Agenda-Item-Number-10-Barlow-Hotel-Development-Agreement-Introduction-of-Ordinance-1 — Sebastopol City Council, April 15, 2025 (part 1 of 2)

CITY OF SEBASTOPOL CITY COUNCIL
AGENDA ITEM REPORT FOR MEETING OF: April 15, 2025
=========================================================================================== To: Honorable Mayor and City Councilmembers
From: Jane Riley, Project Planner
Emi Thériault, Community Development Director
Don Schwartz, City Manager
Subject: Introduction and First Reading of Ordinance approving the Barlow Hotel Development Agreement. Applicant has requested a Development Agreement to allow the development and operation of an 83 room hotel, to be named the Barlow Hotel, at 6782 Sebastopol Avenue. The hotel would replace the existing 36,402 square foot Guayaki Yerba Mate building at this site and would make use of the “batch plant” lot at 385 Morris Street for overflow and valet parking. No further environmental review of the Project is required pursuant to CEQA Guidelines section 15183. =========================================================================================== RECOMMENDATIONS:

Introduce and Waive First Reading of Ordinance approving the Barlow Hotel Development Agreement.

EXECUTIVE SUMMARY:

Highway Partners LLC; Sebastopol Industrial Park LLC; and Barlow Star LLC; collectively “Barlow Hotel” has requested a Development Agreement to allow the development and operation of the Barlow Hotel at 6782 Sebastopol Avenue.

The project proposed is for redevelopment of an existing industrial building to create a single, 69,934 square foot hotel resulting in a structure of two and three stories, up to 55 feet in height; and including up to 83 hotel rooms; retail space of 940 SF; 305 total new parking spaces, 73 spaces on site and 242 new spaces at the “batch plant” parking lot at 385 Morris Street; public improvements to include a new high-visibility crosswalk at Morris and Laguna Park Way; a public access easement consisting of a new pathway on the south side of the new batch plant parking lot, leading from Morris Street to a new Laguna promenade with picnic area and overlook to be developed at the rear of the parking lot site; dedication of land for the existing AmeriCorps trail; and a permanent Open Space Easement over the Laguna de Santa Rosa, from the 50’ Laguna setback line east to the edge of the site.

Once fully operational, we project the hotel to generate about $1M in new revenue, primarily from transient occupancy taxes (TOT). It will also likely increase General Fund City costs by less than $100,000/year. The project’s fiscal benefits and recommended fee reductions are discussed under the Fiscal Analysis section below and in the attachments.

BACKGROUND/DISCUSSION:

Project Setting
The project site includes a 1.23-acre hotel site at 6782 Sebastopol Avenue within the Barlow market district (or “The Barlow”), with an additional 2 acre parking lot on a 2.9 acre site across the street at 385 Morris (“Batch Plant”) adjacent to The Barlow. The Barlow is a 12.4-acre, pedestrian-oriented development located immediately east of downtown Sebastopol. It is a destination for Sebastopol-area residents as well as visitors to the area and contains 222,000 square feet of building area between 18 buildings. Within The Barlow, 36 different tenants conduct a wide range of uses including industrial, food producers, retail shops, artisan restaurants and cafes, a community-based supermarket, and premium wine, beer, and cider-makers. Music and other special events are regularly conducted within The Barlow under their approved use permits.

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As noted above, the 69,935 square foot hotel structure would be within The Barlow and would replace the existing 36,402-square-foot Guayakí organic beverage company warehouse building, which spans from Sebastopol Avenue to McKinley Avenue (see Figure 1, below). The Guayaki organic beverage company has not renewed their lease and will be vacating the project site by the end of 2025.

The Project Site has a land use designation of Limited Industrial. The hotel site is zoned Commercial Industrial, and the parking lot site is zoned Industrial/Environmental & Scenic Open Space Combining Zone.

Figure 1, Project Location
Batch Plant Parking Lot Site. The 385 Morris Street parking lot site was formerly a concrete batch plant. Equipment associated with that former use was removed years ago and most of the existing disturbed area is paved. This site is adjacent to the Laguna de Santa Rosa, and as such carries the Environmental and Scenic Open Space (ESOS) Combining Zone designation (see discussion under Zoning Consistency, below). A pedestrian walkway including a new high-visibility crosswalk across Morris Street on the north side of Laguna Park Way would provide safe access for guests, employees, Barlow customers, and persons accessing Laguna Park and the AmeriCorps Trail from Laguna Parkway or Morris Street & the West County Trail. The parking lot would include 232 spaces, including 5 compact spaces, 6 ADA accessible spaces, 126 valet spaces and 19 spaces with EV charging. The valet spaces would be flexible, remaining available for self-parking when stacked parking is not needed. The parking lot design will feature the addition of 133 native trees, including 10 street trees, 31 shade trees within parking medians, 5 accent shade Agenda Item Number 10 Agenda Item Number: 10
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trees along a Laguna promenade, 53 accent understory trees, and 34 riparian upper story trees. A series of bioswales designed to pre-treat stormwater runoff add additional planting area to the site. An unmanned utility shed would be installed in the northwest corner of the lot to provide storage and house the valet function. As noted above, the project will feature a Laguna promenade, picnic area, and overlook with benches and interpretive signage. The “Laguna” portion of the parcel (east of the 50’ setback line) is offered as permanent undisturbed open space under an Open Space Easement (see Figure 2, below).

Figure 2: Landscaping Plan for Barlow Hotel Parking Lot at 385 Morris Street (Bach Plant site) Development Agreements
As noted above, the approval mechanism for the Barlow Hotel will be a Development Agreement. A Development Agreement (DA) is a voluntary contract between a property owner and a local government to establish the terms and conditions that govern the development and use of a specific property.

Development Agreements (DAs) are governed by state law (Government Code §65864-65868.5) and by Chapter

17.440 of the City Code. They are intended to strengthen the planning process, encourage comprehensive planning, and reduce uncertainty and costs in the development review process. A DA is a type of ordinance, and it must be consistent with the General Plan and must be approved by the City Council following a public hearing. The Planning Commission’s role in approval of the Development Agreement is to review it and to make a recommendation to the City Council, much like they would review and recommend any other ordinance affecting land use and zoning.

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Code Section 17.440.070 requires that the City make certain findings as part of the approval of the Development Agreement; see the Analysis section, below.

A Development Agreement providesthe site-specific land use and developmentstandards for the property covered in the Agreement. State law authorizes the use of Development Agreements to establish standards for virtually every aspect of a development, including but not limited to:
• Building sizes, heights, densities,setbacks, vehicular access and parking, site design, landscaping, and other physical development features;
• Permitted uses and operating standards;
• Mitigation measures and conditions of approval;
• Amount and payment schedule of any impact fees;
• Required dedications, if any;
• Term of the Agreement;
• Development phasing, if any; and
• Procedures for subsequent reviews, along with standards for implementing decisions.

The Development Agreement for the Barlow Hotel incorporates each of its land use entitlements and conditions of approval that the City would otherwise handle through issuance of use permits and design review approvals.

Because Development Agreements are adopted by Ordinance, they can approve certain allowances or design aspects that are different than what is required by the Zoning Code so long as the Development Agreement is consistent with the General Plan and the proposed uses are allowed by the Zoning Code. Approval of the Development Agreement is not a change to the Zoning Code and does not affect any other property in the City.

Table 1 reflects the different land use entitlements for the Barlow Hotel and indicates the typical and proposed processing mechanism for each:

Table 1: Barlow Hotel Project Components and Approval Procedures As permitted through a Development Agreement process, planning entitlements may be approved by Council, after a recommendation has been made by the Planning Commission. The Planning Commission (PC) reviewed all project components, in conjunction with the Design Review Board (DRB) at a joint meeting of the DRB and PC on March 25, 2025 as described further in the Joint Meeting PC/DRB Project Comments. Thistable explainsthe project components reviewed by the joint body:

Project Component Allowed
by
Zoning
Code?
Typical Processing &
Approval Procedure
Procedure for
Barlow Hotel
Project
Hotel Hotel, with accessory
uses including spa,
restaurant, cafe & retail
Yes Use Permit Development
Agreement
Bar spaces/alcohol sales Yes Admin Review or Use
Permit, depending on
seats and food service
Development
Agreement
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Hotel structure, height,
massing, architectural
features, colors &
materials, landscaping,
lighting
Yes Design Review Board;
Planning Commission
(height)
Development
Agreement;
Subsequent
Admin Design
Review if
consistent with
Development
Agreement
Signs Yes Admin Review if
consistent with Sign
Program
Admin Review if
consistent with
Sign Program &
Development
Agreement
Tree Removal (Tree #1) Yes Tree Board Development
Agreement
Parking
Lot Site
Offsite Parking (batch
plant parking lot)
Yes Use Permit Development
Agreement
Valet Parking (batch
plant parking lot)
Yes Use Permit Development
Agreement
ESOS Setback reduction
from 100’ to 50’
Yes Use Permit Development
Agreement
Landscaping & Lighting;
Shed structure
Yes Design Review Board Development
Agreement;
Subsequent
Admin Design
Review if
consistent with
Development
Agreement
It is important to note the Development Agreement covers only the project’s land use entitlements, and only those under the City’s authority. It does not cover additional City or other agency reviews that will be required before development can begin. The project will still need to apply for and receive permits for such things as Improvement Plans, Grading Permits, Encroachment Permits (both City and Caltrans), Department of Alcohol Beverage Control (ABC) Permits to allow alcohol sales, food service permits from the County Health Department, and so on.

The Development Agreement has a term of ten (10) years, which is a common term for development agreements.

The Project’s approvals are vested during this period of time. Annual review of the Development Agreement by the City is required during each year of the DA. The conditions of approval for the project, and authorized uses, will continue after the expiration of the Development Agreement. Although the Development Agreement has a ten (10) year term, the applicant anticipates commencing construction during 2026.

California Environmental Quality Act (CEQA) Review
CEQA Regulations ( 14 CCR §15183) include a special environmental review process for projects that are consistent with the General Plan and whose potential impacts have been studied in a previously certified Environmental Impact Report. When this occurs, the law considers that the project’s environmental impacts have already been studied and limits additional environmental review to those potential impacts that are peculiar to the proposed project or site. The Barlow Hotel, with up to 90 rooms, was anticipated by and studied within the certified EIR for the 2019 General Plan and therefore the City must process the project using the Section 15183 procedure. While Agenda Item Number 10 Agenda Item Number: 10
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the City cannot impose additional CEQA review of the project, the statute does permit the City to request specific studies to demonstrate conformance with the previous reviews or to examine any aspects of the projects that may not have been analyzed in the earlier CEQA review. The following additional studies have been requested and provided by the applicant:
• Barlow Hotel Project CEQA Transportation Assessment, Fehr & Peers, June 2024 • Intersection LOS Assessment for Barlow Hotel Project, Fehr & Peers, May 2024 • Crosswalk Improvement Study for the Barlow Hotel, W-Trans, February 2025 • Historical Resources Evaluation Report, Yarborough Architectural Resources, Dec 2024 • Batch Plant Parking Lot Biological Assessment, WRA Consultants, May 2024 • Arborist’s Report, Gary Balcerak, July 2024 with revision letter dated January 2025 • GHG and Air Quality Model Outputs for Barlow Hotel and Parking w/Detailed Bay Area Air Quality Management District (BAAQMD) Health Risk Report, December 2024 • Initial Stormwater Low Impact Development Submittal for Barlow Hotel, Adobe & Associates, August 2024 Attachment B presentsthe Section 15183 “Checklist” (similar in format to aNegative Declaration) and itssupporting documentation. The CEQA documentation was prepared by Environmental Science Associates (ESA) on behalf of the applicant and has been peer reviewed by Rincon Consultants on behalf of the City. The Checklist confirmed that there are no project-specific environmental effects which are peculiar to the project or its site, and all potential significant effects were previously discussed by the General Plan EIR. Accordingly, Staff has determined that the applicable requirements are met and recommends that the Planning Commission adopt the draft resolution which includes findings that the previous CEQA review, along with the additional studies and documentation, are adequate and appropriate to support the project.

Joint Meeting PC/DRB Project Comments.

As part of their review of the proposed project the Planning Commission and the Design Review Board reviewed the following matters:

The role of the Planning Commission in reviewing a Development Agreement is to provide the first review of the proposal and make a recommendation to the City Council. In their review, the Commission considers the project’s consistency with the General Plan and with the uses allowed by the Zoning Code. Their recommendation is to include findings as indicated in the attached Resolution approved by the Planning Commission on March 25, 2025 recommending approval of the Development agreement.

The Design Review Board/Tree Board has no formal role in the approval of a Development Agreement. However, the DRB’s review and direction is important to advise the City Council and inform the subsequent reviews that will take place between approval of the DA and the start of construction. Statutes allow for subsequent discretionary approvals, such as administrative design review, as long as they do not preclude development of the project described within the Development Agreement. Staff will rely on the project’s compliance with the Development Agreement and with the direction provided by the Design Review Board when performing their administrative design reviews. Analysis of the project included the following considerations:

General Plan Consistency
There are many General Plan policies applicable to the Barlow Hotel project proposal, including the goals and policies of the Land Use, Circulation, Community Services & Facilities, Conservation & Open Space, Community Design, and Economic Vitality Elements. A short list of applicable goals and policies from the Economic Vitality Agenda Item Number 10 Agenda Item Number: 10
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Element is presented below; for more details please see the complete General Plan Consistency Analysis dated February 2025 and provided as Attachment E.

GOAL EV 1: Encourage Economic Development that Broadens the City’s Employment Base, Attracts High-Quality Jobs, Provides Services and Goods that Reflect the City’s Values, and Increases the City’s Tax Base GOAL EV 4: Emphasize Sebastopol's Role as a Market, Service, and Tourism Hub for the West County and as a Gateway to the Coast
GOAL EV 7: Maintain a Stable and Self-Sustaining Fiscal Base in Order to Generate the Resources Necessary to Provide Desired City Services and Support New Growth that is Consistent with the City’s Values and Goals Policy EV 4-3: Encourage amenities needed to support tourism, including hotels, bed-and-breakfasts, ecolodging, and a variety of restaurants, shopping, and services.

Policy EV 4-4: Encourage the development of civic amenities, entertainment venues, retail and restaurants, and services that increase visitation, spending, and tourism.

Policy EV 4-5: Promote both the City, and the City’s open space and natural resources, with emphasis on the Laguna Wetlands Preserve, as a tourist destination.

Analysis and Conclusion. The Barlow Hotel project is consistent with the Sebastopol General Plan. It meetsthe goals of increasing the City’s tax base, increases its role as a tourism hub for the west county by providing accommodations for visitors, and increases the City’s fiscal base. It provides the amenities necessary to support tourism in a location and with a pedestrian orientation that is designed to increase spending both in The Barlow and within the adjacent Downtown. It promotes the Laguna de Santa Rosa as an important natural resource and tourism destination.

Zoning Consistency
As noted above, Development Agreements can set their own design and development standards for developments on the site or sites that are covered by the DA, so long as the proposed uses are allowed by Zoning. As noted in Table 1 provided above, each of the project’s components are uses permitted or conditionally permitted by the Zoning Code. The analysis below provides details for the Council’s consideration, including the applicable findings for approval of the different project components.

Hotel Site (CM Zoning): Hotels are considered to be transient residential uses under the Municipal Code. The Land Use Table for Commercial and Industrial Uses lists these uses as conditionally permitted in the Commercial Industrial (CM) Zone. Findings for approval of a Use Permit are provided below.

The Zoning Code further defines “hotel” to include accessory uses such as restaurants, small shops, gyms and beauty/barber shops:
“Hotel” means a residential building other than a bed and breakfast inn containing six or more guest rooms which are used, rented or hired for sleeping purposes by transient guests or travelers for generally less than 30 consecutive days. Such uses may also include accessory uses such as beauty and barber shops, restaurants, florists, small shops, and indoor athletic facilities. Hotel includes “motel” uses.

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Hotel Use. The Code sets forth the following standard Use Permit findings necessary for approval of the Barlow Hotel:
a. That the use is consistent with the General Plan; and b. That the establishment, maintenance, and operation of the use applied for will not, under the circumstances of the particular case (location, size, design, and operating characteristics), be detrimental to the health, safety, peace, morals, comfort, or general welfare of persons residing or working in the area of such use or be detrimental or injurious to property and improvements in the neighborhood or to the general welfare of the City.

Analysis and Conclusion. The use is consistent with the Sebastopol General Plan, as discussed above. The project size, design, and operation are appropriate for its location within The Barlow, adjacent to downtown Sebastopol and providing convenient access and service to visitors. The hotel construction and operation will be regulated by a Development Agreement which is required to be reviewed annually, as well as by project conditions of approval to protect the public health, safety, and general welfare of residents and visitors alike.

Parking Requirements. The parking requirements in the Zoning Code include both a schedule of required spaces and standards for the provisions of parking spaces. The Parking Schedule (17.110.030) requirement for hotel and motel uses is 2 spaces for each room up to 75 rooms, then .75 space for each room over 75. This 83 room hotel therefore requires 156 parking spaces; 305 total spaces are provided. The number of spaces and the dimensions of spaces and aisleways meet or exceed the minimums required. Thirty-one bicycle parking spaces are also required and provided, along with 18 EV charging stations.

Code Sections (17.110.020 D and E) allow a portion of a project’s parking requirement to be met off-site and through valet arrangements, with the Planning Commission’s approval of a use permit,subject to finding asfollows:
a. The number of parking spaces conveniently available to the use will be sufficient for its safe, convenient and efficient operation;
b. A greater number of parking spaces than required by the Commission will not be necessary to mitigate adverse parking or traffic impacts of the use on surrounding properties; c. For use of valet parking, the Commission determines that use of valet parking is appropriate due to the type of use, scale of use, or other factors;
d. For use of valet parking, tandem parking, a higher proportion of compact parking spaces, or other changes to dimensional parking space requirements, the configuration of parking spaces and operation of the parking facility will ensure that the use has adequate parking availability; and e. The Commission findsthat any modifications under these provisions will not create an impairment to public safety, impede safe and efficient pedestrian or vehicle traffic flow, or otherwise interfere with the operation of area uses or functions.

Analysis and Conclusion: The proposed parking arrangement is consistent with the General Plan, as discussed above. Taken as a whole, the proposed parking arrangement including redevelopment of the existing shared parking lot on-site and the development of a new parking facility adjacent to The Barlow provides sufficient parking for the newhotel use and provides additional parking for existing uses. A greater number ofspacesis not necessary, and the use of valet parking is appropriate for this hotel use. The provision of a new high-visibility crosswalk at Morris Street and Laguna Park Way will provide safe access to the off-site parking facilities. Project conditions of approval will require approval of a parking phasing plan to address short-term parking needs during project construction.

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Alcohol Use Permit. The Zoning Code also requires a Use Permit for facilities serving alcohol. The Barlow Hotel would include a lobby bar and a rooftop café bar and would also serve alcohol within its restaurant and with room service meals. Alcohol sales would feature products produced within the Barlow and local area. Food would be available during all timesthat alcohol isserved. Because the combined restaurant areasinclude more than 50 seats, a use permit is required. In addition to the standard Use Permit findings outlined above, the following minimum standards are applicable to the alcohol uses associated with the project:
a. A copy of the conditions of approval for the conditional use permit must be kept on the premises of the establishments and posted in a place where it may readily be viewed by any member of the general public. b. In making any of the findings required pursuant to this chapter, the City Council shall consider whether the proposed use will adversely affect the health, safety or welfare of area residents or will result in an undue concentration in the area of establishments dispensing, for sale or other consideration, alcoholic beverages, including beer and wine.

The City Council shall also consider whether the proposed use will detrimentally affect nearby residentially zoned communities in the area, after giving consideration to the distance of the proposed use from the following:

1. Residential buildings;

2. Churches, schools, hospitals, public playgrounds and other similar uses; and

3. Other establishments dispensing, for sale or other consideration, alcoholic beverages including beer and wine.

Analysis and Conclusion: The Barlow Hotel project, as proposed and conditioned, is consistent with the Sebastopol General Plan and Zoning, as set forth above. Its establishment, maintenance, and operation will not, under the circumstances of this particular case, be detrimental to the health, safety, peace, morals, comfort, or general welfare of persons residing or working in the area of such use or be detrimental or injurious to property and improvements in the neighborhood or to the general welfare of the City. The project is the subject of a DA that will be reviewed annually. The project is further subject to conditions of approval as shown in Attachment F, which conditions shall be posted on site as required by Code. Alcohol sales and service within the Barlow Hotel will not adversely affect the health, safety or welfare of area residents because of the placement and operating conditions of these uses within a hotel within The Barlow Market District, adjacent to Downtown Sebastopol. It will not form an undue concentration inconsistent with the activities and land uses within a vibrant downtown, and food will be available during all times that alcohol is served. There are no nearby residentially zoned properties, churches, or public playgrounds.

Parking Lot Site (M Zoning with ESOS Combining Zone): The Industrial (“M”) Zoning District lists Parking Lots as a conditionally permitted use in Table 17.25-1. As noted in the Project Description section of this Staff Report, the parking lot would be developed to include 232 spaces, including 5 compact spaces, 6 ADA accessible spaces, 126 valetspaces and 19 spaces with EV charging. The valetspaces would be flexible, remaining available forself-parking when stacked parking is not needed. The parking lot design will feature the addition of 133 native trees, including 10 street trees, 31 shade trees within parking medians, 5 accent shade trees along a Laguna promenade, 53 accent understory trees, and 34 riparian upperstory trees. Speciesinclude live oak, valley oak, willows and maples. A series of bioswales will handle stormwater runoff and add additional planting area to the site. An unmanned utility shed would be installed in the northwest corner of the lot to provide storage and house the valet function. The project will also feature a Laguna promenade and overlook with benches and interpretive signage. The “Laguna” portion of the parcel (everything east of the 50’ setback line) will be offered as permanent undisturbed open space under an Open Space Easement.

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The parking lot site is also within the Environmental and Scenic Open Space (ESOS) Combining Zone, which requires an additional level of review for projects within 100’ of the Laguna de Santa Rosa. The proposed parking, access, promenade and overlook are located less than 100 feet but greater than 50 feet from the Laguna de Santa Rosa wetland/riparian boundary. The Zoning Code at Section 17.46.050 specifies a 100-foot minimum setback buffer from the edge of a wetland or identified riparian dripline, which may be reduced to not less than 50 feet with approval from the Planning Commission. Approval of the parking lot site plan by the City, including areas within 100 feet of wetland and riparian habitat associated with Laguna de Santa Rosa, would be consistent with the approach identified in the Sebastopol General Plan. In order to approve the parking lot development in the ESOS Zone and decrease the required setback to 50 feet, the City Council must generally make the following findings pursuant to Section 17.46.060:
a. The required resource analysis is consistent with the requirements of this chapter; b. The proposed project complies with all applicable standards required by this chapter; c. No wetlands or vernal pools would be eliminated;
d. Mitigation measures have been imposed that will reduce any impacts to other identified resources to a less than significant level; and
e. That any mitigation shall be consistent with the Conservation and Open Space Element of the General Plan.

However, the Zoning Code Section on the ESOS Combining Zone, at subsection 17.46.090, sets forth the circumstances under which the Planning Commission can approve a reduced ESOS setback without full submittal of a biological and visual analysis, as follows:
. . .where the applicant demonstrates to the satisfaction of the Planning Commission that, due to the existing character of the property or the size, nature, or scope of the proposed project or previous development of the property, the full scope of studies called for by SMC 17.46.050(D) is not necessary, the Commission may modify study requirements of this chapter if it finds, on the basis ofsubstantial evidence provided by a qualified professional, thatspecific resources of potential concern do not occur on the property or will not be affected by the project.

