2022, 2022 California Code of Regulations Title 24, Part 11, https://codes.iccsafe.org/content/CAGBC2022P1, accessed June 1, 2023.
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CPUC Natural Gas Regulations
The CPUC regulates natural gas utility rates and services as well as the transportation of natural gas over the extensive transmission and distribution pipeline systems. The CPUC also regulates gas storage facilities. The Gas Safety and Reliability Branch of the CPUC ensures that natural gas pipeline systems are designed, constructed, operated, and maintained according to the safety standards set by the CPUC and the federal government. The regulations are provided in the CPUC General Order No. 112-E and the Natural Gas Pipeline Safety Act of 2011.
Local Regulations
Santa Rosa City Code
The SRCC includes various directives pertaining to energy-related infrastructure. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to energy infrastructure are in Title 3, Revenue and Finance; Chapter 13, Underground Utilities; Title 18, Buildings and Construction; and Chapter 19, Subdivisions, as follows:
Chapter 3-32, Utility Users Tax. This chapter is also known as the utility users tax ordinance. Section 3-
32.060, Electricity Users Tax, outlines the tax that electric energy users in the city must pay. This code also defines what a charge and what using electric energy use means in this context. Section 3-32.070, Gas Users Tax, outlines the tax imposed on every person in the city that uses gas through main or pipes. Some exclusions from the tax are applicable and described in this code as well. Chapter 13-12, Underground Utilities. This chapter regulates and controls the wires, poles, and other wire-carrying structures within certain areas of the city. Section 13-12.30, Poles and wires prohibited aboveground on Montgomery Drive, prohibits aboveground wires, poles, or any other structure designed to carry telephone, telegraph, electric conduit at any place within 100 feet of the centerline of Montgomery Drive. Article II, Procedure for Undergrounding, outlines public hearing procedure, designation of underground utility districts, exceptions, notices, and the responsibilities of utility companies, property owners, and the City. Article III, Electric Underground District, describes the area designated as electric underground district. Article IV, Undergrounding in Other Areas, describes the requirements for undergrounding in other areas of the City that are part of the electric underground district.
Title 18, Buildings and Construction. This title adopts by reference, with the additions, insertions, deletions and changes listed throughout, the California Energy Code in Chapter 18-33, California Energy Code, and the California Green Building Standards Code in Chapter 18-42, California Green Building Standards Code. This title also includes Chapter 18-68, Expedited Permit Process for Small Residential Rooftop Solar Energy Systems, which provides for an expedited, streamlined solar permitting process that complies with the Solar Rights Act and AB 2188 in order to achieve timely and
cost-effective installations of small residential rooftop solar energy systems. It also includes Chapter 18-69, Expedited Process for Electric Vehicle Charging Stations.
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Chapter 19-04.090, Energy Conservation. This chapter provides for subdivisions to be designed to include passive or natural heating or cooling opportunities. Some examples of these opportunities include having the alignment of the subdivision be in the east-west direction and taking advantage of the available shade and prevailing breezes on the site. Chapter 20-44, Telecommunication Facilities. This chapter provides uniform and comprehensive standards for development of telecommunication facilities, including antenna installation, to protect environmental resources and ensure facilities comply with exposure standards from the Federal Communication Commission.
Santa Rosa City-Wide Energy Efficiency, Renewables, and Microgrid Feasibility Study The City prepared a feasibility study to identify opportunities to reduce greenhouse gas emissions and improve the energy resiliency in light of the increased frequency of natural disasters and catastrophic climate change events.
59 A total of 47 City facilities and 63 parks were evaluated to identify locations for solar voltaic installations, electrification of building heating, air conditioning and ventilation systems, and other building efficiency measures. Seven buildings within the city were recommended for microgrids (i.e., a mix of distributed energy resources to improve energy delivery and resiliency).
Existing Conditions
Electricity
Two energy providers, Sonoma Clean Power (SCP) and Pacific Gas & Electric (PG&E), serve the EIR Study Area. SCP is the public electricity provider for Sonoma and Mendocino counties.60 As a not-for-profit public agency, SCP is independently run by Sonoma County and the participating cities of Coverdale, Cotati, Petaluma, Rohnert Park, Santa Rosa, Sebastopol, and Sonoma and the Town of Windsor . SCP provides electricity generated from renewable sources such as solar, wind, geothermal, and hydropower.
Individuals residing or working within the SCP service area are automatically enrolled in SCP . SCP offers three program options; the CleanStart program provides 42 percent renewable power service; the EverGreen program provides 100 percent local renewable power service; or the OptOut program allows individuals to continue to receive PG&E’s basic service. 61 The electric energy provided by SCP is conveyed
to customers through PG&E’s existing infrastructure. PG&E continues to maintain the grid, repair lines, and customer billing within the SCP service area.
PG&E is a publicly traded utility company that generates, purchases, and transmits energy and natural gas under contract with the CPUC. PG&E’s service territory is 70,000 square miles, roughly extending north to south from Eureka to Bakersfield, and east to west from the Sierra Nevada to the Pacific Ocean. PG&E’s electricity distribution system consists of 106,681 circuit miles of electric distribution lines and 18,466
59 City of Santa Rosa, July 2021, City-Wide Energy Efficiency, Renewables, and Microgrid Feasibility Study. 60 Sonoma Clean Power, 2023, Who We Are, https://sonomacleanpower.org/whoweare, accessed July 25, 2023. 61 Sonoma Clean Power, 2023, You have the Power, https://sonomacleanpower.org/cleanstart-evergreen, accessed July 25, 2023.
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circuit miles of interconnected transmission lines with approximately 5.5 million electric customer accounts.62
PG&E electricity is generated by a combination of sources such as natural gas-fired power plants, nuclear power plants, and hydro-electric dams as well as newer sources of energy such as wind turbines and photovoltaic plants, also known as solar farms. The electric grid is a network of high-voltage transmission lines that link power plants with the PG&E system. The distribution system, comprised of lower voltage secondary lines, is at the street and neighborhood level and consists of overhead or underground distribution lines, transformers, and individual service “drops” that connect to the individual customer .
The power mix PG&E provided to customers in 2021 consisted of renewable resources (50 percent), nuclear (39 percent), natural gas plants (7 percent), and large hydroelectric facilities (4 percent). The renewable resources include wind, geothermal, biomass, solar, and small hydro. 63 PG&E also has 600
megawatts of battery storage capacity already connected to the electric grid and has contracts for an additional 3,300 megawatts of capacity by 2024.
PG&E’s projected average annual electricity demand growth (mid-demand forecast) between 2019 and 2035 is approximately 1.5 percent. Total mid-electricity consumption in PG&E’s service area was 106,617 gigawatt-hours per year in 2019 and is forecast to increase to 133,893 gigawatt-hours in 2035. 64 PG&E is
expected to meet its electricity demands in 2035 and is ahead of schedule on meeting California’s GHG- free requirements.
Natural Gas
PG&E is also the natural gas service provider for the city of Santa Rosa. The natural gas system includes approximately 50,000 miles of natural gas pipelines, including 6,700 miles of transmission pipelines and 42,000 miles of distribution pipelines.65 The transmission pipelines move natural gas from compressor stations and storage facilities to regulator stations. At the regulator station, the pressure in the pipeline is reduced before gas enters the distribution system, which consists of smaller diameter pipelines that deliver gas to residences and businesses. PG&E has approximately 4.5 million natural gas customer accounts. Natural gas demand statewide is projected to decline an average of 1.1 percent per year through 2035.
66 This is primarily due to the goal of reducing greenhouse gas emissions and the ordinances of some cities for new construction to be all electric. Gas demand is expected to decrease from 5,298 million cubic feet of gas per day in 2022 to 4,857 million cubic feet per day by 2035. California’s gas
62 Pacific Gas and Electric Company, 2023, Company Profile, https://www.pge.com/en_US/ about-pge/company-information/profile/profile.page, accessed on June 1, 2023. 63 Pacific Gas and Electric Company, 2023, PG&E’s 2021 Power Mix, https://www.pge.com/en_US/about- pge/environment/what-we-are-doing/clean-energy-solutions/clean-energy-solutions.page, accessed June 1, 2023. 64 California Energy Commission, 2023, California Energy Demand Forecast, 2021-2035, https://www.energy.ca.gov/data- reports/reports/integrated-energy-policy-report/2021-integrated-energy-policy-report/2021-1, accessed June 1, 2023. 65 Pacific Gas and Electric Company, 2023, PG&E Natural Gas System, https://www.pge.com/en_US/safety/how-the-system- works/natural-gas-system-overview/natural-gas-system-overview.page, accessed February 18, 2023. 66 California Public Utilities Commission, 2022, 2022 California Gas Report, https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_Gas_Report_2022.pdf, accessed June 1, 2023.
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storage facilities supplement pipeline gas supply during high demand periods and also provide supply reliability. The supplies of natural gas would meet the demand through year 2035.67 Telecommunications and Internet Providers
Telecommunications services include wireless internet, cell phone and land line telephone, cable television, and satellite television. There are numerous telecommunication and internet providers that serve the EIR Study Area. Telecommunication providers include AT&T, Verizon, CDS Wireless, and others.
Internet providers include Comcast, Sonic, AT& T, T-Mobile, Vista Broadband Networks, and others.
Multiple choices give Santa Rosa residents and businesses a variety of options when choosing telecommunication providers. The wireless networks consist of fiber-optic cables that connect major internet hubs over long distances. The networks can be expanded by using small cell facilities, which are small antennae placed on existing utility poles or streetlights along with small pole-mounted radios and other accessory equipment. In this manner, the fiber-optic network can be easily expanded to meet the demand for wireless services. The current infrastructure in place is sufficient to serve existing and future customers in the EIR Study Area.
STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impacts related to energy infrastructure if it would:
12. Require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
13. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to electric power, natural gas, or telecommunications facilities.
IMPACT DISCUSSION
USS-12 Implementation of the proposed project would not require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
Electrical service to the EIR Study Area would be provided by SCP and PG&E through connections to existing off-site electrical lines and new on-site infrastructure. As shown in Table 4.17-13, Year 2050 Forecast Electricity Consumption, electricity use in the EIR Study Area would increase by 63,691,182 kilowatt-hours per year . However, the per-person electricity use would decrease by 548 kWh per year,
67 California Public Utilities Commission, 2022, 2022 California Gas Report, https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_Gas_Report_2022.pdf, accessed June 1, 2023.
4.17.5.2 4.17.5.3
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which reflects the replacement of existing building stock with new development that meets the California Building Energy Efficiency Standards and CALGreen standards.
TABLE 4.17-13 YEAR 2050 FORECAST ELECTRICITY CONSUMPTION Land Use
Electricity Usage (kWh/year)
Existing Conditions
Proposed
General Plan 2050 a Net Change
EIR Study Area
Residential 367,395,591 415,787,730 48,392,139
Nonresidential 525,542,438 540,841,480 15,299,042
Total 892,938,028 956,629,210 63,691,182
Service Population 275,569 355,425 79,856
Per Service Population Annual Consumption 3,240 2,692 -548 Notes: kWh = kilowatt hour.
a. Modified with State Actions to reduce greenhouse gas emissions (see Chapter 4.6, Energy, of this Draft EIR).
Source: See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR.
As shown in Table 4.17-14, Year 2050 Forecast Natural Gas Consumption, natural gas use under the proposed project is estimated to total 48,851,700 therms annually. While the City currently has a reach code requiring all new residential construction of three stories and below to be all electric (SRCC Section 18-42.4.106.5), it cannot be guaranteed that every individual development project facilitated by the proposed project would be subject to this requirement. To provide a conservative assessment of what energy consumption may be in 2050 resulting from implementation of the proposed project, the new growth in building space anticipated through 2050 was assumed to include natural gas for space and water heating. With this assumption, by 2050, natural gas use in the EIR Study Area would be 4,525,626
therms annually, or approximately a 10 percent increase, from existing conditions. However, the per- service population natural gas consumption is estimated to slightly decrease from 161 therms per person per year in 2019 to 137 therms per person per year in 2050 for natural gas. As described above, this number can be considered to represent a conservative (i.e., “worst case”) scenario as many residential projects in the city would be subject to the reach code’s all-electric requirements.
TABLE 4.17-14 YEAR 2050 FORECAST NATURAL GAS CONSUMPTION Land Use
Natural Gas Usage (Therms per year)
Existing Conditions
Proposed
General Plan 2050 a Net Change
EIR Study Area
Residential 28,371,401 31,665,210 3,293,809
Nonresidential 15,954,672 17,186,490 1,231,818
Total 44,326,074 48,851,700 4,525,626
Service Population 275,569 355,425 79,856
Per Service Population Annual Consumption 161 137 -24
Note:
a. Modified with State Actions to reduce greenhouse gas emissions (see Chapter 4.6, Energy, of this Draft EIR).
Source: See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR.
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These energy consumption rates are modest increases when considered in the context of SCP’s and PG&E’s service territories. The increase in electricity usage for the EIR Study Area is approximately 0.1 percent of PG&E’s projected energy supply in 2035, and the increase in natural gas consumption for the EIR Study Area is less than 0.03 percent of PG&E’s natural gas supply.68 PG&E also states that there would be sufficient electrical and natural gas supplies to cover its service area in 2035.
In addition, potential future development would be required to comply with the current and future updates to the California Energy Code and CALGreen, which would contribute to reducing energy demands. New buildings would also use new energy-efficient appliances and equipment pursuant to the Appliance Efficiency Regulations, which would ensure the use of efficient electricity and natural gas consumption. New and replacement buildings in compliance with these standards would generally have greater energy efficiency than existing buildings. Additionally, new construction within the City would underground utilities per SRCC Chapter 13-20, Underground Utilities, which would improve electricity efficiency and safety.
Chapter 3, Circulation, Conservation, and Greenhouse Gas Reduction Element, of the proposed General Plan contains goals, policies, and actions that require local planning and development decisions to consider electricity and natural gas impacts. The following goal, policies, and actions would serve to improve energy efficiency and reduce energy impacts:
Goal 3-7: Strive to achieve net carbon neutrality no later than 2045. Policy 3-5.3: Increase the use of renewable, carbon free, and distributed energy resources throughout the city.
Action 3-7.5: Require regular energy audits of existing City-owned and operated structures, identifying levels of existing energy use and potential conservation and efficiency measures. Action 3-7.6: Develop a capital project list and funding strategy to complete energy-efficiency projects for City-owned and operated structures and adjust the list annually to add new projects as needed.
Action 3-7.7: Provide information on the cost-savings potential and other benefits of energy audits and energy-efficient retrofits to encourage their preparation for buildings throughout the city.
Action 3-7.9: Identify incentives to encourage new buildings to exceed State energy efficiency requirements and/or meet or exceed the U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Program or equivalent standards. Action 3-7.11: Use education and incentives to promote and sustain energy-conserving design and practices.
Policy 3-7.3: Increase the use of renewable, carbon-free, and distributed energy resources throughout the city.
68 PG&E’s projected energy supplies for electricity and natural gas do not extend beyond 2035.
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Action 3-7.12: Revise any existing codes and policies that constrain or prohibit the installation of environmentally acceptable forms of distributed energy generation. Action 3-7.13: Identify incentives and other means to encourage new and existing buildings to include battery energy storage systems, especially buildings with solar energy installations and municipal buildings that provide essential community services. Action 3-7.14: Participate in State and local efforts to develop appropriate policies and review procedures for the installation of photovoltaic solar and other forms of distributed energy generation.
Action 3-7.15: Continue to participate in utility-sponsored renewable energy programs that allow the city to receive a significant portion of energy from renewable sources. Action 3-7.16: Seek and identify resources to assist low-income homeowners and small business owners with identifying financing options for installation of rooftop solar energy systems, energy storage, and electrification of existing buildings. Action 3-7.17: Support the development of local-serving renewable energy projects that expand the availability of local renewable energy, provide sustainable local jobs, and support local and regional housing, economic development, and sustainability goals and initiatives. Action 3-7.18: Encourage the establishment of neighborhood renewable energy microgrids to support resilience.
Action 3-7.19: Support State and utility efforts to improve grid resilience and capacity.
Compliance with federal, State, and local regulations (e.g., Building Energy Efficiency Standards, CALGreen, and Renewables Portfolio Standards) would increase building energy efficiency and reduce building energy demands. Additionally, the proposed General Plan 2050 goal, policies, and actions listed above will contribute to minimizing building-related energy demands and demands on nonrenewable sources of energy. Implementation of the proposed General Plan 2050 goals, policies, and actions in conjunction with and complementary to regulatory requirements would ensure that energy demand associated with growth under the proposed project would be efficient, therefore avoiding the need for new or expanded electric power and natural gas facilities. In addition, the energy providers and telecommunications providers that serve the EIR Study Area indicate that they have the capability to serve future increases in population within their service areas without significant changes to the existing infrastructure. Therefore, implementation of the proposed project would not require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities and impacts would be less than significant.
Significance without Mitigation: Less than significant.
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USS-13 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulatively considerable impact to electric power, natural gas, or telecommunications facilities.
The area considered for cumulative impacts are the service areas of SCP and PG&E for electricity and PG&E for natural gas. Other projects within the service areas would increase electricity and natural gas demands. The CPUC has identified the Integrated Energy Policy Report as “the appropriate venue for considering issues of load forecasting, resource assessment, and scenario analyses, to determine the appropriate level and ranges of resource needs for load serving entities in California.” The latest report shows that California’s electricity sector is leading efforts to reduce GHG emissions and electricity consumption is projected to increase compared to previous energy demand projections, mostly attributable to increased levels of transportation electrification. 69 Natural gas consumption is expected to
level out between 2020 and 2026 before decreasing from 2026 to 2035 from new building standards and the implementation of city and county ordinances that require new construction to have all-electric appliances and heating.
In addition, all future projects developed within the SCP and PG&E service areas would implement the requirements of the California Energy Code and CALGreen. New buildings would also use new energy- efficient appliances and equipment, pursuant to the Appliance Efficiency Regulations. Counties and cities review project design plans against these codes and ensure compliance before issuing construction permits. These measures would reduce the overall consumption of electricity and natural gas. The energy providers and telecommunications providers that serve the EIR Study Area and Sonoma County indicate that they have the capability to serve future increases in population within their service areas without significant changes to the existing infrastructure. In addition, the proposed General Plan 2050 includes goals, policies, and actions that would contribute to minimizing inefficient, wasteful, or unnecessary energy consumption and ensure compliance with State, regional, or local plans for renewable energy, therefore avoiding the need for new or expanded electric power and natural gas facilities. Therefore, the proposed project would not result in a significant impact to electric power, natural gas, or telecommunication facilities, and cumulative impacts would be less than significant.
Significance without Mitigation: Less than significant.
69 California Energy Commission, February 2023, Final 2022 Integrated Energy Policy Report Update, https://www.energy.ca.gov/sites/default/files/2023-02/Adopted_2022_IEPR_Update_with_errata_ada.pdf, accessed September 7, 2023.
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4.18 WILDFIRE
This chapter of the Draft Environmental Impact Report (EIR) describes the potential wildfire impacts associated with the adoption and implementation of the proposed project. This chapter describes the regulatory framework and existing conditions, identifies criteria used to determine impact significance, provides an analysis of the potential wildfire impacts, and identifies proposed General Plan 2050 goals, policies, and actions, as well as feasible mitigation measures, that would minimize any potentially significant impacts.
4.18.1 ENVIRONMENTAL SETTING
REGULATORY FRAMEWORK
Federal Regulations
National Cohesive Wildfire Management Strategy
In the Federal Land Assistance, Management, and Enhancement Act of 2009, Congress mandated the development of a National Cohesive Wildland Fire Management Strategy for all lands in the United States.
Wildfire management is guided by the National Cohesive Wildland Fire Management Strategy, which has three primary goals:
1 Resilient landscapes
Fire adapted communities
Safe and effective wildfire response
These three goals enable land managers to manage vegetation and fuels; protect homes, communities, and other values at risk; manage human-caused ignitions; and effectively and efficiently respond to wildfires. California is part of the Western Regional Strategy Committee, chartered to support and facilitate the implementation of the National Cohesive Wildland Fire Strategy.
Healthy Forests Restoration Act
The Healthy Forests Restoration Act (US Code Title 16, Chapter 84, Section 6501) was approved on December 3, 2003, to reduce wildfire risk to communities, municipal water supplies, and at-risk federal lands expediting projects designed to reduce hazardous fuels. This Act provides regulations for the protection of watersheds, forests, and rangelands from catastrophic wildfires across the landscape.
Measures include improving systems to detect insect and disease infestations in hardwood forests; providing forestry assistance to state, private, and tribal landowners; facilitating research on large-scale
1 United States Department of the Interior and United States Department of Agriculture, April 2014, The National Strategy:
The Final Phase of Development of the National Cohesive Wildland Fire Management Strategy, https://www.forestsandrangelands.gov/documents/strategy/strategy/CSPhaseIIINationalStrategyApr2014.pdf, accessed April 3, 2023.
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treatments to reduce pest infestations; and entering into contracts with private landowners to manage their forests.
National Fire Protection Association Standards
National Fire Protection Association (NFPA) codes, standards, recommended practices, and guides are developed through a consensus standards development process approved by the American National Standards Institute. NFPA standards are recommended (advisory) guidelines for fire protection that are referenced in the California Fire Code (CFC), which is adopted by the City of Santa Rosa every three years.
Specific standards applicable to wildland fire hazards include, but are not limited to:
NFPA 1141, Fire Protection Infrastructure for Land Development in Wildlands NFPA 1142, Water Supplies for Suburban and Rural Fire Fighting NFPA 1143, Wildland Fire Management
NFPA 1144, Reducing Structure Ignition Hazards from Wildland Fire NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations
State Regulations
California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) is dedicated to the fire protection and stewardship of over 31 million acres of California’s wildlands. CAL FIRE provides fire assessment and firefighting services for land in State Responsibility Areas (SRA), conducts educational and training programs, provides fire planning guidance and mapping, and reviews general plan safety elements to ensure compliance with State fire safety requirements. CAL FIRE staff, or a designee, also reviews building permit applications, parcel maps, and use permits for construction or development in SRAs and Local Responsibility Areas (LRA).
The Board of Forestry and Fire Protection is a government-appointed approval body within CAL FIRE. It is responsible for developing the general forest policy of the state, determining the guidance policies of CAL FIRE and representing the State’s interest in federal forestland in California. The Board of Forestry and Fire Protection also promulgates regulations and approves general plan safety elements that are adopted by local governments for compliance with State statutes.
The California Office of the State Fire Marshal supports the mission of CAL FIRE by focusing on fire prevention. These responsibilities include regulating buildings in which people live, congregate, or are confined; controlling substances and products that may, in and of themselves or by their misuse, cause injuries, death, and destruction by fire; providing statewide direction for fire prevention within wildland areas; regulating hazardous liquid pipelines; developing and renewing regulations and building standards; and providing training and education in fire protection methods and responsibilities. These are accomplished through major programs, including engineering, education, enforcement, and support from the Board of Forestry and Fire Protection. For jurisdictions in SRAs or very high fire hazard severity zones (Very High FHSZs), the Land Use Planning Program division of the Office of State Fire Marshal reviews SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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safety elements during the update process to ensure consistency with California Government Code, Section 65302(g)(3).
Together, the Board of Forestry and Fire Protection, Office of State Fire Marshal, and CAL FIRE protect and enhance the forest resources of all wildland areas of California that are not under federal jurisdiction.
Fire Hazard Severity Zones and Responsibility Areas
CAL FIRE designates FHSZs as authorized under California Government Code Sections 51175 et seq. FHSZs may be designated Very High, High, or Moderate. CAL FIRE considers many factors when designating FHSZs, including fire history, existing and potential vegetation fuel, flame length, blowing embers, terrain, and weather patterns for the area. CAL FIRE designates FHSZs in two types of areas depending on which level of government is financially responsible for fire protection. Local Responsibility Area (LRA). Incorporated communities are financially responsible for wildfire protection.
State Responsibility Area (SRA). CAL FIRE and contracted counties are financially responsible for wildfire protection.
CAL FIRE Strategic Plan
CAL FIRE produced the 2018 Strategic Fire Plan for California, which contains goals, objectives, and policies to prepare for and mitigate the effects of fire on California’s natural and built environments. The 2018 Strategic Fire Plan for California focuses on fire prevention and suppression activities to protect lives, property, and ecosystems, in addition to providing natural resource management to maintain state forests as a resilient carbon sink to meet California’s climate change goals. A key component of the 2018 Strategic Fire Plan for California is the collaboration between communities to ensure fire suppression and natural resource management is successful.
2 2021 California’s Wildfire and Forest Resilience Action Plan The Governor’s Forest Management Task Force developed California’s Wildfire and Forest Resilience Action Plan, which is a framework for establishing healthy and resilient forests that can withstand and adapt to wildfire, drought, and climate change. The Wildfire and Forest Resilience Action Plan accelerates efforts to restore the health and resilience of California’s forests, grasslands, and natural places; improves the fire safety of communities; and sustains the economic vitality of rural forested areas. CAL FIRE, in partnership with the US Forest Service, intends to scale up forest thinning and prescribed fire; integrate climate adaptation into the statewide network of regional forest and community fire resilience plans; improve the electricity grid resilience, and promote sustainable land use.
2 California State Board of Forestry and Fire Protection, 2018, 2018 Strategic Fire Plan for California, https://osfm.fire.ca.gov/media/5590/2018-strategic-fire-plan-approved-08_22_18.pdf, accessed November 28, 2022.
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State Responsibility Area and Very High Fire Hazard Severity Zone Fire Safe Regulations California Code of Regulations (CCR) Title 14, Division 1.5, Chapter 7, Subchapter 2, SRA/Very High FHSZ Fire Safe Regulations, establishes minimum wildfire protection standards for construction and development in the SRA and Very High FHSZ and requires CAL FIRE to review development proposals and enact recommendations that serve as conditions of approval in these zones. These standards include basic emergency access and perimeter wildfire protection measures; signing and building numbering; private water supply resources for emergency fire use; and vegetation modification. These regulations apply to all residential, commercial, and industrial buildings in the SRA and Very High FHSZs in the LRA, the siting of new mobile homes, and all tentative and parcel maps. Fire Safe Regulations also include a minimum setback of 30 feet for all buildings from property lines and/or the center of a road. Section 1273.08, Dead-End Roads, of these standards provide regulations for the maximum lengths of single access roadways require the following:
Parcels zoned for less than one acre: 800 feet
Parcels zoned for 1 acre to 4.99 acres: 1,320 feet
Parcels zoned for 5 acres to 19.99 acres: 2,640 feet
Parcels zoned for 20 acres or larger: 5,280 feet
Fire Safe Regulations, Section 1299.03, Fire Hazard Reduction Around Buildings and Structure Requirements, provides defensible space requirements for areas within 30 feet of a structure (Zone 1) and between 30 and 100 feet from a structure (Zone 2). In Zone 1, all dead and dying plants must be removed, as must any flammable vegetation that could catch fire. In Zone 2, horizontal and vertical spacing among shrubs and trees must be created and maintained.
Public Resources Code Section 4291
Public Resources Code (PRC) Section 4291, Mountainous, Forest-, Brush- and Grass-Covered Lands, is intended for any person who owns, lease, controls, operates, or maintains a building or structure in a mountainous area, forest-covered lands, shrub-covered lands, grass-covered lands, or land that is covered with flammable material, regardless of whether the property is in an SRA or Very High FHSZ. This section requires defensible space to be maintained within 100 feet from each side of a structure. An ember- resistant zone is also required within 5 feet of a structure and more intense fuel reduction between 5 and 30 feet of a structure.
California Building Code
Building Design Standards
The California Building Code (CBC), Part 2 of Title 24 of the CCR, identifies building design standards, including those for fire safety. The CBC is updated on a three-year cycle. It is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions under specific amendment rules prescribed by the State Building Standards Commission. Commercial and residential buildings are plan-checked by local City and County building officials for compliance with the CBC and any applicable local amendments. Typical fire safety requirements of the CBC include the installation of sprinklers in buildings and other facilities; the establishment of fire-resistance standards for fire doors, SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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building materials, and particular types of construction in high FHSZs; requirements for smoke-detection systems; exiting requirements; and the clearance of debris. The City of Santa Rosa regularly adopts each new CBC update under the Santa Rosa City Code (SRCC) Chapter 18.44, 2022 California Fire Code.
Materials and Methods for Exterior Wildfire Exposure
Chapter 7A of the CBC, Materials and Methods for Exterior Wildfire Exposure, prescribes building materials and construction methods for new buildings in an FHSZ or Wildland-Urban Interface Fire Area (WUIFA). Chapter 7A contains requirements for roofing; attic ventilation; exterior walls; exterior windows and glazing; exterior doors; decking; protection of underfloor, appendages, and floor projections; and ancillary structures. Other requirements include vegetation management compliance, as prescribed in the CFC Section 4906 and PRC 4291.
California Fire Code
The CFC incorporates, by adoption, the International Fire Code of the International Code Council, with California amendments. This is the official fire code for the State and all political subdivisions. It is found in CCR Title 24, Part 9, and, like the CBC, it is revised and published every three years by the California Building Standards Commission. Also like the CBC, the CFC is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions. The City of Santa Rosa regularly adopts each new CFC update under SRCC Chapter 18-44, 2022 California Fire Code. The CFC is a model code that regulates minimum fire safety regulations for new and existing buildings; facilities; storage; processes, including emergency planning and preparedness; fire service features; fire protection systems; hazardous materials; fire flow requirements; and fire hydrant locations and distribution. Typical fire safety requirements include installation of sprinklers in all buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.
Fire Safety During Construction and Demolition
Chapter 33 of the CFC, Fire Safety During Construction and Demolition, provides requirements for fire safety precautions during construction and demolition of a development project. The purpose of this chapter is to provide reasonable safety to life and property from fire during construction and demolition operations, including those in underground locations. Specific requirements include a prohibition of smoking on-site, except for in approved areas; management of combustible materials and debris; cutting and welding; electrical wiring; and cooking. Additional requirements include the preparation of site safety plans prior to building permit issuance, providing fire watch during nonworking hours, and maintaining water supply for fire protection as soon as combustible materials arrive on a project site.
Wildland-Urban Interface Areas
Chapter 49 of the CFC, Requirements for Wildland Urban Interface Fire Areas, applies to any geographical area identified as an FHSZ by CAL FIRE. It defines FHSZs, connects to the SRA/Very High FHSZ Fire Safe Regulation requirements for defensible space, and parallels requirements for wildfire protection buildings construction and hazardous vegetation fuel management in other sections of the CCR and PRC.
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Chapter 49 of the 2022 CFC includes a definition for the Wildland-Urban Interface (WUI) and provides requirements for fire protection plans, landscape plans, long-term vegetation management, and creation and maintenance of defensible space for all new development within the WUI.
California Public Utilities Commission
In 2007, wildfires in southern California were ignited by overhead utility power lines and aerial communication facilities near power lines. In response, the California Public Utilities Commission (CPUC) began considering and adopting regulations to protect the public from fire hazards due to overhead power lines and nearby aerial communication facilities. The CPUC published a Fire-Threat Map under Rulemaking 15-05-006, following procedures in Decision 17-01-009, revised by Decision 17-06-024, which adopted a work plan for the development of a utility high fire-threat district where enhanced fire safety regulations in Decision 17-12-024 apply.
3 The fire regulations require electric utilities to:4
Prioritize the correction of safety hazards.
Correct nonimmediate fire risks in “Tier 2” (elevated fire threat) areas on the CPUC high fire-threat district within 12 months, and in “Tier 3” (extreme fire threat) areas within 6 months. Maintain increased clearances between vegetation and power lines within the high fire-threat district. Maintain stricter wire-to-wire clearances for new and reconstructed facilities in Tier 3 areas. Conduct annual inspections of overhead distribution facilities in rural areas of Tier 2 and Tier 3 areas. Prepare a fire prevention plan annually if overhead facilities exist in the high fire-threat district.
California Government Code
California Government Code Section 65302(g) and Section 65302.15 require that the mandatory safety element of a general plan be reviewed and revised as needed with the revision of a housing element or local hazard mitigation plan, but no less than every eight years, to ensure the goals, policies, actions, mapping, and background content are consistent with State regulations and reflect the best available information for wildfire risks, climate adaptation and resiliency, and emergency evacuation routes for certain residential areas. Communities with local hazard mitigation plan updates after January 1, 2022, must also ensure their safety elements or local hazard mitigation plans include an assessment of evacuation routes and their capacity, safety, and viability as well as evacuation locations under a range of emergency scenarios.
For wildfire and evacuation purposes, a safety element must:
Identify wildfire hazards with the latest fire severity zone maps from the Board of Forestry and Fire Protection, US Geological Survey, and other sources.
Consider guidance given by the Office of Planning and Research’s Fire Hazard Planning document.
3 California Public Utilities Commission, Fire Map, https://ia.cpuc.ca.gov/firemap/, accessed April 3, 2023. 4 California Public Utilities Commission, CPUC Adopts New Fire-Safety Regulations, press release, , http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M201/K352/201352402.PDF, accessed April 3, 2023.
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Demonstrate that the jurisdiction or contract agency and associated codes satisfactorily address adequate water supply, egress requirements, vegetation management, street signage, land use policies, and other criteria to protect from wildfires. Establish in the safety element (and other elements that must be consistent with it) a set of comprehensive goals, policies, and feasible implementation measures for protection of the community from unreasonable risks of wildfire.
Identify evacuation-constrained residential parcels in hazard-prone areas.
Governor’s Office of Planning and Research Fire Hazard Technical Advisory The Governor’s Office of Planning and Research published the Fire Hazard Technical Advisory in 2015 and revised it in 2022 as a planning guide for addressing fire hazards, reducing risk, and increasing resilience across California’s diverse communities and landscapes. The Fire Hazard Technical Advisory provides a range of goals, policies, and programs for fire hazard prevention and mitigation, disaster preparedness, and emergency response and recovery. The 2022 update includes specific land use strategies to reduce fire risk to buildings, infrastructure, and communities.
California Environmental Quality Act
In November 2022 the California Attorney General issued the Best Practices for Analyzing and Mitigating Wildfire Impacts of Development Projects Under the California Environmental Quality Act. This guidance document was designed to help lead agencies comply with the California Environmental Quality Act (CEQA) when considering whether to approve projects in wildfire-prone areas. These areas are often in the WUI area—i.e., the area where the built environment meets or intermingles with the natural environment. This guidance provides suggestions for how best to comply with CEQA when analyzing and mitigating a proposed project’s impacts on wildfire ignition risk, emergency access, and evacuation. The guidance is aimed at proposed development projects, such as residential, recreational, or commercial developments. The extent to which it applies will vary by project based on project design and location. It does not impose additional requirements on local governments or alter any applicable laws or regulations but is intended to provide guidance on some of the issues, alternatives, and mitigation measures that should be considered during the environmental review process.
Regional Regulations
Sonoma-Lake-Napa Unit Strategic Fire Plan
CAL FIRE developed the Sonoma-Lake-Napa Unit Strategic Fire Plan, adopted in 2022, which protects more than two million acres of the SRA in Sonoma, Napa, Lake, Yolo, Colusa, and Solano Counties.5 The goal of this strategic fire plan is to build resilience and resistance to damaging wildfires while recognizing fire’s beneficial aspects to forestry and environment practices. This is completed through education and
5 California Department of Forestry and Fire Protection, updated May 2022, Sonoma-Lake-Napa Unit 2022 Strategic Fire Plan, https://osfm.fire.ca.gov/media/s1vdava4/2022-sonoma-lake-napa-solano-yolo-colusa-unit-fire-plan.pdf, accessed June 22, 2023.
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participation with communities, collecting data and proper record keeping, monitoring the effectiveness of the Sonoma-Lake-Napa Unit’s programs, and identifying and improving areas of the WUI.
Sonoma County Community Wildfire Protection Plan
The Sonoma County Community Wildfire Protection Plan (CWPP), developed by the Permit Sonoma Fire Prevention Division, Communications Division, and Natural Resources Division, as well as Fire Safe Sonoma and Steering committee members, identifies and prioritizes fuel reduction opportunities throughout the county and addresses structural ignitability and collaboration with stakeholders. The Sonoma County CWPP has been developed upon the priority goals and objectives identified by the Healthy Forest Restoration Act in partnership with local collaborators. The priority actions of the CWPP include structural modifications, defensible space vegetation management, landscape scale fuel break projects, and education and pre-fire planning. The strategies in the Sonoma County CWPP provide significant risk reduction, and the document is updated every five years, with most recent update in 2023.6 The City of Santa Rosa’s CWPP serves as an Annex of the County of Sonoma’s CWPP .
Local Regulations
Santa Rosa City Code
The SRCC includes various directives pertaining to wildfire. The SRCC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to wildfire impacts are in Title 9, Health and Safety; Title 13, Street, Sidewalks and Public Places; Title 17, Environmental Protection; Title 18, Buildings and Construction; and Title 20, Zoning, as follows:
Chapter 9-08, Weeds and Rubbish. Weeds, as defined in this chapter, which: a) bear seeds of a wingy or downy nature that have attained a natural growth in height in excess of four inches, or attain such a large growth as to become a fire menace when dry, or which are otherwise noxious or dangerous, and b) are on undeveloped parcels, on developed parcels over 0.5 acres with more than 0.5 acres of unimproved land, or on parcels located in a WUIFA within city limits, constitute a public nuisance.
Section 9-08.020, Nuisance Determination, requires that all weeds as defined in this chapter, may be declared to be a public nuisance by the City Council and may thereafter be abated as provided by this chapter.
Chapter 9-28, Fuels Mitigation Pile Burning. This chapter includes provisions related to pile burning in the City’s WUIFA to reduce wildfire fuel hazards and accomplish a combination of fire protection and resource management goals. Section 9-28.020, Application, outlines that this application applies to parcels that are over 5 acres in size and in the WUIFA. However, parcels that do not meet these criteria can still perform this application through the approval of the fire chief.
6 Sonoma County, 2023, Sonoma County Community Wildfire Protection Plan, https://permitsonoma.org/sonomacountycwpp, accessed June 22, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-9
Chapter 9-30, Hazardous Vegetation and Fuel Management. The purpose and intent of this chapter is to require compliance with defensible space for all parcels within the WUIFA. It will also require property owners to maintain defensible space throughout the entire WUIFA, remove dead trees, hazardous vegetation and limit certain mulch under specific conditions. Chapter 13-12, Underground Utilities. This chapter regulates and controls the wires, poles, and other wire-carrying structures within certain areas of the city. Section 13-12.30, Poles and wires prohibited aboveground on Montgomery Drive, prohibits aboveground wires, poles, or any other structure designed to carry telephone, telegraph, electric conduit at any place within 100 feet of the centerline of Montgomery Drive. Article II, Procedure for Undergrounding, outlines public hearing procedure, designation of underground utility districts, exceptions, notices, and the responsibilities of utility companies, property owners, and the City. Article III, Electric Underground District, describes the area designated as electric underground district. Article IV, Undergrounding in Other Areas, describes the requirements for undergrounding in other areas of the city that are part of the electric underground district.
Chapter 17-08, Seismic Safety. Section 17-08.020, Earthquake Fault Zones, sets forth the requirements for a State Geologist to delineate active and recently active earthquake fault zones that are a potential hazard. Any projects within the delineated earthquake fault zone require specialized approval authority from the decision-making body. Section 17-08.060, Building Permits for Projects within Earthquake Fault Zones, states that the decision-making body shall evaluate the suitability of a project and can attach conditions to the project if necessary. The decision-making body also can deny permits if it is found that the site is unsuitable for the proposed project. Title 18, Adoption by Reference. This section adopts the CBC in its entirety, subject, however, to the amendments, additions, and deletions set forth in this chapter . The purpose of the CBC is to prescribe regulations governing the erection, construction, enlargement, alteration, repair, moving, removal, demolition, conversion, occupancy, equipment, use, height, area and maintenance of all buildings and structures within the city. The CBC includes the establishment of fire resistance standards for fire doors, building materials, and particular types of construction, and clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas. Chapter 18-16, California Building Code. This chapter describes all the sections of the CBC. This includes a section about living in the FHSZ or any WUIFA. Section 18-16.701A.3, Application, states that buildings located in the FHSZ or any WUIFA that has been constructed, altered, moved, repaired, or maintained after the application date shall comply with the provisions of this chapter around certain building aspects such as additions, maintenance, and vegetation management compliance.
Section 18-22R337.2, Definitions. This section defines a WUIFA as a geographical area identified by the City of Santa Rosa as a FHSZ in accordance with the PRC, as designated on the map titled “Wildland-Urban Interface Fire Area,” dated January 28, 2009. Chapter 18-44, California Fire Code. This chapter adopts regulations governing conditions hazardous to life and property from fire or explosion. This includes the 2022 CFC, which consists of portions of the 2022 International Fire Code as amended by the California Building Standards Commission. This title includes building regulations related to the fire resistance of buildings with amendments to the 2022 CFC, enforcing greater restrictions than those required by the State.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-10 OCTOBER 2024
Chapter 20-32, Hillside Development Standards. This chapter includes the regulations required to preserve the City’s natural waterways and hillsides, amongst other areas, conserves open spaces and natural features, design standards to ensure the hillside development will be sensitive to existing terrain. Section 20-32.050, Site Planning and Development Standards, specifically requires
that development on hillsides be located on the most geologically stable portion of the site. Section 20-32.060, Hillside Development Permit, requires a review process for the City to consider the appropriateness of proposed development on hillside parcels, to ensure that a proposed project minimizes its environmental impact, including the preparation of geotechnical reports that identify and mitigate impacts.
Emergency Operations Plan
The Santa Rosa Emergency Operations Plan (EOP), originally adopted by Council in June 2017 and updated in December 2022, outlines how the City coordinates their response to major emergencies and disasters. 7 The EOP identifies operational strategies and plans for managing complex and potentially catastrophic events. It addresses the four phases of emergency management: preparedness, response, recovery, and mitigation. The EOP is organized into three parts. Part I, Basic Plan, presents the planning assumptions, policies, and concept of operations that guide the responsibilities for emergency preparedness, response, recovery and mitigation for the City. Part II, Hazard Annexes, and Part III, Functional Annexes, provide additional detail and guidance for specific hazards, functions, and operations.
Hazard Mitigation Plan
On December 7, 2021, the Santa Rosa City Council adopted the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) which also provides an update to the City’s Local Hazard Mitigation Plan (LHMP).
8 The MJHMP is comprised of two volumes. Volume 1 includes all federally required elements of a disaster mitigation plan as they apply to the entirety of Sonoma County. Volume 2 is comprised of Annexes (chapters) for each local agency and special district participating in the MJHMP . The City of Santa Rosa Annex, which serves as a five-year update to the LHMP, is found in Volume 2, Chapter 3. The LHMP identifies the natural hazards faced by the city, assesses vulnerabilities to these hazards, and identifies hazard mitigation strategies that can be taken to reduce or alleviate the loss of life, personal injury, and property damage that otherwise might result from each natural hazards. Mitigation actions are suggested and carried out by various City departments. A description of the mitigation actions for wildfires include:
In accordance with the adaptation strategies of the Climate Action Plans, integrate climate change adaptation into future updates of the Zoning Code, Building Code, General Plan, Urban Water Management Plan, and other related documents.
Continue to update the City’s emergency planning documents every five years to ensure consistency with state and federal law, local conditions, and best practices and the most recent science.
7 City of Santa Rosa, June 2017, City of Santa Rosa Emergency Operations Plan, https://www.srcity.org/DocumentCenter/View/16434/Emergency-Operation-Plan, accessed March 22, 2023. 8 City of Santa Rosa, 2021, Local Hazard Mitigation Plan, https://www.srcity.org/540/Local-Hazard-Mitigation-Plan, accessed March 9, 2023.
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PLACEWORKS 4.18-11
Prepare a Zoning Code update to identify vegetation management requirements in the Wildland- Urban Interface zone for existing and new development.
Retrofit, replace, or relocate critical facilities that are shown to be vulnerable to damage in natural disasters prioritizing those structures that have experienced repetitive losses and/or are located in a high or medium ranked hazard.
Work with residents and property owners to develop an incentive program to replace shake roofs in the WUIFA.
Continue to implement improvements to water flow capacity in the WUIFA. Continue to tie public education on defensible space and a comprehensive defensible space ordinance to a field program of enforcement.
Implement actionable Items identified within the City of Santa Rosa Community Wildfire Protection Plan.
Integrate the Hazard Mitigation Plan into other plans, ordinances and programs that dictate land use decisions within the community, including the General Plan, Specific Plans, and the City Code. Develop a plan for expediting the repair and functional restoration of water and wastewater systems through stockpiling of shoring materials, temporary pumps, surface pipelines, portable hydrants, and other supplies, such as those available through the Water/Wastewater Agency Response Network (WARN). Communicate that plan to local governments and critical facility operators. Explore the feasibility of resilience hubs within the City of Santa Rosa.
Community Wildfire Protection Plan
The Santa Rosa CWPP , developed for the Santa Rosa Fire Department (SRFD) through a collaborative process with the SRFD and the Sonoma-Lake-Napa Unit of CAL FIRE, as well as interested parties, key stakeholders, community members, local fire departments, and state and federal agencies managing land in the vicinity of Santa Rosa.9 The Santa Rosa CWPP was built off of the October 2016 City of Santa Rosa Local Hazard Mitigation Plan, which as stated above, was updated in 2021. The Santa Rosa CWPP meets the requirements of both FEMA’s Core Capabilities and the 2003 Healthy Forests Restoration Act and provides the City with tools that can enhance the protection of life safety and improve the resiliency of structures, critical infrastructure, and other assets to wildfire. Like the Sonoma County CWPP , the Santa Rosa CWPP identifies and prioritizes fuel reduction opportunities throughout the city and addresses structural ignitability and collaboration with stakeholders. Section 6 of the Santa Rosa CWPP includes the Action Plan for the City. The Action Plan section of the Santa Rosa CWPP recognizes that preparedness for the inevitable wildfire event includes activities and actionable items such as community education, emergency planning, protection of assets, reducing structure ignitibility, a comprehensive fuels mitigation strategy, and evacuation preparedness, and that a combination of hazardous fuel mitigation, structural
9 City of Santa Rosa Community Wildfire Protection Plan, last modified August 25, 2020, Community Wildfire Protection Plan, https://srcity.org/DocumentCenter/View/30136/City-of-Santa-Rosa-Community-Wildfire-Protection-Plan-CWPP_91820, accessed September 9, 2024.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-12 OCTOBER 2024
hardening, defensible space, and emergency preparedness activities can significantly affect firefighter success in protecting life safety and reducing the threat to the City’s assets.
Santa Rosa Fire Department Strategic Plan
The Santa Rosa Fire Department developed a community-driven Strategic Plan (2024-2029), identifying the following key goals:
Revitalize the fire department’s workforce through innovative recruitment strategies to maximize organizational effectiveness.
Improve physical resources to ensure the highest level of safety and service for our community and personnel.
Enhance the overall technical readiness and communication infrastructure of the fire department to ensure efficient emergency response and personnel safety. Strengthen community engagement, safety, and preparedness through active community collaboration, communication, and outreach to create a more prepared community.
EXISTING CONDITIONS
Wildfire Background
The term “wildfire” refers to fires that usually result from the ignition of dry grass, brush, or timber .
Historically, wildfires commonly occurred in steep or heavily vegetated areas, which makes suppression of the fire difficult. More recently, wildfires have been encroaching into more urban areas, that is, the WUIFA, threatening homes, businesses, and essential infrastructure. Though wildfires play an important role in the ecology of many natural habitats, risks to human safety and property increase as urban development moves into areas susceptible to wildfire hazards.
Types of Wildfires
There are three basic types of wildland fires:
10 Crown fires burn trees to their tops; these are the most intense and dangerous wildland fires. Surface fires burn surface litter and duff. These are the easiest fires to extinguish and cause the least damage to the forest. Brush and small trees enable surface fires to reach treetops and are thus referred to as ladder fuels.
Underground fires occur underground in deep accumulations of dead vegetation. These fires move very slowly and can be difficult to extinguish.
10 Natural Resources Canada, updated April 16, 2021, Fire Behavior, https://www.nrcan.gc.ca/forests/fire-insects- disturbances/fire/13145, accessed April 3, 2023.
4.18.1.2 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-13
Wildfires burn in many types of vegetation—forest, woodland, scrub (including chaparral and sage scrub), and grassland. Many species of native California plants are adapted to fire, and habitats such as woodlands, chaparral, and grasslands can recover from fire. For example, some species of chaparral plants, such as ceanothus, require intense heat for germination and therefore have flammable resins on leaves and roots that can quickly sprouts up in burned areas.11 Between 2010 and 2017, wildfires in California burned about 265,000 acres of forest land, 207,000 acres of scrub vegetation, 99,000 acres of grassland, 18,000 acres of desert vegetation, and 14,000 acres of other vegetation types. 12 Wildfires have
been observed to be more frequent and growing in intensity over the past several years.
Wildfire Causes
Although the term wildfire suggests natural origins, a 2017 study that evaluated 1.5 million wildfires in the United States between 1992 and 2012 found that humans were responsible for igniting 84 percent of wildfires, accounting for 44 percent of acreage burned. 13 The three most common types of human-caused
wildfires are debris burning (logging slash, farm fields, trash, etc.), arson, and equipment use.14 Power lines can also ignite wildfires through downed lines, vegetation contact, conductors that collide, and equipment failures.
15 CAL FIRE determined that between 2017 and 2021, 1,344 fires and 639,437 acres were burned due to electrical power and distribution lines.16 Lightning is the most common natural cause of wildfire in the United States.17 Power lines can ignite wildfires several ways, including:18 Downed lines: downed power lines can produce arcing that can cause the powerlines to spark and ignite vegetation.
Vegetation contact: a branch contacting two conductors for a sufficient duration may ignite the branch; a tree falling on a line can cause a downed line. High winds and severe weather: conductors can slap together during high winds and severe weather, creating arcing of the powerlines and ejecting hot metal particles that can ignite flammable matter on the ground.
11 National Park Service, updated January 8, 2018, Wildland Fire in Chaparral: California and Southwestern United States, accessed April 3, 2023, https://www.nps.gov/articles/wildland-fire-in-chaparral.htm. 12 California State Board of Forestry and Fire Protection, 2019, 2019 Strategic Fire Plan for California, accessed November 28, 2022, https://www.fire.ca.gov/media/5504/strategicplan2019-final.pdf. 13 Jennifer Balch, Bethany Bradley, John Abatzoglou, et al., March 2017, “Human-Started Wildfires Expand the Fire Niche across the United States,” Proceedings of the National Academy of Sciences: Volume 114 No. 11, https://www.pnas.org/content/pnas/114/11/2946.full.pdf. 14 Pacific Biodiversity Institute, May 2007, Roads and Wildfires, accessed April 3, 2023, http://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf. 15 Texas Wildfire Mitigation Project, 2014, How Do Power Lines Cause Wildfires? accessed April 3, 2023, https://wildfiremitigation.tees.tamus.edu/faqs/how-power-lines-cause-wildfires. 16 California State Board of Forestry and Fire Protection, 2023, Statistics: Past Wildfire Activity Statistics (Redbooks), accessed April 3, 2023, https://www.fire.ca.gov/our-impact/statistics. 17 Jennifer Balch, Bethany Bradley, John Abatzoglou, et al., March 2017, “Human-Started Wildfires Expand the Fire Niche across the United States,” Proceedings of the National Academy of Sciences: Volume 114 No. 11, https://www.pnas.org/content/pnas/114/11/2946.full.pdf. 18 Texas Wildfire Mitigation Project, 2014, How Do Power Lines Cause Wildfires? accessed June 23, 2023, https://wildfiremitigation.tees.tamus.edu/faqs/how-power-lines-cause-wildfires.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-14 OCTOBER 2024
Equipment failures: As circuit components deteriorate, they can arc and spark and thus ignite nearby flammable matter.