Analysis and Conclusion. The parking lot use is consistent with the Sebastopol General Plan, as discussed above. Its establishment, maintenance, and operation will not, under the circumstances of this particular case, be detrimental to the health, safety, peace, morals, comfort, or general welfare of persons residing or working in the area of such use or be detrimental or injurious to property and improvements in the neighborhood or to the general welfare of the City.

The Code allows the decision-making body to modify the setback requirements based on substantial evidence provided by a qualified professional that specific resources of potential concern do not occur on the property or will not be affected by the project. The biological resource study prepared for this project (WRA, 2024, provided as an attachment to the CEQA Section 15183 Checklist) determined that the proposed use of the site as a parking lot would not differ significantly and would improve current conditions. As noted in Table 1, the mechanism for approval of the setback in this case will be the Development Agreement. The attached Ordinance contains a suggested finding that it is appropriate to modify the ESOS submittal requirements and grant the reduced setback because a qualified professional has provided substantial evidence that resources of potential concern do not occur on the project site in the area to be developed (see May 2024 Biological Assessment by WRA Consultants, provided as an attachment to the CEQA 15183 Checklist), and that the development with the addition of 133 native trees and dedication of a permanent open space easement over the Laguna portion of the site from the 50’ setback line east results in an environmentally and visually superior condition than currently exists on the site.

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Development Agreement
Pursuant to Municipal Code Section 17.440.070, the City Council’s approval of the Projectshall include the Council’s determination of whether or not the proposed Development Agreement meets the following findings:

A. Is consistent with the objectives, policies, general land uses and programs specified in the General Plan and any applicable specific plan.

B. Is compatible with the uses authorized in, and the regulations prescribed for, the district in which the real property is located.

C. Is in conformity with public convenience, general welfare and good land use practice.

D. Will not be detrimental to the public health, safety and general welfare.

E. Will not adversely affect the orderly development of property.

F. Will provide sufficient benefit to the City to justify entering into the agreement.

Analysis and Conclusion As outlined in the above analyses, the Barlow Hotel project, as conditioned and with enforcement of the terms of the Development Agreement, meets the required findings. It is consistent with the Sebastopol General Plan and the uses allowed by zoning; it isin conformity with the public welfare and convenience; it is not detrimental to the public health, safety and welfare; and it does not adversely affect the orderly development of property. The project’s fiscal benefits to the City, discussed under Fisal Analysis below, justify entering into the Development Agreement.

Hotel Design Considerations
The following design statement is provided by the project architect:
“The proposed project is a mixed-use hotel with up to 83 rooms, located on the Guayaki site within the Barlow Market District. It is conceived as a unique destination with a distinct identity and image that complements and draws inspiration from the Barlow Market District.

The architectural character of the hotel drawsfrom the regional vernacular (farmhouses, local agricultural buildings found in the surrounding wine country, and the industrial aesthetic of venues situated nearby). The building's proposed finish materials pull inspiration from the region with a combination of materials - wood,stone, and metal.

The building is finished in a combination of lime-washed stone, stucco, grain-wood siding, and metal gabled roofs (along the north and south ends of the building). The adjacent Gravenstein Court parking lot is converted into a large grove of trees extending the rural character beyond the footprint of the proposed hotel.

The building layout is organized around a sequence of three beautifully landscaped courtyards, each with a distinct image and character, together creating a visual and experiential sequence between open-to-sky and covered spaces. The building is entered in three locations - along McKinley via a covered paseo; along Gravenstein Court from the drop-off area; and along Sebastopol Ave via ramp and stair. Two of the entries lead into the first (north) large courtyard from where one enters the lobby, bar and restaurant. The spa has a separate entrance off Sebastopol Ave but can also be accessed internally from the hotel. The materialselections above weave themselves throughout the courtyards, drawing the aesthetic of the exterior into the experience within the courtyards and interior spaces.

The hotel guest rooms are configured around single-loaded arms overlooking the courtyards. The public functions of the hotel, such as the restaurant, meeting rooms, bar, and kitchen are situated closer to McKinley, around the courtyard entrance. The restaurant wraps around to line McKinley Street along with more retail to enliven the pedestrian experience. The design provides a spa located along Sebastopol Ave.

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The building’s highest massing is a fourth story rooftop bar which constitutes only 4% percent of the overall footprint, located in the least visible part of the site. The rest of the building is a combination of 2 and 3 stories.

This varied massing is a conscious design approach generating a picturesque, and human-scale massing as opposed to a single monolithic and over-scaled building. The result is an aggregate compound of buildings intending to meet the scale of the adjacent buildings. The roofs are a combination of flat and sloping planes of varying degrees and materials, further scaling down the building's size.”
The Zoning Code Section 17.25.030 (B) sets forth design criteria applicable to large projects within the CM Zone:

1. The development shall be human-scale and pedestrian-friendly, with the site plan focused on pedestrian access and architecture.

2. The development shall be oriented toward the street frontages and primary pedestrian access points, rather than the parking lot. Safe and convenient pedestrian access shall be provided throughout the development, with access and connections provided to existing and planned sidewalks and bicycle routes.

3. Development shall not resemble a typical strip commercial development. Strip commercial development is characterized by uses that are one store deep, buildings are arranged in a linear fashion rather than clustered, and site design that emphasizes automobile access and parking.

4. Off-street parking shall be distributed to the rear of buildings, except in unusual circumstances when parking to the side will be considered.

Analysis and Conclusion: The project uses a pedestrian scale with 2-storied elements along the street frontages.

The third story and rooftop features are limited to the central portion of the building. Architectural features including courtyards and arches invite pedestrian interaction. Connections are made to sidewalks and walkways. It is not a strip mall commercial development. Off-street parking is provided to the side of the building, shared with the Community Market parking lot, and off site in a new parking lot to be developed at the old batch plant site at 385 Morris Street. The design criteria set forth in the Zoning Code for large projects within the CM Zone are met.

See also Attachment D for the City’s Design Guidelines.

Orientation Toward Street Frontages
During their deliberations on the project design, the members of the Planning Commission and the Design Review Board indicated that the building elevation facing Sebastopol Avenue, a key gateway into the township, should be updated to appear less like a side or rear entry façade. The current façade is designed, in part, to address American with Disability Act (ADA) requirements related to handicap access to the building at that location. Joint body members comments included: DRB Summary - “Members agreed that it was appropriate to treat the building’s facades differently and generally recommended that the applicants pay more attention to the Sebastopol Avenue facade to make it appear more welcoming. PC Summary - “Commissioners agreed with the Board that the Sebastopol Avenue side of the building should be upgraded to provide a better facade treatment and pedestrian experience.”
The joint body’s direction to staff did not specify what features were to be updated but left it to staff to share their recommendations with Council as we have in Attachment K Memo re. PC/DRB Joint meeting comments. There are planning best practices staff is able to use to evaluate recommended updates to the façade as part of the administrative design review. For example, the façade can provide more of a statement at the gateway through applied materials to the ADA ramp such as stone work and/or landscaping, placement of a significant public art piece on or near the façade of the building near the gateway drawing attention to the building, updates to building Agenda Item Number 10 Agenda Item Number: 10
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fenestration (windows/entry door features) or building roof trim eyebrow (filigree) details, etc. to provide more an entryway statement to that façade.

For this reason, staff is recommending a new condition of approval (COA #21).

Public Art
Sebastopol’s Public Art program is set forth in Chapter 17.310 of the Zoning Code. This local law requires that a developer install approved public art, or pay an in-lieu fee, as required. The Barlow Hotel will be required to meet a modified version of this obligation, with a cap of $50,000 value of the public art or in-lieu fee provided by the Hotel prior to the issuance of a certificate of occupancy, as reflected in the DA and the project Conditions of Approval. This amount is less than the 1% construction valuation that could be potentially assigned to the project.

Any public art proposed by the Barlow Hotel to meet this requirement must be approved by the City Council following recommendation from the Public Arts Committee.

Parking Lot & Laguna Promenade with Overlook
The Laguna de Santa Rosa is the largest freshwater wetlands complex on the northern California coast. Its 14-mile channel forms the largest tributary to the Russian River, draining a 254-square-mile watershed which encompasses nearly the entire Santa Rosa Plain. Forming the eastern edge of the City, the Laguna de Santa Rosa is an important community asset and the preservation of its history and function is highly valued by the community. The Barlow Hotel project seeks to feature the Laguna as a community asset to be experienced by residents and visitors alike.

The project features a promenade along the Laguna frontage just before the 50’ ESOS setback line discussed above, and includes an overlook with bicycle parking, benches, trash receptacles, and interpretive signage (Figure 3, below). Public access to this area will be provided by a public access easement consisting of anew pathway on the south side of the batch plant lot, and the promenade path at the easterly edge of the parking lot continues to the northern property line where is could eventually connect with the existing AmeriCorps trail on the adjacent City property to the north. The entire easterly portion of the parking lot site, from the 50’ ESOS setback line to the easterly parcel boundary, would be dedicated as permanent open space through recordation of an open space easement. Finally, dedication of a strip of land 10’ wide would be made to accommodate the existing AmeriCorps trail where it crosses the northeast corner of the property.

The batch plant parking lot utilizes a series of bioswales to provide drainage and percolation of stormwater while also enhancing the biodiversity and aesthetics of the setting. The bioswales are extensively landscaped with native (Laguna-area) plants, including under-story and upper-story trees.

Tree Removal, Protection, and Replacement
Plans for the hotel project include reconstruction of the existing parking lot located between the Guayaki and Community Market buildings. This reconstruction will include the removal of 41 existing parking lot trees, none of which are of a size or species that are protected under the City’s Tree Protection Ordinance. The 41 existing parking lot trees will be replaced with 51 new trees, including 5 new street trees, which is a net gain of 10 trees. Landscape plans for the Parking Lot site include the provision of 133 new plantings of native trees. While no protected native trees are proposed to be removed from the parking lot site, there are two nearby protected native trees that will be subject to protective measures outlined in the Arborist’s Report (Trees #3 and #5) and formalized in the project conditions of approval.

Figure 3: Landscaping Plan and Cross Section for Laguna Overlook The Arborist’s Report prepared for the project dated June 2024, along with an update letter dated January 2025, indicate that the only protected tree that will need to be removed for the project is a 27” dbh Valley Oak that is Agenda Item Number 10 Agenda Item Number: 10
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located between the existing Guayaki and Co-Op buildings (Tree #1). The tree has poor structural integrity and has been cabled for a number of years. The crown is one-sided, and construction activities would further destabilize the tree, thereby necessitating itsremoval under Sections 8.12.060(D) 2. &4. The Development Agreement includes tree removal authorization for Tree #1 only and does not authorize the removal of any other protected native tree.

Other protected trees are located on or near the parking lot site but outside of the limits of work. A Condition of Approval will require the submittal of a Tree Protection Plan, including A TPP sheet within the Grading Permit plan set. If it is determined during project construction that any Trees #3 and/or #5 cannot be saved, a Tree Removal Permit will be required.

Traffic and Parking
According to the Intersection Level of Service for the Barlow Hotel Project (Fehr & Peers, May 2024) submitted as a part of the CEQA review for this project, the Barlow Hotel will generate approximately 39 new net automobile trips during the am peak hour and 39 during the pm peak hour. This increase to existing traffic would not cause a change in the Level of Service (LOS) at any of the study intersections except at the intersection of Sebastopol (Highway 12) and Petaluma Avenues, where the LOS would decrease from C to D due to an increased delay of 3.8 seconds during the am peak hour. The Report concludes that because the City’s LOS standard is D for all signalized intersections, the standard would continue to be met and additional mitigation is not required.

Senate Bill 743 was signed into law in 2013 and went into effect in 2020. Under this law, the standard for CEQA review of traffic impactsis no longer LOS. The new measurement is Vehicle Miles Traveled, or VMT, because it more accurately reflects the environmental impacts associated with traffic. Under this measurement, the Barlow Hotel project actually decreases traffic impacts because it provides a “park once” strategy whereby guests and visitors can park one time and make multiple stops on foot or by bicycle. Using the VMT measurement that is now required for CEQA analysis, the project will reduce VMT in the City and the region (see CEQA Traffic Analysis for Barlow Hotel (Fehr & Peers, June 2024), provided as an attachment to the CEQA Section 15183 Checklist).

Additional information re. the joint body’s comments on the project are provided in Attachment X, Memorandum re. Summary of DRB and PC comments from March 25, 2025 Joint Meeting.

STAFF ANALYSIS:

Development Agreement terms:

Legal Terms.

The project will be governed by the Development Agreement, which has a term of ten (10) years. The Project’s approvals are vested during this period of time, which allows the project to be developed in accordance with the City’srequirement in place currently, even if those requirements change during the term of the Agreement. Annual review of the Development Agreement by the City is required during each year of the DA.

The Development Agreement incorporates the project components discussed herein, as well as the condition of approvals for the project. The conditions of approval for the project, and authorized uses, will continue after the expiration of the Development Agreement. The Development Agreement established that the City Manager, or designee, is responsible for approving all subsequent permits or approval necessary as part of the Project, except permitsrequired by law to be approved by the Building Official or City Engineer. However, any permits and approval for changes to the Project are required to be approved by the body identified in the Municipal Code, except for minor changes, as defined in the agreement.

Business Terms.

See Fiscal Impact Section, below.

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COMMUNITY OUTREACH:

This item has been noticed in accordance with the Ralph M. Brown Act and was available for public viewing and review at least 72 hours prior to the scheduled meeting date. The City has also used social media to promote and advertise the City Council Meeting Agenda items. As of the posting of this report, staff has received public comments, which are attached. If additional public comments are received after the posting of this report, they will be submitted to City Council and posted to the City website.

FISCAL IMPACT:

Upon completion, the Barlow Hotel is expected to bring significant fiscal benefits to the City by generating substantial tax revenue, particularly Transit Occupancy Tax (TOT), as well as increased property and sales taxes.

This analysis is based on two studies, one by RRC Associates provided by the Applicant and one by Economic and Planning Systems, commissioned by the City (see Attachments G and H). These studies were informed by an analysis of the project by HVS Global Hospitality Services, which specializes in the hotel industry (Attachment I).

Our best professional judgment is that all three firms are credible, although there is significant variation between the RRC and EPS estimates.

In general, the RRC study provides higher projected revenues to the City and the EPS Study provides significantly more conservative figures, explained below. Study estimates of the projected financial benefits to the City are shown in Table 3 below. Note that they assume that the hotel is fully operational, which is expected to take about five years from opening. The projections below exclude the Barlow Hotel’s impact on the City’s public service costs, estimated by EPS to increase by about $84,000 per year.

Table 3: Comparison of Projected Annual Revenues from the Barlow Hotel TOT Property Tax* Sales Tax** Total
RRC Associates $1,548,000 $180,000 $350,000 $2,078,000
EPS $891,000 $54,000 $34,200 $979,200
*Reported as the incremental property tax over the industrial/office building currently on the project site. **The EPS sales tax estimate is mid-way between estimates that vary based on assumptions regarding future Measure U revenue. The RRC Associates estimate did not consider Measure U, which had not been proposed at the time of their study.

The primary source of tax revenue identified in both studies is Transit Occupancy Tax, or TOT. However, the EPS projections are significantly more conservative than those provided by RRC due to differences in assumptions for the average annual room rate (both studies assume an occupancy rate of 70 percent). RRC assumes a nightly rate of $575 per room, citing the HVS analysis. EPS sets the rate at a more conservative $350 per room-night.

Presently, hotel rooms in Sonoma County average $200 per room-night, with luxury-class accommodations around $370 per room-night.

The property tax estimates in the two studies also differ widely. This is because the two firms used significantly different assumptions on the value of the hotel at completion. RRC estimates the value at $90.3 million, while EPS estimates the value at $35 million based on its size and likely market performance. RRC cites the HVS analysis for this value.

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The sales tax estimates differ even more widely. RRC estimates that the hotel’s guests will generate annual sales of $23.4 million in Sebastopol (including at the hotel); EPS estimates this benefit at $4 million.1 The reason for this substantial discrepancy is different sources for spending data and approaches in classifying taxable retail sales.

RRC attributes the $23.4 million spending total to the HVS study and assumes that 85 percent would be taxable.

EPS bases their estimate on 2023 visitor spending data from the Sonoma County Economic Development Board and assumes that 36 percent is taxable (as the spending is mainly lodging and transportation).

Fees. The Barlow Hotel is subject to $933,740 in one-time fees payable to the City, including $417,042.88 in processing fees (see Table 4, below) and $516,697.66 in impact fees (see Table 5, below). Processing fees cover the costs of City staff time to process the project’s various applications, entitlements, plan checks and inspections.

Impact fees address the impact of the development on City services related to traffic, parks, community facilities, water and sewer systems, and so on. The amount of the fees will remain fixed until July 1, 2026. Thereafter, the fees will increase by the same percentage as the City’s fee scheduled. The final amount of the fees will be set when building permits are pulled for the project. The Development Agreement defers payment of the impact fees until issuance of a certificate of occupancy for the project, and thereafter allows the Developer to pay the fees over 60 equal monthly payments. The City and developer agreed to similar arrangements when The Barlow was developed, and the developer met the obligations. This is a policy decision for the City Council; staff is supportive of the request.

The above figures include credits that staff is proposing be granted toward the Parks impact fees for the development of the Laguna Overlook with promenade, benches, and interpretive signs, as well as for the dedication for the existing AmeriCorps Trail and the permanent open space easement over the Laguna portion of the batch plant site (full credit toward Parks fee to be granted). It also includes a recommended credit of $51,727 (half the value of the cost of the improvements) toward the Traffic Impact Fees due to the provision of a highvisibility pedestrian crossing at Laguna Park Way and Morris Street. Providing such credits for on-site or nearby improvements is a common practice because the developer is directly providing the types of improvements and mitigation measures that impact fees from the project would otherwise be used to fund. The applicable fees without credits, the amount of the recommended credits, and the final level of proposed impact fees are shown in Table 5, below.

Table 4: Processing Fees Expected from Barlow Hotel
Barlow Hotel Processing Fees
Permit Processing and Engineering Fees1
Building (Hotel Facility) Portion of Project
Subtotal-Processing Fees (Building) $392,079.82
Parking Lot Portion of Project
Subtotal-Processing Fees (Parking Lot) $24,963.06
TOTAL - PROCESSING FEES $417,042.88
1) Public Art Fee to be evaluated separately; Developer to either meet % requirement in art equivalent or pay same value in lieu fees.
1 Includes spending on non-taxable expenses like Lodging, Transportation, and Food.

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Table 5: Impact Fees Estimate for Barlow Hotel
Barlow Hotel Fees Value of In Lieu
Improvements
Applicable
Impact Fees
Traffic Impact $229,112.00 $51,727.00 $177,385.00
Park Land and Development $309,258.00 $309,258.00 $0.00 General Government $6,358.00 $6,358.00
Fire Facilities $10,528.00 $10,447.00
General Plan Update $15,106.66 $15,106.66
Storm Water $28,800.00 $28,800.00
Water Connection Fee $172,434.00 $172,434.00
Sewer Connection Fee $106,167.00 $106,167.00
TOTAL - IMPACT FEES $877,763.66 $360,985.00 $516,697.66 Conclusion: The Barlow Hotel is likely to provide substantial financial benefits to the City. While the range of those benefits varies substantially between the studies provided, the ‘bottom line’ is that the project, once built and operating, will provide important benefits to the City.

Note: As of this writing, staff anticipate that the applicant will submit a request for additional credits for fees. Staff will add that request as a supplemental attachment to this report, as well as a staff response if one can be prepared before the Council meeting.

STAFF RECOMMENDATION:

Introduce and Waiver First Reading of Ordinance approving the Barlow Hotel Development Agreement.

ATTACHMENTS:

A – Project Description Details
B – CEQA Section 15183 Checklist, with supporting attachments C – Planning Commission Resolution
D – Design Guidelines – staff analysis for Barlow Hotel E – General Plan Consistency Analysis, January 2025
F – Project Conditions of Approval
G – Barlow Hotel Economic and Tax Impact, RRC Associates, April 22, 2024 H – Sebastopol Barlow Hotel Fiscal Impact Analysis, EPS, March 7, 2025 I – AVS Hospitality Feasibility Study for the Barlow Hotel J – Ordinance with Exhibit A - Development Agreement for Barlow Hotel, with attachments K – Memorandum re. Summary of DRB and PC comments from March 25, 2025 Joint Meeting L – Public Comments
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APPROVALS:

Department Head Approval: Approval Date: 4.2.25
CEQA Determination (Planning): Approval Date: 4/2.25
The proposed action is consistent with CEQA Regulations ( 14 CCR §15183), which include a special environmental review process for projects that are consistent with the General Plan and whose potential impacts have been studied in a previously certified Environmental Impact Report.

Administrative Services (Financial) Approval Date:_____N/A_____________ Costs authorized in City Approved Budget: ☐ Yes ☐ No  N/A Account Code (f applicable) ___________________________ City Attorney Approval: Approval Date: 4.7.25
City Manager Approval: Approval Date: 4.7.25
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Attachment A
Description of Each Hotel Space

1. Ground Floor On-site Restaurant / Patio space:
a. Characteristic: Open to hotel guests and the public. Will serve breakfast, lunch, and dinner.
b. Approximate square footage: 1,473 SF
c. Maximum occupancy & Approximate Seats: 99 occupants; 53 seats interior + 12 patio = 65 seats
d. Approximate hours of operation: 7 days a week - 7am - 10pm e. Approximate Employees/Staff: 10-12
f. Will serve alcohol and be managed by the designated food/alcohol management company. Will provide room service to hotel rooms.

2. Ground Floor Interior/Lobby Bar
a. Characteristic: Open to hotel guests and the public. b. Approximate square footage: 721 SF
c. Maximum occupancy & Approximate Seats: 49 occupants; 31 seats interior + 12 patio = 43 seats
d. Approximate hours of operation: 7 days a week - 10am - 10pm e. Approximate Employees/Staff: 2
f. Will serve alcohol and be managed by the designated food/alcohol management company.

3. Rooftop Pool Café Bar
a. Characteristic: Open to hotel guests and the public at the discretion of Hotel Management company.
b. Approximate square footage: 1,027 SF
c. Maximum occupancy & Approximate seats: 69 max occupants; approximately 18 seats
d. Approximate hours of operation: 7 days a week - 11am - 9pm. Acoustic music if applicable 11am - 8pm.
e. Approximate Employees/Staff: 2
f. Will serve alcohol and be managed by the designated food/alcohol management company.

4. Rooftop Pool and Pool Deck
a. Characteristic: The swimming pool and pool deck are for Hotel Guests only. b. Approximate square footage: approximately 6,788 SF
a. Maximum occupancy: Per Building Code. Seating/lounge areas for about 50-60 Hotel Guests is planned.
b. Hours of Operation: 24/7 for Hotel Guests only
c. Approximate Employees/Staff: 2
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5. Ground Floor Meeting Room
a. Characteristic: Hotel Guests Private Events Only. Available for community meetings when not in use by Hotel Guests.
b. Approximate square footage: 1,494 SF
c. Maximum occupancy: 100 occupants
d. Hours of Operation: Pending event type at the discretion of Hotel Management. e. Approximate Employees/Staff: Pending event type at the discretion of Hotel Management.

6. Ground Floor Conference Room
a. Characteristic: Hotel Guests Private Events Only. Available for community meetings when not in use by Hotel Guests.
a. Approximate square footage: 942 SF
b. Maximum occupancy: 62 occupants
c. Hours of Operation: Pending event type at the discretion of Hotel Management. d. Approximate Employees/Staff: Pending event type at the discretion of Hotel Management.