An analysis of United States Forest Service wildfire data from 1986 to 1996 determined that 95 percent of human-caused wildfires and 90 percent of all wildfires started within a half mile of a road and that about 61 percent of all wildfires and 55 percent of human-caused wildfires started within approximately 650 feet (200 meters) of a road. The study concluded that the increase in human-caused ignition greatly outweighs the benefits of increased access for firefighters. 19 Wildfires ignite structures in three ways: burning embers landing on the structure or flammable material next to the structure, direct flame contact, and radiant heat from fire close to the structure. Embers are the most common cause of home ignition. Embers ignite structures by entering through attic vents, igniting flammable materials around the home (litter in the roof gutter; wood stacks; or wood fencing), or finding their way under roofing materials.
20 CAL FIRE estimated in 2010 that there were about three million housing units in California in FHSZs and potentially at risk from wildland fire—that is, just over 20 percent of the total housing units in the state.21 According to CAL FIRE data, approximately 95 percent of structures seriously damaged in California wildfires from 2013 to 2020 took place in FHSZs in the LRA, SRA, or Federal Responsibility Area. 22 Wildland-Urban Interface Fire Area
A WUIFA in Santa Rosa is any area where structures and other human developments meet or intermingle with wildland vegetative fuels—shrubs, trees, and grasses. Developments in the WUIFA exacerbate fire occurrence and fire spread in several ways:
Increased numbers of people near and in wildland areas, creating more frequent human-caused wildfires.
Wildfires become harder to fight due to simultaneous evacuation and firefighting resources diverted from containing the wildfire to protecting lives and homes. Letting natural fires burn becomes impossible; leading to buildup of fuel in brush and forested areas and overgrowth of grasslands, increasing wildfire hazard further . 23 19 Pacific Biodiversity Institute, May 2007, Roads and Wildfires, accessed April 3, 2023, http://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf. 20 California Chaparral Institute, Protecting Your Home from Fire, accessed June 23, 2023, https://www.californiachaparral.org/fire/protecting-your-home/. 21 State Board of Forestry and Fire Protection and California Department of Forestry and Fire Prevention, August 2018, 2018 Strategic Fire Plan for California, accessed June 23, 2023, https://osfm.fire.ca.gov/media/5590/2018-strategic-fire-plan -approved-08_22_18.pdf.
22 CapRadio, December 2021, After years of delays, CAL FIRE says updated and expanded wildfire hazard maps are on their way, accessed June 23, 2023, https://www.capradio.org/articles/2021/12/20/after-years-of-delays-calfire-says-updated-and -expanded-wildfire-hazard-maps-are-on-their-way/.
23 Volker Radeloff, David Helmers, H. Kramer, et al., February 2018, Rapid Growth of the US Wildland-Urban Interface Raises Wildfire Risk, https://www.pnas.org/content/pnas/115/13/3314.full.pdf, accessed June 23, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-15
Secondary Effects
Secondary effects of wildfire include additional hazards such as poor air quality, landslides, and power outages. After a high intensity wildfire, the burn scar is typically bare of its vegetative cover, which had supported the hillsides and steeper slopes. As a result, heavy rainstorms increase the possibility of severe landslides and debris flows in these areas. The intense heat from the fire can also cause a chemical reaction in the soil that makes it less porous, causing water to run off during precipitation events, leading to flooding downstream. As discussed in Chapter 4.7, Geology and Soils, of this Draft EIR, the EIR Study Area has experienced landslides in the past ranging from small, localized events to events that caused injury and substantial damage. On December 31, 2005, a mudslide on Montgomery Drive collided with houses and automobiles as it extended into the middle of the road. Two houses were damaged and a third was destroyed. In 1997, decreased vegetation from wildfires combined with excessive ground moisture from heavy rains to cause the Hidden Acres landslide in the Bennet Valley area (outside of the Santa Rosa city limits). It was also a major concern following the 2017 wildfires, with preventative actions taken to cover and protect exposed slopes in fire-damaged hillside areas of the city. As shown on Figure
4.7-2, Landslide Map, in Chapter 4.7 of this Draft EIR, the EIR Study Area contains several areas that are prone to landslides and have experienced landslides in the past.
In addition to damaging natural environments, wildfires can injure and kill residents and firefighters as well as damage or destroy structures and personal property. Wildfires also deplete water reserves, down power lines, disrupt communication services, and block evacuation routes, which can isolate communities. Wildfires can also indirectly cause flooding if flood control facilities become inadequate to handle increases in stormwater runoff, sediment, and debris that are generated from burn scars.
Regionally, smoke from wildfires creates poor air quality that can last for days or weeks, depending on the scale of the wildfire and wind patterns. Smoke itself is made up of a complex mixture of gases and fine particles produced when wood and other organic materials burn. Health risks from smoke inhalation are largely from microscopic particles (PM
2.5) that can penetrate the lungs and cause a range of health problems, including chronic heart and lung diseases. Exposure to particulate pollution is even linked to premature death. There are some populations that are more sensitive than others to smoke—for instance, people with heart or lung diseases, seniors, children, people with diabetes, people with compromised immune systems, and pregnant women.24 Through observations of wildfires, experts have determined that wildfires which produce large plumes of smoke can result in that smoke and ash being carried thousands of miles from the burn area of the wildfire. Therefore, air pollution is a major secondary risk from wildfires in the region.
25 24 United States Environmental Protection Agency, updated October 20, 2022, Why Wildfire Smoke is a Health Concern, https://www.epa.gov/wildfire-smoke-course/why-wildfire-smoke-health-concern, accessed April 3, 2023. 25 Nasa Earth Observatory, August 2018, Smoky Skies in North America, https://earthobservatory.nasa.gov/images/92612/smoky-skies-in-north-america, accessed April 3, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-16 OCTOBER 2024
Wildfire in Santa Rosa
As shown on Figure 4.18-1, Fire Hazard Severity Zones, the EIR Study Area is in both the LRA and SRA.
Lands within the city limit are within the LRA, and lands between the city limit and the Planning Area boundary are within the SRA. Figure 4.18-1 shows Very High FHSZs in the LRA are in the Fountaingrove, Skyhawk, and Oakmont neighborhoods of the city. The SRA to the north and south of the city limits contain Moderate and High FHSZs. As shown on Figure 4.18-2, General Plan Land Uses in Wildland Urban Interface Fire Areas, land uses within the WUIFA consist of very low and low density residential, with other land uses consisting of parks and recreation, medium density residential, medium low density residential, public/institutional, and retail and business services.
The wildland-urban interface is the zone of transition between unoccupied land and human development.
It is the line, area, or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels. In the different zones, the intermix zone is land with at least one housing unit per 40 acres and 50 percent or more vegetation cover, and the interface zone is land with at least one housing unit per 40 acres and less than 50 percent vegetation cover . In Santa Rosa, the WUIFA is a geographical area identified by the City as an FHSZ, in accordance with PRC, Sections 4201 through 4204, and Government Code, Sections 51175 through 51189, or other areas designated by the enforcing agency to be at a significant risk from wildfires.
Areas within EIR Study Area and adjacent unincorporated areas of Sonoma County are in the CPUC high fire-threat district, as shown on Figure 4.18-3, CPUC Fire-Threat Map. These areas are mainly to the east and west of the EIR Study Area in the surrounding mountain ranges. Both areas are a Tier 2 and 3 high fire-threat district.
26 Wildfire History
As shown on Figure 4.18-4, Historic Wildfire Perimeters, several wildfires have burned in and near the EIR Study Area. These include the 1870 Great Fire, 1923 Mayacamas Fire, 1939 Airport Fire, 1964 Nuns Canyons Fire, 1964 Hanly Fire, 2003 Lofty Perch Fire, and more recent wildfire described below.
The following image from the Santa Rosa CWPP provides additional details regarding the names and year of occurrences of historic wildfires.
27 26 California Public Utilities Commission, revised August 19, 2021, CPUC Fire-Threat Map, https://files.cpuc.ca.gov/safety/fire-threat_map/2021/CPUC%20Fire%20Threat%20Map_v.3_08.19.2021.Letter%20Size.pdf, accessed April 3, 2023.
27 City of Santa Rosa Community Wildfire Protection Plan, last modified August 25, 2020, Community Wildfire Protection Plan, https://srcity.org/DocumentCenter/View/30136/City-of-Santa-Rosa-Community-Wildfire-Protection-Plan-CWPP_91820, accessed September 9, 2024.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-17
On Friday, October 6, 2017, the National Weather Service issued a Red Flag Warning for Sonoma County from Sunday, October 8, through Tuesday morning, October 10. On the night of Sunday, October 8, 2017, Santa Rosa and surrounding areas were experiencing above-normal wind speeds and reports of fires across the County. SRFD responded to 20 vegetation fires and six structure fires between 6:00 p.m. and midnight. The Tubbs Fire ignited near Highway 128 and Bennett Lane in Calistoga at 9:45 p.m., and the Nuns Fire ignited in the Sonoma County area north of Glen Ellen around the same time as the Fire Department was responding to multiple fires in the city and adjacent areas. Strong winds pushed the Tubbs Fire toward Santa Rosa, spreading at an average speed of approximately 4.5 miles per hour, or 1 mile every 13.3 minutes. By 1:10 a.m., the fire reached the Fountaingrove neighborhood, and by 2:01 a.m. it had jumped US Highway 101, impacting a regional commercial center and surrounding neighborhoods, including Coffey Park. Nine Santa Rosa residents lost their lives, and 100,000 county residents evacuated their homes. Three emergency shelters operated in the City. A Major Disaster Declaration was made on October 10th. The Tubbs and Nuns fires were finally declared contained on October 30 and 31.
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Fire Hazard Severity Zones
Source: City of Santa Rosa, 2020; ESRI, 2022; CAL FIRE 2024; PlaceWorks, 2024. 0 1 20.5
Miles
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Urban Growth Boundary
Sphere of Influence
City Limit
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FHSZ shown are LRA as of 2008 and
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2024. LRA boundaries are
currently under review by CAL FIRE.
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Figure 4.18-2
General Plan Land Use in Wildland Urban Interface Fire Areas Source: City of Santa Rosa, 2020; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
Miles
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CPUC Fire-Threat Map
Source: City of Santa Rosa, 2020; CPUC, 2021; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
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Urban Growth Boundary
Sphere of Influence
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Creeks and Waterways
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WILDFIRE
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-22 OCTOBER 2024
The City spent approximately $9 million in reserves for initial fire response costs, and total suppression costs for the Tubbs Fire are estimated at $100 million. In all, the Tubbs Fire destroyed 3,043 residential units in the city of Santa Rosa--constituting 5 percent of the residential building stock—as well as 36 commercial buildings, including two hotels, a winery, a department store, and restaurants. It affected virtually the same areas of Santa Rosa as the 1964 Hanley Fire, but it also spread west of US Highway 101 and burned 1,432 homes in the Coffey Park neighborhood.
The city was again threatened by wildfire on the evening of October 23, 2019, when the Kincade Fire started near the Geysers Geothermal plant in north Sonoma County. The Kincade Fire burned 77,758 acres and destroyed 374 buildings, prompting the largest evacuation in the history of Sonoma County. The fire burned to the outskirts of Windsor, north of the city, before the southerly progression of the fire was stopped.
In August 2020, Northern California recorded over 12,000 lightning strikes, which sparked over 585 wildfires across the region. This lightning storm ignited the Sonoma Lightning Complex fires, which burned 61,875 acres and the Sonoma-Lake-Napa Unit Lightning Complex and Hennessey fires, which burned over 305,000 acres. In September 2020, the Glass Fire ignited, threatening neighborhoods in eastern Santa Rosa. The Glass Fire prompted evacuations of approximately 70,000 people in Santa Rosa and surrounding region, burning 67,484 acres and destroying 611 structures. Within the Santa Rosa City limits, 34 residential units and five commercial structures were destroyed. By October 22, 2020, Governor Newsom announced that Sonoma County, along with Napa and Shasta Counties, had been added to a Major Disaster Declaration due to the wildfires.
28 Factors Influencing Wildfire
Several factors influence wildfire conditions and facilitate the spread of wildfires, including weather conditions, fuels, topography, and climate change. Human actions are also the leading cause of wildfires in California, increasing the risk of wildfire devastating natural lands and communities.
Weather
The climate in Santa Rosa is generally referred to as “Mediterranean,” with hot, dry summers and cool, wet winters. The weather is generally mild throughout the year . Fog and low overcast often move in from the Pacific Ocean during the mornings and evenings, usually clearing up to warm, sunny weather by late morning or noon.29 Because the summer months are generally hot and dry, the risk of wildfires has historically been greatest in summer and fall. Relative humidity is also an important fire-related weather factor . As humidity levels drop, the dry air causes vegetation moisture levels to decrease, thereby
28 California Office of Emergency Management, October 2020, Three Additional Counties Added to Presidential Major Disaster Declaration to Support State’s Response to Wildfires, http://news.caloes.ca.gov/three-additional-counties-added-to- presidential-major-disaster-declaration-to-support-states-response-to-wildfires/, accessed on November 22, 2022. 29 Tetra Tech, 2021, Sonoma County Multijurisdictional Hazard Mitigation Plan Santa Rosa Annex, https://permitsonoma.org/Microsites/Permit%20Sonoma/Documents/Long%20Range%20Plans/Adopted%20Plans/Hazard%20M itigation%20Plan/Sonoma-County-2021-MJHMP-Volume-2-City-Of-Santa-Rosa-Annex.pdf, accessed June 28, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-23
increasing the likelihood that plant material will readily ignite and burn; the risk of wildfire increases when lightning strikes occur during dry periods.
Wind is a primary weather factor of wildfire behavior. Diablo winds, which are a type of downslope, warm, northerly to northeasterly wind, flow over the mountains east of the EIR Study Area and can have speeds exceeding 50 to 60 miles per hour .
30 As wind speeds increase, the rate of fire spread, intensity, and ember spread potential also increases. Gusty and erratic wind conditions can cause a wildfire to spread irregularly, making it difficult to predict its path and effectively deploy fire suppression forces. Winds from the east in the late summer and fall compound with lower relative humidity, creating “red flag” conditions.
31 High winds and low humidity are especially dangerous because low humidity can dry out trees and other fuel that may also be weakened by the winds. This can increase wildfire conditions in the EIR Study Area. Wind shifts can also occur suddenly due to temperature changes and interactions with steep slopes or hillsides, causing fires to spread unpredictably. Fall has historically been one of the most dangerous times for wildfire risk, as periods of very high temperatures, low humidity, and strong wind increases cause red flag warnings and extreme fire danger .
Fuel
The qualities of vegetation that directly influence fire risk include fuel type and size, loading, arrangement, chemical composition, and dead and live fuel moisture, which contributes to the flammability characteristics of the vegetation. As described in more detail in Chapter 4.4, Biological Resources, of this Draft EIR, vegetation within the EIR Study Area consists of hardwood forest, conifer forest, grassland, nonnative forest, and shrub. Forest vegetation is the dominant vegetation type in the eastern portion of the EIR Study Area, and grassland and agriculture are dominant in the western portion of the EIR Study Area. Grasslands and woodlands are highly flammable, particularly leaf litter that is left to accumulate, ultimately dries, and provides fuel for potential fires. The fire risk in grassland and woodlands vegetation communities can be reduced through several tactics, primarily controlled burns and annual grazing. 32 Topography
Slope is a measure of land steepness, and wildfire intensity and rate of spread increase as slope increases due to the tendency of heat from a fire to rise via convection. For example, as slope increases from 20 to 40 percent, flame heights can double and rates of fire spread can increase fourfold; from 40 to 60 percent, flame heights can become three times higher, and rates of spread can increase eightfold. The arrangement of vegetation throughout a hillside can also contribute to increased fire activity on slopes. As mentioned in Chapter 4.7, Geology and Soils, of this Draft EIR, the topography of the EIR Study Area varies from steep slopes in the hillsides of the eastern and southern portions, to generally flat in the western
30 Tetra Tech, 2021, Sonoma County Multijurisdictional Hazard Mitigation Plan, Volume I, https://permitsonoma.org/Microsites/Permit%20Sonoma/Documents/Planning/Long%20Range%20Plans/Hazard%20Mitigation% 20Plan/Adopted-Sonoma-County-MJHMP-Volume-1-December-2021.pdf, accessed June 28, 2023. 31 The National Weather Service issues “red flag” weather day warnings when certain weather elements such as low relative humidity and strong winds could increase wildfire risk. 32 The Nature Conservancy, updated March 28, 2022, Restoring Fire to Native Grasslands, https://www.nature.org/en- us/about-us/where-we-work/united-states/minnesota/stories-in-minnesota/restoring-fire-to-native-grasslands/, accessed April 3, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
4.18-24 OCTOBER 2024
portion sloping toward the Laguna de Santa Rosa to the west. The steeply sloped area largely coincides with the fire-prone areas in the EIR Study Area.
Human Actions
Most wildfires are ignited by human action, the result of direct acts of arson, carelessness, or accidents.
Many fires originate in populated areas along roads and around homes and are often the result of careless disposal of cigarettes, mowing of dead grass, electrical equipment malfunction, use of equipment, or burning of debris. Recreation areas with increased human activity that are in fire-prone areas also increase the potential for wildfires.
Climate Change
Climate change is likely to increase annual average maximum temperatures in Santa Rosa from a historical
70.8 degrees Fahrenheit (°F) to 75.4 °F by 2050 and 78.6°F by 2100.33 This will likely create warmer temperatures earlier and later in the year. Precipitation levels are projected to increase over the course of the century, changing from a historical annual average of 35.9 inches per year to an annual average of
40.4 inches by 2050 and 44.8 inches by 2100.
34 Variations in precipitation patterns will also lead to an increase in frequency and intensity of heavy precipitation events as well as prolonged periods of drought.
The combination of extreme heat and droughts cause soils and vegetation to dry out, creating more fuel for wildfires. These factors are expected to increase wildfire conditions, creating the risk of more frequent and intense wildfires. Historically, an average of 229 acres burned annually in the city. 35 Wildfires are
projected to increase to an annual average in the city of 257 acres burned annually by 2050 and 267 acres burned annually by 2100.36
Fire Protection Resources
SRFD has primary responsibility for fire protection within city limits. The City is aided by CAL FIRE, the Sonoma County Fire Protection District and Sonoma Valley Fire District. Santa Rosa has a 2006 agreement with CAL FIRE that provides for CAL FIRE response on LRA lands as needed, which allows the City to leverage the state’s considerable firefighting resources, including aircraft. Based on fire danger, various dispatch levels have been established in the agreement that define the number and kind of resources that CAL FIRE will send to a reported wildfire.
SRFD has a Fire Prevention Bureau staffed by a Fire Marshal, three Assistant Fire Marshals, six Fire Inspectors, a Plan Checker, two community outreach specialists and administrative personnel.
Additionally, all ten of the City’s fire stations are involved in a fire inspection program and work closely with Fire Inspectors to reduce community fire risk. Chapter 4.14, Public Services, Park, and Recreation, of this Draft EIR provides additional details about fire protection services in the EIR Study Area.
33 Cal-Adapt, 2023, Annual Averages, https://cal-adapt.org/tools/annual-averages/, accessed April 3, 2023. 34 Cal-Adapt, 2023, Annual Averages, https://cal-adapt.org/tools/annual-averages/, accessed April 3, 2023. 35 Cal-Adapt, 2023, Wildfire, https://cal-adapt.org/tools/wildfire/, accessed April 3, 2023. 36 Cal-Adapt, 2023, Wildfire, https://cal-adapt.org/tools/wildfire/, accessed April 3, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Evacuation and Access
Potential evacuation routes are roadways that allow many people to quickly leave an area due to a potential or imminent disaster . These routes should have sufficient capacity to accommodate the needs of the community, be safely and easily accessible, and allow people to travel far enough away to be safe from emergency conditions. As shown on Figure 4.18-5, Evacuation Routes and Evacuation-Constrained Residential Parcels, primary evacuation routes include US Highway 101 and State Route 12. Figure 4.18-5 also shows dozens of additional evacuation routes throughout the city.
During emergencies, the Santa Rosa Police Department and the Santa Rosa Fire Department coordinate evacuation warnings and orders with the City of Santa Rosa emergency management team. Notifications are coordinated with the County of Sonoma Department of Emergency Management.
Several neighborhoods throughout the city have evacuation constraints, as shown on Figure 4.18-5. An evacuation-constrained residential parcel is defined as the following:
A residential parcel with only one ingress and egress point; and/or A residential parcel that is more than 0.5 miles from the closest designated evacuation route based on the distance along the roadway network.
Evacuation-constrained residential parcels are throughout the EIR Study Area, and many are in or near the WUIFA and wildfire prone areas.
4.18.2 STANDARDS OF SIGNIFICANCE
If located in or near SRAs or lands classified as Very High FHSZs, the proposed project would result in a significant wildfire impact if it would:
1. Substantially impair an adopted emergency response plan or emergency evacuation plan.
2. 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.
3. 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.
4. 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.
5. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to wildfire.
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Evacuation Routes and Evacuation Constrained Residential Parcels Source: CalOES, 2021; ESRI, 2022; PlaceWorks, 2024.
0 1 20.5
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Sphere of Influence
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
WILDFIRE
PLACEWORKS 4.18-27
4.18.3 IMPACT DISCUSSION
As described in Chapter 4.0, Environmental Analysis, of this Draft EIR, some proposed General Plan 2050 policies and actions are required as means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable at the discretion of the decision-maker through permit conditions, agreements, or other legally binding instruments. These mitigating policies and actions use the imperative “shall,” include performance criteria, and are marked with an asterisk (*). Note that all actions are required to be implemented by the City and therefore the imperative “shall,” if not explicitly stated, is implied.
WF-1 Implementation of the proposed project could substantially impair an adopted emergency response plan or emergency evacuation plan.
Adopted emergency response plans and emergency evacuation plans include those discussed under Section 4.18.1.1, Regulatory Framework, such as the Santa Rosa EOP . The proposed project could result in a significant impact if it would substantially impair the implementation of this EOP .
Potential future development in the EIR Study Area would be required to integrate applicable emergency operation and evacuation requirements as necessary to facilitate evacuation for people in wildfire-prone areas. Future development, regardless of whether it includes new development or redevelopment, is required to comply with adopted local, regional, and State plans and regulations addressing emergency access, response, and evacuation. Future development in the WUIFA or Very High FHSZs would be required to comply with the Very High FHSZ Fire Safe Regulations, the CBC, the CFC, and the SRCC, which have requirements for maximum lengths of single-access roads, minimum widths of roadways, and vegetation fuel management around roadways.
A temporary impact to emergency response and evacuation over the buildout horizon of the proposed project could occur from construction of future development projects if they were to result in temporary lane closures that would potentially alter evacuation routes. However, potential future development over the buildout horizon of the proposed project would be required to comply with applicable Very High FHSZ Fire Safe Regulations, the CBC, the CFC, and the SRCC, which would prohibit the obstruction of the circulation network. Additionally, these activities would be limited to the duration of the construction period, and direct impacts of construction would be evaluated during the permit review process by SRFD and/or CAL FIRE. Review and approval of temporary lane closures, if needed, for future development projects in the EIR Study Area would ensure that that no inconsistencies with emergency evacuation plans would occur .
Furthermore, as described in Chapter 3, Project Description, of this Draft EIR, the expansion of the city into surrounding lands is no longer a focus of City planning efforts. The proposed General Plan 2050 identifies 21 Areas of Change where the City will focus on housing, services, connectivity, and/or infrastructure needed to make these complete neighborhoods (see Figure 3-6, Proposed General Plan 2050 Areas of Change, in Chapter 3 of this Draft EIR). Potential future development in the EIR Study Area is projected to occur primarily in the proposed Areas of Change in the form of infill/intensification on sites already developed or underutilized, and/or in close proximity to existing development and infrastructure.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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WILDFIRE
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Out of the 21 Areas of Change, only the Oakmont (#20) location is partially in the WUIFA (the majority of this Area of Change is outside the WUIFA) and none of the Areas of Change are in the Very High FHSZ.
Areas of Change that border WUIFAs include Fountaingrove/Mendocino Interchange (#1), Mendocino Corridor (#8), Flamingo Center (#10), and Howarth Commercial (#14). Therefore, the majority of the projected growth would not be in areas prone to wildfire hazards where evacuation due to fire threat would be greater than non-fire prone areas.
Buildout in the EIR Study Area would result in changes to the circulation patterns or emergency access routes throughout Santa Rosa. As described in Chapter 3, and evaluated in Chapter 4.15, Transportation, of this Draft EIR, the proposed project also includes new and improved circulation infrastructure, of which many of the circulation modifications reflected in the proposed General Plan 2050 are also identified in the recent Moving Forward 2050 Sonoma County Comprehensive Transportation Plan. As shown in Table 3-4, Major Planned Roadway Circulation Improvements, and Table 3-5, Major Planned Multimodal Circulation Improvements in Chapter 3 of this Draft EIR, the proposed changes to the circulation infrastructure include strategic roadway widenings on key arterials and highways, including SR 12, Fulton Road, Stony Point Road, and new or expanded roadways in WUIFA areas of Santa Rosa, to facilitate access of emergency responders. Specifically, improvements include evacuation route upgrades primarily on arterials in the WUIFA, including Fountaingrove Parkway and Montgomery Drive, and on the Farmers Lane Extension from Bennett Valley Road to Petaluma Hill Road, including sidewalks, bike lanes, and transit route. Accordingly, proposed circulation improvements would not substantially impair the implementation of the Santa Rosa EOP.