7. Retail Space
a. Characteristic: Leased to a future retail tenant to match similar commercial tenants throughout the Barlow
b. Approximate square footage: 936 SF
c. Maximum occupancy: 16 occupants
d. Hours of Operation: Pending future retail tenant.
e. Approximate Employees/Staff: Pending future retail tenant.

8. Spa Area including circulation space and Spa Courtyard a. Characteristic: Managed by the hotel management company and open to hotel guests and the public.
b. Approximate square footage: approximately 5,891 SF including the courtyard c. Maximum occupancy: 99 max occupants including courtyard area d. Hours of Operation: 8am - 8pm and at the discretion of the hotel management company.
e. Approximate Employees/Staff: Up to 13

9. Hotel Parking and Batch Plant Parking
a. Hotel Valet Service – approximate hours of operation: 7 days a week - 8am - 8pm.

The majority of hotel guests will be required to valet. Valet service will park cars at Batch Plant Parking Lot.
b. Hotel Guests - 18 stalls will be onsite adjacent to the hotel for Hotel and Spa Guests.
c. Hotel Employees - All Hotel employees will park at the Batch Plant Parking Lot d. Barlow Employees - Batch Plant Parking lot will have designated spaces for Barlow Employees. This frees up space within the Barlow for customers and public. e. EV Charging stations will be located at the Batch Plant Parking Lot Agenda Item Number 10 Agenda Item Number: 10
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THE BARLOW HOTEL PROJECT
CEQA Section 15183 Environmental Review
Consistency Checklist
Prepared for January 2025
City of Sebastopol
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THE BARLOW HOTEL PROJECT
CEQA Section 15183 Environmental Review
Consistency Checklist
Prepared for January 2025
City of Sebastopol
2600 Capitol Avenue
Suite 200
Sacramento, CA 95816
916.564.4500
esassoc.com
Atlanta
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Palm Beach County
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Pensacola
Petaluma
Portland
Rancho Cucamonga
Sacramento
San Diego
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Santa Barbara
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Seattle
Tampa
Thousand Oaks
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OUR COMMITMENT TO SUSTAINABILITY | ESA helps a variety of public and private sector clients plan and prepare for climate change and emerging regulations that limit GHG emissions. ESA is a registered assessor with the California Climate Action Registry, a Climate Leader, and founding reporter for the Climate Registry. ESA is also a corporate member of the U.S. Green Building Council and the Business Council on Climate Change (BC3). Internally, ESA has adopted a Sustainability Vision and Policy Statement and a plan to reduce waste and energy within our operations. This document was produced using recycled paper.

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The Barlow Hotel Project i ESA / D202301440
CEQA Section 15183 Environmental Review Consistency Checklist January 2025

CONTENTS
CEQA Section 15183 Environmental Review
Consistency Checklist
Page
Introduction ....................................................................................................................................... 1 Project Description ........................................................................................................................... 2 Introduction ................................................................................................................................ 2 Project Location ......................................................................................................................... 2 Land Use Designation and Zoning............................................................................................. 5 Project Description..................................................................................................................... 7 City of Sebastopol General Plan Update and Final EIR ............................................................... 12 Terminology Used in This Document............................................................................................ 12 GPU FEIR and GPU DEIR....................................................................................................... 12 Planning Area........................................................................................................................... 13 Summary of Findings...................................................................................................................... 13 CEQA Section 15183 Environmental Review Consistency Checklist......................................... 15

1. Aesthetics ....................................................................................................................... 16

2. Agriculture and Forestry Resources ............................................................................... 19

3. Air Quality ....................................................................................................................... 21

4. Biological Resources ...................................................................................................... 27

5. Cultural Resources ......................................................................................................... 34

6. Energy ............................................................................................................................ 39

7. Geology and Soils........................................................................................................... 41

8. Greenhouse Gas Emissions ........................................................................................... 45

9. Hazards and Hazardous Materials.................................................................................. 49

10. Hydrology and Water Quality .......................................................................................... 56

11. Land Use and Planning................................................................................................... 63

12. Mineral Resources.......................................................................................................... 66

13. Noise and Vibration ........................................................................................................ 68

14. Population and Housing.................................................................................................. 75

15. Public Services ............................................................................................................... 77

16. Recreation ...................................................................................................................... 80

17. Transportation................................................................................................................. 82

18. Tribal Cultural Resources ............................................................................................... 89

19. Utilities and Service Systems.......................................................................................... 91

20. Wildfire............................................................................................................................ 96 Agenda Item Number 10 Agenda Item Number: 10
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Contents
The Barlow Hotel Project ii ESA / D202301440
CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Appendices
A. Project Plans
B. Air Quality and Greenhouse Gas Model Outputs
C. Biological Assessment for Parking Lot Site
D. Historical Resources Evaluation Report
E. DTSC EnviroStor SWRCB GeoTracker Database Search Results F. Barlow Hotel Project CEQA Transportation Assessment
Figures
Figure 1 Regional Location ........................................................................................................ 3 Figure 2 Project Site................................................................................................................... 4 Figure NOI-1 Noise Measurement Locations................................................................................... 70 Tables
Table 1 Project Parcel Information............................................................................................ 2 Table AQ-1 Construction Emissions.............................................................................................. 22 Table AQ-2 Daily and Annual Operational Emissions ................................................................... 23 Table AQ-3 Modeled Maximum Cancer Risk, Chronic Hazard Index, and Annual Average PM2.5 Concentrations at the MEIR and MEIW Location ....................................... 25 Table GHG-1 Annual Project Construction GHG Emissions ............................................................ 46 Table GHG-2 Annual Project Operational GHG Emissions .............................................................. 47 Table NOI-1 Long-Term Ambient Noise Levels in the Project Site Vicinity..................................... 71 Table NOI-2 Short-Term Ambient Noise Levels in the Project Site Vicinity .................................... 71 Table NOI-3 Typical Maximum Noise Levels from Construction Equipment................................... 72 Table NOI-4 Vibration Levels for Construction Equipment ............................................................. 74 Table TR-1 Net Change in Regional VMT Using SCTA Model ..................................................... 86 Table TR-2 Net Change in Regional VMT..................................................................................... 87 Agenda Item Number 10 Agenda Item Number: 10
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The Barlow Hotel Project 1 ESA / D202301440
CEQA Section 15183 Environmental Review Consistency Checklist January 2025

THE BARLOW HOTEL PROJECT
CEQA Section 15183 Environmental Review
Consistency Checklist
Date: January 2025
Project Title: The Barlow Hotel Project
GP Designation: Light Industrial (LI)
Density: 12.1 to 25 units per acre
Zoning: Hotel Site: Commercial Industrial (CM)
Parking Lot Site: Industrial (M) and Environmental and Scenic Open Space (ESOS) Combining District
Applicant: Aldridge Development, Inc
Staff Contact: John Jay, Associate Planner
City of Sebastopol Planning Department
(707) 823-6167
[email protected]
Introduction
California Public Resources Code Section 21083.3 and California Environmental Quality Act (CEQA) Guidelines Section 15183 provide an exemption from additional environmental review for projects that are consistent with the development density established by existing zoning, community plan, or general plan policies for which an Environmental Impact Report (EIR) was certified, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. Section 15183 specifies that examination of environmental effects shall be limited to those effects that (1) are peculiar to the project or the parcel on which the project would be located, and were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent; (2) are potentially significant off-site impacts and cumulative impacts that were not discussed in the prior EIR prepared for the general plan, community plan, or zoning action; or (3) are previously identified significant effects which, as a result of substantial new information that was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR. Section 15183(c) further specifies that if an impact is not peculiar to the parcel or to the proposed project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, then an additional EIR need not be prepared for that project solely on the basis of that impact. Accordingly, this document comprises a statement of reasons for exemption from additional environmental review under CEQA for the proposed Barlow Hotel Project in the City of Sebastopol.

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CEQA Section 15183 Environmental Review Consistency Checklist The Barlow Hotel Project 2 ESA / D202301440
CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Project Description
Introduction
The Barlow Hotel Project (“proposed project” or “project”) is a component of the Barlow market district, which is a 12.6-acre mixed use retail, restaurant, and light industrial development that was approved in 2009. The Barlow Hotel Project consists of a proposed hotel with up to 83 rooms, with a ground floor restaurant, bar, retail space, spa, gym, as well as meeting rooms and internal courtyards, a parking lot, and ancillary improvements on portions of other parcels. The project is intended to add to the diversity of uses at the existing Barlow market district in downtown Sebastopol and provide support for Barlow industrial producers and retailers as well as surrounding Sebastopol businesses. The project would be approved via a Development Agreement.

Project Location
The project site includes a hotel site at 6782 Sebastopol Avenue and a separate parking lot site at 385 Morris Street. Collectively, the project site includes the primary hotel, with additional uses in or on the hotel structure as is set forth herein, and parking lot components and related areas for utilities, landscaping, other minor improvements, and construction staging. Table 1 identifies all parcels and portions of parcels where the project would occur:

TABLE 1

PROJECT PARCEL INFORMATION
Name/
Description Project Component APN
Project Development
Acreagea Owner
General Plan
Land Use
Designation Zoning
Hotel Parcel Hotel Structure 004-750-030 1.23 Highway
Partners, LCC
Light Industrial
(LI)
Commercial
Industrial (CM)
Former Batch
Plant
Parking and electric
vehicle charging stations 004-011-017 1.4
Sebastopol
Industrial
Park, LCC
Light Industrial
(LI)
Light Industrial
(LI) with ESOS
combining
Former Batch
Plant
Parking and electric
vehicle charging stations 004-011-020 1.5
Sebastopol
Industrial
Park, LCC
Light Industrial
(LI)
Light Industrial
(LI) with ESOS
combining
McKinley
Street Landscaping and sidewalk 004-750-019 0.46
Sebastopol
Industrial
Park, LCC
Light Industrial
(LI)
Commercial
Industrial (CM)
Co-op Parcel Landscaping and sidewalk 004-750-034 0.90 Barlow Star, LLC
Light Industrial
(LI)
Commercial
Industrial (CM)
Gravenstein
Court
Demolish part of parking
lot, valet access to hotel,
parking, utilities,
landscaping
004-750-020 0.21
Sebastopol
Industrial
Park, LCC
Light Industrial
(LI)
Commercial
Industrial (CM)
NOTES:
a. Indicates the approximate acres of development that would occur within each parcel for the specified project component.

SOURCE: Aldridge Development, 2024; Adobe Associates, Inc, 2024.

Figure 1 shows the regional location for the project. Figure 2 shows the hotel and parking lot sites and the construction staging areas.

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Project Site
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Santa Rosa
Sebastopol
Rohnert Park
Cotati
Path: U:\GIS\GIS\Projects\2023xxx\D202301440_Barlow_Development\Fig1_RegLoc.mxd, RTeitel 5/9/2024 SOURCE: ESRI Barlow Hotel Project
Figure 1
Regional Location
Sebastopol
Geyserville
Napa
Vallejo
Antioch
Oakland
San
Francisco
Fairfield
Area of
Detail
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Morris St
Laguna Park Way
McKinley St
Depot St
Brown St
Petaluma Ave
Sebastopol Ave
Laguna Park Way
Johnson St
Flynn St
Morris St
Laguna Park Way
McKinley St
Depot St
Brown St
Petaluma Ave
Sebastopol Ave
Laguna Park Way
Johnson St
Flynn St
Laguna
de Santa Rosa
Laguna
de Santa Rosa
Parking Lot Site
Barlow Market
District
Hotel
Site
Construction Staging Area
approximately 2,000 square feet
Construction Staging Area
approximately 1,500 square feet
Barlow Market
District
Hotel
Site
Construction Staging Area
approximately 1,500 square feet
Figure 2
Project Site
0 200
Feet N
SOURCE: Aldridge Development, 2024; ESA, 2024; Google Earth, 2024 Barlow Hotel Project 2023/D202301440.00 - Barlow Development Agreement Project/05 Graphics-GIS-Modeling/Illustrator Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The Barlow market district (or “the Barlow”) is a 12.4-acre pedestrian-oriented development with a wide range of uses, with most square footage occupied by industrial uses, but also including retail shops; artisan restaurants, cafes, and food producers; a community-based supermarket; premium wine, beer, and cider-makers; and other uses. In addition, music and other special events are regularly conducted. The Barlow is a destination for Sebastopol-area residents as well as visitors to the area. There are approximately 36 tenants in the Barlow, ranging from one tenant occupying less than 230 square feet to a winery occupying over 60,000 square feet. Total building square footage in the Barlow is approximately 222,000 square feet in 18 buildings. Industrial space comprises approximately 61 percent of the Barlow square footage; food and beverage comprise 23 percent; office comprises 7 percent; retail and service uses comprise 5 percent; and vacant, common, and property management comprise approximately 4 percent of the total square footage.

The hotel structure would replace the existing 36,402-square-foot Guayakí organic beverage company warehouse building, which spans from Sebastopol Avenue to McKinley Avenue. The parking lot site was formerly a concrete batch plant. Equipment associated with that former use was removed several years ago and most of the parking lot site is paved.

The Barlow is located just east of downtown Sebastopol. To the north are industrial uses along Morris Street. Land uses on the east side of Morris Street include a combination of office, industrial, and utility uses; the Laguna Preserve public park; and the Sebastopol Community Cultural Center. Across Depot Street and across Sebastopol Avenue are a variety of commercial uses, with one retail site having townhomes behind it. Further east on Sebastopol Avenue is a single-family residence, with rental units behind it, as well as the City-owned Park Village mobile home park. Sebastopol Avenue is State Route 12 (SR-12). To the north across Laguna Park Way is the City’s Skategarden park and residential uses.

Riparian habitat is present to the north and east of the parking lot site in association with the Laguna de Santa Rosa, which is the largest freshwater wetlands complex on the northern California coast. The Laguna’s 14-mile channel forms the largest tributary to the Russian River, draining a 254-square-mile watershed which encompasses nearly the entire Santa Rosa Plain. This includes parts of the communities of Windsor, Santa Rosa, Rohnert Park, Cotati, Forestville, and Sebastopol.

Land Use Designation and Zoning
The proposed project is consistent with the Sebastopol General Plan and would be approved through a Development Agreement.

The project site (both the hotel site and parking lot site) is designated as Light Industrial (LI) on the City of Sebastopol General Plan Land Use Map. The LI designation provides for a wide variety of commercial, wholesale, service, and processing uses. Other uses allowed in this designation include office ancillary to industrial uses; warehousing and agricultural products sales and services; auto sales and repair; food and drink processing; construction yards; research and development, laboratories; light manufacturing; and similar uses. Residential uses are permitted as a secondary use to the primary light industrial uses allowed in this land use designation at a density of 12.1 to 25 units per acre. Maximum floor area ratio (FAR) shall not exceed 0.75 (excluding residential use). The General Plan does not include height limits for the Office/Light Industrial land use designation. Moreover, General Plan Policy CD 1-11 allows additional height for projects that encourage and support the inclusion of quasi-public spaces in new developments, Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 as the proposed project does with the dedication of open space for the extension of the AmeriCorps Trail, and public overlook, and parking for the open space and trail uses. This policy requires additional height to be consistent with the surrounding area, which is the case here since the site is directly adjacent to the Central Core where taller 50-foot buildings are permitted and encouraged.

General Plan Action Item LU 1d called for an amendment to the City’s Zoning Code to clarify whether hotels are residential or commercial uses. As a result, Zoning Code Section 17.08.100, which was adopted on October 16, 2018, states that “Hotel” means a residential building other than a bed and breakfast inn containing six or more guest rooms which are used, rented, or hired for sleeping purposes by transient guests or travelers for generally less than 30 consecutive days. Further, the proposed hotel is a secondary use to the overall Barlow market district, which is described above under Project Location.

The hotel site is zoned Commercial Industrial (CM) in the City of Sebastopol Zoning Code (Title 17 of the City of Sebastopol Municipal Code). The CM District is intended to encourage local production, innovation, and sales of local art, textile, food, beverage, and other tangible goods by allowing a range of complementary, community-oriented building types and spaces that accommodate small- and mid-size makers, fabricators, producers, and manufacturers, as well as specified commercial, residential, and other uses. The City of Sebastopol Zoning Code defines hotels as residential uses. The maximum FAR (not including residential uses) in the CM District is 0.75. The maximum building height is 35 feet (two stories). Up to four stories and up to 50 feet in height are allowed for projects with residential uses, including hotel rooms, on upper floors, provided the City of Sebastopol Planning Commission finds that the project is consistent with the General Plan and compatible with the uses authorized in and regulations for the district in which it is located.

These findings will be considered by the Planning Commission through a Development Agreement, rather than a conditional use permit. A Development Agreement allows the City to approve projects that provide benefits to the city but do not conform to the strict provisions of the zoning regulations if they are compatible with uses permitted in the district. Here, the proposed project is consistent with the permitted uses in both the General Plan LI designation and the CM zoning district. The project is also consistent with the LI density of 12.1 to 25 units per acre and the LI and CM maximum FAR of 0.75. The project height exceeds the CM District 50 feet by 5 feet but is consistent with the General Plan and with General Plan Policy CD 1-11 which contemplates height exceedances.

The parking lot site is zoned Industrial (M) and Environmental and Scenic Open Space (ESOS) Combining District. The purpose of the M District is to implement the industrial land use category of the General Plan and to provide areas for the manufacture, assembly, packaging, or storage of products which are not harmful, injurious, or detrimental to property or the general welfare of the City and its residents; and other general commercial and residential uses that are compatible with the industrial uses. The purpose of the ESOS Combining District is to control land use within areas of great scenic or environmental value to the citizens of the Sebastopol General Plan area. The ESOS Combining District is applicable to areas bordering the Laguna de Santa Rosa, including the parking lot site, and 1.2 acres of the parking lot site that is disturbed and paved would be used for the parking lot. The remaining 1.7acres of the parking lot site, including all of the currently undisturbed area, would be preserved, and an irrevocable offer of dedication would be provided to the City for the extension of the AmeriCorps Trail. The uses allowed in the ESOS Combining District include parking associated with the open space and, with a conditional use Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 permit, all uses allowed in the underlying zoning district. Parking facilities are allowed in the M district with a conditional use permit. The Planning Commission will consider the conditional use permit findings through a Development Agreement rather than a conditional use permit.

Project Description
Project Objectives
• Strengthen and enhance the diversity of uses and economic activity at the Barlow and in Sebastopol’s downtown by constructing a high-quality, architecturally unique hotel with associated commercial uses all of which are in compliance with relevant policies in the Sebastopol General Plan. • Design the project in a manner that reflects the unique and diverse character of Sebastopol. • Support the Barlow’s Sonoma County artisan producers making local food, cheese, bread, wine, beer, and crafts onsite, as well as the local farm market. These producers rely on selling their goods directly to customers, and Barlow’s goal with this project is to bring additional customers to the area to help these producers thrive, thereby bolstering and preserving the Barlow’s industrial character as well as supporting Sebastopol’s and West Sonoma County’s economic vitality. • Create an additional unique local venue for weddings, small conferences, and other events within the hotel structure.
• Protect existing environmental resources of the project sites, including native oak trees, wetlands, and sensitive species at the former batch plant site by limiting development at that site to the previously developed/disturbed portion of the site, and by maintaining appropriate setbacks from the preserved area of the property.
• Minimize visual impacts of the project through careful siting, varied building massing, the use of a rich blend of building materials and colors, and lighting that does not intrude on surrounding areas, while also providing visual amenities for visitors and residents. • Minimize traffic by enhancing the mix of uses in the Barlow and downtown area, promoting a ‘park once’ strategy, and by developing in an existing pedestrian-oriented area.

Project Components
Hotel
The proposed project would include demolition of the existing 36,402-square-foot Guayakí organic beverage company warehouse building at 6782 Sebastopol Avenue and construction and operation of a hotel with associated ground floor restaurant, bar, events, retail, gym, spa, and meeting room uses and a rooftop bar. In addition, there would be a kitchen serving the restaurant, bars, meeting rooms, and guest rooms, as well as other ‘back of house’ uses, including restrooms, storage, and equipment rooms.

The hotel restaurant, indoor bar, rooftop café/bar, retail, spa, and meeting/event rooms would be open to the public. The restaurant would be open seven days a week, from 7 a.m. to 10 p.m. The ground floor lobby bar would be open seven days a week from 10am up to 10 p.m. The spa would also be open seven days a week from about 8 a.m. up to 8 p.m. The meeting rooms would be open seven days a week from about 8 a.m. up to 10 p.m. The rooftop café/bar would be open seven days a week from approximately 11 a.m. up to 9 p.m. There would be a rooftop pool, which would be open 24/7 for hotel guests only.

The rooftop café/bar would include acoustical and other non-amplified sound.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 It is anticipated that the hotel, including staffing for hotel, restaurant, bars, retail, gym, spa, and meeting room uses, would include up to 50 employees with up to 10 extra employees for events.

The gross square footage of the hotel structure would be approximately 82,275 square feet with a net square footage of approximately 69,934 square feet. 1 A detailed breakdown of square footages for hotel components is included in Appendix A, Project Plans. The hotel would be in a four-story, 55-foot-high building, with up to 83 guestrooms, with architectural features that would not exceed 65 feet in height. 2 The hotel would be constructed and operated in compliance with all other applicable requirements of the City of Sebastopol Zoning Code.

All hotel rooms and most of the other square footage would be located a minimum of two feet above the 100-year flood elevation in compliance with City flood protection regulations. Any non-residential areas below this level would be protected with flood barriers in the event of projected flooding.

The proposed project would include demolition of portions of the existing parking lot directly east of the existing warehouse building (or, generally, the “hotel site”), which would reduce the number of parking spaces on this parking lot from 87 to 73 (a reduction of 14 spaces). Twelve bicycle parking spaces would be provided at the hotel site for use by guests, visitors, and staff. To help reduce vehicle trips, hotel workers would be offered bus passes at no cost to employees. See Summary of Proposed Parking Facilities below for a discussion of the proposed parking program for the overall proposed project.

The hotel is conceived as a unique destination with a distinct identity and image yet complimenting the rest of the Barlow district. The architectural design of the proposed hotel is inspired by the regional vernacular, specifically farmhouses and local agricultural buildings found in the surrounding wine country. The adjacent Gravenstein Court parking lot would be enhanced to include a grove of trees, extending the rural character beyond the footprint of the structures.

The proposed hotel building is organized around a sequence of five landscaped courtyards, each with a distinct image and character, together creating a visual and experiential sequence between open-to-sky and covered spaces. The proposed hotel building has three entrances: along McKinley Street via a covered paseo, along Gravenstein Court from the drop-off area, and at Sebastopol Avenue. Both the McKinley Street and Gravenstein Court entries would lead visitors into the first large courtyard from where they would enter the lobby, bar, and restaurant.

The hotel rooms would be configured around single-loaded arms overlooking the courtyards. The public functions of the hotel, such as the restaurant, meeting rooms, bar, and kitchen would be situated closer to McKinley Street, around the entrance courtyard. The restaurant would wrap around to line the street, along with more retail to enliven the pedestrian experience. The hotel spa would be located along and entered within the hotel, with another entrance from Sebastopol Avenue. 1 Gross square footage (GSF) is the total space a building takes up. The GSF does not include courtyards or any roof deck elements which are not covered by a roof. GSF includes all of the area inside the building, including unusable space between walls. Net square footage (NSF) includes only the areas of the building that are accessible by the user or tenant. NSF does not include corridors or vertical circulation (stairs and elevators). 2 The current design shows the tallest building element (mechanical penthouses that shelter the building's elevators) to be approximately 62 feet. The height of the proposed building is measured from average grade height to top of roof assembly.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The building’s highest massing would comprise a fourth-story rooftop bar, which would be located in the least visible part of the site. The rest of the building would be a combination of two and three stories. This varied design is intended to provide a human-scale massing as opposed to a single monolithic building. The building would include a combination of flat and sloping roofs of varying slopes and materials.