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider impacts to emergency response and evacuation. The following goal, policies, and actions would serve to minimize potential adverse impacts related to emergency response and evacuation:
Goal 5-5: Ensure that Santa Rosa is prepared for future emergencies. Policy 5-5.1: Encourage City staff and community members to be prepared for and capable of responding to emergency events.
Action 5-5.1: Maintain and periodically update the City’s Emergency Operations Plan. Action 5-5.2: Coordinate with staff of the Sonoma County Operational Area (which consists of the cities, special districts, and unincorporated areas of the county) to update joint emergency response and disaster response plans, as needed. Action 5-5.3: Promote public awareness of the natural hazards and potential effects of disasters in the Planning Area through community and volunteer organizations. Policy 5-5.3: Promote emergency response and preparedness training for City staff, community members, and businesses to increase community resilience. Action 5-5.6: Participate in emergency response exercises in the Operational Area that involve key hazards of concern for the city.
Policy 5-5.4: Prioritize projects and strategies that mitigate hazards and increase community resilience.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Action 5-5.7: Update the Local Hazard Mitigation Plan per State and federal requirements and implement action items as feasible.
Policy 5-5.5: Ensure that coordination between the City and Operational Area continuously improves to meet the changing risks of the community.
Action 5-5.11: Continue to implement mutual aid, automatic aid, and California’s Mutual Master Aid System to provide effective emergency response. Action 5-5.12: Maintain effective mutual-aid agreements with neighboring cities and Sonoma County to support emergency management.
Action 5-5.13: Continue to execute mutual-aid agreements with public and private entities to support community emergency management.
Policy 5-5.6: Prioritize investments that expand and enhance evacuation capacity and capabilities. *Action 5-5.14: Require all new development projects to provide adequate access for fire and emergency response personnel.
*Action 5-5.15: Prohibit the creation of new single ingress/egress roadway conditions in the city.
*Action 5-5.16: Retrofit existing single-access residential neighborhoods to include additional access routes or other provisions to increase evacuation safety. *Action 5-5.17: Analyze the capacity, viability, and safety of evacuation routes for hazard areas in the city (e.g., WUIFA) and incorporate the results into the City’s Emergency Operations Plan.
Without adequate access there is the potential for impacts related to evacuation to be potentially significant.
Impact WF-1: Implementation of the proposed General Plan 2050 could result in inadequate evacuation access the impair the implementation of an emergency evacuation plan.
Significance with Mitigation: Less than significant. Implementation of the proposed General Plan 2050 goals, policies, and actions would increase the effectiveness of emergency operations and evacuation, and therefore would not impair or conflict with applicable plans. Specifically, proposed *Action 5-5.16 would reduce the number of evacuation-constrained residential parcels identified on Figure 4.18-5, Evacuation Routes and Evacuation-Constrained Residential Parcels, by retrofitting existing single- access roads in residential neighborhoods to include additional access routes or other provisions to increase evacuation safety. Proposed *Action 5-5.17 requires the City to conduct an analysis of the evacuation route network to determine the capacity, viability, and safety of evacuation routes, which would be incorporated into the Emergency Operations Plan and would improve evacuation scenarios.
In addition, as described, the proposed changes to the circulation infrastructure include strategic improvements that include evacuation route upgrades primarily on arterials within Wildland-Urban
Interface Fire Areas. Future development, regardless of whether it includes new development or redevelopment, would be required to comply with adopted local, regional, and State plans and regulations addressing emergency response and evacuation, including proposed *Action 5-5.14 and SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
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4.18-30 OCTOBER 2024
*Action 5-5.15, which require the provision of adequate access for fire and emergency response personnel and prohibit the creation of new single access roadways in the city. Therefore, implementation of the proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant.
WF-2 Implementation of the proposed project could, 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.
As discussed in Section 4.18.1.2, Existing Conditions, the topography of the EIR Study Area varies from steeply slopes in the hillsides of the eastern and southern portions, to generally flat in the western portion sloping towards the Laguna de Santa Rosa to the west. The steeply sloped area largely coincides with the fire-prone areas in the EIR Study Area. Construction of potential future development in fire-prone areas of the EIR Study Area would require grading and site preparation; however, these activities would not significantly change the slope. All potential future development in Santa Rosa would be required to comply with the CBC, CFC, and SRCC requirements for grading, which would minimize the ignition and spread of wildfire due to slopes.
As discussed in Section 4.18.1.2, Existing Conditions, Santa Rosa is prone to periods of high winds. These winds can shift suddenly, and they are often accompanied by low humidity. They create dangerous conditions for starting and spreading wildfires during the drier months of the year, and they also spread wildfire smoke hazards, as can prevailing winds. Section 4.18.1.1, Regulatory Framework, describes plans, policies, regulations, and procedures that help to reduce wildfire risks. The 2018 Strategic Fire Plan for California, 2021 California Wildfire and Forest Resilience Action Plan, Sonoma County CWPP , Santa Rosa CWPP , and Sonoma County MJHMP are intended to reduce wildfire hazards and coordinate response to these hazards on a statewide and regional scale. In addition, the Bay Area Air Quality Management District provides air quality alerts, advisories, and an interactive online map to view current air quality conditions in the region. Furthermore, proposed General Plan 2050 Policy 5-6.4 requires the City to continue to implement the City’s existing policy for cooling center activation, weatherize City buildings, and participate in cooling strategies for persons engaged in outdoor work and persons experiencing homelessness, and Action 5-6.10 requires the City to seek funding to upgrade existing warming and cooling centers to have the ability to offer refuge from extreme heat events and poor air quality due to regional wildfire smoke.
Other factors, such as vegetation, have the potential to exacerbate wildfire risks. The forest, grassland, and shrub areas of Santa Rosa are easily ignited, especially during late summer and fall when temperatures and winds are high and relative humidity is low. During these conditions, vegetation can dry out, particularly in areas with unirrigated vegetation, becoming extremely flammable and increasing wildfire risks. As described in Section 4.18.1.1, Regulatory Framework, the Sonoma County MJHMP, Sonoma County CWPP , and the Santa Rosa CWPP contain several vegetation management, defensible space, fuel reduction, and fuel break projects to reduce the uncontrolled spread of wildfire due to vegetation. Additionally, all potential future development in wildfire-prone areas or the WUIFA in Santa Rosa would be required to comply with the Very High FHSZ Fire Safe Regulations, CFC Chapter 49, PRC SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
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Section 4291, and the SRCC. These regulations have specific requirements for new and existing development to create defensible space and extensive fuel reduction within 100 feet of a structure, an ember-resistant zone within 5 feet of a structure, and the overall maintenance of properties to reduce the risk of uncontrolled fires or the spread of fires to other properties.
Furthermore, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider impacts of slope, prevailing winds, and vegetation to wildfire risks. In addition to the proposed goals, policies, and actions identified under impact discussions WF-1, the following goals, policies, and actions would minimize wildfire risks:
Goal 5-1: Minimize community exposure to seismic and geologic hazards. *Policy 5-1.1: New development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards.
*Action 5-1.1: Prior to new development approval, ensure geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable hazard conditions.
*Action 5-1.2: Restrict development in areas where adverse impacts associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer . Action 5-1.3: Avoid or adequately mitigate development of critical facilities—hospitals, fire stations, emergency management headquarters, broadcast services, sewage treatment plants, and places of large congregations—in high-risk geologic hazard zones (e.g., Rodgers Creek Fault zone, liquefiable soils, areas of slope instability. *Policy 5-1.2: Promote erosion-control strategies that reduce hazards to structures, properties, and drainages.
Action 5-1.9: Identify enhanced erosion-control measures for properties that exhibit high erosion potential, are in areas of steep slopes, or have experienced past erosion problems. Action 5-1.10: Ensure each update to the Community Wildfire Protection Plan identifies slope stability and wildfire hazard areas and mitigation strategies to reduce post-wildfire erosion. Goal 5-3: Increase community resilience to future wildfire threats. Policy 5-3.1: Encourage greenbelts as nature-based solutions to enhance climate resilience and reduce hazards in and around Santa Rosa.
Action 5-3.1: Consider ways that new development can incorporate greenbelt zones into the design to reduce wildfire risk and enhance climate resilience. Action 5-3.2: Work with land use applicants to locate development relative to landscape features that can act as buffers from oncoming wildfires (like agricultural lands and maintained parks and greenbelts).
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Action 5-3.3: Seek provision of land management plans or alternative methods to fund vegetation management efforts, support defensible space maintenance on private property, and create fire breaks, greenbelts, and staging areas in strategic locations. Policy 5-3.2: Increase wildfire resiliency using required and voluntary risk reduction regulations and strategies.
Action 5-3.4: Adhere to State and local regulations and recommendations of the Community Wildfire Protection Plan that address wildfire risk and vulnerabilities. Action 5-3.5: Continue to require new development, redevelopment, and remodels to comply with adopted codes and standards and promote implementation of recommendations for fire-safe design in the Community Wildfire Protection Plan. Action 5-3.6: Continue to require conformance with the California Fire Safe Regulations for existing nonconforming properties in the Wildland-Urban Interface Fire Area (includes the Very High Fire Hazard Severity Zone).
Action 5-3.7: Continue improving the City’s previously developed post-wildfire recovery framework to assist with future post-wildfire redevelopment activities. *Action 5-3.8: Require the preparation of fire protection plans for new development and major remodels in the City’s Wildland-Urban Interface Fire Area (WUIFA). Require that fire protection plans be consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for non-conforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans.
Policy 5-3.3: Promote new development in areas of the community that have lower risk of wildfire hazards.
Action 5-3.9: Consider updating the Zoning Code to prohibit land uses in the WUIFA that serve mobility-limited persons, such as assisted care facilities and additional uses recommended by the State.
Action 5-3.10: Explore the development of a pilot program to transfer rights for current or new development from fire hazard areas to less fire-prone areas and consider managed retreat, which could move people and existing structures away from wildfire risk. Action 5-3.11: Explore prohibiting increased land use densities or intensities in the WUIFA and Very High Fire Hazard Severity Zone in accordance with State guidance. Policy 5-3.4: Implement the vegetation management strategies and enhanced roadway standards in fire-prone areas through the City’s Community Wildfire Protection Plan. Action 5-3.12: Require properties in the WUIFA to adhere to the City’s Hazardous Vegetation and Fuel Reduction Ordinance, and all properties in the WUIFA and Very High Fire Hazard Severity Zone to comply with California Fire Safe Regulations (Title 14 of the California Code of Regulations).
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Action 5-3.13: Implement the fire mitigation projects in the Community Wildfire Protection Plan.
Action 5-3.14: Establish a monitoring program to track the effectiveness of Community Wildfire Protection Plan fuel-treatment activities.
Action 5-3.15: Update the Community Wildfire Protection Plan every five years to reflect the needs of the community and the changing risks in the WUIFA. Action 5-3.16: Ensure each update to the Community Wildfire Protection Plan identifies slope stability and wildfire hazard areas and mitigation strategies to reduce post-wildfire erosion. Policy 5-3.5: Ensure all community members and businesses are informed and empowered to address hazard vulnerabilities, considering the specific needs of Equity Priority Populations. Action 5-3.17: Continue to conduct multilingual and culturally appropriate education and outreach campaigns that assist property owners with defensible space, fire-safe landscaping, home hardening, and wildfire preparedness, as identified in the Community Wildfire Protection Plan.
Action 5-3.18: Prioritize wildfire mitigation, education, and outreach efforts to vulnerable populations who may not receive typical outreach.
Action 5-3.19: Work with local and regional partners to assist low-income households with maintaining defensible space around their homes and properties. Action 5-3.20: Identify at-risk populations and developments in the WUIFA and ensure that emergency management planning and training include efforts to increase resilience in these areas.
These proposed General Plan 2050 goals, policies, and actions would ensure that fire hazard reduction measures occur and are maintained, and that existing and new development in woodland, grassland, and shrub areas would incorporate vegetation management measures. However, wildfire smoke could potentially travel into other areas of the EIR Study Area due to slope and prevailing winds during a wildfire. Therefore, even with existing regulatory requirements and proposed General Plan 2050 goals, policies, and actions, potential future development over the buildout horizon of the proposed project could expose people to the uncontrolled spread of wildfire or pollutant concentrations due to slope conditions and prevailing winds within the EIR Study Area.
Implementation of the proposed project could increase population, buildings, and infrastructure in wildfire prone areas. The introduction of additional humans (through new development and redevelopment) and human activities (including the use of construction equipment) to fire-prone areas inherently exacerbates existing fire hazards. Though the proposed General Plan 2050 goals, policies, and actions and mandatory State wildfire hazard reduction measures reduce risks in wildfire-prone areas, impacts related to exacerbating the risk of pollutant concentrations from wildfire and the uncontrolled spread of wildfire would be reduced, but not to a less-than-significant level. The proposed General Plan 2050 contains goals, policies, and actions that require existing development, new, and redevelopment projects to create and maintain fire safe vegetation around structures and roadways and enforcement of Very High FHSZ Fire Safe Regulations. New development would also be required to prepare Fire Protection SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Plans. These policies provide the best wildfire hazard reduction measures available. Adherence to the above building practices, fire safety regulations, and vegetation fuel management requirements would reduce the potential for exacerbating wildfire risks. However, due to the programmatic nature of this analysis, the unknown details and potential impacts of specific future potential development projects over the buildout horizon of the proposed project, and the potential for future development to be in wildfire- prone areas, impacts are considered significant.
Impact WF-2: Potential future development over the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.
Significance with Mitigation: Significant and unavoidable. Goals, policies, and actions identified in the proposed General Plan 2050 provide the best wildfire hazard reduction measures available.
Specifically, proposed *Action 5-3.8 requires the preparation of fire protection plans for new development and major remodels in the City’s Wildland-Urban Interface Fire Area (WUIFA), which are highly vulnerable areas; that are consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for nonconforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans. However, the only way to fully avoid the wildfire impact from implementation is to prohibit development in Very High Fire Hazard Severity Zones (FHSZ) and the WUIFA. The majority of northern and eastern Santa Rosa is in a Very High FHSZ and/or the WUIFA. Prohibiting new development in this portion of Santa Rosa is not feasible or practical because the City has a responsibility to meet other, conflicting obligations, including increasing the number and type of housing available and allowing reconstruction of homes burned by wildfires. Therefore, this measure is considered and rejected, and there are no feasible mitigation measures beyond the policies and plans described above. Due to potential unknown impacts from future development over the buildout horizon of the proposed project, impacts at the programmatic level would remain significant and unavoidable. This conclusion does not preclude a finding of less-than-significant impacts at the project level.
WF-3 Implementation of the proposed project would require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) but doing so would not exacerbate fire risk or result in temporary or ongoing impacts to the environment.
Potential buildout over the buildout horizon of the proposed project could require the installation of new roadways, fuel breaks, emergency water sources, transmission lines, and other utilities to serve future potential development in Santa Rosa. Furthermore, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider impacts of wildfire management infrastructure to reduce wildfire risks. In addition to the proposed goals, policies, and actions identified under impact discussions WF-1 and WF-2, the following goals, policies, and actions would minimize wildfire risks from infrastructure and maintenance:
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Goal 5-6: Ensure Santa Rosa is a resilient city able to adapt to, recover from, and thrive under changing climate conditions.
Policy 5-6-7: Strengthen the community’s ability to respond to the risks and negative effects of power outages, including public safety power shutoffs (PSPS) and other climate-related threats. Action 5-6.26: Support efforts to underground electrical transmission infrastructure throughout the city, including substations, prioritizing high-voltage transmission lines and areas in the WUIFA.
Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.1: Ensure water quality, water service delivery, and wastewater treatment are sufficient to meet the needs of current and future residents.
Action 5-9.2: Continue to require that water supply capacity and infrastructure are in place prior to occupancy of new development.
Action 5-9.8: Evaluate the City’s long-term water supply strategies, including development of new sources of water supply, enhanced water-efficiency programs, and implementation of appropriate growth-control measures, if deemed necessary by the City. Action 5-9.10: Implement the Water Supply Alternatives Plan to mitigate potential impacts of climate change, drought, and natural or human-caused catastrophic events by enhancing water supply resiliency and reliability.
The following addresses the types of wildfire risk management infrastructure that could be required in the EIR Study Area over the 2050 buildout horizon.
Roadways. Buildout of the proposed project would include new roadways in the western and southern portions of the EIR Study Area. Potential future development over the buildout horizon of the proposed project could also create new or expanded roadways in WUIFA areas of Santa Rosa, including developing roadways to new development and expanding existing roads to accommodate new development and multimodal forms of transportation. All new roadways would be built to code to accommodate emergency vehicles and routinely maintained pursuant to vegetation management regulations.
Fuel Breaks. Proposed General Plan 2050 *Action 5-3.8 and Action 5-3.12 require the preparation of fire protection plans for new development that addresses defensible space and fuel modifications around buildings and structures for properties or development within the Very High FHSZ and WUIFA. Emergency Water Sources. Proposed General Plan 2050 Action 5-9.2, Action 5-9.8, and Action 5-9.10 continue to require water supply capacity and infrastructure are in place prior to occupancy of new development, require the evaluation of the City’s long-term water supply, and implement the Water Supply Alternatives Plan for reducing impacts from natural or human-caused catastrophic events, such as a wildfire.
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Power Lines. Potential future development over the buildout horizon of the proposed project would require electrical line installations and connections to provide power to buildings and infrastructure.
Proposed General Plan 2050 Action 5-6.26 supports efforts to underground electrical transmission infrastructure throughout the city, including substations, prioritizing high-voltage transmission lines and areas in the WUIFA, which is consistent with SRCC Chapter 13-12. Additionally, the CPUC requires maintenance of vegetation around power lines, strict wire-to-wire clearances, annual inspections of aboveground power lines, and the preparation of fire prevention plans for aboveground power lines in high fire-threat districts. These measures would reduce the wildfire risks associated with the installation and maintenance of power lines.
Other Utilities. Potential future development over the buildout horizon of the proposed project would require the installation and maintenance of water systems, septic or sewer systems, internet infrastructure, and stormwater systems in wildfire-prone areas.
These types of improvements would involve temporary construction and result in changes to the existing built environment. Development in the WUIFA and Very High FHSZ areas in the EIR Study Area would also be required to comply with building and design standards in the CBC, CFC, and Very High FHSZ Fire Safe Regulations, which include provisions for fire-resistant building materials, the clearance of debris, and fire safety requirements during demolition and construction activities. Additionally, PRC Section 4291 requires a defensible space within 100 feet of a structure and an ember-resistant zone within 5 feet of a structure.
These measures, along with the other applicable State regulations and the proposed General Plan 2050 goals, policies, and actions discussed above, would minimize wildfire risks associated with the installation and maintenance of infrastructure. Therefore, impacts would be less than significant.
Significance with Mitigation: Less than significant.
WF-4 Implementation of the proposed project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, postfire slope instability, or drainage changes.
Wildfires, such as the 2017 Tubbs Fire and the 2019 Kincade Fire, can create favorable conditions for other hazards, such as flooding and landslides during the rainy season. Wildfires on hillsides can burn the vegetation that stabilizes the slope and create hydrophobic conditions that prevent the ground from absorbing water, causing water to run off and affect downslope or downstream areas. A project would result in a significant impact if—due to slopes, drainage patterns, or postfire slope instability—it would expose people or structures to significant risks from landsides, debris flows, or flooding.
As discussed in Chapter 4.10, Hydrology and Water Quality, of this Draft EIR, approximately 168 acres in the EIR Study Area are within the 100-year floodplain and about 284 acres are in the 500-year floodplain.
As shown on Figure 4.10-3, Potential Flood Hazards, in Chapter 4.10 of this Draft EIR, these areas are primarily located along the creeks that run through the city, including Spring Creek, Matanzas Creek, Colgan Creek, Naval Creek, Roseland Creek, and Kawana Springs Creek. These areas are generally outside of the fire-prone areas of the Very High FHSZ and the WUIFA.
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As discussed in Chapter 4.7, Geology and Soils, of this Draft EIR, the topography of the EIR Study Area varies from steep slopes in the hillsides of the eastern and southern portions to generally flat in the western portion, sloping towards the Laguna de Santa Rosa to the west. The steeply sloped area largely coincides with the fire-prone areas in the EIR Study Area. These areas are considered susceptible to landslides from precipitation and other causes. This overlap could cause areas outside of a flood hazard or landslide-susceptible zone to be affected by runoff, post-fire slope instability, or drainages changes following a wildfire.
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of proposed General Plan 2050 provides guidance to help protect the community and mitigate potential impacts from natural and human-caused hazards. In addition to the proposed goals, policies, and actions identified under impact discussions WF-1 and WF-2, the following goals, policies, and actions would serve to minimize potential adverse impacts related to postfire slope instability or drainage changes upstream:
Goal 5-2: Effectively manage the potential effects of flooding and dam failure. Policy 5-2.1: Ensure land use strategies consider flood impacts and stormwater management tactics to reduce the effects of future inundation.
Action 5-2.1: Ensure land use strategies consider flood impacts and stormwater management tactics to reduce the effects of future inundation.
Action 5-2.2: Complete and implement the Storm Drain Master Plan. Action 5-2.3: Coordinate with Sonoma Water regarding flood zones, land use, and flood mitigation strategies.
Action 5-2.4: Employ flood mitigation strategies in the development of plans and projects along creeks and waterways.
Policy 5-2.2: Promote the enhancement and expansion of open space for flood management and passive recreation where appropriate and safe.
Action 5-2.5: Protect floodplains by retaining and expanding, as feasible, open space areas that can retain stormwater, recharge groundwater/aquifers, and prevent/reduce flooding. Action 5-2.6: Limit the use of areas designated for flood control to passive recreation activities (e.g., hiking, fishing, bike riding), consistent with requirements to maintain the integrity of these areas to protect public safety.
Policy 5-2.3: Comply with all applicable FEMA flood-management regulations and requirements. Action 5-2.7: Continue to maintain and periodically update flood hazard data, and coordinate with federal, State, and local agencies responsible for flood hazard analysis and management activities.
Action 5-2.8: Continue to incorporate into public works projects features and appropriate standards that reduce flooding hazards, including daylighting culverts in urban areas such as downtown.
Policy 5-2.4: Ensure that the design of new development in a flood zone provides adequate flood protection without negatively impacting adjacent or downstream properties.
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Action 5-2.9: Require an evaluation of flood hazards and appropriate on-site mitigation options by a qualified professional for any project in a FEMA- and Department of Water Resources (DWR)– designated flood zone during the development review process. Policy 5-2.6: Manage, maintain, and improve stormwater drainage and capacity. Action 5-2.12: Require dedication, improvement, and ongoing maintenance of stormwater management and retention areas as a condition of development approval. Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for new development.
Action 5-2.14: Require improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks.
Action 5-2.15: Ensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Active Transportation Plan and are incorporated into stormwater improvement projects along creek corridors.
Policy 5-2.7: Provide storm drainage facilities that accommodate increased development and enhanced water quality.
Action 5-2.16: Cooperate with Sonoma Water and the Northern California Regional Water Quality Control Board on assessments of stormwater drainage facilities to ensure adequate capacity to accommodate increases in residential and commercial development.
Action 5-2.17: Require implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system. Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.1: Ensure water quality, water service delivery, and wastewater treatment are sufficient to meet the needs of current and future residents.
Action 5-9.3: Maintain water, wastewater, and recycled water system integrity and capacity by continuing to prioritize maintenance and preserve funding for maintenance, rehabilitation, and replacement of existing infrastructure.
Policy 5-9.2: Maintain water quality and encourage Santa Rosa Water customers to save water. Action 5-9.13: Require new development projects to provide water-efficient landscaping in accordance with the City’s Water Efficient Landscape Ordinance. Action 5-9.15: Promote water efficiency through public education, incentives, rebates, technical assistance, customer programs, and information about indoor and outdoor water use efficiency measures.
Policy 5-9.4: Ensure that adequate wastewater capacity is available to serve existing and future needs of the city.
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Action 5-9.28: Improve stormwater management to increase infiltration, provide treatment, promote groundwater recharge, reduce flood risk, capture trash, and enhance the environment.
Action 5-9.30: Evaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks.
Action 5-9.32: Employ a multibenefit “one-water” approach for new capital projects to include stormwater quality (low-impact development features) on a large scale, flood mitigation, creek restoration, and increased groundwater recharge.
Furthermore, all new development in the EIR Study Area would be required to comply with State and local regulations, such as the CBC and SRCC, both of which have provisions to reduce flooding and landslides in existing and new development. For example, CBC Section 1803 (SRCC Chapter 18-16) requires a geotechnical investigation that must assess existing landslide susceptibility on a project site. In addition, SRCC Chapter 20-32 and proposed General Plan 2050 *Policy 5-1.1, *Action 5-1.1, and *Action 5-1.2 include requirements for hillside development and the preparation of geotechnical reports that identify and mitigate impacts from the potential from landslides such that there would not be a significant impact.
New development complying with state and local regulations, as well as the proposed General Plan 2050 goals, policies, and actions identified above would not expose people or structures to downslope landslides or downstream flooding due to postfire hazards. Furthermore, as identified under impact discussions WF-1 and WF-2, potential future development over the buildout horizon of the proposed project must also comply with best management practices regarding wildfire prevention, action, and recovery as outlined in the Santa Rosa EOP , Sonoma County MJHMP , and the Sonoma County CWPP. All future development, regardless of the location, is required to comply with adopted local, regional, and State plans and regulations addressing wildfire prevention, which would minimize risks of postfire hazards.
Compliance with these policies, actions, and regulatory requirements would ensure that impacts from postfire instability would be less than significant.
Significance with Mitigation: Less than significant.
WF-5 In combination with past, present, and reasonably foreseeable projects, implementation of the proposed project could result in a cumulatively considerable impact to wildfire impacts.
The cumulative setting includes potential future development in the EIR Study Area and the surrounding region. Future development over the buildout horizon of the proposed project would not impair an adopted emergency response plan or emergency evacuation plan; would not exacerbate wildfire risks due to the installation or maintenance of infrastructure; and would not cause downslope or downstream post- fire flooding or landslide hazards. Cumulative development in the surrounding unincorporated county, local jurisdictions, and State lands would be subject to the same State regulations applicable to future SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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projects over the buildout horizon of the proposed project. Although federal lands would not be subject to State regulations, they would still be subject to the National Cohesive Wildfire Management Strategy and the NFPA Standards.
However, the proposed project would result in significant and unavoidable impacts where it would potentially expose project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors, as described under impact discussion WF-2. The addition of other proposed development projects in adjacent jurisdictions in similar environments that are sloped and contain high fuel loads would have the potential to contribute to cumulative wildfire risks.
These projects would have the potential to result in significant environmental impacts and they could also potentially expose project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors. These would potentially result in cumulatively considerable impacts when taken into consideration with the proposed project. Future potential development in the EIR Study Area and the surrounding region would be required to comply with the same State regulations, such as SRA and Very High FHSZ Fire Safe Regulations, PRC Section 4291, CBC, and CFC. Lands throughout Sonoma County would also implement wildfire reduction strategies through implementation of the Sonoma County CWPP and the Sonoma County MJHMP . However, the increase of potential development projects within the SRA in the Sphere of Influence and Urban Growth Boundary and unincorporated County lands outside of the EIR Study Area, along with the VHFHSZ or WUIFA, would result in a cumulatively significant impact due to the inherent risk of any increased human activity in these areas. Therefore, cumulative wildfire impacts would be considered significant.
Impact WF-5: Potential development over the buildout horizon of the proposed project could, in combination with other surrounding and future projects in the State Responsibility Areas (SRA), Very High Fire Hazard Severity Zones (FHSZ), or Wildland-Urban Interface Fire Areas (WUIFA), result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
Significance with Mitigation: Significant and unavoidable. Same as Impact WF-2, even with implementation of the proposed General Plan 2050 goals, policies, and actions, including proposed *Action 5-3.8, the only way to fully avoid the cumulative wildfire impact is to prohibit development in the SRA, Very High FHSZs, and WUIFA throughout the region. As a full prohibition of development in these areas is not feasible in the region, this impact is significant and unavoidable.
PLACEWORKS 5-1
Alternatives to the Proposed Project
The following discussion is intended to inform the public and decision makers of feasible alternatives to the proposed project that would avoid or substantially lessen any of the significant effects of the proposed project. The California Environmental Quality Act (CEQA) Guidelines set forth the intent and extent of alternatives analysis to be provided in an environmental impact report (EIR). Section 15126.6(a) of the CEQA Guidelines states that:
An EIR shall describe a range of reasonable alternatives to the project, or 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.
5.1 PURPOSE
The alternatives evaluated in this Draft EIR were developed consistent with Section 15126.6(b) of the CEQA Guidelines, which states that:
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.
5.2 SELECTION OF A REASONABLE RANGE OF ALTERNATIVES
Section 15126.6(c) of the CEQA Guidelines states:
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
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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.
5.2.1 PROJECT OBJECTIVES
Pursuant to CEQA Guidelines Section 15126.6(c), the range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the proposed project. As listed in Chapter 3, Project Description, of this Draft EIR, the City has identified objectives, which build on the framework of the Santa Rosa Vision and reflect the community’s desires for the future of Santa Rosa to serve as the project objectives for the EIR. As described in Chapter 3 of the Draft EIR, the primary purpose of the proposed project is to plan for the growth and conservation of Santa Rosa over an approximately 25-year time horizon while achieving the vision. The project objectives to realize the Santa Rosa Vision are related specifically to growth in the 21 Areas of Change, the majority of which capitalize on infill opportunities in and around Priority Development Areas (PDAs) and Transit Priority Areas (TPAs).
Development of infill sites near transit makes the most of existing infrastructure and allows for the streamlining of future development in a manner that is consistent with the proposed General Plan 2050.
Meeting the vision also includes making major improvements to the transportation network, which focus on bridging east and west and enhancing multimodal connectivity and safety citywide. Achieving the vision also entails creating complete streets and complete neighborhoods to activate the Areas of Change.
Further, it includes creating a cross-sector approach to integrating greenhouse gas reduction into all parts of the general plan; creating new opportunities for a vital thriving downtown and entertainment district; preserving community character and environmental, historic and cultural resources as the city develops and becomes denser; and creatively blending old and new development to create a cohesive urban fabric and public realm. A complete list of project objectives is provided in Section 3.6, Project Objectives, of Chapter 3 of this Draft EIR. Achieving these objectives requires extending the buildout horizon to year 2050 and updating goals, policies, and actions so that they meet current State requirements and community priorities, as articulated during an extensive public engagement process conducted for the project (https://www.santarosaforward.com/engagement).
5.2.2 SIGNIFICANT AND UNAVOIDABLE IMPACTS
All the potential environmental impacts associated with adoption and implementation of the proposed project were found to be either less than significant without mitigation or less than significant with mitigating General Plan 2050 policies and actions, except for impacts to agricultural resources (AG), air quality (AIR), noise (NOI), transportation (TRAN), and wildfire (WF), which were found to be significant and unavoidable at the program level. As described in the impact discussions of these chapters, although the proposed project results in significant and unavoidable impacts, the identification of these program-level impacts does not preclude the finding of less-than-significant impacts for subsequent development proposals analyzed at the project level that do not exceed the applicable project-level thresholds. The program-level significant and unavoidable impacts include the following:
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Agricultural Resources
Impact AG-1: Implementation of the proposed project could result in the conversion of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland land (together referred to as “CEQA Important Farmland”) to non-agricultural land uses. Impact AG-2: Implementation of the proposed project could result in the loss of agricultural land under the Williamson Act.
Impact AG-4: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in a significant cumulative impact with respect to the conversion of CEQA Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) and Williamson Act properties to non-agricultural uses. Air Quality
Impact AIR-2b: Buildout of the proposed project could generate operational emissions that could exceed the Bay Area Air Quality Management District’s (BAAQMD) regional significance thresholds for reactive organic compounds (ROG), nitrogen oxides (NOX) and particulate matter (PM2.5 and PM10).
Impact AIR-3b: Large industrial or warehouse development projects under the proposed project could expose air quality-sensitive receptors to substantial toxic air contaminants (TAC) and particulate matter (PM2.5) concentrations and exceed the Bay Area Air Quality Management District’s (BAAQMD) project-level and cumulative significance thresholds. Impact AIR-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in cumulative air quality impacts with respect to generation of criteria pollutant and exposure of substantial pollutant concentrations to sensitive receptors. Noise
Impact NOI-1a: Construction activities associated with potential future development could expose sensitive receptors to excessive noise from construction equipment. Impact NOI-1b: Operational vehicle traffic noise increases could exceed the City’s significance thresholds with implementation of the proposed project. Impact NOI-4: Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, could result in cumulative noise impacts, with respect to generation of construction-and transportation related noise. Transportation
Impact TRAN-2a: Implementation of the proposed project could result in a significant vehicle miles traveled (VMT) impact for residential VMT per capita. Impact TRAN-2b: Implementation of the proposed project could result in a significant roadway network vehicle miles traveled (VMT) impact associated with increasing the capacity of the arterial street network.
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Impact TRAN-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in significant cumulative impact with respect to vehicle miles traveled (VMT).
Wildfire
Impact WF-2: Potential future development over the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.
Impact WF-5: Potential development over the buildout horizon of the proposed project could, in combination with other surrounding and future projects in the State Responsibility Areas (SRA), Very High Fire Hazard Severity Zones (FHSZ), or Wildland-Urban Interface Fire Areas (WUIFA), result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
5.2.3 ALTERNATIVES CONSIDERED AND REJECTED AS BEING
INFEASIBLE
Pursuant to CEQA Guidelines Section 15126.6(c) of the State CEQA Guidelines, EIRs should 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. Section 15126.6(c) provides that among the factors that may be used to eliminate alternatives from detailed consideration in the EIR are (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. The following is a discussion of alternatives considered and rejected, along with the reasons they were not included in the analysis.
REDUCED HOUSING ALTERNATIVE
The City considered alternatives that would reduce the construction-related impacts of the proposed project by reducing the proposed buildout potential, including the amount of potential housing development. The City rejected any alternative that would reduce the amount of housing due to the ongoing housing crisis.
The State of California has enacted several laws intended to address California’s housing needs. The California Housing Accountability Act was initially passed in 1982 and has been revised in recent years.
Under the Housing Accountability Act, so long as a project complies with applicable objective General Plan and zoning standards, a local agency may not deny a project or approve it at a lower density unless the agency finds that the project would have specific, adverse, unavoidable impacts on public health or safety.
Pursuant to Government Code Section 65589.5(j), a local agency may only require a reduction in housing density as a condition of approval if the proposed project has a specific adverse effect on public health and safety that can only be mitigated by lowering the residential density. Accordingly, for many housing projects with no specific, adverse, unavoidable impacts on public health or safety, local agencies find reduced housing alternatives to be infeasible.
5.2.3.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-5
The City finds that with implementation of proposed General Plan 2050 goals, policies, and actions that require the evaluation and mitigation of impacts on public health and safety from potential future development, including the construction and operation of the potential future housing, a reduction in housing is not necessary to avoid a public health and safety impact. Therefore, due to the well- documented housing crisis and the lack of housing in Santa Rosa and the requirements to evaluate and mitigate impacts to public health and safety as a result of any future housing, a reduced housing alternative should be considered infeasible. Furthermore, while the reduced housing alternative would reduce impacts from construction and operation when compared to the proposed project, it would not entirely avoid significant mitigable environmental impacts.
Lastly, a reduced housing alternative would not fully achieve the project objectives that seek to provide and ensure that a
diverse mix of high-quality, safe, thoughtfully designed, efficiently planned, and well- served housing at all affordability levels is available throughout the community to accommodate everyone, including formerly homeless, immigrants, local workers, multigenerational households, seniors, students, and formerly incarcerated people, within neighborhoods that are increasingly walkable/bikeable.
INCREASED PLANNING AREA ALTERNATIVE
During the scoping process, the expansion of the Urban Growth Boundary (UGB) and/or Sphere of Influence (SOI) was considered. The City rejected any alternative that would expand the UGB or SOI because, as described in Chapter 3, Project Description of this Draft EIR, the expansion of the city into surrounding lands is no longer a focus of City planning efforts. Growth and change in the city will be tailored to support maintenance and development of complete neighborhoods, particularly in Areas of Change. These are places where the City will focus efforts to address housing, services, connectivity, and/or infrastructure needs and help provide complete neighborhoods with goods and services that are easily available. The proposed General Plan 2050 identifies 21 Areas of Change, as shown on Figure 3-6, Proposed General Plan 2050 Areas of Change, in Chapter 3 of this Draft EIR.
The City finds that with implementation of the proposed General Plan 2050 land use map and the goals, policies, and actions that require the evaluation and mitigation of impacts from potential future development, the expansion of the UBG and/or SOI is not required to accommodate the proposed potential buildout or to reduce any potentially significant impacts. Rather, the City finds that the potential expansion of the UGB or SOI to accommodate growth in areas would potentially increase impacts caused by developing on undisturbed lands and on lands further away from core services areas such that VMT could be increased when compared to the proposed project.
Lastly, an expanded UGB and/or SOI alternative would not fully achieve the project objectives that seek to provide and ensure the primary purpose of the proposed project, which is to plan for the growth and conservation of Santa Rosa over an approximately 25-year time horizon while achieving the Santa Rosa Vision. Expansion of the planning area would not support the vision to ensure that natural resources are restored, protected, and expanded to provide accessible green space for everyone in all neighborhoods, mitigate drought, and minimize GHG.
5.2.3.2 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-6 OCTOBER 2024
An expansion of the City would not support an increasingly dense urban core or streamline future development by focusing on infill sites near transit to make the most of existing infrastructure; nor would it ensure strong connections between land use, transportation, utilities, and other infrastructure.
Additionally, this alternative would not focus development in the 21 Areas of Change, the majority of which capitalize on infill opportunities in and around PDAs and TPAs, so that implementing the plan supports the City in reaching its climate mandates and supports regional strategies to reduce greenhouse gas (GHG) emissions and improve air quality.
Finally, the Increased Planning Area alternative would not support the activation of the Areas of Change by developing complete neighborhoods that are walkable/bikeable and increasingly protected from environmental hazards nor support the cross-sector approach to integrating GHG reduction into all parts of the general plan.
SELECTED ALTERNATIVES
Two project alternatives and the comparative merits of the alternatives are discussed in this section in accordance with the CEQA Guidelines. The alternatives to be analyzed in comparison to the proposed project include:
Alternative A: No Project Alternative (Current General Plan 2035) Alternative B: Increased Density Alternative
The first alternative is the CEQA-required “No Project” Alternative, which assumes the current General Plan 2035 and the City’s 2012 Community-wide Climate Action Plan (CCAP) remain in effect and are not replaced by the proposed project. The second alternative is the Increased Density Alternative. This alternative assumes the same amount of households, residential units, population, and jobs would occur as under the proposed project, but would allow for more opportunity for dense housing connected to transit facilities through the redesignation of certain medium low density residential parcels as medium high density residential.
5.2.4 ASSUMPTIONS AND METHODOLOGY
The alternatives analysis is presented as a comparative analysis to the proposed project. The development intensity for the alternatives varies from the proposed project. The estimated growth under each alternative, as well as the proposed project, is provided in Table 5-1, Forecast Additional Growth for the Proposed Project and the Alternatives to the Proposed Project.
5.2.3.3 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-7
TABLE 5-1 FORECAST ADDITIONAL GROWTH FOR THE PROPOSED PROJECT AND THE ALTERNATIVES TO THE
PROPOSED PROJECT
Category Proposed Project Alternative A: No Project a Alternative B: Increased Density Residential Units 24,090 3,996 b 24,090
Population 65,760 17,270 b 65,760
Jobs 14,090 -30,000 b 14,090
Notes:
a. Based on a review of existing conditions and projected trends, the City is not on track to meet the 2035 buildout estimates of the current General Plan 2035 and is accordingly revising local growth projections to be more in line with regional growth. b. City of Santa Rosa, March 2009, General Plan 2035 Environmental Impact Report, Table 3-1, Buildout Changes Between the 2020 to 2035 General Plans, https://www.srcity.org/DocumentCenter/View/3096/Draft-General-Plan-Environmental-Impact-Report-Santa-Rosa-2035-PDF.
Source: City of Santa Rosa, 2023.
The alternatives analysis assumes that the proposed General Plan 2050 goals, policies, and actions would apply to Alternative B, including the mitigating policies and actions, but would not apply to Alternative A.
The following discussion compares the environmental impacts of the alternatives with those of the proposed project for each of the environmental topics analyzed in detail in Chapter 4.0, Environmental Analysis, of this Draft EIR. The impacts of each alternative are classified as less than (<), similar or comparable to (=), or greater than (>) the level of impacts associated with the proposed project. Table 5-2, Impact Comparison of the Proposed Project and Alternatives by Environmental Topic, summarizes the relative impacts of each environmental topic of the alternatives compared to the proposed project.
TABLE 5-2 IMPACT COMPARISON OF THE PROPOSED PROJECT AND THE ALTERNATIVES BY ENVIRONMENTAL TOPIC Environmental Topic
Impact Conclusion of the
Proposed Project a
Impact Conclusion Compared to the Proposed Project
Alternative A:
No Project
Alternative B:
Increased Density
Aesthetics LTS = =
Agricultural Resources SU < <
Air Quality SU > <
Biological Resources LTS/M > <
Cultural Resources LTS/M > >
Energy LTS > <
Geology and Soils LTS/M > =
Greenhouse Gas Emissions LTS > <
Hazards and Hazardous Materials LTS/M > =
Hydrology and Water Quality LTS/M > =
Land Use and Planning LTS > =
Noise SU > <
Population and Housing LTS > =
Public Services and Recreation LTS < =
Transportation SU > <
Tribal Cultural Resources LTS/M > <
Utilities and Service Systems LTS < =
Wildfire SU > <
Note:
a. The impact conclusions in this column represent the highest significance determination for each respective standard of significance.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-8 OCTOBER 2024
TABLE 5-2 IMPACT COMPARISON OF THE PROPOSED PROJECT AND THE ALTERNATIVES BY ENVIRONMENTAL TOPIC Environmental Topic
Impact Conclusion of the
Proposed Project a
Impact Conclusion Compared to the Proposed Project
Alternative A:
No Project
Alternative B:
Increased Density
LTS Less Than Significant
LTS/M Less Than Significant with Mitigation
SU Significant and Unavoidable
< Less impact in comparison to the proposed project
= Similar impact in comparison to the proposed project
> Greater impact in comparison to the proposed project
As previously stated, the alternatives were selected because of their potential to further reduce and avoid the significant and unavoidable impacts listed in Section 5.2.2. Table 5-3, Comparison of Significant and Unavoidable Impacts of the Proposed Project and the Alternatives by Environmental Topic and Standard of Significance, summarizes the relative impacts of each environmental topic of the alternatives compared to the proposed project.
TABLE 5-3 COMPARISON OF SIGNIFICANT AND UNAVOIDABLE IMPACTS OF THE PROPOSED PROJECT AND THE
ALTERNATIVES BY ENVIRONMENTAL TOPIC AND STANDARD OF SIGNIFICANCE Environmental
Topic Impact Statement
Proposed
Project
Alternative A:
No Project
Alternative B:
Increased
Density
Agricultural
Resources
Impact AG-1: Implementation of the proposed project
could result in the conversion of Prime Farmland,
Farmland of Statewide Importance, and Unique
Farmland land (together referred to as “CEQA Important
Farmland”) to non-agricultural land uses.
SU < <
Impact AG-2: Implementation of the proposed project
could result in the loss of agricultural land under the Williamson Act.
SU < <
Impact AG-4: The proposed project, in combination with
past, present, and reasonably foreseeable projects,
could result in a significant cumulative impact with
respect to the conversion of CEQA Important Farmland
(Prime Farmland, Farmland of Statewide Importance,
and Unique Farmland) and Williamson Act properties to
non-agricultural uses.
SU < <
Air Quality Impact AIR-2b: Buildout of the proposed project could generate operational emissions that could exceed the
Bay Area Air Quality Management District’s (BAAQMD)
regional significance thresholds for reactive organic
compounds (ROG), nitrogen oxides (NO
X) and particulate
matter (PM2.5 and PM10).
SU > <
Impact AIR-3b: Large industrial or warehouse
development projects under the proposed project could
expose air quality-sensitive receptors to substantial toxic air contaminants (TAC) and particulate matter (PM
2.5)
concentrations and exceed the Bay Area Air Quality
Management District’s (BAAQMD) project-level and
cumulative significance thresholds.
SU > <
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-9
TABLE 5-3 COMPARISON OF SIGNIFICANT AND UNAVOIDABLE IMPACTS OF THE PROPOSED PROJECT AND THE
ALTERNATIVES BY ENVIRONMENTAL TOPIC AND STANDARD OF SIGNIFICANCE Environmental
Topic Impact Statement
Proposed
Project
Alternative A:
No Project
Alternative B:
Increased
Density
Impact AIR-5: The proposed project, in combination with past, present, and reasonably foreseeable projects,
could result in cumulative air quality impacts with
respect to generation of criteria pollutant and exposure of substantial pollutant concentrations to sensitive
receptors.
SU > <
Noise Impact NOI-1a: Construction activities associated with potential future development could expose sensitive
receptors to excessive noise from construction
equipment.
SU > <
Impact NOI-1b: Operational vehicle traffic noise
increases could exceed the City’s significance thresholds with implementation of the proposed project.
SU > <
Impact NOI-4: Implementation of the proposed project,
in combination with past, present, and reasonably
foreseeable projects, could result in cumulative noise
impacts, with respect to generation of construction-and transportation related noise.
SU > <
Transportation Impact TRAN-2a: Implementation of the proposed project could result in a significant vehicle miles traveled (VMT) impact for residential VMT per capita.
SU > <
Impact TRAN-2b: Implementation of the proposed
project could result in a significant roadway network
vehicle miles traveled (VMT) impact associated with
increasing the capacity of the arterial street network.
SU > <
Impact TRAN-5: The proposed project, in combination
with past, present, and reasonably foreseeable projects, could result in significant cumulative impact with respect to vehicle miles traveled (VMT).
SU
> <
Wildfire Impact WF-2: Potential future development over the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-
prone areas, thereby exacerbating wildfire risks.
SU > <
Impact WF-5: Potential development over the buildout
horizon of the proposed project could, in combination
with other surrounding and future projects in the State Responsibility Areas (SRA), Very High Fire Hazard
Severity Zones (FHSZ), or Wildland-Urban Interface Fire Areas (WUIFA), result in cumulative impacts associated
with the exposure of project occupants to pollutant
concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
SU > <
Notes:
SU Significant and Unavoidable
< Less impacts in comparison to the proposed project
= Similar impact in comparison to the proposed project
> Greater impact in comparison to the proposed project
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-10 OCTOBER 2024
5.3 ALTERNATIVE A: NO PROJECT (GENERAL PLAN 2035)
5.3.1 DESCRIPTION
Pursuant to CEQA Guidelines Section 15126.6(e)(1), the No Project Alternative is required as part of the “reasonable range of alternatives” to allow decision makers to compare the impacts of approving the proposed project with the impacts of taking no action or not approving the proposed project. Consistent with CEQA Guidelines Section 15126.6(e)(3)(A), when the project is the revision of a plan, as in this case, the no project alternative will be the continuation of the existing plan. Under Alternative A, potential future development in Santa Rosa would continue to be subject to existing policies, regulations, development standards, and land use designations of the existing General Plan 2035. Alternative A would not implement the amendments to the North Station Area Specific Plan (NSASP), Downtown Station Area Specific Plan (DSASP), or Santa Rosa City Code (SRCC) associated with the proposed General Plan 2050 and Land Use Map. Alternative A would also not adopt the proposed GHG Reduction Strategy to serve as the strategic plan for how the City will reduce GHG emissions and foster a sustainable community through 2050 and beyond.
As described in Chapter 3, Project Description, of this Draft EIR, the existing General Plan was adopted in 2009 and included a horizon year of 2035. A number of State and federal laws guiding general plan policies have also been updated during this time. Many of the community issues vetted in the General Plan 2035 are still relevant, well addressed, and do not require major changes. However, Alternative A would not incorporate new topics that are now required by State law, such as environmental justice, and would not revise relevant policies and actions to meet those requirements.
Pursuant to CEQA Guidelines Section 15126.6(e)(3)(C), the City of Santa Rosa, acting as the lead agency, should analyze the impacts of the No Project Alternative by projecting what would reasonably be expected to occur in the foreseeable future if the proposed project were not approved, based on current plans and consistent with available infrastructure and community services. Implementation of the No Project Alternative assumes that development growth throughout the city would remain unchanged until the buildout horizon year 2050, which is consistent with other regional plans, including Plan Bay Area 2050.
Future development permitted under the No Project Alternative would not increase development potential in Santa Rosa beyond what was considered in the existing General Plan 2035 and analyzed in the associated EIR (State Clearinghouse No. 2008092114), but rather assumes the remaining development growth shown in Table 5-1 would occur through 2050. No General Plan land use designations changes or zoning amendments would be required to accommodate these uses.
Table 5-4, 2019 to 2050 Growth Under the Proposed Project and Alternative A, shows the difference between 2019 to 2050 growth of the proposed project compared to Alternative A. As shown in Table 5-4, Alternative A would result in less residential and job growth when compared to the proposed project.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-11
TABLE 5-4 2019 TO 2050 GROWTH UNDER THE PROPOSED PROJECT AND ALTERNATIVE A Category
Proposed
Project
Alternative A:
No Project
Difference between the
Proposed Project and Alternative A
Residential Units 24,090 3,996a 20,094 more residential units Population 65,760 17,270 a 48,490 more population
Jobs 14,090 -30,000 a 44,090 more jobs
Notes:
a. City of Santa Rosa, March 2009, General Plan 2035 Environmental Impact Report, Table 3-1, Buildout Changes Between the 2020 to 2035 General Plans, https://www.srcity.org/DocumentCenter/View/3096/Draft-General-Plan-Environmental-Impact-Report-Santa-Rosa-2035-PDF.
Source: City of Santa Rosa, 2023.
5.3.2 IMPACT DISCUSSION
The potential environmental impacts associated with Alternative A when compared to the proposed project are described herein.
AESTHETICS
As described in Chapter 4.1, Aesthetics, of this Draft EIR, the proposed project would not result in any significant impacts related to aesthetics.
While there are no officially designated scenic vistas in the EIR Study Area, the City has officially designated certain roadways in Santa Rosa as scenic roads in the General Plan. The EIR Study Area also includes portions of State Route (SR) 12 which have been designed as “eligible” for and “officially designated” as a State Scenic Highway.
Like the proposed project, potential future development in the EIR Study Area under Alternative A is anticipated to occur in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, where future development would have a lesser impact on scenic vistas. The proposed General Plan 2050 reinforces existing uses, heights, and densities in most locations, with allowances for greater intensity only in a limited number of locations and therefore would not substantially increase building height beyond what is previously accounted for under the current General Plan 2035.
Potential future development under both the proposed project and Alternative A would be required to comply with SRCC regulations, including those for the Scenic Road Combining District and Design Review.