Batch Plant Parking Lot
The proposed project includes development of a parking lot on the 2.9-acre site of the former concrete batch plant at 385 Morris Street. As previously noted, equipment associated with that former use was removed several years ago. Approximately 2.06 acres of the site are currently either disturbed or paved.

The site is currently vacant and used for overflow Barlow parking for events and temporary vehicle storage. The project would add 232 parking spaces to the former batch plant site. Some of these spaces would be valet spaces reserved for hotel guests. Eighteen of the new parking stalls would have electric vehicle (EV) chargers. The proposed parking lot would also include 20 bicycle parking spaces. The proposed parking lot would supply parking for the hotel, events at the hotel, and the Barlow generally.

A small maintenance shed would be located on the parking lot site.

The proposed project includes the addition of bioswales, engineered drainage systems, and native plants for landscaping on the parking lot. Parking lot lighting would be the minimum necessary for safety, to comply with ‘dark sky’ objectives, and to minimize impacts on wildlife.

The easterly portion of the parking lot site, which was not actively used by the former batch plant, comprises approximately 0.84 acres and would remain undeveloped and protected with a 50-foot setback from the areas of concern in the Laguna de Santa Rosa in compliance with the City of Sebastopol Zoning Code.

While specifics would be set by the hotel operator, the minimum valet parking is planned to operate seven days a week, from 8 a.m. to 8 p.m. and by hotel front desk staff in off hours. It is anticipated that there would be two employees for valet operations during the 12 staffed hours. Hotel guests could also selfpark at the parking lot.

Irrevocable Offer of Dedication
The project includes an irrevocable offer of dedication for an easement for an existing public trail (a portion of the AmeriCorps Trail) which is located on the undeveloped portion of the project site. The precise location of the trail would be set forth in the Development Agreement.

Parking Compliance with Zoning Code
As discussed above, the proposed project includes demolition of portions of the existing parking lot directly east of the existing warehouse building, which would reduce the number of parking spaces on this parking lot from 87 to 73 (a reduction of 14 spaces). The project would add 232 parking spaces to the former batch plant site, which is currently vacant and includes no developed parking facilities. and operated in compliance with the applicable requirements of the City of Sebastopol Zoning Code, including required use, setbacks, and other development parameters. Therefore, the project would include 218 net new vehicle parking spaces. Twelve bicycle parking spaces would be provided at the hotel site for use by guests, visitors, and staff, and 20 bicycle parking spaces would be included at the parking lot at the former batch plant site, resulting in the addition of 32 new bicycle parking spaces. Finally, 18 of the new parking stalls at the parking lot at the former batch plant site would have EV chargers.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Utilities
Water
The City of Sebastopol would provide water service to the hotel building via an existing 8-inch water supply main in Sebastopol Avenue. No off-site improvements to the existing water mains are needed to serve the hotel building. The water line to the hotel building would be slightly relocated as is shown on the project plans (see Appendix A), but an 8-inch supply pipe would continue to serve the hotel building.

No new water supply infrastructure is proposed for the parking lot site.

Wastewater
Wastewater generated by the hotel building would be collected by the City of Sebastopol’s sewer system via an 8-inch main located in Sebastopol Avenue. No off-site improvements to the existing sewer mains are needed to serve the hotel building. The 8-inch main located in Sebastopol Avenue would be slightly relocated as is shown on the project plans (Appendix A), but an 8-inch main would continue to serve the hotel building. No new wastewater infrastructure is proposed for the parking lot site.

Storm Drainage
Storm drainage facilities that are owned and maintained by the City of Sebastopol would serve the hotel building (with facilities located in McKinley Street) and the parking lot site (with facilities located in Morris Street). Storm water on both the hotel building and parking lot site would be managed with a combination of Low Impact Development (LID), storm water quality treatment, and flood control measures. These measures would include, but are not limited to, planting new trees, handling roof downspouts, and installing bioretention areas. Storm water on the project site (i.e., the two locations that primarily comprise the project site) would be directed to on-site bioretention areas. No off-site improvements to the existing drainage infrastructure are needed to serve the proposed project, including both the hotel building and parking lot sites.

Natural Gas Service
The hotel parcel is currently served by existing natural gas lines. The existing service to the building would be relocated as required by building code and Pacific Gas and Electric Company (PG&E) requirements.

Electrical Service
Electrical service to the hotel and parking lot site would be provided by PG&E via existing infrastructure in the project area. No off-site improvements to existing electrical infrastructure are needed at this time.

Tree Program
Hotel Site
As described above, the proposed project would include demolition of the existing parking lot directly east of the existing warehouse building. This would include removal of the existing trees in the parking lot. Approximately 36 larger trees and 27 smaller trees in the existing parking lot would be removed.

Construction of the hotel building would require the removal of two protected trees directly to the west of the existing warehouse building (on APN 004-750-034). As indicated in the tree report prepared for the proposed project (discussed and cited in Section 4, Biological Resources, of this document), these protected trees (as defined in the City Tree Protection Ordinance) include a valley oak with a 27-inch diameter and a Hankow willow with a 10.2-inch diameter. While the willow is a protected tree, it is nonnative, and, as a result, the City Tree Protection Ordinance threshold for protection is 20-inches in diameter. As discussed in the tree report, given the location of the trees and the necessary excavation required for the hotel, preservation of these trees is not possible and, as a result, the trees would be removed to accommodate the hotel building. The removal of these two protected trees would be approved via the Development Agreement.

Parking Lot Site
No trees are proposed for removal at the parking lot site. The proposed project would add 40 mixed live and valley oaks, eight valley oaks as street trees, 14 large canopy riparian trees (in bioswales and bioretention areas), and 60 small understory native and/or riparian trees at the parking lot site.

Project Construction
Project construction is anticipated to start in 2026 and could start as early as 2025, depending on the entitlement process and the City’s review of building permit and other ministerial applications.

Construction of the hotel is estimated to occur over a duration of 18 months and include approximately 75 peak daily construction workers. Construction of the parking lot is estimated to occur over a duration of 90 days and include approximately 6 peak daily construction workers. Construction activities would occur between 7 a.m. and 5 p.m., Monday through Saturday. Construction activities would include demolition of the existing 36,402-square-foot Guayakí organic beverage company warehouse building on the hotel site; site preparation, including grading and excavation on the hotel and parking lot sites; and development of the hotel and parking lot. The maximum depth of excavation for the hotel is anticipated to be 5 feet below ground surface. The maximum depth of excavation for the parking lot is anticipated to be 4 feet below ground surface. Construction staging for the hotel would be located at the east end of Depot Street, immediately west of the Guayakí warehouse building, and on the parking spaces immediately east of the Guayakí warehouse building. Construction staging for the parking lot would be located on the parking lot site. Parking for construction worker vehicles would be located on the parking spaces immediately east of the Guayakí warehouse building and on the parking lot site. All construction equipment would meet Tier 4 emission standards.3
3 Tier 4 standards are emission standards created by the California Air Resources Board and the U.S. Environmental Protection Agency (EPA). These standards apply to new engines used in heavy equipment and off-road machinery used in several industries, including mining, construction, and agriculture. Tier 4 standards target two exhaust pollutants. The first is particulate matter (PM), which contains soot and other unconsumed hydrocarbons. The second is NOx, a chemical compound made up of nitrogen and oxygen. NOx is the main pollutant in smog.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Required Project Approvals
The hotel site fronts Sebastopol Avenue, a State Highway (SR-12), so any frontage improvements (sidewalks, driveways, utilities) would require a California Department of Transportation (Caltrans) encroachment permit. Alcohol uses would require permits from the California Department of Alcoholic Beverage Control (ABC). Required discretionary project approvals are listed below. • CEQA Compliance
• Ordinance Approving Development Agreement
• Development Agreement
City of Sebastopol General Plan Update and Final EIR
The City of Sebastopol General Plan Update (GPU) is a comprehensive, long-term general plan for the physical development of the City’s Planning Area. The GPU Final EIR (GPU FEIR) was certified in conjunction with adoption of the GPU on November 15, 2016. The GPU FEIR comprehensively evaluated environmental impacts that would result from implementation of the GPU, including information related to existing site conditions, analyses of the types and magnitude of project-level and cumulative environmental impacts, and that the GP EIR included analysis of project-level impacts and feasible mitigation measures that could reduce or avoid environmental impacts.

Terminology Used in This Document
GPU FEIR and GPU DEIR
For the reasons explained in this subsection, this document references both the GPU FEIR and the GPU Draft EIR (GPU DEIR).

In accordance with CEQA, the GPU DEIR described and analyzed the environmental effects of implementing the GPU and discussed ways of mitigating or avoiding potentially significant effects, where feasible. The Draft GPU and the GPU DEIR were made available for public review from May 23, 2016, through July 8, 2016. In accordance with CEQA, the GPU FEIR was prepared to address comments received in response to the GPU DEIR and included textual changes to the GPU DEIR, where warranted.

Responses to comments received during the comment period did not involve any new significant impacts or significant new information that required recirculation of the GPU DEIR pursuant to CEQA. The GPU FEIR was certified in conjunction with adoption of the GPU on November 15, 2016 (State Clearinghouse [SCH] Number 2016032001).

Because the GPU DEIR contains the primary environmental analysis that supports the GPU FEIR, this document makes frequent reference (by impact number and page numbers) to the GPU DEIR. These references to the GPU DEIR incorporate any and all revisions to the GPU DEIR contained in the certified GPU FEIR. References in this document to the GPU FEIR refer to the certified EIR for the adopted GPU, including all textual changes to the GPU DEIR.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Planning Area
As described on pages 2-1 to 2-2 of the GPU Land Use Element and shown on GPU Figure 2.1, General Plan Land Use Map, the Sebastopol Planning Area consists of the incorporated City limits, the City’s Sphere of Influence (SOI), and the City’s Urban Growth Boundary (UGB).

Summary of Findings
A comprehensive environmental evaluation has been completed for the proposed project as allowed by PRC Section 21083.3 and as further clarified by CEQA Guidelines Section 15183. This evaluation concludes that the proposed project is consistent with the development density and use characteristics established by the City of Sebastopol GPU, as analyzed by the GPU FEIR and, thus, no additional environmental review is required.

In accordance with CEQA Guidelines Section 15183, the following findings can be made for the proposed project:

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

The project consists of a proposed hotel with up to 83 rooms with additional commercial uses in or on the hotel structure, a parking lot, and ancillary improvements on portions of other parcels. The project site (inclusive of the hotel site, parking lot site, and other associated landscaping, sidewalk, and utilities uses) is designated as Light Industrial (LI) on the City of Sebastopol General Plan Land Use Map. GPU Policy LU 1-4 specifies that the LI land use designation provides for a wide variety of commercial, wholesale, service, and processing uses that do not generate excessive adverse environmental impacts. Other uses allowed in this designation include office ancillary to industrial uses; warehousing and agricultural products sales and services; auto sales and repair; food and drink processing; construction yards; research and development, laboratories, light manufacturing; and similar uses. Residential uses are permitted as a secondary use to the primary light industrial uses allowed in this land use designation at a density of 12.1 to 25 units per acre. Maximum floor area ratio (FAR) shall not exceed 0.75 (not including the residential use). The proposed project is consistent with Policy LU 1-4 in that it includes residential and ancillary uses (commercial uses in the hotel and required parking). Hotels are considered a transient residential use under the City’s Zoning Ordinance. 4 Within the context of the Barlow development, including non-residential uses on the parcel where it would be developed, the residential uses are secondary to other uses. With regard to density, hotel rooms are not dwelling units in that they lack kitchens, which under the City's definition, must be present for the use to count as a residential unit.5 Therefore, the residential unit density standards do not apply to the proposed project. As noted above, because the hotel is a residential use, it is not subject to GPU FAR limits. The parking lot does not contain any floor area, with the exception of the small storage shed and, as such, is below the maximum FAR of 0.75. The proposed project is consistent with the General Plan.

It is anticipated that the Development Agreement for the proposed project will allow an extended term for the project approval; allow the project components, including proposed variations from specific zoning standards or procedures; approve Design Review; provide some allowance and 4 Sebastopol Municipal Code (SMC) Section 17.08.119. 5 As specified in Section 17.08.060 of the City of SMC, “Dwelling” or “dwelling unit” means a room or group of internally connected, habitable rooms that have sleeping, cooking, and sanitation facilities, but not more than one kitchen occupied by or intended for one household on a long-term basis. A “dwelling” is the same as an independent housekeeping unit.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 procedure for possible future modification of the project components; provide for streamlined plan checks; and modify the application or timing of some impact fee requirements.

2. There are no project specific effects which are peculiar to the project or its site.

As detailed in the CEQA Section 15183 Environmental Review Consistency Checklist included in this document, there are no project specific effects which are peculiar to the project or its site.

3. There are no project specific impacts which the GPU FEIR failed to analyze as significant effects.

As detailed in the CEQA Section 15183 Environmental Review Consistency Checklist included in this document, there are no project specific impacts which the GPU FEIR failed to analyze as significant effects.

4. There are no potentially significant off-site and/or cumulative impacts which the GPU FEIR failed to evaluate.

As detailed in the CEQA Section 15183 Environmental Review Consistency Checklist included in this document, there are no potentially significant off-site and/or cumulative impacts which the GPU FEIR failed to evaluate.

5. There is no substantial new information which results in more severe impacts than anticipated by the GPU FEIR.

As detailed in the CEQA Section 15183 Environmental Review Consistency Checklist included in this document, there is no substantial new information which results in more severe impacts than anticipated by the GPU FEIR.

6. The project will undertake any applicable mitigation measures specified in the GPU FEIR.

As detailed in the CEQA Section 15183 Environmental Review Consistency Checklist included in this document, there are no mitigation measures specified in the GPU EIR that are applicable to the proposed project. However, the proposed project would be constructed and operated in accordance with all applicable GPU policies.

Signature Date
Printed Name Title
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 CEQA Section 15183 Environmental Review Consistency
Checklist
The checklist below provides an analysis of potential environmental impacts resulting from implementation of the proposed project. Following the format of CEQA Guidelines Appendix G, environmental effects are evaluated to determine if the proposed project would result in a potentially significant impact triggering additional review under CEQA Guidelines Section 15183. • Items checked “Significant Project Impact” indicate that the proposed project could result in a significant effect that is peculiar to the proposed project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR. • Items checked “Project Impact not Identified by GPU FEIR” indicate that the proposed project would result in a significant project-specific impact that was not identified in the GPU FEIR. • Items checked “Off-Site or Cumulative Impact not Identified by GPU FEIR” indicate that the proposed project would result in a significant off-site or cumulative impact that was not identified in the GPU FEIR.
• Items checked “Substantial New Information” indicate that there is new information which leads to a determination that a project impact is more severe than what had been anticipated by the GPU FEIR.

As shown in the following checklist, none of the above items are checked. An analysis of potential environmental impacts resulting from the proposed project is provided in the checklist below for each environmental resource topic included in CEQA Guidelines Appendix G.

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1. Aesthetics
AESTHETICS — Except as provided in Public Resources
Code Section 21099, would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Have a substantial adverse effect on a scenic vista? No No No No b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway?
No No No No
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings (public views are those that
are experienced from publicly accessible vantage
point). If the project is in an urbanized area, would the project conflict with applicable zoning and other
regulations governing scenic quality?
No No No No
d) Create a new source of substantial light or glare which would adversely affect daytime or nighttime views in
the area?
No No No No
Discussion
a) Impacts related to scenic vistas that would result from implementation of the GPU were evaluated under Impact 3.1-1 on pages 3.1-1 to 3.1-23 of the GPU DEIR. The analysis determined that, while the City’s Planning Area contains numerous areas and viewsheds with relatively high scenic value, there are no officially designated scenic vista points in the Planning Area.

Additionally, the analysis determined that there are no officially designated scenic highways located in the City of Sebastopol. The analysis identified that significant visual resources in the Planning Area include views of agricultural land, grassland, woodlands, riverine, wetlands, and public art. These resources can be viewed from public vantage points, including highways, roads, open space areas, and private residences throughout the Planning Area. The analysis determined that buildout of the GPU would allow for new development to occur in areas that have historically been used for agricultural operations and areas that have been previously undeveloped. The analysis determined that the introduction of new development into previously undisturbed areas or areas that have been historically used for agricultural operations may result in potentially significant impacts to scenic resources or result in the degradation of the Planning Area’s visual character.

The analysis determined that implementation of the policies and programs contained in the GPU Land Use, Community Design, and Conservation and Open Space Elements would ensure that new urban residential and commercial development in the City’s Planning Area is located in and around existing urbanized areas and developed to be visually compatible with nearby open space resources, which would limit impacts to scenic resources. However, the analysis determined that even with the implementation of the policies and actions in GPU, the potential for new development to interrupt scenic views, particularly new industrial and commercial development on agricultural or undeveloped lands, would remain. The analysis determined that the only method to completely avoid impacts to scenic resources would be to severely limit the development potential on all undeveloped lands. The analysis determined that this type of mitigation is not consistent with the objective of the GPU to support local employment opportunities and expand the local jobs base.

Therefore, the analysis concluded that the impact would be significant and unavoidable.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 As described in the Project Description of this document, the proposed project would include demolition of the existing 36,402-square-foot Guayakí organic beverage company warehouse building at 6782 Sebastopol Avenue and construction and operation of a hotel with related parking, landscaping, and utilities improvements. The hotel would be a four-story, 55-foot-high, building with architectural features that would not exceed 65 feet in height.6 The proposed project would also construct and operate a parking lot on the site of the former concrete batch plant at 385 Morris Street. The proposed development sites are urbanized, and both sites have been previously developed. The hotel would replace an existing warehouse in relatively poor condition. The parking lot site, much of which is paved, is currently vacant and used for overflow Barlow parking for events and temporary vehicle storage. The sites are both urban infill areas, except that the parking lot site is adjacent to the Laguna de Santa Rosa (as well as adjoining industrial uses).

The proposed project has been designed to be consistent with the GPU (see discussion of plan consistency in Section 11, Land Use and Planning, of this document) and would conform with the City of Sebastopol Zoning Code in terms of use, setbacks, and other development parameters.

Therefore, the proposed project would not have a substantial adverse effect on a scenic vista. b) Impacts related to scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway that would result from implementation of the GPU were evaluated under Impact 3.1-1 on pages 3.1-1 to 3.1-23 of the GPU DEIR. The analysis determined that there are no officially designated scenic highways located in the City of Sebastopol. SR-12 and SR-116 are the principal highway corridors through the City’s Planning Area. The analysis determined that development under the GPU would allow primarily for infill commercial and industrial land uses along these highway corridors, primarily in areas that are currently urbanized. However, the analysis determined that buildout of the GPU has the potential to result in new and expanded development along highway corridors with high scenic values, even though these corridors are not officially designated as State Scenic Highways. The analysis determined that the only method to completely avoid impacts to scenic resources would be to severely limit the development potential on all undeveloped lands. The analysis determined that this type of mitigation is not consistent with the objective of the GPU to support local employment opportunities and expand the local jobs base. Therefore, the analysis concluded that the impact would be significant and unavoidable.

As discussed above, the proposed project has been designed to be consistent with the GPU (see discussion of plan consistency in Section 11, Land Use and Planning, of this document) and would conform with the City of Sebastopol Zoning Code in terms of use, setbacks, and other development parameters. Therefore, the proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
c) As discussed above, the proposed project has been designed to be consistent with the GPU (see discussion of plan consistency in Section 11, Land Use and Planning, of this document) and 6 The current design shows the tallest building element (mechanical penthouses that shelter the building's elevators) to be approximately 62 feet.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 would conform with the City of Sebastopol Zoning Code. Therefore, the proposed project would not conflict with applicable zoning and other regulations governing scenic quality. d) Impacts related to creation of new sources of substantial light or glare which would adversely affect daytime or nighttime views that would result from implementation of the GPU were evaluated under Impact 3.1-2 on pages 3.1-23 to 3.1-24 of the GPU DEIR. The analysis determined that the primary sources of nighttime lighting in the City’s Planning Area are generally from exterior building lights, streetlights, and vehicle headlights. The analysis determined that exterior lighting around commercial and industrial areas may be present throughout the night to facilitate extended employee work hours, ensure worker safety, and to provide security lighting around structures and facilities. The analysis determined that nighttime lighting impacts that would result from buildout of the GPU would be most severe in areas that do not currently experience high levels of nighttime lighting. The analysis determined that increased nighttime lighting can reduce visibility of the night sky, resulting in fewer stars being visible and generally detracting from the rural quality of life in Sebastopol. The analysis determined that the primary sources of daytime glare in the Planning Area are generally sunlight reflecting from structures and other reflective surfaces and windows. The analysis determined that implementation of the GPU would introduce new sources of daytime glare into previously undeveloped areas of the Planning Area and increase the amount of daytime glare in existing urbanized areas. The analysis determined that future development would be required to be consistent with the GPU, as well as lighting requirements in the Municipal Code. The analysis determined that the GPU contains policies and action items related to the regulation and reduction of daytime glare and nighttime lighting. The analysis concluded that, through the implementation of these policies and action items during the development review process, the City can ensure that adverse impacts associated with daytime glare and nighttime lighting are reduced to a less than significant level.

As discussed above, the proposed project has been designed to be consistent with the GPU, as well as the lighting requirements in the Municipal Code. It is further noted that the proposed parking lot site has no lighting but is adjacent to urban development to the south and west that does include external light sources. The Development Agreement includes a condition of approval that requires all parking lot lighting to meet the International Dark Sky Association standards. Consequently, new parking lot lighting would not be adding lights to an otherwise unlit area and thus would not result in new impacts or a substantial increase to any impact compared to existing conditions. Therefore, the proposed project would not create a new source of substantial light or glare which would adversely affect daytime or nighttime views in the area.

Conclusion
As discussed above, the proposed project would not result in effects related to aesthetics that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

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2. Agriculture and Forestry Resources
AGRICULTURE AND FORESTRY RESOURCES —
Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified in
the GPU FEIR
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?
No No No No
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
No No No No
c) Conflict with existing zoning for, or cause rezoning of, forest land (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))?
No No No No
d) Result in the loss of forest land or conversion of forest land to non-forest use?
No No No No
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
No No No No
Discussion
a) Impacts related to conversion of farmland that would result from implementation of the GPU were evaluated under Impact 3.2-1 on pages 3.2-6 to 3.2-8 of the GPU DEIR. The analysis determined that Sebastopol does not have any prime farmlands, unique farmlands, or farmlands of statewide importance within the City’s Planning Area, as designated by the California Department of Conservation Farmland Mapping and Monitoring Program. The analysis determined that portions of locally important farmlands may be converted to accommodate additional residential and industrial opportunities. However, the analysis concluded that, with implementation of GPU policies and actions that provide protection and preservation of agricultural lands, the impact would be less than significant impact.

The project site (both the hotel site and parking lot site) is designated as Urban and Built-Up Land by the California Department of Conservation Farmland Mapping and Monitoring Program (California Department of Conservation, 2024a). According to Figure 3.2-1 of the General Plan EIR, a portion of the parking lot site is mapped as Farmland of Local Importance. However, this portion of the site is beyond the 50-foot setback of Laguna de Santa Rosa and, therefore, would not be affected by the project. The proposed project would construct and operate a hotel and associated parking lot on development sites that are urbanized and have been previously developed. The proposed project would not convert any prime farmlands, unique farmlands, farmlands of statewide importance, or farmlands of local importance to non-agricultural use. b) Impacts related to conflicts with existing zoning for agricultural use or a Williamson Act contract that would result from implementation of the GPU were evaluated under Impact 3.2-2 on pages

3.2-8 to 3.2-9 of the GPU DEIR. The analysis determined that no parcels within the City’s Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Planning Area are under a Williamson Act Contract. The analysis determined that several parcels within the city are zoned for Residential Agricultural (RA) uses in the City of Sebastopol Zoning Code (Title 17 of the City of Sebastopol Municipal Code). The analysis determined that the majority of the RA zoned parcels within the city are designated Low Density Residential (LDR) on the City of Sebastopol General Plan Land Use Map. The analysis determined that the GPU includes a comprehensive set of policies and actions aimed at protecting, enhancing, and preserving agricultural lands and agricultural resources throughout the Planning Area and lands in the vicinity of Sebastopol. The analysis determined that implementation of the GPU would have a less than significant impact relative to this topic and no mitigation is required.

The project site (both the hotel site and parking lot site) is designated as Light Industrial (LI) on the City of Sebastopol General Plan Land Use Map. The hotel site is zoned Commercial Industrial (CM), and the parking lot site is zoned Industrial (M) and Environmental and Scenic Open Space (ESOS) Combining District. The project site is not on or adjacent to land under a Williamson Act Contract or zoned for agricultural use, and there would be no impact under this significance criterion.
c,d) As discussed on pages 3.2-2 to 3.2-3 of the GPU DEIR, there are no forest lands or timber lands located within the City’s Planning Area. There would be no impacts related to forest lands or timber lands.
e) As previously discussed, the proposed project would construct and operate a hotel and associated parking lot on development sites that are urbanized, have been previously developed, and do not include agricultural or forest uses. There would be no impacts related to forest lands or timber lands.

Conclusion
As discussed above, the proposed project would not result in effects related to agriculture and forestry resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
California Department of Conservation, 2024a. California Important Farmland Finder. Available at:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed April 28, 2024.

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3. Air Quality
AIR QUALITY — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Conflict with or obstruct implementation of the
applicable air quality plan?
No No No No
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
No No No No
c) Expose sensitive receptors to substantial pollutant
concentrations?
No No No No
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
No No No No
Discussion
a) Impacts related to conflicting or obstructing implementation of the applicable air quality plan resulting from implementation of the GPU were evaluated under Impact 3.3-1 on pages 3.3-25 to

3.3-31 of the GPU DEIR. The analysis determined that implementation of the GPU would not conflict with or obstruct implementation of the Bay Area Air Quality Management District (BAAQMD) 2010 Clean Air Plan (CAP) (BAAQMD, 2010a), which was the latest plan when the GPU was adopted. The analysis identified that the CAP’s primary goal is to protect air quality, which it does with 55 control measures aimed at reducing air pollution in the Bay Area. The GPU Conservation and Open Space Element includes an extensive list of policies and action measures that are specifically aimed at improving air quality. These policies and action measures are consistent with the intent of the CAP’s control measures.

Additionally, the Circulation Element of the GPU includes a wide range of policies and actions that would effectively reduce vehicle miles traveled throughout the City’s Planning Area.

Therefore, the analysis concluded that implementation of the GPU would not disrupt, delay, or otherwise hinder the implementation of the CAP, and the impact was found to be less than significant.

As described in the Project Description of this document, the proposed project would include demolition of the existing 36,402-square-foot Guayakí organic beverage company warehouse building at 6782 Sebastopol Avenue and construction and operation of a four-story, up to 83- room hotel, with related parking, landscaping, and utilities improvements. The proposed project also would add 218 new parking spaces.

The development sites are urbanized, and both sites have been previously developed. The hotel would replace an existing warehouse. The parking lot site, much of which is paved, is currently vacant and used for overflow Barlow parking for events and temporary vehicle storage. The sites are both urban infill areas, except that the parking lot site is adjacent to the Laguna de Santa Rosa (as well as adjoining industrial uses).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 As discussed in Section 17, Transportation, of this document, the proposed project (i.e., the hotel) would result in a decrease in vehicle miles traveled (VMT) compared to existing conditions, as visitors attracted to the area would not have to travel as far for lodging (Fehr & Peers, 2024). This decrease in VMT was incorporated into the criteria pollutant emissions analysis [discussed below in (b)].

The proposed project would also not disrupt, delay, or otherwise hinder the implementation of the CAP. The proposed project is an allowable use under the GPU. The GPU DEIR demonstrated that development allowed under the GPU would not conflict with or hinder implementation of the CAP, because the policies and action items included throughout the GPU, most specifically within the Conservation and Open Space, Land Use, and Circulation Elements, cover the full breadth of air quality issues as recommended in the 2010 Clean Air Plan. b) The GPU DEIR did not include a separate impact discussion that addressed impacts related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. The following analysis addresses this significance criterion for the proposed project.

The proposed project activities described above would result in combustion pollutants from construction equipment and vehicles, fugitive dust from demolition and earthmoving, and reactive organic compounds from parking lot paving. These emissions were estimated using the CalEEMod land use emissions model (version 2022.1.1), approved by all California air districts for use in CEQA projects. Dust control measures, consistent with GPU Action COS-7g were incorporated in the modeling. Construction emissions are shown in Table AQ-1, below.

TABLE AQ-1

CONSTRUCTION EMISSIONS
Project Site/Construction Yeara
Proposed Project Emissions (average pounds/day)
ROG NOX PM10 Exhaust PM2.5 Exhaust
Year 2025 Construction
Hotel 0.56 2.99 0.04 0.04
Parking Lot 0.18 0.39 0.01 0.01
Total Year 2025 Emissions 1.26 9.78 0.39 0.36
Threshold 54 54 82 54
Significant? No No No No
Year 2026 Construction
Hotel 2.58 1.11 0.01 0.01
Threshold 54 54 82 54
Significant? No No No No
NOTES:
a. Emissions were calculated for the construction years of 2025 and 2026. A subsequent change to 2026 and 2027 will result in marginally reduced emissions due to improvements in the construction equipment fleet. Therefore, these emission estimates are conservative.

SOURCE: ESA, CalEEMod (see Appendix B).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Operational emissions from the proposed project were also estimated using the CalEEMod land use emissions model. Operational emissions would be generated from natural gas combustion for space and water heating, plus consumer product use (solvents, paints, cleaning products). These operational emissions are summarized in Table AQ-2, and as shown, would not exceed significance thresholds from the 2010 BAAQMD CEQA Guidelines (those used in the 2010 Clean Air Plan).

TABLE AQ-2

DAILY AND ANNUAL OPERATIONAL EMISSIONS
Project Source ROG NOX PM10 PM2.5
Average Daily Emissions (lbs/day)
Mobile -0.02 -0.07 -0.13 -0.03
Area 2.29 0.01 <0.01 <0.01
Energy 0.04 0.64 0.05 0.05
Total Daily Emissions 2.31 0.58 -0.08 -0.02
Threshold 54 54 82 54
Significant? No No No No
Annual Emissions (tons/yr)
Mobile -0.01 -0.01 -0.02 -0.01
Area 0.42 <0.01 <0.01 <0.01
Energy 0.01 0.1 0.01 0.01
Total Annual Emissions 0.36 0.10 -0.01 -0.01
Threshold 10 10 15 10
Significant? No No No No
SOURCE: ESA, CalEEMod (see Appendix B).

Note: Mobile PM10 and PM25 emissions included break and tire wear and entrained road dust. c) Impacts related to health risks associated with toxic air contaminants (TACs) resulting from implementation of the GPU were evaluated under Impact 3.3-2 on pages 3.3-31 to 3.3-32 in the GPU DEIR and found to be less than significant. As explained in the GPU DEIR, the GPU includes policies that are intended to minimize exposure of TACs to sensitive receptors. These policies and actions are consistent with the BAAQMD recommendations that are intended to reduce health risks associated with TACs. Implementation of the GPU, including the policies and actions that are intended to mitigate TAC impacts, would ensure that this impact is reduced to a less than significant level.

Emissions of TACs from the proposed project were analyzed for a potential to increase cancer risk, chronic hazard index, and PM2.5 concentrations above BAAQMD significance thresholds.

The proposed project was evaluated to assess the potential for exposure to sensitive and workplace receptors from TAC concentrations during construction. Diesel exhaust particulate matter (DPM) is a carcinogen and chronic health hazard pollutant that would be emitted from Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 heavy, diesel-fueled equipment during construction. Emissions of PM2.5 would also result from construction activities (fugitive dust and diesel exhaust).

Sensitive receptors are located within 1,000 feet of the hotel and parking lot location. Sensitive receptors are individuals that are more susceptible to the effects of air pollutants and include children, the elderly, and those with chronic health conditions. Residences are considered sensitive receptors, as these individuals could be present there. In addition to residences, nearby workers or employees of businesses could also be exposed to TAC concentrations.

A health risk assessment (HRA) was conducted to evaluate the cancer risk, chronic hazard index, and annual average PM2.5 concentrations at nearby sensitive and workplace receptors from the proposed project construction DPM emissions. The results are presented for the maximally exposed individual resident (MEIR) and maximally exposed individual worker (MEIW). The operational phase of the proposed project would not generate substantial TAC emissions, because the majority of emissions would be from gasoline-powered passenger vehicles. The health risk driver from mobile sources is from heavy, diesel-powered vehicles.

The HRA follows the protocols outlined by the Office of Environmental Health Hazard Assessment (OEHHA, 2015). Consistent with guidelines and recommendations from these agencies, the HRA evaluated the estimated incremental increase in cancer risks, chronic hazard index (DPM concentrations divided by an acceptable reference exposure level), and PM2.5 concentrations from exposure to emissions from heavy construction equipment.

The OEHHA guidelines provide age sensitivity factors to apply to the cancer risk calculation.

These factors reflect the increased sensitivity of children to the effects of carcinogens. In addition, children have higher breathing rates, which increases the intake of pollutants. The modeling exposure assumptions for the nearby residences conservatively assume a child in the age group from third-trimester fetus to 2 years of age, which is the age group most susceptible to DPM emissions from a cancer risk perspective, could be living at these residences.

The HRA was conducted using the U.S. Environmental Protection Agency (EPA) AERMOD dispersion model (version 23132) and measured meteorology from the Sonoma County Airport to predict conservative concentrations at specific locations defined by a Cartesian coordinate system. Diesel construction equipment would be used during the site preparation, grading, building construction, paving, and architectural coating phases. A conservative representation of the on-site construction equipment within the hotel site and parking lot site was modeled as a rectangular area source for each site. The modeling parameters are as follows:

Rectangular area sources covering the hotel site and parking lot, with:
● Release height of 5 meters for construction equipment exhaust; ● Initial vertical dimension of 1.4 meters; and
● Emissions occurring only between the hours of 7:00 a.m. and 5:00 p.m. ● Release height of 2.55 meters for haul truck exhaust; ● Receptor flagpole height of 1.5 meters (ground-level receptor at breathing height).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The sources were modeled with an emission rate of one gram per second to obtain a dispersion factor (unit concentration) at each receptor location. Emissions of exhaust PM10 were assumed to be DPM. The DPM concentrations were calculated using the modeled dispersion factors and the DPM and PM2.5 emissions from Table AQ-1.

The cancer risk (expressed as a probability per million) was calculated using the resulting DPM concentrations along with equations and factors from the OEHHA 2015 Risk Assessment Guidelines (OEHHA 2015). The results of the HRA are presented in Table AQ-3 below. The cancer risk probability and chronic hazard index are below BAAQMD thresholds (BAAQMD 2010b), resulting in a less than significant impact. The MEIR is at a residence south of SR-12, near Morris Street, and the MEIW is a business on McKinley Street, north of the hotel site.

TABLE AQ-3

MODELED MAXIMUM CANCER RISK, CHRONIC HAZARD INDEX, AND ANNUAL AVERAGE PM2.5 CONCENTRATIONS AT THE MEIR AND MEIW LOCATION Cancer Risk
(in 1 million)
Chronic Hazard Index
(unitless)
PM2.5
(µg/m3)
MEIR 6.9 0.01 0.06
MEIW 2.0 0.04 0.28
BAAQMD Significance Threshold 10 1.0 0.3
Exceeds Threshold? No No No
Risk from Nearby Existing Sources
Coffee Catz (6761 Sebastopol Ave.) 0.01 0 0
City of Sebastopol Generator (6850 Laguna Park Way 3.3 0 0 State Route 12 11.5 0.03 0.15
Total Existing plus Project at MEIRa 21.7 0.04 0.21
BAAQMD Significance Threshold 100 10.0 0.8
Exceeds Threshold? No No No
SOURCE: ESA, see Appendix B.
a. The existing risk values are reported at the MEIR, which represents the most conservative impact. The residential exposure parameters are more conservative due to the higher breathing rates and sensitivity factors for children. In addition, these exposure parameters were used by BAAQMD for its calculation of risk from existing sources.

Also shown in Table AQ-3 are existing sources of health risk in the project vicinity. Existing sources of health risk are those producing TAC emissions within 1,000 feet of the MEIR.

Therefore, this analysis evaluates existing risk impacts from these sources combined with risk impacts from implementation of the proposed project, compared to the BAAQMD’s cumulative risk thresholds. The nearby sources and their reported risks are shown in Table AQ-3. The ‘total existing plus project’ value includes the risks from existing sources added to the risk at the MEIR.

The risk values at the MEIW are not included in this total, as the MEIW is calculated with different exposure parameters than the residential for the MEIR. Therefore, the MEIW tends to be a lower value to do less conservative exposure parameters.

For existing sources, the risk data were obtained from the BAAQMD’s stationary and mobile source risk screening tools (BAAQMD 2022b) to estimate the cumulative risk at the proposed Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 project’s MEIR. Table AQ-3 shows that the cumulative risks would not exceed BAAQMD’s cumulative risk thresholds, resulting in a less than significant cumulative impact. d) The impact related to generation of objectionable odors from implementation of the GPU was evaluated under Impact 3.3-3 on page 3.3-33 of the GPU DEIR and found to be less than significant. The BAAQMD CEQA Guidelines recommendation for assessing plan level odor impacts is to identify the location of existing and planned odor sources in the plan area and policies to reduce potential odor impacts in the plan area. Common odor sources in the project vicinity may include skunks, livestock, and their waste, decomposing dead animals along roadways, stagnant water, etc. Wastewater from Sebastopol travels to Santa Rosa for treatment so wastewater odor issues are not expected. There are not any industrial or commercial users in the City Planning Area that are expected to cause nuisance odors. Lastly, fresh asphalt can be a temporary odor nuisance for people. Dust emissions can contribute to increased ambient concentrations of PM10 and can also contribute to reduced visibility and soiling of exposed surfaces. There are no other existing or planned sources of odors within Sebastopol.

The proposed project would introduce two new sources of odors: those associated with temporary construction-related sources and cooking-related odors from commercial-grade restaurant exhaust. These odors were addressed in the GPU DEIR, as discussed above, and the impacts related to these odors were found to be less than significant.” See GP DEIR p. 33-33.

Conclusion
As discussed above, the proposed project would not result in effects related to air quality that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
Bay Area Air Quality Management District (BAAQMD), 2010a. Bay Area 2010 Clean Air Plan.

September. Available at: https://www.baaqmd.gov. Accessed May 13, 2024.

BAAQMD, 2010b. CEQA Air Quality Guidelines. Available at: https://www.baaqmd.gov/en/plans-andclimate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines/archived-ceqaguidelines. Accessed December 31, 2024.

BAAQMD, 2022b. Health Risk Screening and Modeling. Available at: https://www.baaqmd.gov/en/ plans-and-climate/california-environmental-quality-act-ceqa/ceqa-tools/health-risk-screening-andmodeling. Accessed December 20, 2024.

Office of Environmental Health Hazard Assessment (OEHHA), 2015. Air Toxics Hot Spots Program – Risk Assessment Guidelines, March 2015. Available at: https://oehha.ca.gov/air/crnr/noticeadoption-air-toxics-hot-spots-program-guidance-manual-preparation-health-risk-0. Accessed May 10, 2024.

Agenda Item Number 10 Agenda Item Number: 10
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4. Biological Resources
BIOLOGICAL RESOURCES — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified in
the GPU FEIR
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S.

Fish and Wildlife Service?
No No No No
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S.

Fish and Wildlife Service?
No No No No
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No No No No
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
No No No No
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No No No No
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
No No No No
Discussion
a) Impacts related to substantial adverse effects, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game (CDFW) or the U.S. Fish and Wildlife Service (USFWS) that would result from implementation of the GPU were evaluated under Impact 3.4-1 on pages 3.4-21 to 3.4-31 of the GPU DEIR. The analysis determined that implementation of the GPU would allow and facilitate future development in Sebastopol, which could result in adverse impacts to special-status plant and wildlife species, as well as sensitive natural habitat or wildlife movement corridors. The analysis determined that subsequent development projects would be required to comply with the General Plan and adopted state, federal, and local regulations for the protection of special status plants and wildlife, including habitat. The analysis identified that the GPU Conservation Element includes numerous policies designed for the protection of special-status species. For example, Policy COS 2-1 requires protection and enhancement of sensitive habitats, which include creek corridors, wetlands, vernal pools, riparian areas, wildlife and fish migration corridors, native plant nursery sites, waters of the United States, sensitive natural communities, and other habitats designated by state and federal agencies. Policy COS 2-2 requires preservation and enhancement of those biological communities that contribute to the City’s and the region’s rich biodiversity including, Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 but not limited to, annual grasslands, freshwater marshes, wetlands, vernal pools, riparian areas, aquatic habitat, and agricultural lands. Policy COS 3-1 requires the protection and enhancement of streams, channels, seasonal and permanent marshland, wetlands, sloughs, riparian habitat, and vernal pools through sound land use planning, community design, and site planning. Policy COS 3-1 further requires the conservation of riparian habitat along local creeks, including but not limited to the Laguna de Santa Rosa. Policy COS 3-8 requires new development to include maintained and managed setbacks and buffers along creeks, wetlands, riparian corridors, and adjacent to sensitive habitat. GPU Action COS 2b specifies that, where sensitive biological habitats have been identified on or immediately adjacent to a project site, the project shall include appropriate mitigation measures identified by a qualified biologist, which may include, but are not limited to the following:
● Pre-construction surveys for species listed under the State or Federal Endangered Species Acts, or species identified as special-status by the resource agencies, shall be conducted by a qualified biologist;
● Construction barrier fencing shall be installed around sensitive resources and areas identified for avoidance or protection, and to reduce potential soil compaction in sensitive areas; and ● Employees shall be trained by a qualified biologist to identify and avoid protected species and habitat.

The analysis concluded that implementation of GPU policies and action measures, as well as federal and state regulations, would reduce impacts to special status plants and wildlife, including habitat, to a less than significant level.

Biological resources on the parking lot site were evaluated in a biological assessment report prepared by WRA in May 2024 (WRA, 2024) and included as Appendix C of this document. In addition, on May 18, 2024, senior ESA biologist Brian Pittman CWB, reviewed the hotel site at 6782 Sebastopol Avenue and the parking lot site at 385 Morris Street, and areas within 500 feet of each area to characterize sensitive and regulated biological resources, and to verify findings of the WRA (2024) biological review. In addition, the California Natural Diversity Database (CDFW, 2024) was reviewed to examine the known distribution of sensitive plant or wildlife species in the project area. The hotel site exists within a fully developed urban envelope. Neither the hotel site nor adjacent developed areas provide habitat for sensitive or special-status plants and wildlife.

The parking lot site has a long history of high-impact use and exists as denuded, bare ground that lacks habitat for special-status plants and wildlife. The nearby Laguna de Santa Rosa provides aquatic and basking habitat for western pond turtle (Actinemys marmorata; federal proposed threatened, California Species of Special Concern); however, habitat for this species does not occur on the parking lot site.

As identified in the biological resources report (WRA, 2024) the only potential sensitive species constraint associated with the proposed project is the potential for migratory birds and raptors to nest in the riparian floodplain located north and east of the parking lot site. Potential impacts to nesting birds at the parking lot site could occur if project construction at the parking lot site would occur during avian nesting period (February 15 to September 1). However, these impacts would be avoided with proposed project’s required adherence to GPU Action COS 2b (provided Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 above) which specifies that, where sensitive biological habitats have been identified on or immediately adjacent to a project site, the project shall include appropriate measures identified by a qualified biologist, including pre-construction surveys for sensitive species conducted by a qualified biologist; installation of construction barrier fencing around sensitive resources and areas; and training for construction workers by a qualified biologist to identify and avoid protected species and habitat. The proposed project’s is consistent with GPU Action COS 2b and the other applicable GPU policies designed for the protection of special-status species identified above, as well as federal and state regulations, would ensure that potential impacts to specialstatus species would be less than significant with no mitigation required. b) Impacts related to substantial adverse effects on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS that would result from implementation of the GPU were evaluated under Impact 3.4-2 on pages

3.4-31 to 3.4-38 of the GPU DEIR. The analysis identified that the City of Sebastopol contains numerous aquatic habitats that qualify as federally protected wetlands and jurisdictional waters.

The most prominent aquatic habitat in Sebastopol is the Laguna de Santa Rosa. As discussed on page 3.4-16 of the GPU DEIR, the Laguna de Santa Rosa is the largest freshwater wetlands complex on the northern California coast. The Laguna’s fourteen-mile channel forms the largest tributary to the Russian River, draining a 254-square-mile watershed which encompasses nearly the entire Santa Rosa Plain. This includes parts of the communities of Windsor, Santa Rosa, Rohnert Park, Cotati, Forestville, and Sebastopol. As further discussed under Impact 3.4-2, the Laguna de Santa Rosa is important in maintaining water quality and flood control for the region.

It provides an important overflow area for the Russian River during periods of heavy winter rain, serving as a natural holding basin which captures and slows floodwaters, easing their impact on lower Russian River communities. Additionally, the Laguna de Santa Rosa provides a unique ecological system for the region. With over 30,000 acres, the Laguna provides a mosaic of creeks, open water, perennial marshes, seasonal wetlands, riparian forests, oak woodland, and grassland.

It is home to hundreds of species of birds, mammals, fish, amphibians, reptiles, and invertebrates.

The Laguna de Santa Rosa provides habitat for a range of species, including several rare and endangered species.

The analysis identified that the GPU Conservation Element includes numerous policies designed to address sensitive natural communities, including the Laguna de Santa Rosa and other local waterways. Policy COS 2- 5 requires the City to implement a range of measures and tools to protect, enhance, and restore environmentally sensitive areas. Policy COS 2-6 maintains the Zoning Code provisions to ensure that development proposals for land located within, or adjacent to, an environmentally sensitive areas include a resources analysis that contains all of the information required in order for the City to determine that impacts to sensitive habitat and natural resources have been reduced, avoided, or mitigated to the greatest extent feasible.

Policy COS 3-1 requires the protection and enhancement of streams, channels, seasonal and permanent marshland, wetlands, sloughs, riparian habitat, and vernal pools through sound land use planning, community design, and site planning. Policy COS 3-1 further requires the conservation of riparian habitat along local creeks, including but not limited to the Laguna de Santa Rosa. Policy COS 3-8 requires new development to include maintained and managed setbacks and buffers along creeks, wetlands, riparian corridors, and adjacent to sensitive habitat.

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Policy COS 3-10 requires the city, consult with state and federal agencies during the development review process to help identify wetland and riparian habitat that has candidacy for restoration, conservation, and/or mitigation, and focuses restoration and/or conservation efforts on areas that would maximize multiple beneficial uses for such habitat. The analysis determined that subsequent development projects would be required to comply with the General Plan and adopted state, federal, and local regulations for the protection of sensitive natural communities, including riparian habitat. The analysis concluded that implementation of General Plan policies and action measures, as well as federal and state regulations, would reduce impacts to these resources to a less than significant level.

Biological resources on the parking lot site were evaluated in a biological assessment report prepared by WRA in May 2024 (WRA, 2024), and an ESA biologist reviewed the hotel site and parking lot site on May 18, 2024, to characterize sensitive and regulated biological resources.