Santa Rosa Design Guidelines would also apply to all projects that require design review, including most new buildings, subdivisions, infill development, and public improvements. Potential future development in the city would also be subject to the various planning documents that govern scenic quality in the city, such as the Citywide Creek Master Plan, Sebastopol Road Urban Vision and Corridor Plan, and Street Light Design Standards.
Similar to the proposed project, Alternative A would result in new lighting sources that could result in sources of glare. Potential future development under both scenarios would be required to comply with best management practices in CALGreen, the SRCC, the Street Light Design Standards, and other adopted
5.3.2.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-12 OCTOBER 2024
plans. Potential future development would be reviewed for consistency with the lighting standards regarding the appropriate use of lighting and avoidance of glare from lighting and other sources.
While there is less development potential under Alternative A when compared to the proposed project, potential future development under both scenarios would be subject to the same regulations; therefore, impacts related to aesthetics would be similar under Alternative A when compared to the proposed project.
AGRICULTURAL RESOURCES
As determined in Chapter 4.2, Agricultural Resources, of this Draft EIR, the proposed project would result in significant and unavoidable impacts related to the loss of agricultural lands due to the potential conversion to non-agricultural land uses. Through the proposed General Plan 2050 goal, policies, and actions, impacts related to the conversion of qualifying agricultural lands would be reduced, but not to a less-than-significant level.
The EIR Study Area contains 43 acres of Prime Farmland, 660 acres of Farmland of Statewide Importance, and 54 acres of Unique Farmland. There is a total of 97 acres of land that are under Williamson Act contracts within the EIR Study Area. Under both scenarios, there is the potential for these agricultural lands to be converted to non-agricultural uses. However, there is less development potential under Alternative A when compared to the proposed project; therefore, impacts related to agricultural resources would be
less under Alternative A when compared to the proposed project.
AIR QUALITY
As described in Chapter 4.3, Air Quality, of this Draft EIR, the proposed project would result in less than significant impacts related to construction with implementation of proposed General Plan 2050 *Action 3-
6.31, *Action 3-6.32, and *Action 6-1.5. However, significant and unavoidable impacts related to operational emissions of reactive organic compounds (ROG), nitrogen oxides (NOX) and particulate matter (PM10 and PM2.5) and exposure of air quality-sensitive receptors to substantial toxic air contaminants (TAC) and PM2.5 concentrations, despite implementation of proposed General Plan 2050 *Action 3-6.31, *Action 6-1.5, and *Action 6-1.6. This significant and unavoidable impact is only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
Alternative A would continue development as allowed under the current General Plan 2035, which would result in less development in the EIR Study Area compared to the proposed project. Therefore, less direct and indirect criteria air pollutant emissions from energy (e.g., natural gas use) and area sources (e.g., aerosols and landscaping equipment) would occur . Additionally, there would be less of an elevation in concentrations of toxic air contaminants in the vicinity of sensitive land uses.
Potential future development under both the proposed project and Alternative A would be subject to the Bay Area Air Quality Management District’s (BAAQMD’s) rules and regulations, including those related to fugitive dust and odor, and would be required to prepare a detailed air quality impact assessment on a project-by -project basis. However, Alternative A would not include the updated policy framework of the proposed project that ensures adequate planning occurs to accommodate the future population increase
5.3.2.2 5.3.2.3
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-13
and potential future development, thereby conflicting with the BAAQMD 2017 Clean Air Plan.
Furthermore, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions or the proposed GHG Reduction Strategy to further reduce potential VMT and GHG emissions.
Therefore, impacts related to air quality would be greater under Alternative A when compared to the proposed project.
BIOLOGICAL RESOURCES
As described in Chapter 4.4, Biological Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to biological resources with implementation of proposed General Plan 2050 *Action 3.5-7, *Action 3-5.10, *Action 3-5.11, *Action 3-5.12, *Action 3-5.13, *Action 3-5.19, and *Action 3-5.20.
The EIR Study Area is not within any local, regional, or State Habitat Conservation Plan areas. Therefore, neither the proposed project nor Alternative A would conflict with the conservation strategy in any Habitat Conservation Plan or Natural Community Conservation Plan. The City of Santa Rosa General Plan is the overriding planning document for the City of Santa Rosa and would therefore not conflict with local policies and ordinances protecting biological resources.
Like the proposed project, potential future development in the EIR Study Area under Alternative A could potentially affect animal and plant species identified as candidate, sensitive, or special-status species but would primarily occur as infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, which reduces the likelihood that special-status plant and animal species could be impacted. Infill development also reduces the likelihood that the riparian habitats, wetlands, and wildlife movement corridors could be impacted. Potential future development under both scenarios would be required to adhere to all federal, state, and local regulations relating to biological resources.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require consultation with the California Department of Fish and Wildlife to preserve populations of plants and animals, continued implementation of existing regulations and procedures, preparation of a biological resource assessments as part of project approval, avoidance of nests of native birds and implementation of protection measures, establishment of ecological buffer zones, and maintenance of adequate setbacks.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to biological resources would be greater under Alternative A when compared to the proposed project.
5.3.2.4 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-14 OCTOBER 2024
CULTURAL RESOURCES
As described in Chapter 4.5, Cultural Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to cultural resources with implementation of proposed General Plan 2050 *Action 3-5.19, *Action 3-5.20, *Action 4-2.1, *Action 4-2.2, *Action 4-2.3, *Action 4-2.4, *Action 4-3.2, *Action 4-3.6, *Action 4-3.7, and *Action 4-3.9.
The EIR Study Area contains existing prehistoric, architectural, historical, or archaeological resources that could be impacted by new demolition, inappropriate modification, or inappropriate new construction under the proposed project or Alternative A. Like the proposed project, potential future development under Alternative A would be subject to the regulations of the SRCC for historic and cultural preservation and the Historic Combining District. Santa Rosa Design Guidelines would also apply to all historic structures and neighborhoods that have been adopted by the city. In the event of the discovery of human remains, procedures of conduct mandated by Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and the California Code of Regulations (CCR) Section 15064.5(e) would be adhered to.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require continued review of proposed developments in conjunction with appropriate entities to determine the presence of historic and archeological resources and mitigation to protect such resources, examination of project areas with significant archaeological resources by a qualified consulting archaeologist with recommendations for protection and preservation, and continued compliance with existing regulations.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to cultural resources would be greater under Alternative A when compared to the proposed project.
ENERGY
As described in Chapter 4.6, Energy, of this Draft EIR, the proposed project would not result in any significant impacts related to energy.
All development that occurs in the State is required to comply with best management practices regulated in the California Green Building Code and Building and Energy Efficiency Standards, which ensure new development would not result in the wasteful or inefficient use of energy. Additionally, neither the proposed project nor Alternative A would introduce a level of development and population growth that would be anticipated to necessitate the construction of new energy supply facilities or transmission infrastructure.
Less development would occur under Alternative A, so energy consumption from construction would be less when compared to the proposed project. Energy use from building electricity, natural gas, and transportation would also be less under Alternative A because there is less development potential when compared to the proposed project. However, as the standard of significance for energy impact is focused
5.3.2.5 5.3.2.6
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-15
on efficiency and not on amount, it is assumed that the net benefits from the proposed General Plan 2050 goals, policies, and actions and the proposed GHG Reduction Strategy would result in more efficient and less wasteful energy use when compared to Alternative A. Because Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions or the proposed GHG Reduction Strategy, impacts related to energy would be greater under Alternative A when compared to the proposed project.
GEOLOGY AND SOILS
As described in Chapter 4.7, Geology and Soils, of this Draft EIR, the proposed project would result in less- than-significant impacts related to geology and soils with implementation of proposed General Plan 2050 *Policy 5-1.1, *Action 5-1.1, and *Action 5-1.2.
Potential future development under both the proposed project and Alternative A would be subject to the same the SRCC regulations, including the requirement for any project within a State Geologist-delineated earthquake fault zone to obtain specialized approval, compliance with the California Building Code and hillside development standards, and implementation of grading, erosion, and sediment control. Potential future development under both scenarios would also be required to comply with the federal Paleontological Resources Preservation Act that limits the collection of vertebrate fossils and other rare and scientifically significant fossils to qualified researchers who have obtained a permit from the appropriate state or federal agency and the PRC Section 5097 that prohibits the removal of any paleontological site or feature from public lands without the permission of the jurisdictional agency.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require avoidance and mitigation of seismic and geological hazards. Geologic studies and analyses are required to be deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer, and where it is determined that hazards cannot be effectively mitigated, development shall be restricted.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to geology and soils would be greater under
Alternative A when compared to the proposed project.
GREENHOUSE GAS EMISSIONS
As described in Chapter 4.8, Greenhouse Gas Emissions, of this Draft EIR, the proposed project would result in less-than-significant impacts related to GHG emissions and consistency with applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.
Potential future development under both the proposed project and Alternative A would experience emission reductions from implementation of State measures and strategies to reduce Statewide GHG emissions. The GHG emissions from new buildings constructed would be subject to the triennial updates of California’s Building and Energy Efficiency Standards, which would presumably improve over time and thereby result in more energy efficient buildings.
5.3.2.7 5.3.2.8
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-16 OCTOBER 2024
Under Alternative A, there would be less development, resulting in an overall decrease in energy usage from construction and operation of potential future development. However, Alternative A would be implemented under the current General Plan 2035, which does not include the new mix of land uses that increase density to reduce VMT. Furthermore, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions or the proposed GHG Reduction Strategy to further reduce potential GHG emissions to achieve State GHG reduction goals consistent with the BAAQMD CEQA Guidelines. Therefore, impacts related to GHG emissions would be greater under Alternative A when compared to the proposed project.
HAZARDS AND HAZARDOUS MATERIALS
As described in Chapter 4.9, Hazards and Hazardous Materials, of this Draft EIR, the proposed project would result in less-than-significant impacts related to hazards and hazardous materials. With respect to impacts related to TACs during construction and operation, which could occur within 0.25 miles of a school, the implementation of proposed General Plan 2050 *Action 6-1.5 and *Action 6-1.6 were found to be less than significant as discussed in Chapter 4.3, Air Quality, of this Draft EIR.
The Charles M. Schulz Sonoma County Airport AIA is located northwest of, but greater than two miles outside of, the EIR Study Area. Therefore, neither the proposed project nor Alternative A would result in a safety hazard or excessive noise for people residing or working in an area within an airport land use plan.
Potential future development within the EIR Study Area under both scenarios would involve the routine use, transport, and handing of hazardous materials throughout the city, and could occur on properties that possibly are contaminated and inactive, undergoing evaluation, and/or undergoing corrective action.
There is a total of 596 hazardous materials sites listed on databases complied pursuant to Government Code Section 65962.5, 103 of which are designated as active and the remaining 493 sites are designated as “closed” or “completed–case closed.” Potential future development under both the proposed project and Alternative A would be required to comply with all federal, State, regional, and local regulations regarding the safe handling, transport, disposal, and use of hazardous materials, as well as those regarding emergency response and evacuation to minimize impacts.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require the preparation of construction and operational health risk assessments to ensure that potential future development would not emit hazardous emissions or handle hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school.
While development in the EIR Study Area would be less than the proposed project and thereby pose less risk of geological hazards, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to hazards and hazardous materials would be greater under Alternative A when compared to the proposed project.
5.3.2.9 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-17
HYDROLOGY AND WATER QUALITY
As described in Chapter 4.10, Hydrology and Water Quality, of this Draft EIR, the proposed project would not result in any significant impacts related to hydrology and water quality with implementation of proposed General Plan 2050 *Action 3-5.10, *Action 3-5.12, Action 3-5.19, *Action 3-5.20, *Action 5-
2.14, *Action 5-2.15, *Action 5-2.17, and *Action 5-9.30.
Like the proposed project, potential future development under Alternative A would likely occur within previously urbanized areas, connect to existing drainage systems already in place, and be subject to the same existing federal, state, and local regulations relating to hydrology and water quality to ensure that pre- and post-construction impacts to water quality are minimized.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require continued implementation of existing regulations and procedures, preparation of a biological resource assessments as part of project approval, establishment of ecological buffer zones, maintenance of adequate setbacks, maintenance and improvements to the storm drainage system, ensured consistency with City plans, implementation of best management practices to reduce discharges to the storm drain system, and maintained consistency with the MS4 National Pollutant Discharge Elimination System (NPDES) permit.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to hydrology and water quality would be greater under Alternative A when compared to the proposed project.
LAND USE AND PLANNING
As described in Chapter 4.11, Land Use and Planning, of this Draft EIR, the proposed project would not result in any significant impacts related to land use and planning.
Like the proposed project, Alternative A would maintain the existing roadway patterns and would not include any new major roadways or other physical features through existing neighborhoods that would create new physical barriers in the EIR Study Area.
Under Alternative A, development would continue to occur throughout the EIR Study Area under the current General Plan 2035 and Zoning Code and would not conflict with these already approved standards. However, Alternative A would not implement the updated land use mix to guide future development in a more sustainable and efficient manner consistent with Plan Bay Area 2050. Alternative A would also not adopt and implement the proposed GHG Reduction Strategy which ensures consistency with Plan Bay Area by supporting the City’s trajectory to meet its GHG reduction targets.
Continuing the use of the current General Plan 2035 would conflict with applicable land use plan adopted for the purpose of avoiding or mitigating an environmental effect and impacts related to land use and planning would be greater under Alternative A when compared to the proposed project.
5.3.2.10 5.3.2.11
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-18 OCTOBER 2024
NOISE
As described in Chapter 4.12, Noise, of this Draft EIR, the proposed project would result in less-than- significant impacts with respect to land use compatibility, vibration (operation and construction), with implementation of proposed General Plan 2050 *Action 5-7.1, Action 5-7.2, *Action 5-7.3, *Action 5-7.9, and *Action 5-7.10. Significant and unavoidable impacts related to exposure of noise-sensitive receptors to excessive construction noise and operational vehicle traffic noise, despite implementation of the proposed mitigating General Plan 2050 actions previously listed plus *Action 5-7.7. These significant and unavoidable impacts are only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
The City boundaries lie outside the 55 dBA CNEL/Ldn contour line of the Charles M. Schulz-Sonoma County Airport located more than two miles northwest of the city. Therefore, neither the proposed project nor Alternative A would expose people residing or working within two miles of a private airstrip or airport to excessive noise levels.
Future development allowed under both the proposed project and Alternative A would be subject to the standards of the SRCC. Because less development would occur under Alternative A and fewer vehicular trips would be generated, noise and vibration from construction and operation of potential future development would be less under Alternative A when compared to the proposed project.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require conducting acoustical studies, implementing conditions of approval or mitigation to reduce noise exceeding normally acceptable levels primarily through site planning, using the Federal Transit Authority’s construction noise and vibration thresholds to assess impacts and identify mitigation, working with Caltrans to evaluate and develop traffic noise mitigation programs, and adopting construction best management practices.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to noise would be greater under Alternative A when compared to the proposed project.
POPULATION AND HOUSING
As described in Chapter 4.13, Population and Housing, of this Draft EIR, the proposed project would not result in any significant impacts related to population and housing.
The proposed General Plan 2050 is the policy document that plans ahead to accommodate the amount of reasonably foreseeable growth given past growth trends and the ability of existing services and infrastructure to support future growth. Therefore, the proposed project would not directly induce growth, but rather is a response to growth that is likely to occur whether the proposed project is adopted or not. The projected growth under the proposed project accounts for future Regional Housing Needs Allocation (RHNA) cycles.
5.3.2.12 5.3.2.13
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-19
Alternative A would not include the updated policy framework of the proposed project that ensures adequate planning occurs to accommodate the future population increase and future development to extended buildout year through 2050. While Alternative A would result in a net increase in housing, like the proposed project, it would not be enough to cover the next RHNA cycle and could result in displacement and require replacement housing. Therefore, impacts related to population and housing would be
greater under Alternative A when compared to the proposed project.
PUBLIC SERVICES AND RECREATION
As described in Chapter 4.14, Public Services and Recreation, of this Draft EIR, impacts under the proposed project to fire protection services, police services, parks, schools, and libraries were found to be less than significant.
Alternative A would result in less residents and jobs in the EIR Study Area compared to the proposed project, and therefore, would result in less demand on the public service providers that serve the EIR Study Area. Potential future development under Alternative A would be required to comply with all existing City regulations adopted to ensure that development pays its fair share of the cost of delivering services, providing park space and libraries, while payment of property taxes would ensure that future development pays its fair share towards schools. Overall, impacts related to public services and recreation would be
less under Alternative A than those of the proposed project.
TRANSPORTATION
As described in Chapter 4.15, Transportation, of this Draft EIR, the proposed project would result in significant and unavoidable impacts related to VMT generation of the proposed project exceeding the City’s thresholds, despite implementation of proposed General Plan 2050 *Action 3-1.1. This significant and unavoidable impact is only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
Any potential new transportation facilities built under both the proposed project and Alternative A, whether constructed as part of private developments or by agencies, including the City of Santa Rosa, to improve circulation consistent with City plans, would be designed and constructed to local, regional, and federal standards. These include, but are not limited to, the California Manual on Uniform Traffic Control Devices, the Caltrans Highway Design Manual, and the City of Santa Rosa’s Street Design and Construction Standards, all of which have been developed to minimize the potential for safety conflicts and hazards.
Like the proposed project, potential future development in the EIR Study Area under Alternative A is anticipated to occur in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, generation of VMT would be lower than if development were proposed in areas not served by public transportation and a network of sidewalks and bicycle facilities. However, Alternative A would be implemented under the current General Plan 2035, which does not include the new mix of land uses that increase density to reduce VMT.
5.3.2.14 5.3.2.15
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-20 OCTOBER 2024
Several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require analysis of project VMT and mitigation as part of the project review process. However, because VMT uncertainties as to whether individual development projects will be able to successfully meet VMT standards even with mitigation, and uncertainties as to the availability of other mitigation strategies such as VMT exchanges or banks.
While the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project would not fully mitigate VMT impacts of the proposed project, Alternative A would not realize these proposed goals, policies, or actions and would not include the new mix of land uses that increase density to reduce VMT. Therefore, impacts related to transportation would be greater under Alternative A when compared to the proposed project.
TRIBAL CULTURAL RESOURCES
As described in Chapter 4.16, Tribal Cultural Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to tribal cultural resources (TCR) with implementation of proposed General Plan 2050 *Action 3-5.19, *Action 3-5.20, *Action 4-2.1, *Action 4-2.2, and *Action 4-2.4. Note, as discussed in Chapter 4.5, Cultural Resources, of this Draft EIR, that *Action 4-2.3 would reduce impacts to archeological resources, which could be identified as TCRs, to less-than-significant levels.
The EIR Study Area does not contain any known TCR; however, there is the potential for TCRs to be identified as part of project-specific development over the course of the implementation of the proposed project. Like the proposed project, potential future development under Alternative A would be subject to the federal and state laws regarding TCRs. In the event of the discovery of human remains, procedures of conduct mandated by Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and the California Code of Regulations (CCR) Section 15064.5(e) would be adhered to.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require continued review of proposed developments in conjunction with appropriate entities to determine the presence of TCRs and mitigation to protect such resources, examination of project areas with significant archaeological resources by a qualified consulting archaeologist with recommendations for protection and preservation, and continued compliance with existing regulations.
While development in the EIR Study Area would be less than the proposed project, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to TCRs would be greater under Alternative A when compared to the proposed project.
UTILITIES AND SERVICE SYSTEMS
As described in Chapter 4.17, Utilities and Service Systems, of this Draft EIR, impacts to water, wastewater, stormwater, solid waste, and energy infrastructure under the proposed project, were found to be less than significant with the compliance of all applicable regulations.
5.3.2.16 5.3.2.17
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-21
Like the proposed project, potential future development under Alternative A would be required to comply with all existing federal, state, and local regulations. Demand and consumption trends generally demonstrate that advances in water-efficient regulations in building and landscaping, stricter stormwater retention requirements and recycling and solid waste reduction requirements would reduce impacts from existing conditions. Additionally, Alternative A would result in less residents and jobs in the EIR Study Area compared to the proposed project, and therefore, would result in less demand on the utilities infrastructures that serve the EIR Study Area. Overall, impacts related to utilities and service systems would be
less under Alternative A when compared to the proposed project.
WILDFIRE
As described in Chapter 4.18, Wildfire, of this Draft EIR, the proposed project would result in less-than- significant impacts related to evacuation with implementation of proposed General Plan 2050 *Action 5-
5.14, *Action 5-5.15, *Action 5-5.16, and *Action 5-5.17. However, even with implementation of proposed General Plan 2050 *Action 5-3.8, the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks and resulting in impacts that are significant and unavoidable.
Like the proposed project, potential future development under Alternative A would be required integrate applicable emergency operation and evacuation requirements as necessary into development to continue its facilitation in evacuation for people in wildfire-prone areas. Potential future development, regardless of whether it includes new development or redevelopment, would also be required to comply with adopted local, regional, and State plans and regulations addressing emergency access, response, and evacuation and wildfire hazards. Future development in the Wildland-Urban Interface Fire Area (WUIFA) or Very High fire hazard severity zones (FHSZ) would be required to comply with the Very High FHSZ Fire Safe Regulations, the California Building Code (CBC), the California Fire Code (CFC), and the SRCC, which have emergency access, building fire safety, and perimeter wildfire protection measures.
However, several new and modified General Plan 2050 policies and actions serve as means to mitigate environmental impacts under CEQA. Such proposed policies and actions require updates to the Community Wildfire Protection Plan identify slope stability and wildfire hazard areas and mitigation strategies and the preparation of fire protection plans for new development and major remodels in the WUIFA.
While development in the EIR Study Area would be less than the proposed project and thereby pose less risk of wildfire hazards, Alternative A would not realize the new or modified General Plan 2050 goals, policies, or actions that were prepared as part of the proposed project, and as such, impacts related to wildfire would be greater under Alternative A when compared to the proposed project.
5.3.3 RELATIONSHIP OF THE ALTERNATIVES TO THE OBJECTIVES Under Alternative A, the proposed project would not be implemented, and therefore this alternative would not accomplish any of the project objectives.
5.3.2.18 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-22 OCTOBER 2024
5.4 ALTERNATIVE B: INCREASED DENSITY
5.4.1 DESCRIPTION
Alternative B assumes the General Plan would be updated as well as the associated amendments to the NSASP , DSASP, and SRCC associated with the proposed General Plan 2050 and Land Use Map. Accordingly, Alternative B, like the proposed project, would focus future commercial and residential growth in PDAs and/or TPAs and in the Areas of Change that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities. Alternative B assumes the same number of households, residential units, population, and jobs as under the proposed project, but would allow for more opportunity for dense housing connected to transit facilities. Alternative B presumes the same General Plan land use designations as the proposed project, except that the parcels designated as Medium Low density residential (8.0-13.0 units per gross acre) in Areas of Change that are in or adjacent to PDAs and/or TPAs would be redesignated to Medium High density residential (8.0-18.0 units per gross acre).
As shown in Table 4-1, Proposed General Plan 2050 Areas of Change by PDA/TPA, in Chapter 4.0, Environmental Analysis, of this Draft EIR, there are 11 Areas of Change that are within or directly adjacent to a PDA and/or TPA. Out of these 11 Areas of Change, there are three that have parcels with Medium Low density land use designations. These are the Marlow Center and Lance Drive Annexation (#4), Downtown Station Area (#7), and Hearn Corridor (#17) Areas of Change (see Figure 3-7, Proposed General Plan 2050 Areas of Change, in Chapter 3). While potential future development under this alternative could occur throughout the 21 Areas of Change, under Alternative B, the parcels in these three Areas of Change with a Medium Low density land use designation would be changed to Medium High density land use designation to allow for more opportunities for the development of more dense housing than what is allowed under the proposed project. However, if a parcel has a Medium Low density land use designation and is within a Historic District, that parcel would not be redesignated to ensure the potential impacts to historic resources would not be greater in Alternative B when compared to the proposed project. The specific purpose of this alternative is to reduce the significant and unavoidable impacts associated with transportation. As described in Chapter 4.15, Transportation, of this Draft EIR, the VMT modeling results indicate that the proposed project’s residential uses would be above the standard of significance that is used to measure residential VMT per capita. Accordingly, to reduce residential VMT per capita, Alternative B would allow for higher residential densities in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities. By allowing more dense housing development in areas that can meet community needs, Alternative B would accommodate the same amount of growth as the proposed General Plan 2050, but in a smaller footprint, and promote active and public transportation to reduce VMT.
The alternatives analysis assumes that the proposed General Plan 2050 goals, policies, and actions would apply to Alternative B, including the mitigating policies and actions.
5.4.2 IMPACT DISCUSSION
The potential environmental impacts associated with Alternative B when compared to the proposed project are described herein.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-23
AESTHETICS
As described in Chapter 4.1, Aesthetics, of this Draft EIR, the proposed project would not result in any significant impacts related to aesthetics.
While there are no officially designated scenic vistas in the EIR Study Area, the City has officially designated certain roadways in Santa Rosa as scenic roads in the General Plan. The EIR Study Area also includes portions of SR 12 which have been designed as “eligible” for and “officially designated” as a State Scenic Highway.
Like the proposed project, potential future development in the EIR Study Area under Alternative B is anticipated to occur in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, where future development would have a lesser impact on scenic vistas. However, Alternative B would allow for greater density in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities. Increased building height would have the potential to affect scenic vistas or scenic roadways in the EIR Study Area, but such development would be focused in infill urban areas.
Potential future development under both the proposed project and Alternative B would be required to comply with SRCC regulations, including those for the Scenic Road Combining District and Design Review.
Santa Rosa Design Guidelines would also apply to all projects that require design review, including most new buildings, subdivisions, infill development, and public improvements. Potential future development in the city would also be subject to the various planning documents that govern scenic quality in the city, such as the Citywide Creek Master Plan, Sebastopol Road Urban Vision and Corridor Plan, and Street Light Design Standards.