Based on these assessments, no riparian habitat or sensitive natural communities occur on or near the hotel site. Hence, no impacts would occur to such areas from site redevelopment. While the parking lot site contains undisturbed areas along the Laguna de Santa Rosa, the area within the limits of disturbance for the proposed parking does not support riparian habitat or sensitive natural communities. Hence, no direct or indirect impacts would occur to riparian habitat or sensitive natural communities (arroyo willow thicket) that occur in association with the Laguna de Santa Rosa.
c) Impacts related to substantial adverse effects on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means that would result from implementation of the GPU were evaluated under Impact 3.4-3 on pages 3.4-38 to 3.4-45 of the GPU DEIR. The analysis identified that the City of Sebastopol contains numerous aquatic habitats that qualify as federally protected wetlands and jurisdictional waters. The analysis identified that the most prominent aquatic habitat in Sebastopol is the Laguna de Santa Rosa, and there are also various tributaries and drainages to the Laguna de Santa Rosa within the City’s Planning Area. The analysis determined that construction activities associated with individual future projects could result in the disturbance or loss of waters of the United States. This includes perennial and intermittent drainages; unnamed drainages; vernal pools; freshwater marshes; and other types of seasonal and perennial wetland communities. The analysis determined that wetlands and other waters of the United States could be affected through direct removal, filling, hydrological interruption (including dewatering), alteration of bed and bank, and other construction-related activities. The analysis further determined that there is a reasonable chance that water features could be impacted throughout the buildout of the individual projects. The analysis identified that the implementation of an individual project would require a detailed and site-specific review of the site to determine the presence or absence of water features. If water features are present and disturbance is required, federal and state laws require measures to reduce, avoid, or compensate for impacts to these resources. The requirements of these federal and state laws are implemented through the permit process. The analysis further identified that the GPU Conservation Element includes numerous policies specifically designed to address wetland features within the City’s Planning Area. Policy COS 2-1 calls for the protection and enhancement of sensitive habitats, which include creek corridors, wetlands, vernal pools, riparian areas, fish migration corridors, waters of the United Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 States, sensitive natural communities, and other habitats designated by state and federal agencies.

Policy COS 3-1 requires the protection of streams, channels, seasonal and permanent marshland, wetlands, sloughs, riparian habitat, and vernal pools through sound land use planning, community design, and site planning. The analysis concluded that implementation of General Plan policies and action measures, as well as federal and state regulations, would reduce impacts to these resources to a less than significant level.

Based on these assessments, no state or federally protected wetlands were identified on the hotel site or the parking lot site. Hence, no impacts would occur from the proposed project. Additionally, the parking lot development area is set back more than 50 feet from wetlands that occur east of the project site. Hence, no impacts would occur to state or federally regulated wetlands. d) Impacts related to substantial interference with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impedance to the use of native wildlife nursery sites that would result from implementation of the GPU were evaluated under Impact 3.4-4 on pages 3.4-45 to 3.4-51 of the GPU DEIR. The analysis identified that movement corridors for wildlife through Sebastopol include creeks, drainages, open space, as well as various low density or rural developed areas. Species using these areas include aquatic, terrestrial, and avian species. The analysis determined that many of the policies already presented in the impact discussions above have ancillary benefits of protecting movement habitat for wildlife. Additionally, Policy COS 2-1 ensures the protection of sensitive habitats, which include creek corridors, wetlands, vernal pools, riparian areas, wildlife and fish migration corridors, native plant nursery sites, waters of the United States, sensitive natural communities, and other habitats designated by state and federal agencies. Policy COS 2-3 focuses conservation efforts on high priority conservation areas that contain suitable habitat for native, endangered, threatened, migratory, or special-status species and that can be managed with minimal interference from nearby urban land uses and are in proximity to other habitat corridors.

Policy COS 3-8: requires new development to include maintained and managed setbacks and buffers along creeks, wetlands, riparian corridors, and adjacent to sensitive habitat. Implementation of the policies and action measures listed below would ensure that all future projects are designed to facilitate the movement of wildlife to the greatest extent feasible. Where full design mitigation is not feasible, compliance with state and federal permit requirements would offset any potential impacts associated with project implementation through requirements to provide habitat connectivity and compensatory mitigation required by any applicable state or federal regulations.

The analysis concluded that implementation of GPU policies and action measures, as well as federal and state regulations, would reduce impacts to these resources to a less than significant level.

Given the developed and disturbed character of the hotel site and the parking lot site, these areas do not support known or expected wildlife movement corridors or serve as wildlife nursery sites.

The parking lot site is situated adjacent to an important wildlife area; however, no common or special-status wildlife species rely upon the mostly fenced, and denuded site during their normal movement or migration. The Laguna de Santa Rosa riparian corridor provides many opportunities Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 for wildlife movement, and development of the site as a parking lot would not substantially alter or interfere with continued wildlife movement through and use of this area. As a result, potential impacts to wildlife movement and/or nursery sites would be less than significant with no mitigation required.
e) Impacts related to conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, that would result from implementation of the GPU were evaluated under Impact 3.4-5 on pages 3.4-52 to 3.4-53 of the GPU DEIR. The analysis determined that the GPU includes numerous policies and action measures intended to protect biological resources, including special status species, habitat, creeks, wetlands, and trees, and the GPU itself does not conflict with its policies. In addition, the analysis determined that the GPU supports the City Tree Protection Ordinance (Chapter 8.12, Tree Protection, of the City of Sebastopol Municipal Code), which defines City-protected trees; requires a tree protection plan prepared by a certified for projects that may affect protected trees; requires a tree removal permit for specified tree removals, and requires that the tree removal permit shall include a condition requiring the provision of replacement trees, in-lieu fee payment, or an approved alternative as specified in Section 8.12.060, Tree Removal Permit. The analysis concluded that implementation of applicable GPU policies and action measures, as well as required compliance with the provisions of the City Tree Protection Ordinance, would reduce impacts to these resources to a less than significant level.

The proposed project would include demolition of the existing parking lot directly east of the existing warehouse building. This would include removal of the existing trees in the parking lot.

Approximately 36 larger trees and 27 smaller trees in the existing parking lot would be removed.

Most of the trees that would be removed are in the 2- to 4-inch diameter range, with one tree approximately 8 inches in diameter. All trees that would be removed from this area are below the 10-inch diameter threshold for protected native trees or the 20-inch threshold for protected nonnative trees as defined in the City Tree Protection Ordinance. The removed trees would be replaced by 26 large and 31 smaller trees (a net reduction of 10 large trees and a net increase of four small trees) for a net reduction of six trees in the parking lot area directly east of the hotel building. Proposed new trees elsewhere on the hotel site would also include one large oak tree and 18 smaller trees in the hotel courtyard areas. In addition, construction of the hotel building would require the removal of two protected trees directly to the west of the existing warehouse building (on APN 004-750-034). As indicated in the arborist report prepared, these protected trees (as defined in the City Tree Protection Ordinance) include a valley oak with a 27-inch diameter and a Hankow willow with a 10.2-inch diameter (Arborist Report 6782 Sebastopol Ave and 385 Morris Street, Balcerak Design, July 20, 2024). While the willow is a protected tree, it is non-native, and, as a result, the City Tree Protection Ordinance threshold for protection is 20-inches in diameter. As discussed in the tree report, given the location of the trees and the necessary excavation required for the hotel, preservation of these trees is not possible and, as a result, would be removed to accommodate the hotel building. The removal of these two protected trees would be approved via the Development Agreement.

Riparian habitat is present to the north and east of the parking lot site in association with the Laguna de Santa Rosa. The site is zoned M (Industrial) and ESOS (Environmental and Scenic Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Open Space). The proposed development is located less than 100 feet but greater than 50 feet from the Laguna de Santa Rosa wetland/riparian boundary (WRA, 2024). Sebastopol Municipal Code, Title 17, Zoning, Chapter 17.46, Section 17.46.050 specifies a 100-foot minimum setback buffer from the edge of a wetland or identified riparian dripline, which may be reduced to no less than 50 feet with approval from the Planning Commission. The Planning Commission may modify the setback requirements based on substantial evidence provided by a qualified professional that specific resources of potential concern do not occur on the property or will not be affected by the project. It is the opinion of the biological resource study (WRA, 2024) that the proposed use of the site as a parking lot would not differ significantly and would improve current conditions.

Approval of the parking lot site plan by the City, including for areas within 100 feet of wetland and riparian habitat associated with Laguna de Santa Rosa would be consistent with the review approach identified in the GPU, which provides for variances from minimum stated avoidance buffer distances. For the proposed site development to move forward, a buffer distance variance would be required by the City, and the project would therefore not conflict with the Environmental and Scenic Open Space ordinance.
f) Impacts related to conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan that would result from implementation of the GPU were evaluated under Impact 3.4-6 on page

3.4-53 of the GPU DEIR. The analysis determined that there are no adopted habitat conservation plans or natural community conservation plans that are applicable to the GPU project. As such, implementation of the GPU would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan, and no impact would occur.

Conclusion
As discussed above, the proposed project would not result in effects related to biological resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
Balcerak Design, 2022. Arborist’s Report, 6782 Sebastopol Avenue, Sebastopol, California, February 14, 2022.

California Department of Fish and Wildlife (CDFW), 2024. California Natural Diversity Database, RareFind 5. Wildlife and Habitat Data Analysis Branch, Sacramento, CA. Accessed May 24, 2024.

WRA, 2024. Updated Preliminary Biological Assessment for the Batch Plant Parking Lot. May 8, 2024.

Agenda Item Number 10 Agenda Item Number: 10
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5. Cultural Resources
CULTURAL RESOURCES — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
No No No No
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section
15064.5?
No No No No
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
No No No No
Discussion
a,b) Impacts related to substantial adverse change in the significance of a historical resource or archaeological resource pursuant to CEQA Guidelines Section 15064.5 that would result from implementation of the GPU were evaluated under Impact 3.5-1 on pages 3.5-15 to 3.5-20 of the GPU DEIR. The analysis determined that a substantial adverse change in the significance of a historical resource is defined at Section 15064.5 (b)(1) of the CEQA Guidelines as the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. The analysis determined that known historical and prehistoric resource sites are located throughout Sebastopol and the City’s Planning Area, and it is expected that additional undiscovered sites may be located in various areas of the city as well. The analysis determined that future development allowed under the GPU could affect known historical and archaeological resources or unknown historical and archaeological resources which have not yet been identified. The analysis determined that prehistoric Native American sites are most likely to occur where several environmental factors combine to provide readily available resources, such as at the interface between valley and hills.

The analysis determined that future development projects considered by the City would be evaluated for conformance with the City’s General Plan, Municipal Code, and other applicable state and local regulations. The analysis identified that the GPU includes policies and actions that would reduce impacts to cultural, historical, and archaeological resources. Policies COS 10-5, COS 10-6, CD 3-1, and CD 3-2 encourage the protection and preservation of cultural and historical resources. Action COS-10c addresses the discovery of significant archaeological and historical resources during construction and grading activities, requiring that development work be stopped in the event of a discovery and that appropriate measures be implemented to protect the resource. The analysis concluded that implementation of GPU policies and action measures, as well as state and local regulations, would reduce impacts to significant historical and archaeological resources to a less than significant level.

Historic Architectural Resources
The hotel would replace the existing 36,402-square-foot Guayakí organic beverage company warehouse building at 6782 Sebastopol Avenue. If the warehouse building were determined to be historically significant, its demolition and removal would result in a significant impact.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Consequently, a historical resource evaluation was conducted by Yarbrough Architectural Resources to determine if the warehouse building qualifies as an historical resource pursuant to CEQA Guidelines Section 15064.5. The historical resource evaluation report is included as Appendix D to this document (Yarbrough Architectural Resources, 2024).

CEQA Guidelines Section 15064.5 defines an “historical resource” as a resource listed in or determined to be eligible for listing in the California Register of Historical Resources (CRHR) or included in a local register of historical resources. Furthermore, CEQA specifies that any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be historically significant if the resource meets any of the following criteria for listing in the CRHR.

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

The historical resource evaluation determined that the warehouse building at 6782 Sebastopol Avenue was constructed in 1924–1925 as the Sebastopol Coop Cannery building, from which preserved apple and other fruit products were shipped to market. As described in the historical resource evaluation report, the building is a utilitarian warehouse with a raised concrete platform foundation set approximately five feet above grade, typical of twentieth century railroad warehouses. As described in the historical resource evaluation report, the wood-frame building is composed of two primary interior spaces: a two-story office portion at the south end and a much larger handling and storage portion comprising about 80 percent of the building’s interior.

As described in the historical resource evaluation report, the elongated rectangular plan of the building allowed for two long exterior elevations facing the railroad tracks for loading to its west and for truck loading doors to its east.

The historical resource evaluation determined that the warehouse building at 6782 Sebastopol Avenue is not listed in the CRHR, the National Register of Historic Places, or a local register of historical resources; is not associated with a significant historical event (Criterion 1) or persons of particular historical significance (Criterion 2); is illustrative of a railroad warehouse type that was well established in California by the 1920s and does not represent innovation or mastery in design or construction (Criterion 3); and is a common structural form and does not embody information that may answer an unresolved historical question regarding design, construction, or history (Criterion 4). For these reasons, the historical resource evaluation report finds that the warehouse building at 6782 Sebastopol Avenue is not an historical resource as defined under CEQA.

Consequently, demolition and removal of the warehouse building to allow for construction of the Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 hotel on the site of the warehouse building would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. Therefore, no impacts to historic architectural resources would result from implementation of the proposed project.

Archaeological Resources
In accordance with Policy COS-10-1 and Action COS-10b, ESA completed a records search and background research at the Northwest Information Center (NWIC) of the California Historical Resources Information System on May 9, 2024 (File No. 23-1599). The purpose of the records search was to (1) determine whether known cultural resources have been recorded in the vicinity of the project site; (2) assess the likelihood for unrecorded cultural resources to be present based on historical references and the distribution of nearby sites; and (3) develop a context for the identification and preliminary evaluation of cultural resources. The records search consisted of an examination of the following documents:
● NWIC digitized base maps (USGS Sebastopol 7.5-minute topographic map) to identify recorded archaeological resources and studies within a 0.5-mile radius of the project site. ● NWIC digitized base maps (USGS Sebastopol 7.5-minute topographic map) to identify recorded historic-era resources of the built environment (building, structures, and objects) within and adjacent to the project site.
● Resource Inventories: California Inventory of Historical Resources (California Register), California Historical Landmarks, Built Environment Resources Directory (BERD) (through March 2021).

The result of the background research indicates that no pre-contact Native American resources have been previously recorded in the project site. There are several previously recorded precontact archaeological resources in the records search radius. These resources consist of the remains of use and occupation areas, including burial sites. None of these resources would be directly impacted by the proposed project.

ESA completed a pedestrian survey of the project site on May 13, 2024. The survey entailed walking the parking lot site and hotel site in transects to provide an overall assessment of site conditions.

The parking lot site is highly disturbed from the construction and activities associated with the former batch plant. The site has been graded and filled to accommodate former structures.

Remnant concrete pads, foundations, pavement, and concrete blocks as well as piles of gravel and soil are located throughout the site. No pre-contact Native American resources or other evidence of indigenous human use or occupation were identified during the survey of the parking lot site.

Given the negative survey results, extensive ground disturbance, and relatively shallow depth of grading associated with the proposed project (maximum of 2 feet below the existing surface), the parking lot site has a relatively low potential to uncover pre-contact resources during ground disturbing activities.

The remnant features of the former batch plant are recommended not eligible for listing in the CRHR. The concrete pads, foundations, pavement, and concrete blocks are remnant utilitarian Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 features that are not associated with events that have made a significant contribution to the broad patterns of local or regional history (Criterion 1) or associated with the lives of persons important to local or California history (Criterion 2). The features do not embody the characteristics of a type, period, region, or method of construction or possess artistic values (Criterion 3). In addition, the features would not have the potential to yield information important to the history of the local area or California (Criterion 4). Therefore, the remnant features of the batch plant are not considered historical resources for the purposes of CEQA, and no further consideration is necessary for the project.

There is no ground visibility at the hotel site. Geologic maps show the hotel project site as Pleistocene-age alluvium. Based on the age of this landform, pre-contact archaeological resources would be located at or near to the surface. Given the general disturbance of the surface of the hotel project site from the existing building and former railroad, there is a relatively low potential to uncover pre-contact archaeological resources during ground disturbing activities.

Historic maps show that prior to construction of the existing building, a dwelling was located at the hotel site. The dwelling (labeled “Priest’s Residence”) was associated with an adjacent church (outside of the project site) and included a water tower and large outbuilding at the rear (within the project site). Outbuildings such as this may have held an outhouse or privy prior to the advent of indoor plumbing. When indoor plumbing became more commonplace, privy pits were often used as refuse containers. Privies can therefore include artifact deposits that, if associated with the lives of persons important to local history, may be considered eligible for listing in the CRHR as significant historical resources. Therefore, based on the results of the background research there is the potential to uncover significant historic-era archaeological resources during ground disturbing activities at the hotel site.

Pursuant to and consistent with General Plan Ation COS-10c and the GPDEIR, the Development Agreement includes the following condition to address impacts to historical resources:

Based on a reasonable presumption that historic-era archaeological resources may be present within the project site, the project sponsor shall retain the services of a Secretary of the Interior qualified archaeologist to conduct an archaeological testing and data recovery program. Testing shall be completed following demolition of the existing building, prior to any ground disturbing activity below grade. The archaeological consultant shall prepare an archaeological testing and data recovery plan (plan) that specifically identifies the expected archaeological resource(s), the testing method to be used, and the locations recommended for testing. The purpose of the plan will be to determine to the extent possible the presence or absence of archaeological resources and to identify and to evaluate encountered archaeological resources. In the event archaeological resources are encountered, archaeological data recovery shall be implemented according to the plan, which includes the identification of research questions and data requirements. The plan will also include field methods and procedures, cataloging and laboratory analysis, interpretive plans, security measures, and development of a final report.

In addition, Action COS-10c addresses the discovery of significant archaeological and historical resources during construction and grading activities, requiring that development work be stopped Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 in the event of a discovery and that appropriate measures be implemented to protect the resource.

With implementation of the contractual condition and Action COS-10c, as well as state and local regulations, impacts to significant archaeological resources would be reduced to a less than significant level.
c) Impacts related to disturbance of human remains that would result from implementation of the GPU were evaluated under Impact 3.5-2 on pages 3.5-20 to 3.5-21 of the GPU DEIR. The analysis determined that indications are that humans have occupied areas along the Laguna de Santa Rosa, east of Sebastopol, for at least 11,000 years and it is not always possible to predict where human remains may occur outside of formal burials. Therefore, excavation and construction activities allowed under the GPU may yield human remains that may not be marked in formal burials. The analysis determined that future development projects considered by the City would be evaluated for conformance with the City’s General Plan, Municipal Code, and other applicable state and local regulations. The analysis determined that Public Resources Code Section 5097 has specific stop-work and notification procedures to follow in the event that Native American human remains are inadvertently discovered during development activities. The analysis determined that GPU includes Policy COS 10-2, which requires that human remains be treated with sensitivity and dignity and ensures compliance with the provisions of California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98.

GPU Action COS-10c includes specific provisions that must be enacted if human remains are inadvertently discovered during construction activities. The analysis concluded that implementation of these policies and actions would ensure that potential adverse impacts to human remains would be less than significant. The proposed project would adhere to all applicable laws, regulations, and policies regarding human remains.

Conclusion
As discussed above, the proposed project would not result in effects related to cultural resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
Yarbrough Architectural Resources, 2024. For CEQA Section 15183, Barlow Hotel Project at 6782 Sebastopol Ave. and Constraints Analysis for 6780 Depot St.), Sebastopol, Sonoma County, California. December.

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6. Energy
ENERGY — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
No No No No
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
No No No No
Discussion
a) Impacts related to non-renewable energy resources that would result from implementation of the GPU were assessed in Section 4.2, Growth-Inducing Effects, on pages 4.0-21 to 4.0-22 of the GPU DEIR. The analysis found that while non-renewable energy resources such as electricity, natural gas, propane, gasoline, and diesel would be consumed during the construction and operation of development projects allowed under the GPU, the GPU includes a variety of policies that seek conserve, protect, and enhance energy resources. These policies focus on energy efficiency in the design, materials, construction, and use of buildings; the use of alternative energy systems; and alternative transportation modes. For example, Policy COS 7-3 encourages implementation of policies and programs contained in the GPU Circulation Element to reduce vehicle trips, vehicle miles travelled, and increase the use of non-vehicular modes of transportation such as bicycling, walking, and the use of shared transit. Policy COS 9-1 requires all new public and privately constructed buildings to meet and comply with CALGreen Tier 1 standards. Policy COS 9-3 directs the City to support innovative and green building best management practices, including, but not limited to, Leadership in Energy and Environmental Design (LEED) certification for new development, and encouraging project applicants to exceed the most current “green” development standards in the California Code of Regulations (CCR), Title 24, if feasible. Policy COS 9-5 promotes the use of sustainable and carbon-neutral energy sources in new development.

Construction of the proposed project would require the use of on-road trucks for deliveries of construction materials and hauling of soil and demolition debris, and the use of off-road equipment such as excavators, cranes, forklifts, and pavers. Construction activities would comply with state and local requirements designed to minimize idling and associated emissions, which would also minimize the use of fuel. Specifically, pursuant to 13 CCR Sections 2485 and 2449, idling of commercial vehicles over 10,000 pounds and off-road equipment over 25 horsepower would be limited to a maximum of five minutes.

Operational energy use would include the use of electricity to power the proposed project. The proposed project would utilize existing energy hookups on the project site and would not extend new natural gas service. Sustainable elements of the proposed project include installation of electric vehicle chargers at the parking lot consistent with CALGreen standards, and compliance with the latest Title 24 energy standards for building construction (see additional discussion of Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 required project compliance with Title 24 in item b) below). In addition, as discussed in Section 17, Transportation, of this document, the proposed project would result in a net decrease in vehicle miles traveled in the region, and there would be a resultant net reduction in operational consumption of gasoline and diesel. Consequently, the proposed project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. b) Construction of new buildings are subject to California’s Title 24 standards, including the Building Energy Efficiency Code and CALGreen Code, both of which are adopted in Title 15, Buildings and Construction, of the City’s Municipal Code. California’s Title 24 reduces energy use in residential and commercial buildings through progressive updates to both the Green Building Standards Code (Title 24, Part 11) and the Energy Efficiency Standards (Title 24, Part 6). Provisions added to Title 24 over the years include consideration and incorporation of new energy efficiency technologies and methods for building features such as space conditioning, water heating, and lighting, as well as construction waste diversion goals. Additionally, some standards focus on larger energy-saving concepts such as reducing loads at peak periods and seasons, improving the quality of energy-saving installations, and performing energy system inspections. Pursuant to Policy COS 9-1 of the GPU, the proposed project would meet and comply with CALGreen Tier 1 energy standards. Because the City has mechanisms in place as part of the building permit process to ensure that these state and local energy efficiency measures are implemented, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Conclusion
As discussed above, the proposed project would not result in effects related to energy resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

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7. Geology and Soils
GEOLOGY AND SOILS — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault? Refer to Division of Mines and
Geology Special Publication 42.