Similar to the proposed project, Alternative B would result in new lighting sources that could result in sources of glare. Potential future development under both scenarios would be required to comply with best management practices in CALGreen, the SRCC, the Street Light Design Standards, and other adopted plans. Potential future development would be reviewed for consistency with the lighting standards regarding the appropriate use of lighting and avoidance of glare from lighting and other sources.
While Alternative B would allow for greater density and increased building height, potential future development would be subject to the same regulations as those under the proposed project; therefore, impacts related to aesthetics would be similar under Alternative B when compared to the proposed project.
AGRICULTURAL RESOURCES
As determined in Chapter 4.2, Agricultural Resources, of this Draft EIR, the proposed project would result in significant and unavoidable impacts related to the loss of agricultural lands. Through the proposed General Plan 2050 goal, policies, and actions, impacts related to the conversion of qualifying agricultural lands would be reduced, but not to a less-than-significant level.
5.4.2.1 5.4.2.2
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-24 OCTOBER 2024
The EIR Study Area contains 43 acres of Prime Farmland, 660 acres of Farmland of Statewide Importance, and 54 acres of Unique Farmland. There is a total of 97 acres of land that are under Williamson Act contracts within the EIR Study Area.
Alternative B allows for more dense infill development potential, reducing the amount of the farmlands— Prime Farmland, Farmland of Statewide Importance, or Unique Farmland, and lands under Williamson Act contracts—to be converted to non-agricultural uses. While the loss of any of these lands through the conversion to non-agricultural uses would result in a significant impact, because less qualifying agricultural lands could be converted, impacts related to agricultural resources would be less under
Alternative B when compared to the proposed project.
AIR QUALITY
As described in Chapter 4.3, Air Quality, of this Draft EIR, the proposed project would result in less than significant impacts related to construction with implementation of proposed General Plan 2050 *Action 3-
6.31, *Action 3-6.32, and *Action 6-1.5. However, significant and unavoidable impacts related to operational emissions of reactive organic compounds (ROG), nitrogen oxides (NOX) and particulate matter (PM10 and PM2.5) and exposure of air quality-sensitive receptors to substantial toxic air contaminants (TAC) and PM2.5 concentrations, despite implementation of proposed General Plan 2050 *Action 3-6.31, *Action 6-1.5, and *Action 6-1.6. This significant and unavoidable impact is only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
Alternative B would result in the same level of development compared to the proposed project.
Therefore, direct and indirect criteria air pollutant emissions from energy (e.g., natural gas use) and area sources (e.g., aerosols and landscaping equipment) would be similar to the proposed project, as would be the concentrations of TACs and PM2.5 to which sensitive receptors are exposed. The additional housing opportunities in these three Areas of Change would have the potential to put more housing where there are known, but mitigable, environmental hazards when compared to the proposed project. However, Alternative B allows for more dense infill development potential, specifically in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities to reduce VMT and therefore automobile emissions in support of the goals of the BAAQMD 2017 Clean Air Plan.
Potential future development under both the proposed project and Alternative B would be subject to the Bay Area Air Quality Management District’s (BAAQMD) rules and regulations, including those related to fugitive dust and odor, and would be required to prepare a detailed air quality impact assessment on a project-by -project basis. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions and the proposed GHG Reduction Strategy to further ensure protection of air quality.
Overall, because Alternative B would result in increased infill opportunities and would be expected to decrease the number and length of driving trips, impacts related to air quality would be less under Alternative B when compared to the proposed project.
5.4.2.3 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-25
BIOLOGICAL RESOURCES
As described in Chapter 4.4, Biological Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to biological resources with implementation of proposed General Plan 2050 *Action 3.5-7, *Action 3-5.10, *Action 3-5.11, *Action 3-5.12, *Action 3-5.13, *Action 3-5.19, and *Action 3-5.20.
The EIR Study Area is not within any local, regional, or State Habitat Conservation Plan areas. Therefore, neither the proposed project nor Alternative B would conflict with the conservation strategy in any Habitat Conservation Plan or Natural Community Conservation Plan. The City of Santa Rosa General Plan is the overriding planning document for the City of Santa Rosa and would therefore not conflict with local policies and ordinances protecting biological resources.
Like the proposed project, the same federal, state, and local regulations related to biological resources would apply under Alternative B. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further ensure protection of biological resources. However, Alternative B allows for more dense infill development potential, reducing the potential for disturbance of undeveloped lands and biological resources compared to the proposed project.
Therefore, while development would be more intensive in some land use designations under Alternative B, development would be concentrated in infill urban areas, and impacts related to biological resources would be
less under Alternative B when compared to the proposed project.
CULTURAL RESOURCES
As described in Chapter 4.5, Cultural Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to cultural resources with implementation of proposed General Plan 2050 *Action 3-5.19, *Action 3-5.20, *Action 4-2.1, *Action 4-2.2, *Action 4-2.3, *Action 4-2.4, *Action 4-3.2, *Action 4-3.6, *Action 4-3.7, and *Action 4-3.9.
The EIR Study Area contains existing prehistoric, architectural, historical, or archaeological resources that could be impacted by new demolition, inappropriate modification, or inappropriate new construction under the proposed project or Alternative B. Like the proposed project, potential future development under Alternative B would be subject to the regulations of the SRCC for historic and cultural preservation and the Historic Combining District. Santa Rosa Design Guidelines would also apply to all historic structures and neighborhoods that have been adopted by the city. While no parcels designated as Medium Low density that are within a Historic District would be redesignated to Medium High density, due to the age of the existing buildings, there would be a greater potential for properties to qualify as historic or for historic districts to become established over the 2050 buildout horizon. Accordingly, there is the potential to cause greater impacts to historic resources.
In the event of the discovery of human remains, procedures of conduct mandated by Health and Safety Code Section 7050.5, PRC Section 5097.98, and 14 CCR Section 15064.5(e) would be adhered to. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals,
5.4.2.4 5.4.2.5
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
5-26 OCTOBER 2024
policies, and actions to further ensure protection of cultural resources. However, Alternative B allows for more dense infill development potential, reducing the potential for disturbance of undeveloped lands and archaeological resources compared to the proposed project.
Therefore, because development would be more intensive where historic buildings may be identified in the future under Alternative B, impacts related to cultural resources overall would be greater under Alternative B when compared to the proposed project.
ENERGY
As described in Chapter 4.6, Energy, of this Draft EIR, the proposed project would not result in any significant impacts related to energy.
All development that occurs in the State is required to comply with best management practices regulated in the California Green Building Code and Building and Energy Efficiency Standards, which ensure new development would not result in the wasteful or inefficient use of energy. Additionally, neither the proposed project nor Alternative B would introduce a level of development and population growth that would be anticipated to necessitate the construction of new energy supply facilities or transmission infrastructure.
The same amount of development would occur under Alternative B, so energy consumption from construction would be similar when compared to the proposed project. Energy use from building electricity and natural gas would also be similar under Alternative B. However, energy use from transportation would be less under Alternative B because there would be greater density in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities to reduce VMT.
As the standard of significance for energy impact is focused on efficiency and not on amount, it is assumed that the net benefits from more compact development, in addition to the proposed General Plan 2050 goals, policies, and actions and the proposed GHG Reduction Strategy, would result in more efficient and less wasteful energy use when compared to the proposed project. Therefore, impacts related to energy would be less under Alternative B when compared to the proposed project.
GEOLOGY AND SOILS
As described in Chapter 4.7, Geology and Soils, of this Draft EIR, the proposed project would result in less- than-significant impacts related to geology and soils with implementation of proposed General Plan 2050 *Policy 5-1.1, *Action 5-1.1, and *Action 5-1.2.
Potential future development under both the proposed project and Alternative B would be subject to the same the SRCC regulations, including the requirement for any project within a State Geologist-delineated earthquake fault zone to obtain specialized approval, compliance with the California Building Code and hillside development standards, and implementation of grading, erosion, and sediment control. Potential future development under both scenarios would also be required to comply with the federal Paleontological Resources Preservation Act that limits the collection of vertebrate fossils and other rare
5.4.2.6 5.4.2.7
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ALTERNATIVES TO THE PROPOSED PROJECT
PLACEWORKS 5-27
and scientifically significant fossils to qualified researchers who have obtained a permit from the appropriate state or federal agency and the PRC Section 5097 that prohibits the removal of any paleontological site or feature from public lands without the permission of the jurisdictional agency.
Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further minimize geologic hazards.
Since the same development potential would occur under Alternative B as the proposed project and the same regulations would apply, impacts related to geology and soils would be similar under Alternative B when compared to the proposed project.
GREENHOUSE GAS EMISSIONS
As described in Chapter 4.8, Greenhouse Gas Emissions, of this Draft EIR, the proposed project would result in less-than-significant impacts related to GHG emissions and consistency with applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.
Potential future development under both the proposed project and Alternative B would experience emission reductions from implementation of State measures and strategies to reduce Statewide GHG emissions. The GHG emissions from new buildings constructed would be subject to the triennial updates to California’s Building and Energy Efficiency Standards, which would presumably improve over time and thereby result in more energy efficient buildings. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions and the proposed GHG Reduction Strategy to further reduce GHG emissions.
The same amount of development would occur under Alternative B so GHG emissions from building electricity and natural gas would also be similar when compared to the proposed project. However, Alternative B but would allow for greater density in infill urban areas in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities to reduce VMT, so GHG emissions from energy consumption during construction and from transportation would be less when compared to the proposed project.
In summary, overall impacts from GHG emissions would be less under Alternative B when compared to the proposed project because there would be greater density in infill urban areas in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities, and the net benefits of the proposed General Plan 2050 goals, policies, and actions and the proposed GHG Reduction Strategy that improve energy efficiency and reduce VMT would be realized.
HAZARDS AND HAZARDOUS MATERIALS
As described in Chapter 4.9, Hazards and Hazardous Materials, of this Draft EIR, the proposed project would result in less-than-significant impacts related to hazards and hazardous materials. With respect to impacts related to TACs during construction and operation, which could occur within 0.25 miles of a school, the implementation of proposed General Plan 2050 *Action 6-1.5 and *Action 6-1.6 were found to be less than significant as discussed in Chapter 4.3, Air Quality, of this Draft EIR.
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The Charles M. Schulz Sonoma County Airport AIA is located northwest of, but greater than two miles outside of, the EIR Study Area. Therefore, neither the proposed project nor Alternative B would result in a safety hazard or excessive noise for people residing or working in an area within an airport land use plan.
Potential future development within the EIR Study Area under both scenarios would involve the routine use, transport, and handing of hazardous materials throughout the city, and could occur on properties that possibly are contaminated and inactive, undergoing evaluation, and/or undergoing corrective action.
A total of 596 hazardous materials sites are listed on databases complied pursuant to Government Code Section 65962.5, 103 of which are designated as active; the remaining 493 sites are designated as “closed” or “completed–case closed.” Potential future development under both the proposed project and Alternative B would be required to comply with all federal, State, regional, and local regulations regarding the safe handling, transport, disposal, and use of hazardous materials, as well as those regarding emergency response and evacuation to minimize impacts. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further minimize hazards.
Since the same development potential would occur under Alternative B as the proposed project and the same regulations would apply, impacts related to hazards and hazardous materials would be similar under Alternative B when compared to the proposed project.
HYDROLOGY AND WATER QUALITY
As described in Chapter 4.10, Hydrology and Water Quality, of this Draft EIR, the proposed project would not result in any significant impacts related to hydrology and water quality with implementation of proposed General Plan 2050 *Action 3-5.10, *Action 3-5.12, Action 3-5.19, *Action 3-5.20, *Action 5-
2.14, *Action 5-2.15, *Action 5-2.17, and *Action 5-9.30.
Like the proposed project, potential future development under Alternative B would likely occur within previously urbanized areas, connect to existing drainage systems, and be subject to the same existing federal, state, and local regulations relating to hydrology and water quality to ensure that pre- and post- construction impacts to water quality are minimized. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further protect hydrology and water quality.
Since the same development potential would occur under Alternative B as the proposed project and the same regulations would apply, impacts related to hydrology and water quality would be similar under Alternative B when compared to the proposed project.
LAND USE AND PLANNING
As described in Chapter 4.11, Land Use and Planning, of this Draft EIR, the proposed project would not result in any significant impacts related to land use and planning.
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Like the proposed project, Alternative B would maintain the existing roadway patterns and would not include any new major roadways or other physical features through existing neighborhoods that would create new physical barriers in the EIR Study Area.
Under Alternative B, development would occur throughout the EIR Study Area under the proposed General Plan 2050. Such development, but with more dense infill development potential, would be the same as under the proposed project and therefore implementation of either scenario would not conflict with any applicable land use plan adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, impacts related to land use and planning would be similar under Alterative B when
compared to the proposed project.
NOISE
As described in Chapter 4.12, Noise, of this Draft EIR, the proposed project would result in less-than- significant impacts with respect to land use compatibility, vibration (operation and construction), with implementation of proposed General Plan 2050 *Action 5-7.1, Action 5-7.2, *Action 5-7.3, *Action 5-7.9, and *Action 5-7.10. Significant and unavoidable impacts related to exposure of noise-sensitive receptors to excessive construction noise and operational vehicle traffic noise, despite implementation of the proposed mitigating General Plan 2050 actions previously listed plus *Action 5-7.7. These significant and unavoidable impacts are only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
The city boundaries lie outside the 55 dBA CNEL/Ldn contour line of the Charles M. Schulz-Sonoma County Airport located more than two miles northwest of the city. Therefore, neither the proposed project nor Alternative B would expose people residing or working within two miles of a private airstrip or airport to excessive noise levels.
Future development allowed under both the proposed project and Alternative B would be subject to the standards of the SRCC. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further minimize noise impacts.
However, Alternative B would result in increased infill opportunities but would not increase overall development potential, which would result in the same construction but less VMT. Because construction is temporary, the reduced VMT from Alterative B would result in less vehicular noise from the operational phase of potential future development. Therefore, impacts related to noise would be less under
Alternative B when compared to the proposed project.
POPULATION AND HOUSING
As described in Chapter 4.13, Population and Housing, of this Draft EIR, the proposed project would not result in any significant impacts related to population and housing.
The proposed General Plan 2050 is the policy document that plans ahead to accommodate the amount of reasonably foreseeable growth given past growth trends and the ability of existing services and infrastructure to support future growth. Therefore, the proposed project would not directly induce
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growth, but rather is a response to growth that is likely to occur whether the proposed project is adopted or not. The projected growth under the proposed project accounts for future RHNA cycles.
Alternative B would result in the same population, housing, and jobs as the proposed project; thus, the regional projections would be the same as the proposed project. Alternative B would also include the updated policy framework of the proposed project, which ensures adequate planning occurs to accommodate the future population increase and future development. Therefore, impacts related to population and housing would be
similar under Alternative B when compared to the proposed project.
PUBLIC SERVICES AND RECREATION
As described in Chapter 4.14, Public Services and Recreation, of this Draft EIR, impacts under the proposed project to fire protection services, police services, parks, schools, and libraries were found to be less than significant.
Alternative B would result in the same amount of growth in residents and jobs in the EIR Study Area as the proposed project, and therefore, would result in the same demand on the public service providers that serve the EIR Study Area. Potential future development under Alternative B would be required to comply with all existing City regulations adopted to ensure that development pays its fair share of the cost of delivering services, providing park space and libraries, while payment of property taxes would ensure that future development pays its fair share towards schools. Overall, due to the same level of growth, impacts related to public services and recreation would be
similar under Alternative B when compared to the
proposed project.
TRANSPORTATION
As described in Chapter 4.15, Transportation, of this Draft EIR, the proposed project would result in significant and unavoidable impacts related to VMT generation of the proposed project exceeding the City’s thresholds, despite implementation of proposed General Plan 2050 *Action 3-1.1. This significant and unavoidable impact is only related to the programmatic nature of the proposed project that precludes the availability of mitigation measures at the project level.
Any potential new transportation facilities built under both the proposed project and Alternative B, whether constructed as part of private developments or by agencies, including the City of Santa Rosa, to improve circulation consistent with City plans, would be designed and constructed to local, regional, and federal standards. These include, but are not limited to, the California Manual on Uniform Traffic Control Devices, the Caltrans Highway Design Manual, and the City of Santa Rosa’s Street Design and Construction Standards, all of which have been developed to minimize the potential for safety conflicts and hazards.
Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further promote safe and efficient paths of travel and active and public transportation.
Like the proposed project, potential future development in the EIR Study Area under Alternative B is anticipated to occur in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, generation of VMT would be lower than
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if development were proposed in areas not served by public transportation and a network of sidewalks and bicycle facilities. However, Alternative B would allow for greater density in Areas of Change that are in or adjacent to PDAs and/or TPAs that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities to reduce VMT.
While Alternative B would result in the same level of development as the proposed project, potential future development under Alternative B would be more compact with greater infill intensity, likely resulting in less VMT. Therefore, impacts related to transportation would be less under Alternative B when compared to the proposed project.
TRIBAL CULTURAL RESOURCES
As described in Chapter 4.16, Tribal Cultural Resources, of this Draft EIR, the proposed project would result in less-than-significant impacts to TCRs with implementation of proposed General Plan 2050 *Action 3-5.19, *Action 3-5.20, *Action 4-2.1, *Action 4-2.2, and *Action 4-2.4. Note, as discussed in Chapter 4.5, Cultural Resources, that *Action 4-2.3 would reduce impacts to archeological resources, which could be identified as TCRs, to less-than-significant levels.
The EIR Study Area does not contain any known TCRs, however, there is the potential for TCRs to be identified as part of project-specific development over the course of the implementation of the proposed project. Like the proposed project, potential future development under Alternative A would be subject to the federal and state laws regarding TCRs. In the event of the discovery of human remains, procedures of conduct mandated by Health and Safety Code Section 7050.5, PRC Section 5097.98, and 14 CCR Section 15064.5(e) would be adhered to. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further ensure protection of TCRs.
However, Alternative B allows for more dense infill development potential, reducing the potential for disturbance of undeveloped lands and archaeological resources compared to the proposed project.
Therefore, while development would be more intensive in some land use designations under Alternative B, development would be concentrated in infill urban areas, and impacts related to TCRs would be less
under Alternative B when compared to the proposed project.
UTILITIES AND SERVICE SYSTEMS
As described in Chapter 4.17, Utilities and Service Systems, of this Draft EIR, impacts to water, wastewater, stormwater, solid waste, and energy infrastructure under the proposed project, were found to be less than significant with the compliance of all applicable regulations.
Like the proposed project, potential future development under Alternative B would be required to comply with all existing federal, state, and local regulations. Demand and consumption trends generally demonstrate that advances in water-efficient regulations in building and landscaping, stricter stormwater retention requirements and recycling and solid waste reduction requirements would reduce impacts from existing conditions. Because Alternative B would result in the same number of residents and jobs in the EIR Study Area compared to the proposed project, demand on the utilities infrastructures that serve the EIR Study Area would be similar when compared to the proposed project. Overall, impacts related to
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utilities and service systems would be similar under Alternative B when compared to the proposed project.
WILDFIRE
As described in Chapter 4.18, Wildfire, of this Draft EIR, the proposed project would result in less-than- significant impacts related to evacuation with implementation of proposed General Plan 2050 *Action 5-
5.14, *Action 5-5.15, *Action 5-5.16, and *Action 5-5.17. However, even with implementation of proposed General Plan 2050 *Action 5-3.8, the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks and resulting in impacts that are significant and unavoidable.
Like the proposed project, potential future development under Alternative B would be required to integrate applicable emergency operation and evacuation requirements as necessary into development to facilitate evacuation for people in wildfire-prone areas. Potential future development, regardless of whether it includes new development or redevelopment, would also be required to comply with adopted local, regional, and State plans and regulations addressing emergency access, response, and evacuation and wildfire hazards. Future development in the WUIFA or Very High FHSZ would be required to comply with the Very High FHSZ Fire Safe Regulations, the CBC, the CFC, and the SRCC, which have emergency access, building fire safety, and perimeter wildfire protection measures. Potential future development under Alterative B would also be subject to the proposed General Plan 2050 goals, policies, and actions to further minimize wildfire hazards.
While the same development potential would occur under Alternative B as the proposed project and the same regulations would apply, Alternative B would provide greater opportunities for infill development that is not in the Very High Fire Hazard Severity Zone and/or the Wildland-Urban Interface Fire Area..
Therefore, impacts related to wildfire would be less under Alternative B when compared to the proposed project.
5.4.3 RELATIONSHIP OF THE ALTERNATIVES TO THE OBJECTIVES The primary purpose of the proposed project is to plan for the growth and conservation of Santa Rosa over a 25-year time horizon and to achieve a more equitable, sustainable, and prosperous future for all residents. This requires extending the buildout horizon to year 2050 and updating goals, policies, and actions so that they meet current State requirements and community priorities on the framework of the Santa Rosa Vision and reflect the community’s desires for the future of Santa Rosa. Because Alternative B would increase opportunities for infill development to support the reduction of VMT and GHG emissions and reduce the amount of qualifying agricultural lands that could be converted to non-agricultural uses, Alternative B would generally meet the project objectives but not to the same degree as the proposed project. For example, Alternative B would eliminate any Medium Low density residential (8.0-13.0 units per gross acre) in the Marlow Center and Lance Drive Annexation (#4), Downtown Station Area (#7), and Hearn Corridor (#17) Areas of Change. Therefore, it would not provide the same range of housing types to meet the needs of all Santa Rosa residents as the proposed project. The additional housing opportunities in these three Areas of Change would have the potential to put more housing where there are known, but mitigable, environmental hazards when compared to the proposed project. Lastly, because these Areas of
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Change have older buildings, there is a greater potential for sites to be identified as historic buildings and districts over the 2050 buildout horizon, and therefore, this alternative would not preserve historic and cultural resources as the city develops and becomes denser, at the same level as the proposed project.
Therefore, although this alternative would further some of the objectives of the proposed project, it would do so less than would the proposed project.
5.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
In addition to the discussion and comparison of impacts of the proposed project and the alternatives, Section 15126.6 of the CEQA Guidelines requires that an “environmentally superior” alternative be selected and the reasons for such a selection be disclosed. In general, the environmentally superior alternative is the alternative to the proposed project that would be expected to generate the least number of significant impacts. Identification of the environmentally superior alternative is an informational procedure and the alternative to the proposed project selected may not be the alternative to the proposed project that best meets the goals or needs of Santa Rosa. Because CEQA Guidelines Section 15126.6(c) requires an evaluation of a reasonable range of alternatives to the proposed project, the proposed project under consideration cannot be identified as the environmentally superior alternative. Additionally, in accordance with CEQA Guidelines Section 15126.6(e)(2), if the environmentally superior alternative is the “No Project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.
As shown in Table 5-2 and Table -5-3, Alternative B would, in comparison to the proposed project, result in greater impacts to cultural resources and reduced environmental impacts related to agricultural resources, air quality, biological resources, energy, GHG emissions, noise, transportation, TCRs, and wildfire. Therefore, as shown in Table 5-2 and Table 5-3, Alternative B would be the environmentally superior alternative.
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PLACEWORKS 6-1
CEQA-Required Conclusions
This chapter provides an overview of the impacts of the proposed project based on the analyses presented in Chapter 4.0, Environmental Analysis, and its subchapters 4.1 through 4.18, of this Draft Environmental Impact Report (EIR). The topics covered in this chapter include impacts found not to be significant, growth-inducing impacts, and significant irreversible changes to the environment. For a more detailed analysis of the proposed project’s environmental effects and the proposed General Plan 2050 mitigating policies and actions to minimize significant impacts, see Chapter 4.0 and its subchapters 4.1 through 4.18, of this Draft EIR.
6.1 IMPACTS FOUND NOT TO BE SIGNIFICANT
California Environmental Quality Act (CEQA) Guidelines Section 15128, Effects Not Found to Be Significant, allows environmental issues to be “scoped out” if there is no likelihood of a significant impact, and they do not need to be analyzed further in the EIR. This section explains the reasoning for the determination that the proposed project would have no effect within an entire environmental topic or under specific criteria within an environmental topic. As shown below, there would be no impacts to mineral resources as a whole pursuant to the CEQA standards; therefore, this topic is not evaluated in Chapter 4.0, Environmental Analysis, of this Draft EIR. Furthermore, there would be no impacts to some of the criteria for forestry resources. These specific criteria are identified in the corresponding subsection of this chapter and are not required to be evaluated in this EIR.
6.1.1 FORESTRY RESOURCES
The following standards of significance are not evaluated in this EIR:
Conflict with existing zoning for, or cause rezoning of, forestland (as defined in 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)). Involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use.
This EIR does not analyze impacts to forestry resources because the Santa Rosa City Code (SRCC) does not contain a zoning district for forest land or timberland production. Further, there are no State or national forest lands in the EIR Study Area. Consequently, the proposed project would not result in any impacts to forestry resources, and this topic is not discussed further in this EIR.
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6.1.2 MINERAL RESOURCES
The following standards of significances are not evaluated in this EIR:
Result in the loss of availability of a known mineral resource that would be a 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.
According to the California Geological Survey, Department of Conservation, there are no known significant mineral resources within the EIR Study Area.1 Furthermore, there are no active/permitted mining or designated land in the City. As such, these standards have been screened out from further evaluation.
Consequently, there would be no impacts to mineral resources as a result of adoption and implementation of the proposed project.
6.2 SIGNIFICANT AND UNAVOIDABLE IMPACTS
Section 15126.2(b) of the CEQA Guidelines requires that “direct and indirect significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short- and long-term effects.”