No No No No
ii) Strong seismic ground shaking? No No No No
iii) Seismic-related ground failure, including
liquefaction?
No No No No
iv) Landslides? No No No No
b) Result in substantial soil erosion or the loss of topsoil? No No No No c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
No No No No
d) Be located on expansive or corrosive soil creating
substantial direct or indirect risks to life or property? No No No No
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal
systems where sewers are not available for the
disposal of wastewater?
No No No No
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
No No No No
Discussion
a) Impacts related to the potential to expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure, including liquefaction, that would result from implementation of the GPU were evaluated under Impact 3.6-1 on pages 3.6-19 to

3.6-22 of the GPU DEIR. The analysis determined that there are no known active or potentially active faults, or Alquist-Priolo Earthquake Fault Zones, located within the City’s Planning Area.

However, the analysis determined that there are numerous faults located in the region. Figure 3.6-1 of the GPU DEIR illustrates the location of these faults. These include the San Andreas Fault System, the Rodgers Creek Fault, the Healdsburg Fault, West Napa Fault, and the Mayacama Fault. The analysis determined that rupture of any of these faults, or of an unknown fault in the region could cause seismic ground shaking. As a result, the analysis determined that future development in the City of Sebastopol may expose people or structures to potential adverse effects associated with a seismic event, including strong ground shaking and seismic-related ground failure.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The analysis determined that all projects undertaken in the City of Sebastopol would be required to comply with the provisions of the California Building Code, which requires development projects to perform geotechnical investigations in accordance with state law, engineer improvements to address potential seismic and ground failure issues, and to use earthquakeresistant construction techniques to address potential earthquake loads when constructing buildings and improvements. The analysis determined that, as future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the California Building Code, the City’s General Plan, Municipal Code, and other applicable regulations related to seismic hazards. The analysis further identified that GPU policies require new land development proposals to avoid unreasonable exposure to geologic hazards, including earthquake damage, subsidence, liquefaction, expansive soils, and landslides. The analysis concluded that, with the implementation of the policies and actions in the GPU, as well as applicable state and local codes, potential impacts associated with a seismic event, including rupture of an earthquake fault, seismic ground shaking, and liquefaction would be less than significant.

The project site (both the hotel site and parking lot site) is not located in a fault rupture hazard zone identified by the Alquist-Priolo Earthquake Fault Zoning Act or located within any other area with substantial evidence of a known fault (California Department of Conservation, 2024b).

As a condition of approval, the proposed project would be required to conform to the requirements of the California Building Code, the City’s General Plan and Municipal Code, and other applicable regulations related to seismic hazards to ensure that potential impacts associated with a seismic event, including rupture of an earthquake fault, seismic ground shaking, liquefaction, expansive soils, and landslides would be less than significant. b) Impacts related to substantial soil erosion or the loss of topsoil that would result from implementation of the GPU were evaluated under Impact 3.6-2 on pages 3.6-22 to 3.6-23 of the GPU DEIR. The analysis determined that the GPU allows development and improvement projects that would involve some land clearing, mass grading, and other ground-disturbing activities that could temporarily increase soil erosion rates during and shortly after project construction. The analysis determined that construction-related erosion could result in the loss of a substantial amount of nonrenewable topsoil and could adversely affect water quality in nearby surface waters. The analysis determined that the majority of soils in the City of Sebastopol fall within the low to moderate range for erosion potential.

The analysis determined that all projects undertaken in the City of Sebastopol would be required to comply with the provisions of the California Building Code, the General Plan, Municipal Code, and other regulations. In addition to compliance with City standards and policies, the Regional Water Quality Control Board (RWQCB) will require a project-specific Storm Water Pollution Prevention Plan (SWPPP) to be prepared for each project that disturbs an area of one acre or larger. The analysis determined that the SWPPPs will include project-specific best management measures (BMPs) that are designed to control drainage and erosion. The analysis determined that, with implementation of the policies and actions in the GPU, as well as applicable state and local requirements, potential impacts associated with erosion and loss of topsoil would be less than significant.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Based on information obtained from the United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey on-line database, the hotel site is mapped as Goldridge fine sandy loam, and the parking lot site is mapped as Blucher fine sandy loam and Clear Lake clay (NRCS, 2024). As discussed on pages 3.6-11 to 3.6-12 of the GPU DEIR, these soils fall within the low to moderate range for erosion potential. As a condition of approval, the proposed project would be required to conform to the requirements of the California Building Code, the City’s General Plan, and Municipal Code that address and minimize soil erosion. In addition, the RWQCB would require a project-specific SWPPP to be prepared for the proposed project, which would include project-specific BMPs that are designed to control drainage and erosion. The proposed project’s required compliance with the above regulations would ensure that potential impacts associated with soil erosion or the loss of topsoil would be less than significant.
c,d) Impacts related to unstable geologic units or soils, landslides, lateral spreading, subsidence, liquefaction, or collapse were evaluated under Impact 3.6-3 on pages 3.6-23 to 3.6-26 of the GPU DEIR. The analysis determined that the Planning Area does not have a significant risk of becoming unstable as a result landslide, lateral spreading, subsidence, or collapse. The analysis determined that limited portions of the Planning Area are subject to liquefaction. The analysis determined that, as future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the California Building Code, the General Plan, Municipal Code, and other applicable regulations. With regard to expansive soils, the GPU DEIR noted that over 95 percent of the Planning Area has low expansive soils, and no portion of the high expansive soils are located in highly developed areas of Sebastopol. The analysis further identified that GPU policies require new land development proposals to avoid unreasonable exposure to geologic hazards, including landslides, lateral spreading, subsidence, liquefaction, or collapse. The analysis concluded that, with the implementation of the policies and actions in the GPU, as well as applicable state and local codes, potential impacts associated with unstable geologic units or soils, landslides, lateral spreading, subsidence, liquefaction, or collapse would be less than significant.

As shown on Figure 3.6-2, Liquefaction Susceptibility, on page 3.6-33, Figure 3.6-4, Soil Erosion Susceptibility, on page 3.6-37, Figure 3.6-5, Soils Shrink-Swell Potential, on page 3.6-39, and Figure 3.6-6, Landslide Potential, on page 3.6-41 of the GPU DEIR, the project site (both the hotel site and parking lot site) is not located in an area with high risk for unstable geologic units or soils, landslides, lateral spreading, subsidence, liquefaction, or collapse. In addition, the proposed project would be required to conform to the requirements of the California Building Code, the City’s General Plan, and Municipal Code that address and minimize these risk factors.

The proposed project’s required compliance with the above regulations would ensure that impacts associated with unstable geologic units or soils, landslides, lateral spreading, subsidence, liquefaction, or collapse would be less than significant. e) The proposed project would connect to the existing City sanitary sewer collection system and does not propose any septic tanks or alternative wastewater disposal systems. There would be no impact under this significance criterion.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 f) Impacts related to unique paleontological resources or site or unique geologic features that would result from implementation of the GPU were evaluated under Impact 3.5-3 on page 3.5-21 of the GPU DEIR. The analysis determined that there are no known paleontological resources located in the Sebastopol Planning Area. However, the analysis determined that development allowed under the GPU could result in the discovery and disturbance of previously unknown or undiscovered paleontological resources. The analysis determined that the GPU provides guidance regarding the conservation of paleontological resources, ensuring that any unique paleontological resources discovered during implementation of the GPU are conserved appropriately. Specifically, GPU Action COS-10c includes specific provisions that must be enacted if paleontological resources are inadvertently discovered during construction activities. The analysis concluded that implementation of GPU Action COS-10c would ensure that potential adverse impacts to paleontological resources would be less than significant.

Geologic maps show the project site (both the hotel site and parking lot site) as Pleistocene-age alluvium. Pleistocene-age sedimentary deposits are generally considered to have a moderate to high potential to contain significant paleontological resources due to their age and previous discoveries of paleontological resources within this geologic unit (Sub Terra Consulting, 2017).

Given the general disturbance of the surface of the hotel and parking lot sites from the existing warehouse building and former concrete batch plant, respectively, there is a relatively low potential to uncover paleontological resources during ground-disturbing activities for the proposed project. In addition, the proposed project would adhere to the provisions GPU Action COS-10c, which would ensure that potential adverse impacts to paleontological resources would be less than significant.

Conclusion
As discussed above, the proposed project would not result in effects related to geology and soils that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
California Department of Conservation, 2024b. California Earthquake Hazards Zone Application ("EQ Zapp"). Available at: https://www.conservation.ca.gov/cgs/geohazards/eq-zapp. Accessed May 9, 2024.

Sub Terra Consulting, 2017. Northwest California Integrated Resources Management Plan, Inventory of Existing Date for Paleontological Resources and Potential Fossil Yield Classification GIS Database. Prepared by Dr. Russel Shapiro.

University of California Museum of Paleontology (UCMP), 2024. UC Museum of Paleontology Localities database. Fossil localities within Sonoma County. Available at:
https://ucmpdb.berkeley.edu/loc.html. Accessed May 25, 2024.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS), 2024 Web Soil Survey On-Line Database. Available at: https://websoilsurvey.nrcs.usda.gov/app/.

Accessed May 25, 2024.

8. Greenhouse Gas Emissions
GREENHOUSE GAS EMISSIONS — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
No No No No
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
No No No No
Discussion
a) Impacts related to GHG emissions that would result from implementation of the GPU were evaluated under Impact 3.7-1 on pages 3.7-15 to 3.7-24 of the GPU DEIR. The analysis determined that the GPU and its policies and actions would encourage the development of a compact urban community, while preserving the agricultural and open space resources in the City’s Planning Area.

The analysis determined that implementation of the GPU would result in increased local employment opportunities, increased transportation and transit options, and the incorporation of conservation and energy efficiency into new development. The analysis determined that the GPU is consistent with the policy guidance provided by the California Air Pollution Control Officers Association (CAPCOA) and the Bay Area Air Quality Management District (BAAQMD) and would assist the state in meeting the GHG reduction goals established by Assembly Bill 32 (AB 32).7 Therefore, the analysis concluded that the impact related to GHG emissions would be less than significant.

Construction Emissions
Construction of the proposed project would involve the combustion of diesel fuel to provide power for the operation of various construction equipment and gasoline for worker commutes, resulting in the generation of GHGs. Construction emissions associated with the proposed project were estimated using project-specific information provided by the project applicant, such as construction schedule and phasing.

Carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions from off-road construction equipment and construction vehicle trips were estimated using CalEEMod. N2O and CH4 emissions were multiplied by their respective Global Warming Potentials GWPs (25 and 298) and added to the CO2 emissions to obtain emissions in terms of carbon dioxide equivalents (CO2e). 7 Signed into law in 2006 by the California Legislature, AB 32 required California to reduce its GHG emissions to 1990 levels by 2020 – a reduction of approximately 15 percent below emissions expected under a “business as usual” scenario.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Table GHG-1 shows that project construction would generate a total of approximately 382 Metric tons of CO2e (MTCO2e) over the 18-month construction period, with annual amortized averages for project construction emission to be 12.7 MTCO2e.

TABLE GHG-1

ANNUAL PROJECT CONSTRUCTION GHG EMISSIONS
Construction Yeara CO2e metric tons/year
2025 295
2026 87.1
Total 382
Amortized 12.7
NOTES: MTCO2e = metric tons of carbon dioxide equivalent Construction-related GHG emissions were amortized over 30 years, which is a commonly accepted method for including construction emissions as part of the Project’s average annual emissions. a. Emissions were calculated for the construction years of 2025 and 2026. A subsequent change to 2026 and 2027 will result in marginally reduced emissions due to improvements in the construction equipment fleet.

Therefore, these emission estimates are conservative.

SOURCE: Data compiled by Environmental Science Associates in 2024 (Appendix B) GHG emissions from the construction phase of a project represent a small portion of emissions over a project’s lifetime, which would be at least 30 years for the proposed project. The BAAQMD’s proposed thresholds are instead designed to address operational GHG emissions from land use development projects which represent the majority of a project’s GHG emissions.

The primary source of GHG emissions from construction is diesel-powered construction equipment. Large reductions in construction emissions are difficult to realize because there are currently no economical alternatives to diesel fuel for powering most construction equipment.

Improvements in statewide regulations governing construction equipment and fuel standards driven by Senate Bill 32 (SB 32) and other initiatives will also contribute to reduced emissions from construction activities. Therefore, GHG emissions associated with construction of the proposed project would be considered less than significant.

Operational Emissions
Direct GHG emissions during operation of the proposed project would occur from onsite energy use and other sources, such as landscape maintenance and fugitive emissions from refrigeration.

Indirect GHG emissions would come from electricity used to power the proposed project, treatment and transportation of water and wastewater, and disposal of generated solid waste.

There are no backup generators associated with the proposed project and no other sources of GHG emissions that would have unusual levels of emissions. In addition, as discussed in Section 17, Transportation, of this document, the proposed project would result in a net decrease in vehicle miles traveled in the region, and there would be a resultant net reduction in mobile GHG emissions. For informational purposes, proposed project operational emissions are presented in Table GHG-2. As can be seen from the table, with the net decrease in vehicle miles traveled, the project would have an overall marginal increase from operational CO2eGHG emissions of 123 metric tons per year.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 TABLE GHG-2

ANNUAL PROJECT OPERATIONAL GHG EMISSIONS
Operational Source CO2e metric tons/year
Mobile -77
Area 1
Energy 150
Water 4
Waste 14
Refrigeration 18
Amortized construction emissions 13
Total Project Operations 123
NOTE:

Emissions were calculated for an operational year of 2027. A subsequent change to 2028 will result in marginally reduced emissions due to reductions in carbon-based electricity by PG&E. Therefore, these emission estimates are conservative.

SOURCES: Data compiled by Environmental Science Associates in 2024 (Appendix B) The proposed project has been designed to be consistent with the GPU (see discussion of plan consistency in Section 11, Land Use and Planning, of this document). Therefore, the emissions related to project construction and operation were considered in the GPU FEIR, which determined that GHG emissions from development under the GPU would result in a 62 percent reduction in GHG emissions compared to existing conditions, and the impact of GHG emissions associated with the GPU was determined to be less than significant.

Since certification of the GPU EIR in 2016, the State of California has updated its statewide climate Change Scoping Plan. An interim 2030 GHG target of 40 percent reduction in GHG emissions relative to 1990 levels was established in the 2017 Scoping Plan update.

The square footage of the proposed project land use development was considered in the calculation of GHG emissions in the GPU FEIR, which determined that GHG emissions from development under the GPU would result in a 62 percent reduction in GHG emissions compared to existing conditions.

Even if the Barlow Hotel project was analyzed independently and without consideration of the GPU, it would not have a significant impact on GHG. The existing Guayaki warehouse building is estimated to produce 146 metric tons of GHG per year, which means the difference in baseline GHG emissions with the Guayaki warehouse building in the proposed hotel is 23 metric tons per year, a de minimus amount. The hotel project achieves a reduction in VMT as is discussed later in this document, which contributes to achieving statewide GHG reduction goals.

Because this estimated reduction would be consistent with the subsequently adopted reduction targets for 2030 and would also be consistent with an interpolated reduction target of the 2035 horizon year of the GPU, estimated to be 55 percent, the proposed project would be consistent with both the less-than-significant finding of the 2016 GPU as well as the GHG reduction targets Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 of the State Scoping Plan, as they would pertain to the 2016 GPU. Therefore, the proposed project would not have a substantial adverse effect on GHG emissions. b) Impacts related to potential conflicts with applicable plans, policies, or regulations adopted to reduce GHG emissions that would result from implementation of the GPU were evaluated under Impact 3.7-2 on pages 3.7-24 to 3.7-25 of the GPU DEIR. The analysis determined that the 2016 GPU Policies are consistent with the City’s Climate Change Action Plan (CCAP) and would assist in meeting the regional GHG reduction goals established by the CCAP.

State of California Climate Change Scoping Plan and Updates Further, the GPU FEIR determined that to ensure consistency with the City’s CCAP and the provisions of Assembly Bill 32, new projects are required to fully implement the City’s Electrical, Energy, and Green Building Standards. The analysis determined that compliance with the City’s Electrical, Energy, and Green Building Standards would reduce GHG emissions from future development to the greatest extent feasible and would further ensure that any future development following adoption of the GPU would be consistent with all applicable plans and policies adopted for the purpose of reducing GHG emissions.

As discussed above in response to question a), because of the GPU’s estimated 62 percent reduction in GHG emissions compared to existing conditions would be consistent with the subsequently adopted reduction targets for 2030 and would also be consistent with an interpolated reduction target of the 2035 horizon year of the GPU estimated to be 55 percent, the proposed project would be consistent with both the less-than-significant finding of the 2016 GPU as well as the updated GHG reduction targets of the State Scoping Plan, as they would pertain to the 2016 GPU.

Sebastopol Climate Action Framework
On July 19, 2022, the Sebastopol City Council unanimously adopted the Sebastopol Climate Action Framework, The Climate Action Framework provides Sebastopol with the next steps towards reaching the goals of the Climate Emergency Resolution adopted in 2019, which included a goal of reducing emissions to net zero by 2030, sequestering additional carbon from the atmosphere, preparing for current and future climate impacts, and centering equity and community engagement in the City’s ongoing climate actions.

As stated in the Framework, the goals in the Framework refer to General Plan goals. Many actions suggested in Appendix A of the Framework, or similar actions, are already included in the City’s 2016 GPU. Actions in the GPU have been reviewed for compliance with CEQA, removing one barrier to implementation.

The proposed project has been designed to be consistent with the GPU (see discussion of proposed project consistency in Section 11, Land Use and Planning, of this document).

Therefore, by virtue of the project’s consistency with the 2016 GPU, the project would also be consistent with actions of the City’s 2022 Climate Action Framework. Consequently, the proposed project would not have a substantial adverse effect with respect to conflicts with applicable plans, policies, or regulations adopted to reduce GHG emissions.

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Conclusion
As discussed above, the proposed project would not result in effects related to GHG emissions that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
City of Sebastopol, 2022. Sebastopol Climate Action Framework, July 2022.

9. Hazards and Hazardous Materials
HAZARDS AND HAZARDOUS MATERIALS — Would the
project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
No No No No
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
No No No No
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
No No No No
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
No No No No
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
No No No No
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
No No No No
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
No No No No
Discussion
a,b) Impacts related to the potential for implementation of the GPU to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 materials, or through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment were evaluated under Impact 3.8-1 on pages 3.8-18 to 3.8-20 of the GPU DEIR. The analysis determined that future development, infrastructure, and other projects allowed under the GPU may involve the transportation, use, and/or disposal of hazardous materials. The analysis determined that the use, transportation, and disposal of hazardous materials is regulated and monitored by local fire departments, Certified Unified Program Agencies (CUPAs),8 the California Division of Occupational Safety and Health (Cal/OSHA), and the California Department of Toxic Substances Control (DTSC), consistent with the requirements of federal, state, and local regulations and policies, as enumerated in the regulatory setting of the Hazards section on pages 3.8-11 to 3.8-17. The analysis determined that all future projects allowed under the GPU would be required to comply with the provisions of federal, state, and local requirements related to hazardous materials. In addition to the requirements associated with state and federal regulations and the City Municipal Code, the analysis determined that the GPU includes policies and actions to address potential impacts associated with hazardous materials among other issues. These policies and actions in the would ensure that potential hazards are identified on a project site, that development is located in areas where potential exposure to hazards and hazardous materials can be mitigated to an acceptable level, and to require that businesses operations comply with federal and state regulations regarding the use, transport, storage, and disposal of hazardous materials. The analysis concluded that compliance with applicable GPU policies and actions, as well as state and federal regulations, would ensure that potential impacts associated with the routine use, transport, storage, or disposal or accidental release of hazardous materials would be less than significant.

Construction
During project construction, construction equipment and materials would include fuels, oils and lubricants, solvents and cleaners, cements and adhesives, paints and thinners, degreasers, cement and concrete, and asphalt mixtures, which are all commonly used in construction. Construction activities would be required to comply with numerous hazardous materials regulations to ensure that hazardous materials would be transported, used, stored, and disposed of in a safe manner to protect worker safety, and to reduce the potential for a release of construction-related fuels or other hazardous materials into the environment, including stormwater and downstream receiving water bodies. Contractors would be required to prepare and implement Hazardous Materials Business Plans (HMBPs) that would require that hazardous materials used for construction would be used properly and stored in appropriate containers with secondary containment to contain a potential release. The California Fire Code would also require measures for the safe storage and handling of hazardous materials.
8 The California Environmental Protection Agency designates specific local agencies as Certified Unified Program Agencies (CUPA), typically at the county level. In Sonoma County, the Sonoma County Fire and Emergency Services Department Hazardous Materials Division is responsible for the County's Certified Unified Program Agency (CUPA) programs. Each designated CUPA is responsible for the implementation of six statewide programs within its jurisdiction. These programs include underground storage of hazardous substances (USTs), hazardous materials business plan (HMP) requirements, hazardous waste generator requirements, the California Accidental Release Prevention (Cal-ARP) program, the Uniform Fire Code hazardous materials management plan, and above ground storage tanks (Spill Prevention Control and Countermeasures Plan only).

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 As discussed in Section 7, Geology and Soils, and Section 10, Hydrology and Water Quality, of this document, the construction contractor would be required to prepare a Storm Water Pollution Prevention Plan (SWPPP) for construction activities that would list the hazardous materials proposed for use during construction; describe spill prevention measures, equipment inspections, equipment and fuel storage; protocols for responding immediately to spills; and describe best management practices (BMPs) for controlling site runoff.

In addition, the transportation of hazardous materials would be regulated by the United States Department of Transportation (USDOT), Caltrans, and the California Highway Patrol (CHP).

Together, federal and state agencies determine driver-training requirements, load labeling procedures, and container specifications designed to minimize the risk of accidental release.

Finally, in the event of an accidental spill that could release hazardous materials at the project site, a coordinated response would occur at the state and local levels, including, but not limited to, the Sonoma County Fire and Emergency Services Department Hazardous Materials Division, which is the local CUPA, along with the CHP and the Sebastopol Police Department, to respond to and assess the situation, as needed.

The required compliance with the numerous laws and regulations discussed above that govern the transportation, use, handling, and disposal of hazardous materials would limit the potential for creation of hazardous conditions due to the use or accidental release of hazardous materials, and this impact would be less than significant.

Operation
Once constructed, the hotel would likely result in the use of common types of hazardous materials that are typically associated with hotel uses, such as cleaning products, disinfectants, and solvents. These products are labeled to inform users of their potential risks and provide instruction regarding appropriate handling procedures. However, most of these materials are consumed through use, resulting in relatively little waste. Routine maintenance activities at the parking lot may involve the transportation, use, or temporary storage of a variety of hazardous materials such as lubricants, paints, and solvents. However, due to the largely self-operating nature of the parking lot, such actions would occur infrequently. In addition, the quantities of hazardous materials used would be relatively small. For these reasons, operation of the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, or through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. c) Impacts related to the potential for implementation of the GPU to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school were evaluated under Impact 3.8-2 on pages 3.8-20 to 3.8-21 of the GPU DEIR. The analysis determined that all hazardous materials would be handled in accordance with federal, state, and local requirements, as described under Impact 3.8-1, which would limit the potential for projects allowed under the GPU to expose nearby uses, including schools, to hazardous emissions or an accidental release. The analysis determined that hazardous emissions are monitored by the Bay Area Air Quality Management District (BAAQMD), the Regional Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Water Quality Control Board (RWQCB), the California Department of Toxic Substances Control (DTSC), and the local CUPA. In the event of a hazardous materials spill or release, notification and cleanup operations would be performed in compliance with applicable federal, state, and local regulations and policies, including hazard mitigation plans. The analysis concluded that compliance with all existing regulations and hazard mitigation plans as well as GPU policies and actions discussed under Impact 3.8-1 of the GPU DEIR would ensure that the impact would be less than significant.

The nearest educational center to the proposed project is a student resource center for students of Analy High School, which is located at 445 Taft Street, approximately 0.2 mile west of the parking lot site and approximately 0.2 mile north of the hotel site. As discussed under question (a, b) above, required compliance with the numerous laws and regulations that govern the transportation, use, handling, and disposal of hazardous materials would ensure that potential for creation of hazardous conditions due to the use or accidental release of hazardous materials associated with construction and operation of the proposed project would be less than significant.