Chapter 2, Executive Summary, of this Draft EIR contains Table 2-1, Summary of Significant Impacts and Mitigating Policies and Actions, which summarizes the significant impacts, mitigating proposed General Plan 2050 policies and actions, and levels of significance with and without mitigating policies and actions. While mitigating General Plan 2050 policies and actions would reduce the level of impact, the following impacts would remain significant and unavoidable after mitigating policies and actions are applied. The identification of these program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level that do not exceed the thresholds of significance. As detailed in Chapter 4.2, Agricultural Resources, Chapter 4.3, Air Quality, Chapter 4.4, Biological Resources, Chapter 4.12, Noise, Chapter 4.15, Transportation, and Chapter 4.18, Wildfire, of this Draft EIR, environmental impacts associated with the proposed project were found to be significant and unavoidable, as listed:
Agricultural Resources
Impact AG-1: Implementation of the proposed project could result in the conversion of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland land (together referred to as “CEQA Important Farmland”) to non-agricultural land uses. Impact AG-2: Implementation of the proposed project could result in the loss of agricultural land under the Williamson Act.
1 California Geological Survey, Department of Conservation, 2013, Special Report 205: Update of Mineral Land Classification:
Aggregate Materials in the North San Francisco Bay Production-Consumption Region, Sonoma, Napa, Marin, and Southwestern Solano Counties, California, accessed April 13, 202, https://maps.conservation.ca.gov/mineralresources/3.
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Impact AG-4: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in a significant cumulative impact with respect to the conversion of CEQA Important Farmland (Prime Farmland, Farmland of Statewide Importance, and Unique Farmland) and Williamson Act properties to non-agricultural uses. Air Quality
Impact AIR-2b: Buildout of the proposed project could generate operational emissions that could exceed the Bay Area Air Quality Management District’s (BAAQMD) regional significance thresholds for reactive organic compounds (ROG), nitrogen oxides (NOX) and particulate matter (PM2.5 and PM10).
Impact AIR-3b: Large industrial or warehouse development projects under the proposed project could expose air quality-sensitive receptors to substantial toxic air contaminants (TAC) and particulate matter (PM2.5) concentrations and exceed the Bay Area Air Quality Management District’s (BAAQMD) project-level and cumulative significance thresholds. Impact AIR-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in cumulative air quality impacts with respect to generation of criteria pollutant and exposure of substantial pollutant concentrations to sensitive receptors.
Noise
Impact NOI-1a: Construction activities associated with potential future development could expose sensitive receptors to excessive noise from construction equipment. Impact NOI-1b: Operational vehicle traffic noise increases could exceed the City’s significance thresholds with implementation of the proposed project. Impact NOI-4: Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, could result in cumulative noise impacts, with respect to generation of construction-and transportation related noise. Transportation
Impact TRAN-2a: Implementation of the proposed project could result in a significant vehicle miles traveled (VMT) impact for residential VMT per capita. Impact TRAN-2b: Implementation of the proposed project could result in a significant roadway network vehicle miles traveled (VMT) impact associated with increasing the capacity of the arterial street network.
Impact TRAN-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, could result in significant cumulative impact with respect to vehicle miles traveled (VMT).
Wildfire
Impact WF-2: Potential future development over the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.
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Impact WF-5: Potential development over the buildout horizon of the proposed project could, in combination with other surrounding and future projects in the State Responsibility Areas (SRA), Very High Fire Hazard Severity Zones (FHSZ), or Wildland-Urban Interface Fire Areas (WUIFA), result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
6.3 GROWTH INDUCEMENT
Section 15126.2(d) of the CEQA Guidelines requires that an EIR discuss the ways in which a proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Typical growth-inducing factors might be the extension of urban services or transportation infrastructure to a previously unserved or under-served area, or the removal of major barriers to development.
This section evaluates the proposed project’s potential to create such growth inducements. As CEQA Guidelines Section 15126.2(d) requires, “[it] must not be assumed that growth in an area is necessarily beneficial, detrimental, or of little significance to the environment.” In other words, negative impacts associated with growth inducement occur only where the projected growth would cause significant adverse environmental impacts.
Growth-inducing impacts fall into two general categories: direct or indirect. Direct growth-inducing impacts are generally associated with providing urban services to an undeveloped area. Indirect, or secondary growth-inducing impacts consist of growth induced in the region by additional demands for housing, goods, and services associated with the population increase caused by, or attracted to, a new project.
As discussed in detail in Chapter 4.13, Population and Housing, of this Draft EIR, the General Plan is the policy document that plans ahead to accommodate the amount of reasonably foreseeable growth given past growth trends and the ability of existing services and infrastructure to support future growth.
Therefore, the proposed General Plan 2050 would not directly induce growth, but rather is a response to growth that is likely to occur whether the proposed project is adopted or not. Because the proposed General Plan 2050 also includes recommendations for future roadway and infrastructure extension, as it is required to do by state law, it has the potential to indirectly induce growth. However, the proposed General Plan 2050 itself is the City’s effort to adequately plan for this growth.
Additionally, this additional growth would likely occur incrementally over a period of approximately 25 years and a policy framework is in place to ensure adequate planning occurs to accommodate it regardless of the development timeline. The proposed project results in mixed-use development and employment centers and implements energy and water conservation requirements related to existing and new development, thereby minimizing consumption of non-renewable resources to the extent practicable.
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6.3.1 DIRECT IMPACTS
The proposed project is a plan-level document and does not propose any specific development; however, implementation of the proposed project would induce growth by increasing the development potential in the EIR Study Area, as shown in Table 3-6, Proposed 2050 Buildout Projections in the EIR Study Area, in Chapter 3, Project Description, of this Draft EIR. As shown in Table 3-6, the 2050 forecast for the EIR Study Area is approximately 263,740 total population, 99,940 housing units, and 91,680 jobs.
State law requires the City to promote the production of housing to meet its fair share of the regional housing needs distribution made by the Association of Bay Area Governments. While the City provides adequate sites to meet its fair-share housing obligations, the additional housing capacity provided by the proposed project would meet the additional demand generated by new job growth.
In addition, the proposed project would result in regional benefits by promoting growth that encourages less automobile dependence, which could have associated air quality and GHG benefits. Encouraging infill growth in designated areas would help to reduce development pressures on lands outside the City Limits.
6.3.2 INDIRECT IMPACTS
The proposed project could be considered growth inducing because it includes policies and actions that encourage new growth in the urbanized areas of Santa Rosa. Development in these areas would consist of infill development on underutilized sites, sites that have been previously developed, and that are vacant and have been determined to be suitable for development. However, infrastructure is largely in place, and growth would be required to comply with the City’s General Plan, zoning regulations, and standards for public services and utilities; secondary effects associated with this growth do not represent a new significant environmental impact that has not already been addressed in the individual resource chapters of this EIR. Additional population and employment growth would likely occur incrementally over a period of approximately 25 years and would be consistent with the regional planning objectives established for the Sonoma County region.
6.4 SIGNIFICANT AND IRREVERSIBLE CHANGES
Section 15126.2(c) of the CEQA Guidelines requires an EIR to discuss the extent to which the proposed project would commit nonrenewable resources to uses that future generations would probably be unable to reverse. The three CEQA-required categories of irreversible changes are discussed herein.
6.4.1 CHANGES IN LAND USE THAT COMMIT FUTURE
GENERATIONS
As described in detail in Chapter 3, Project Description, of this Draft EIR, the proposed project maintains the land use pattern of the existing General Plan. Development is encouraged in existing urban areas, and new development is required to be contiguous with the existing City Limits. The current General Plan 2035 provided development allocations for buildout of the city through the year 2035. Some future SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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development under the proposed project would be on land that is generally urbanized or on infill sites and sites in developed areas that are underutilized. However, some potential future development may occur on vacant non-urban sites that are already designated for development. Once future development under the proposed project occurs, it would not be feasible to return the developed land to its existing (pre-project) condition. Therefore, there is potential that some of the development allowed under the proposed project would lead to irreversible changes in land use.
6.4.2 IRREVERSIBLE DAMAGE FROM ENVIRONMENTAL
ACCIDENTS
Irreversible changes to the physical environment could occur from accidental release of hazardous materials associated with development activities; however, compliance with the applicable regulations and proposed General Plan 2050 goals, policies, and actions as discussed in Chapter 4.9, Hazards and Hazardous Materials, of this Draft EIR would ensure these impacts would be less than significant.
Therefore, irreversible damage is not expected to result from the adoption and implementation of the proposed project.
6.4.3 LARGE COMMITMENT OF NONRENEWABLE RESOURCES
Future development allowed under the proposed project would result in the commitment of limited, renewable resources, such as lumber and water . In addition, development under the proposed project would irretrievably commit nonrenewable resources for the construction of buildings, infrastructure, and roadway improvements. These nonrenewable resources include mined minerals, such as sand, gravel, steel, lead, copper, and other metals. Future buildout under implementation of the proposed project also represents a long-term commitment to the consumption of fossil fuels such as natural gas and gasoline.
Increased energy demands would be used for construction, lighting, heating, and cooling of residences, and transportation of people within, to, and from Santa Rosa. However , as shown in Chapter 4.6, Energy, and in Section 4.17.1, Water, and Section 4.17.4, Solid Waste, of Chapter 4.17, Utilities and Service Systems, of this Draft EIR, several regulatory measures and proposed General Plan 2050 goals, policies, and actions encourage energy and water conservation, alternative energy use, waste reduction, alternatives to automotive transportation, and green building. Future development under the proposed project would be required to comply with all applicable building and design requirements, including those set forth in Title 24 relating to energy conservation. In compliance with CALGreen, the State’s Green Building Standards Code, future development would be required to reduce water consumption by 20 percent, divert 50 percent of construction waste from landfills, and install low pollutant-emitting materials. Therefore, while the construction and operation of future development, as a result of increased development allocations under the proposed project, would involve the use of nonrenewable resources, compliance with applicable standards and regulations and implementation of proposed General Plan 2050 goals, policies, and actions would reduce the use of nonrenewable resources to the maximum extent practicable; therefore, the proposed project would not represent a large commitment of nonrenewable resources in comparison to a business-as-usual situation.
PLACEWORKS 7-1
Organizations and Persons Consulted
This Draft Environmental Impact Report (EIR) was prepared by the contributors listed herein and includes content and information provided by individuals with the lead agency, other agencies, service providers, consultants, and other contributors.
7.1 LEAD AGENCY
City of Santa Rosa
Gabe Osburn .......................................................................... Planning and Economic Development Director Jessica Jones ........................................................................................................... Deputy Director - Planning Amy Nicholson.................................................................................... Supervising Planner – Advance Planning Amy Lyle .............................................................................. (former) Supervising Planner – Advance Planning Jimmy Bliss ....................................................................................................................... Chief Building Official Jesse Oswald...................................................................................................... (former) Chief Building Official Cleve Gurney ....................................................................................... Deputy Director, Development Services Michael Enright ................................................................................................................ Supervising Engineer Flannery Banks ...................................................................................................... Acting Supervising Engineer Rafael Rivero ....................................................................................................................... Program Specialist II Nancy Woltering .......................................................................................................................... Senior Planner Shari Meads .................................................................................................................. (former) Senior Planner Beatriz Guerrero Auna ................................................................................................. (former) Senior Planner Ashle Crocker .................................................................................................................. Assistant City Attorney Molly Maclean ................................................................................................................ Assistant City Attorney Scott Moon .............................................................................................................. Division Chief, Fire Marshal Scott Westrope ................................................................................................................................... Fire Chief Tony Gossner ........................................................................................................................ (former) Fire Chief Paul Lowenthal ....................................................................................................... Division Chief/Fire Marshall John Cregan ...................................................................................................................................... Police Chief Ryan Corcoran, ............................................................................................................................ Police Captain Rainer (Ray) Navarro ......................................................................................................... (former) Police Chief Jill Scott .......................................................................................................................... Real Property Manager Dina Manis ........................................................................................................................................... City Clerk Neil Bregman ............................................................................................. Emergency Preparedness Manager Alan Alton ........................................................................................................................ Chief Financial Officer Lon Peterson .................................................. Chief Communication and Intergovernmental Relations Officer Scott Alonso..................................................................... Intergovernmental Relations and Legislation Officer
7. SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ORGANIZATIONS AND PERSONS CONSULTED
7-2 OCTOBER 2024
Donte Watson ............................................................................... Director, Recreation and Parks Department Jen Santos ............................................................................................................... Recreation Deputy Director Jeff Tibbetts ............................................................................................................ Deputy Director Recreation Scott Wilkinson ............................................................................................................................. Parks Planner Terri Bladow ............................................................................. Recreation Department Research and Program Emily Anders .................................................................................................................. Assistant Parks Planner Cameron Freedman .................................................................................................... Office and Program Aide Danielle Garduno ................................................................................ Program Manager, Violence Prevention Daryel Dunston .............................................................................................................. Assistant City Manager Jason Nutt ...................................................................................................................... Assistant City Manager Dan Hennessey ................................................................................ Director, Transportation and Public Works Nancy Adams ...................................................................................................(former) Transportation Planner Torina Wilson ................................................................................................................. Transportation Planner Rachel Ede .................................................................................................................... Deputy Director, Transit Rob Sprinkle...................................................................................................... Transportation Deputy Director Yuri Koslen ........................................................................................................ Transportation Deputy Director Doug Williams ....................................... Transportation Department Facilities and Maintenance Coordinator Jennifer Burke ................................................................................ Director, Water and Engineering Resources Peter Martin ................................................................................................ Deputy Director, Water Resources Mike Prinz ........................................................................ Deputy Director, Regional Water Reuse Operations Sean McNeil .................................................................................. Deputy Director of Environmental Services Heather Johnson ........................................................................................................... Environmental Services Lori Urbanek ..................................................................................... Deputy Director – Engineering Resources Claire Nordlie .................................................................................................. Senior Water Resources Planner Claire Myers ................................................................................................. Storm Water and Creeks Manager Nick Sudano ..................................................................................................... Senior Environmental Specialist Steve Brady ...................................................................................................... Senior Environmental Specialist Alicia Quilici ............................................................................................... Research and Program Coordinator Lisa Cuellar ............................................................................................................... Sustainability Coordinator Madee Brandt ...................................................................................................... Sustainability Representative Andrew Allen .................................................................................... Supervising Engineer, Water Department Caryn Lozada ............................. Bureau Veritas Contractor (PED), former Development Review Coordinator Colin Close ........................................................................................ (former) Senior Water Resources Planner Emma Walton ................................................................................... Deputy Directory, Engineering Resources Megan Basinger ............................................................................. Director, Housing and Community Services Nicole Del Fiorentino .................................................................... Housing and Community Services Manager Renae Gunde ......................................................................................... Environmental Compliance Inspector Brian Tickner .............................................................................................................. Chief Information Officer Matt Stull ................................................................................................................................... GIS Coordinator Mike Hargreaves ............................................................................................................................... GIS Analyst SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ORGANIZATIONS AND PERSONS CONSULTED
PLACEWORKS 7-3
7.2 ORGANIZATIONS CONSULTED
Sonoma County Regional Parks
Melanie Parker ......................................................................................................................... Deputy Director Sonoma County Library
Ray Holley ......................................................................................................... Community Relations Manager Roseland School District
Amy Jones-Kerr .......................................................................................................................... Superintendent Santa Rosa City Schools District
Dr . Diann Kitamura .................................................................................................................... Superintendent Rick Edson ................................................................................... Assistant Superintendent, Business Services Lori Kolacek .................................................................................................. Chief Assistant to Superintendent
7.3 CONSULTANTS
PlaceWorks: Environmental Prime Consultant
Charlie Knox .................................................................................... Principal, General Plan Principal-in-Charge Andrea Howard ..................................................................... Senior Associate, General Plan Project Manager Terri McCracken ............................................................................................ Principal, EIR Principal-In-Charge Vivian Kha ......................................................................................................... Associate, EIR Project Manager Nicole Vermillion ............................................................ Principal, Air Quality and Greenhouse Gas Emissions Emily Parks ................................................................... Associate, Air Quality and Greenhouse Gas Emissions Cathy Fitzgerald ........................... Principal Engineer, Hydrology, Water Quality, Utilities and Service Systems Steve Bush ...................................... Senior Engineer, Hydrology, Water Quality, Utilities and Service Systems Tammy Seale............................................................................. Principal, Climate Action & Resiliency Services Eli Krispi ....................................................................... Senior Associate, Climate Action & Resiliency Services Jacqueline Protsman Rohr ........................................... Senior Associate, Climate Action & Resiliency Services Rob Mazur ....................................................................................................................................... GIS Director Rachel Goren .................................................................................................................... Associate, EIR Author Madeline Miller ....................................................................................................... Project Planner, EIR Author Grant Reddy……. ................................................................................................... …Graphic Designer, Graphics Environmental Collaborative: Biological Resources
James Martin ........................................................................................................................................ Principal SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ORGANIZATIONS AND PERSONS CONSULTED
7-4 OCTOBER 2024
Tom Origer and Associates: Cultural and Tribal Cultural Resources Eileen Barrow ........................................................................................................................... Senior Associate Illingworth and Rodkin: Noise
Carrie Janello .......................................................................................................................... Senior Consultant W-Trans: Transportation
Zachary Matley ..................................................................................................................................... Principal Barry Bergman............................................................................................................................. Senior Planner Kevin Rangel .......................................................................................................................... Assistant Engineer Julia Walker………………………………………………………………………………………………………………………. Assistant Planner
PLACEWORKS 8-1
Acronyms and Abbreviations
ACRONYM/
ABBREVIATION MEANING
°C degrees Celsius
°F degrees Fahrenheit
AAQS ambient air quality standards
AB Assembly Bill
ABAG Association of Bay Area Government
ACF Advanced Clean Fleets
AFY acre-feet per year
AIA Airport Influence Area
AQMP air quality management plan
AR4 Fourth Assessment Report: Climate Change 2007 (IPCC) BAAQMD Bay Area Air Quality Management District
BES Battery Energy Storage
BMP best management practice
BPMP Bicycle and Pedestrian Master Plan
BTU British thermal unit
BUSD Bellevue Union School District
BVSD Bennett Valley School District
CAA Clean Air Act
CAFE corporate average fuel economy
CAISO California Independent System Operator
CAL FIRE California Department of Forestry and Fire Protection Cal OES California Office of Emergency Services
Cal/OSHA California Division of Occupational Safety and Health CalARP California Accidental Release Prevention
CalEMA California Emergency Management Agency
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards Code
CALGreen California Green Building Standards Code
California Register California Register of Historic Resources CalOES California Governor’s Office of Emergency Services CalRecycle California Department of Resources, Recycling, and Recovery
8. SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
ACRONYMS AND ABBREVIATIONS
8-2 OCTOBER 2024
ACRONYM/
ABBREVIATION MEANING
Caltrans California Department of Transportation
CARB California Air Resources Board
CBC California Building Code
CCAP community climate action plan
Ccf hundreds of cubic feet
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEP Community Empowerment Plan
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System
CES4 CalEnviroScreen v.4
CESA California Endangered Species Act
CFC California Fire Code
CFD Community Facilities District
CFF capital facilities fee
CFGC California Fish and Game Code
CGP Construction General Permit
CH4 methane
CHP California Highway Patrol
CIP Capital Improvements Program
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO carbon monoxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CSC California Species of Concern
CTP Comprehensive Transportation Plan
CTS California tiger salamander
CUPA Certified Unified Program Agency
CWA Clean Water Act
CWPP Sonoma County Community Wildfire Protection Plan
dB Decibel
dBA A-Weighted Decibel
Design Guidelines Santa Rosa Design Guidelines
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ACRONYMS AND ABBREVIATIONS
PLACEWORKS 8-3
ACRONYM/
ABBREVIATION MEANING
DNL or Ldn Day-Night Sound Level
DPM diesel particulate matter
DSOD Division of Safety of Dams (CA)
DTSC Department of Toxic Substances Control
DWR Department of Water Resources (CA)
EAP emergency action plan
EMS Emergency Medical Services
EO Executive Order
EOC emergency operations center
EOP Emergency Operations Plan
EPA Environmental Protection Agency (US)
EPCRA Emergency Planning Community Right-to-Know Act
ESMP Environmental Site Management Plan
ESU evolutionarily significant unit
EV electric vehicle
FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act
FHSZ fire hazard severity zone
FHWA Federal Highway Administration
FMMP Farmland Mapping and Monitoring Program
FMP facilities master plan
FTA Federal Transit Administration
gcpd gallons per capita per day
GHG greenhouse gas
gpm gallons per minute
GSA groundwater sustainability agency
GSP groundwater sustainability plan
GW gigawatts
GWP global warming potential
HazMat Sonoma County Fire and Emergency Services Department Hazardous Materials HMRT Hazardous Materials Response Team
Hz Hertz
IPCC Intergovernmental Panel on Climate Change
IRP Integrated Resource Plan
ISO Insurance Service Office
KSD Kenwood School District
KW kilowatts
kWh Kilowatt-hours
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
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ACRONYMS AND ABBREVIATIONS
8-4 OCTOBER 2024
ACRONYM/
ABBREVIATION MEANING
LAFCO Local Agency Formation Commission
LCFS low-carbon fuel standard
Leq Equivalent Continuous Noise Level
LHMP Local Hazard Mitigation Plan
LID low impact development
Ln Statistical Sound Level
LNU Sonoma-Lake-Napa Unit [CAL FIRE]
LOS level of service
LRA local responsibility area
LSE load-serving entities
LUSTIS Leaking Underground Storage Tank Information System MBTA Migratory Bird Treaty Act
Mcf thousands of cubic feet
MGD million gallons per day
MJHMP Multi-Jurisdictional Hazard Mitigation Plan
MLD Most Likely Descendant
MMT million metric tons
MPG miles per gallon
MPO metropolitan planning organization
MS4 municipal separate storm sewer system
MT metric ton
MTC Metropolitan Transportation Commission
MW megawatts
MWELO Model Water Efficient Landscape Ordinance
N2O nitrous oxide
NAHC Native American Heritage Commission
NAHC Native American Heritage Commission
National Register National Register of Historic Places
NFIP National Flood Insurance Program
NFPA National Fire Protection Association
NOAA National Oceanic and Atmospheric Administration
NOx nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NWPRR Northwest Pacific Railroad
O3 ozone
OD origin-destination
OEHHA Office of Environmental Health Hazard Assessment
OPR Governor’s Office of Planning and Research
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
ACRONYMS AND ABBREVIATIONS
PLACEWORKS 8-5
ACRONYM/
ABBREVIATION MEANING
OSHA Occupational Safety and Health Administration
PBO Programmatic Biological Opinion for U.S. Army Corps of Engineers Permitted Projects That May Affect California Tiger Salamander and Three Endangered Plant Species on the Santa Rosa Plain, California (USFWS) PDA Priority Development Area
PG&E Pacific Gas and Electric Company
PHSMA Pipeline and Hazardous Materials Safety Administration PM particulate matter
POSD Piner-Olivet School District
ppd pounds per day
ppm parts per million
PPV Peak Particle Velocity
PRC Public Resources Code
PRD permit registration documents
RAMS Roseland Accelerated Middle School
RCRA Resource Conservation and Recovery Act
RCRIS Resource Conservation and Recovery Act Information System REF residential equivalency factor
RHNA Regional Housing Needs Allocation
RPS renewable portfolio standard
RSD Roseland School District
RTAC Regional Transportation Advisory Committee
RTP/SCS regional transportation plan / sustainable communities strategy RVUSD Rincon Valley Unified School District
RWQCB Regional Water Quality Control Board
SARA Superfund Amendments and Reauthorization Act
SB Senate Bill
SCFPD Sonoma County Fire Protection District
SCL Sonoma County Library
SCLL Sonoma County Law Library
SCP Sonoma Clean Power
SCS sustainable communities strategy
SCTA Sonoma County Transportation Authority
SCTM Sonoma County Travel Model
SFBAAB San Francisco Bay Area Air Basin
SGMA Sustainable Groundwater Management Act
SMART Sonoma-Marin Area Rail Transit
SMARTS Stormwater Multiple Application and Report Tracking System SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
ACRONYMS AND ABBREVIATIONS
8-6 OCTOBER 2024
ACRONYM/
ABBREVIATION MEANING
SO2 sulfur dioxide
SOI sphere of influence
SR State Route
SRA state responsibility area
SRCC Santa Rosa City Code
SRCSD Santa Rosa City School District
SRFD Santa Rosa Fire Department
SRJC Santa Rosa Junior College
SRPCS Santa Rosa Plain Conservation Strategy
SRPD Santa Rosa Police Department
SSMP sewer system management plan
SSO sanitary sewer overflow
SWLIDS Storm Water Low Impact Development Submittal
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TAZ traffic analysis zone
TCR tribal cultural resource
TDM transportation demand management
TISG Vehicle Miles Traveled–Focused Transportation Impact Study Guide (Caltrans) TMDL total maximum daily load
TPA transit priority area
TRU transport refrigeration unit
UGB urban growth boundary
USACE United States Army Corps of Engineers
USC United States Code
USDOT United States Department of Transportation
USEPA United States Environmental Protection Agency
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
UST underground storage tank
UWMP urban water management plan
VdB vibration decibels
VMT vehicle-miles traveled
VOC volatile organic compound
WARN Water/Wastewater Agency Response Network
WDO water demand offset
WESD Wright Elementary School District
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ACRONYMS AND ABBREVIATIONS
PLACEWORKS 8-7
ACRONYM/
ABBREVIATION MEANING
WMP water master plan
WSA water supply assessment
WUI wildland-urban interface
WUIFA Wildland-Urban Interface Fire Area
WWTP wastewater treatment plant
ZE zero emissions
ZEV zero-emission vehicle
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
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ACRONYMS AND ABBREVIATIONS
8-8 OCTOBER 2024
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(~ Cityof
~ SantaRosa
-;" CALIFORNIA
ORANGE COUNTY • BAY AREA • SACRAMENTO • CENTRAL COAST • LOS ANGELES • INLAND EMPIRE • SAN DIEGO 2040 Bancroft Way, Suite 400
Berkeley, California 94704
t 510.848.3815
www.PlaceWorks.com
~ PLACEWORKS