Therefore, the proposed project would have a less-than-significant impact related to hazardous emissions or materials within 0.25 mile of a school.
d) Impacts related to implementation of the GPU to result in projects located on a site included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.59 and, as a result, create a significant hazard to the public or the environment were evaluated under Impact

3.8-3 on pages 3.8-21 to 3.8-23 of the GPU DEIR. The analysis determined that development allowed by the GPU could create a hazard to the public or the environment through a disturbance or release of contaminated materials if the development occurs on or adjacent to contaminated sites without appropriate measures to contain or mitigate the existing contamination. The analysis determined that state and federal regulations, including those enforced by the U.S. Environmental Protection Agency (EPA), the DTSC, and the RWQCB, ensure that existing hazards, including those associated with known hazardous materials sites, are addressed prior to development. The analysis determined that compliance with state and federal regulations would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5 would be less than significant.

The Cortese List, compiled pursuant to Government Code Section 65962.5 includes listings of hazardous waste sites from the DTSC EnviroStor database, leaking underground storage tank sites from the State Water Resources Control Board (SWRCB) GeoTracker database, solid waste disposal sites with waste constituents above hazardous waste levels outside the waste management unit, active cleanup and desist orders and cleanup and abatement orders from the RWQCB, and hazardous waste facilities subject to corrective action by DTSC. ESA conducted a search of the DTSC EnviroStor database and the SWRCB GeoTracker database on May 20, 2024. 9 Section 65962.5(a)(1) requires that DTSC shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following: (1) all hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code (HSC). The hazardous waste facilities identified in HSC Section 25187.5 are those where DTSC has taken or contracted for corrective action because a facility owner/operator has failed to comply with a date for taking corrective action in an order issued under HSC Section 25187, or because DTSC determined that immediate corrective action was necessary to abate an imminent or substantial endangerment. This is a very small and specific subgroup of facilities, and they are not separately posted on the DTSC or CalEPA’s website.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The results are included as Appendix E of this document and demonstrate that the leaking underground storage tanks were removed and remediated such that no active hazardous materials sites are located within, adjacent to, or within 1,000 feet of the project site (both the hotel site and parking lot site) (DTSC/SWRCB, 2024).

In addition, the Phase I Environmental Site Assessment (Phase I ESA) prepared for the parking lot site in May 2024 revealed no evidence of any recognized environmental condition (REC10), controlled recognized environmental condition (CREC11), or Business Environmental Risk (BER12) in connection with the parking lot site. The report identified one historical recognized environmental condition (HREC13) on the parking lot site, which comprised two former underground storage tanks (USTs) that have been removed and all required cleanup has been completed (GeoTracker ID T0609700461). Based on these findings, the Phase I recommends no further investigation of parking lot site (Partner Engineering and Science 2024). In addition, a Phase I ESA prepared for the Barlow in August 2016 did not directly address the hotel site (6782 Sebastopol Avenue) but as part of its adjacent property reconnaissance identified a former leaking underground storage tank (LUST) at 6782 Sebastopol Avenue (GeoTracker ID T0609700195) with a status of cleanup complete and case closed (Partner Engineering and Science, 2024).

The findings of the Phase I reports are consistent with ESA’s updated searches of the DTSC EnviroStor database and the SWRCB GeoTracker database, which demonstrate that no known active hazardous materials sites are located within, adjacent to, or within 1,000 feet of the project site (both the hotel site and parking lot site), and there would be no impact under this significance criterion.
e) As discussed under Impact 3.8-4 on pages 3.8-23 to 3.8-24 of the GPU DEIR the City of Sebastopol does not have any airport facilities located within the city limits, sphere of influence, or urban growth boundary. The closest airport is the Charles M. Schulz – Sonoma County Airport located approximately 11 miles north of the City of Sebastopol. There would be no impact under this significance criterion.
f) Impacts related to the potential for implementation of the GPU to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan were evaluated under Impact 3.8-5 on pages 3.8-24 to 3.8-26 of the GPU DEIR. The analysis determined 10 A recognized environmental condition (REC) refers to the presence of hazardous substances or petroleum products in, on, or at the subject property due to a release to the environment; the likely presence of hazardous substances or petroleum products in, on, or at the subject property due to a release or likely release to the environment; or the presence of hazardous substances or petroleum products in, on, or at the subject property under conditions that pose a material threat of a future release to the environment.
11 A controlled recognized environmental condition (CREC) refers to a REC affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority or authorities with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls. 12 A Business Environmental Risk (BER) is a risk which can have a material environmental or environmentally driven impact on the business associated with the current or planned use of commercial real estate, not necessarily related to those environmental issues required to be investigated in this practice. 13 A historical recognized environmental condition (HREC) refers to a previous release of hazardous substances or petroleum products affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority or authorities and meeting unrestricted use criteria established by the applicable regulatory authority or authorities without subjecting the subject property to any controls (for example, activity and use limitations or other property use limitations).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 that the GPU would allow a variety of new development, including residential, commercial, industrial, and public service projects, which would result in increased jobs and population in the City of Sebastopol. The analysis determined that roads and infrastructure improvements would occur to accommodate the new growth. The analysis determined that future projects are not anticipated to remove or impede evacuation routes and the GPU does not include land uses, policies, or other components that conflict with adopted emergency response or evacuation plans.

The analysis determined that the GPU would improve transportation systems throughout the City and includes policies and actions designed to ensure that an emergency response plan is prepared and maintained. The analysis determined that the GPU would also ensure that the City’s emergency access routes, emergency contact lists, and public information regarding designated facilities and routes are regularly reviewed to ensure that up to date information is available to the City and the public in the event of an emergency. The analysis concluded that implementation of the GPU would have a less than significant impact with regards to this issue.

The City of Sebastopol Local Hazard Mitigation Plan (LHMP) was adopted on June 7, 2022, and received final approval from the Federal Emergency Management Agency (FEMA) on July 15, 2022 (City of Sebastopol, 2022). The LHMP provides emergency management guidance related to prevention, preparedness, response, and recovery. The LHMP uses an all-hazards approach to emergency planning and, therefore, encompasses all hazards that are applicable to the city, both natural and manmade, ranging from planned events to large-scale disasters. The City ensures fire safety primarily through provisions of the building and fire codes. Final building plans for the proposed project would be reviewed and approved by the City fire department, building department, public works department, and planning department to ensure conformance with the applicable provisions related to emergency response plan and emergency evacuation. Implementation of the proposed project could add incrementally to transportation conditions in the immediate area in the event of an emergency evacuation. The proposed project’s contribution to traffic conditions would not be substantial within the context of the urban setting of the project site, and it is expected that project-related traffic would be dispersed within the existing street system, such that there would be no significant adverse impacts on transportation conditions. Therefore, the proposed project would not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan. This impact would be less than significant. g) Impacts related to the potential for implementation of the GPU to expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires were evaluated under Impact 3.8-6 on pages 3.8-26 to 3.8-29 of the GPU DEIR. The analysis determined that there are no Fire Hazard Severity Zones (FHSZs) within State Responsibility Areas (SRAs) or Very High Fire Hazard Severity Zones (VHFHSZs) within any Local Responsibility Areas (LRAs) in the City of Sebastopol.14 The analysis identified that the nearest moderate and high level FHSZs are located approximately three miles to the west of the City of Sebastopol. The analysis identified that LRAs are concentrated in the incorporated areas of Sonoma County. The City of Sebastopol is an LRA that is served by the Sebastopol Fire 14 The state has charged CAL FIRE with the identification of Fire Hazard Severity Zones (FHSZ) within State Responsibility Areas. In addition, CAL FIRE must recommend Very High Fire Hazard Severity Zones (VHFHSZ) identified within any Local Responsibility Areas. The FHSZ maps are used by the state Fire Marshall as a basis for the adoption of applicable building code standards.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Department within the city limits and the Gold Ridge Fire Protection District, which provides fire protection services to unincorporated rural areas surrounding Sebastopol. The analysis identified that SRAs within the vicinity of Sebastopol are primarily found to the south and west of the city limits. The analysis identified that there are no Federal Responsibility Areas (FRAs) within the vicinity of the City of Sebastopol.15 The analysis identified that all future projects allowed under the GPU would be required to comply with the provisions of federal, state, and local requirements related to wildland fire hazards, including state fire safety regulations associated with wildlandurban interfaces, fire-safe building standards, and defensible space requirements. The analysis determined that as future development and infrastructure projects are considered by the City, each project would be evaluated for potential impacts, specific to the project, associated with wildland fire hazards as required under CEQA. The analysis identified that the GPU includes policies and actions that would ensure that potential wildland fire hazards are mitigated through requirements for adequate water supply and water flow availability, ensuring adequate emergency access, adequate fire protection services, and ensuring public awareness regarding fire safety. The analysis concluded that implementation of the GPU would have a less than significant impact with regards to this issue.

The project site (both the hotel site and the parking lot site) are both urban infill areas and are not adjacent to wildlands that have the potential to support wildland fires. Construction and operation of the proposed project would adhere to all applicable state and local regulations, codes, and policies that address fire safety, ensuring that impacts related to fire risk would be less than significant.

Conclusion
As discussed above, the proposed project would not result in effects related to hazards and hazardous materials that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
California Department of Forestry and Fire Protection (CAL FIRE), 2024. Fire Hazard Severity Zones in State Responsibility Area. Available at: https://osfm.fire.ca.gov/what-we-do/community-wildfirepreparedness-and-mitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-maps-2022.

Accessed May 26, 2024.

City of Sebastopol, 2022. City of Sebastopol Local Hazard Mitigation Plan. Adopted June 7, 2022.

Available at: https://www.cityofsebastopol.gov/local-hazard-mitigation-plan-lhmp/. Accessed May 26, 2024.
15 An updated query of the CAL FIRE Fire Hazard Severity Zone Viewer conducted by ESA on May 26, 2004, confirmed that there are no FHSZs within SRAs or VHFHSZs within any LRAs within or near the City of Sebastopol (CAL FIRE 2024).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Department of Toxic Substances Control and State Water Resources Control Board (DTSC/SWRCB), 2024. Combined EnviroStor and GeoTracker Online Databases. Accessed May 20, 2024.

Partner Engineering and Science, 2024. Phase I Environmental Site Assessment Report for 385 Morris Street, Sebastopol, California 95472. May 1, 2024.

Partner Engineering and Science, 2016. Phase I Environmental Site Assessment Report for the Barlow Sebastopol, California 95472. August 10, 2016.

10. Hydrology and Water Quality
HYDROLOGY AND WATER QUALITY — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or ground water quality?
No No No No
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
No No No No
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on- or offsite; No No No No
ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding
on- or offsite;
No No No No
iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide substantial
additional sources of polluted runoff; or
No No No No
iv) impede or redirect flood flows? No No No No
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
No No No No
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
No No No No
Discussion
a) Impacts related to the potential for implementation of the GPU to result in a violation of water quality standards or waste discharge requirements were evaluated under Impact 3.9-1 on pages

3.9-15 to 3.9-17 of the GPU DEIR. The analysis determined that compliance with the Clean Water Act and regulations enforced by the Regional Water Quality Control Board (RWQCB) would ensure that construction-related impacts to water quality are minimized and future projects comply with all applicable laws and regulations. The analysis determined that the City’s stormwater system is covered under a National Pollutant Discharge Elimination System (NPDES) Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 MS4 Phase II permit program, which requires both mitigation of stormwater quantity and stormwater quality. The analysis determined that the Santa Rosa Storm Water Low Impact Development Technical Design Manual (LID Manual) provides specific guidance for postconstruction stormwater control measures (as required under GPU Action COS-3d). The analysis determined that implementation of the requirements of the NPDES permit, the LID Manual requirements (or any successor documents), as well as the various GPU policies that address water quality would ensure that future development projects under the GPU do not result in significant adverse effects to water quality, and the impact would be less than significant.

Construction
Grading, excavation, and other activities associated with construction of the proposed project could temporarily increase runoff, erosion, and sedimentation. In addition, construction of the proposed project would require the use of hazardous materials (e.g., fuels, oil, lubricants, solvents, or other potentially hazardous materials commonly used in construction), which could be mobilized and transported offsite potentially degrading the water quality of local surface waters, including the Laguna de Santa Rosa, which is adjacent to the parking lot site. However, because the proposed project would disturb greater than one acre, it is subject to coverage under the NPDES Construction General Permit, which would require the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) that would require compliance with best management practices (BMPs) such as settlement basins, silt fences, and straw wattles to prevent sediment and other pollutants from leaving the work site and entering waterways. Therefore, impacts relative to water quality during construction would be less than significant.

Operation
The proposed project would construct a hotel on a currently developed site and a parking lot on the 2.9-acre site of the former concrete batch plant, much of which is paved. The proposed project, specifically the parking lot would add additional areas of impervious surface which could introduce constituents into storm water flows that are typically associated with urban runoff, including sediments, petroleum hydrocarbons, pesticides, fertilizers, and heavy metals such as lead, zinc, and copper. As discussed above, the City’s stormwater system is covered under an NPDES MS4 Phase II permit program, which requires both mitigation of stormwater quantity and stormwater quality. In addition, the LID Manual provides specific guidance for postconstruction stormwater control measures (as required under GPU Action COS-3d). The proposed project would be designed and operated in compliance with these programs and all applicable GPU policies that address post-construction water quality. These policies include Policy COS 3-6, which requires the use and site design integration of natural features such as bioswales, vegetation, retention ponds, and other measures to remove surface water pollutants prior to discharge into surface waters; and Policy COS 3-8, which requires new development to include maintained and managed setbacks and buffers along creeks, wetlands, riparian corridors, and adjacent to sensitive habitat. The project’s required compliance with applicable federal, state, and local regulations and policies would ensure that operational impacts related to water quality would be less than significant.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 b) Impacts related to the potential for implementation of the GPU to substantially decrease groundwater supplies or interfere substantially with groundwater recharge were evaluated under Impact 3.9-2 on pages 3.9-20 to 3.9-26 of the GPU DEIR. The analysis determined that subsequent development projects under the GPU, such as residential, commercial, industrial, and roadway projects would result in new impervious surfaces and could reduce rainwater infiltration and groundwater recharge. The analysis determined that projects located in urban areas would have less of an impact than projects converting open lands and spaces. The analysis identified that the City is participating in the regional voluntary Santa Rosa Plain Groundwater Management Plan to better manage groundwater resources now and into the future. The analysis determined that the GPU Community Services and Facilities Element and the Conservation and Open Space Element include policies and action items, which include numerous requirements that would reduce impermeable surfaces and increase groundwater recharge opportunities throughout the city. For example, Policy COS 5-3 encourages new groundwater recharge opportunities and protects existing groundwater recharge areas throughout the Sebastopol Planning Area. Policy COS 5-4 promotes the use of permeable surface materials and provides for ample areas of open space and naturalized land in order to decrease surface runoff and promote groundwater recharge.

Policy COS 5-5 ensures the City seeks opportunities to expand the groundwater recharge capacity of City-owned parcels throughout Sebastopol, and Action CSF-3j calls for the preparation of a study that accurately establishes the groundwater recharge area for Sebastopol. Policy CSF 3-1:
requires that prior to the approval of new development, projects must demonstrate proof of adequate water supply. The analysis concluded that implementation of GPU policies and action measures relating to water conservation and groundwater recharge, in addition to the City’s participation in the regional Santa Rosa Plain Groundwater Management Plan, would ensure that the GPU would have a less than significant impact related to groundwater supplies or interfere substantially with groundwater recharge.

The proposed project would construct a hotel on a currently developed (e.g., paved) site and a parking lot on the 2.9-acre site of the former concrete batch plant, much of which is paved. Both sites are urbanized and neither site currently allows for substantial rainwater infiltration and groundwater recharge. In addition, as discussed in Section 19, Utilities and Service Systems, of this document, there are sufficient water supplies to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years. Consequently, development of the hotel and surface parking lot on the sites would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge, and this impact would be less than significant.
c) Impacts related to the potential for implementation of the GPU to alter the existing drainage pattern in a manner which would result in substantial erosion, siltation, flooding, or polluted runoff were evaluated under Impact 3.9-3 on pages 3.9-26 to 3.9-27 of the GPU DEIR. The analysis determined that individual future projects developed after adoption of the GPU would create new impervious surfaces. This would result in an incremental reduction in the amount of natural soil surfaces available for infiltration of rainfall and runoff, potentially generating additional runoff during storm events. In addition, the increase in impervious surfaces, along with the increase in surface water runoff, could increase the discharge of pollutants that could degrade the quality of receiving waters. Additionally, the analysis determined that individual future Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 projects developed after adoption of the GPU could potentially alter surface drainage patterns as a result of directly altering flow patterns, or placing structures in a floodway, all of which could yield increased amounts of stormwater runoff. The analysis determined that the GPU Community Services and Facilities Element and Conservation and Open Space Element include policies and action items, which include numerous requirements that would reduce the potential for GPU implementation to result in increased flooding or result in water quality impacts associated with increased runoff, siltation or erosion, and polluted runoff. For example, Policy CSF 1-4 provides for adequate public infrastructure including storm drainage to meet the needs of existing and future development. Policy CSF 4-4 ensures adequate funding is available for needed improvements to the wastewater conveyance infrastructure, and to reduce stormwater infiltration to the greatest extent feasible. Policy COS 3-5 requires discretionary projects, as well as new flood control and stormwater conveyance projects, to integrate BMPs and natural features to the greatest extent feasible, while ensuring that these features adequately convey and control stormwater to protect human health, safety, and welfare. Policy COS 3-6 requires the use and design integration of natural features such as bioswales, vegetation, retention ponds, and other measures to remove surface water pollutants prior to discharge into surface waters. Policy COS 3-7 preserves the existing and future floodwater carrying capacity of creeks and channels during creek restoration. Policy COS 3-8 requires new development to include maintained and managed setbacks and buffers along creeks, wetlands, and riparian corridors. The analysis determined that implementation of these policies and action items would ensure that implementation of the GPU would have a less than significant impact from these issues.

Construction and operation of the proposed project would adhere to all applicable regulations, development standards, and policies that address drainage and potential water quality impacts associated with increased runoff, siltation or erosion, and polluted runoff. As discussed above under question (a) construction of the proposed project would be subject to coverage under the NPDES Construction General Permit, which would require the preparation and implementation of a SWPPP that would describe (BMPs such as settlement basins, silt fences, and straw wattles to prevent sediment and other pollutants from leaving the work site and entering waterways, ensuring that impacts relative to water quality during construction would be less than significant.

As also discussed above under question (a), the project’s required compliance with applicable federal, state, and local regulations and policies would ensure that operational impacts related to water quality would be less than significant. Consistent with GPU Policy COS 3-6 the design for the parking lot integrates bioswales, vegetation, and other measures to remove surface water pollutants prior to discharge into surface waters. Consistent with GPU Policy COS 3-7, The easterly portion of the parking lot site, which was not actively used by the former batch plant, would remain undeveloped and protected with a 50-foot setback in compliance with the City of Sebastopol Zoning Code.
d) Water quality impacts related to flood hazard, tsunami, or seiche zones in relation to implementation of the GPU were addressed under Impact 3.9-6 on pages 3.9-37 to 3.9-38 of the GPU DEIR. The analysis identified that a tsunami is a sea wave caused by a submarine earthquake, landslide, or volcanic eruption. Tsunami can cause catastrophic damage to shallow or exposed shorelines. The analysis concluded that the Planning Area is sufficiently distant from the San Francisco Bay to preclude effects from a tsunami, and this impact would be less than Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 significant. The analysis identified that seiches are changes or oscillations of water levels within a confined water body. Seiches are caused by fluctuation in the atmosphere, tidal currents, or earthquakes. The effect of this phenomenon is a standing wave that would occur when influenced by the external causes. The analysis concluded that the Planning Area is not located within close proximity to a confined water body that would pose a significant risk from a seiche, and this impact would be less than significant.

The analysis determined that the City of Sebastopol is located within dam inundation areas.

As shown on Figure 3.9-3, of the GPU DEIR, the city is subject to inundation through the failure of one, or a combination of several area dams including Matanzas Creek Reservoir, Coyote Valley Dam (Lake Mendocino), and Warm Springs (Lake Sonoma). Dam failure is generally a result of structural instability caused by improper design or construction, instability resulting from seismic shaking, or overtopping and erosion of the dam. The analysis identified that larger dams that are higher than 25 feet or with storage capacities over 50 acre-feet of water are regulated by the California Dam Safety Act, which is implemented by the California Department of Water Resources, Division of Safety of Dams (DSD). The DSD is responsible for inspecting and monitoring these dams. The Act also requires that dam owners submit to the California Office of Emergency Services inundation maps for dams that would cause significant loss of life or personal injury as a result of dam failure. The County Office of Emergency Services is responsible for developing and implementing a Dam Failure Plan that designates evacuation plans, the direction of floodwaters, and provides emergency information. Through regular inspections by DSD and maintenance by the dam owners ensure that the dams are kept in safe operating condition. As such, the analysis identified that failure of these dams is considered to have an extremely low probability of occurring and is not considered to be a reasonably foreseeable event. The analysis further identified that the GPU Safety Element includes Action SA-1k to maintain an inventory of all natural hazards, including projected dam failure inundation areas. The analysis concluded that implementation of the GPU would result in a less than significant impact relative to this topic.

Impacts related to the potential for implementation of the GPU to place housing and structures within a 100-year flood hazard area as mapped on a Federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map were evaluated under Impact 3.9-5 on pages 3.9-33 to 3.9-37 of the GPU DEIR. The analysis determined that the City of Sebastopol is subject to flooding problems along the natural creeks and drainages that traverse the area. The Laguna de Santa Rosa is the most prominent drainages in Sebastopol that is subject to flooding.

Small areas in the western-most portion of the city are also subject to flooding from Atascadero Creek. The 100-year floodplain extends onto many properties that are located immediately adjacent to these drainages. Additionally, the analysis determined that land near the downtown area, and in the southeast portions of the city is within the 500-year floodplain. The flood hazards in Sebastopol are illustrated on Figure 3.9-2 on page 3.9-41 of the GPU DEIR. The analysis determined that approximately 15.6 percent of the land within the city limits is located within an area with a Federal Emergency Management Agency (FEMA) flood zone AE, which is an area that is subject to 100-year flooding (a one percent chance of being flooded in any given year).

The analysis determined that approximately 2.3 percent of the land within the city limits is located within an area with a FEMA flood zone X, which is an area that is subject to 500-year flooding (a Agenda Item Number 10 Agenda Item Number: 10
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0.2 percent chance of being flooded in any given year). The analysis determined that approximately

82.1 percent of the land within the city limits is located within an area with a FEMA flood zone X, which is an area that is determined to be outside the 500-year, and 100-year floodplain.

The analysis identified that the GPU Safety Element includes numerous policies specifically designed to address flood hazards. Policy SA 2-1 supports strong local and countywide measures to protect and increase the floodwater storage capacity in the Laguna de Santa Rosa. Policy SA 2-2 ensures the City utilizes the most recent FEMA Flood Insurance Rate Maps (FIRMs) to reduce risk of flooding, identify special flood hazard areas subject to 100-year flood inundation, and calculate flow rates within identified stream channels. Policy SA 2-3 requires the City to continue to work with Sonoma County agencies to ensure that additional storm drain runoff resulting from development occurring in unincorporated areas upstream from drainage channels in the Sebastopol Planning Area is adequately mitigated through improvements on-site and/or downstream. Policy SA 2-5 reduces flood risk to development and infrastructure by maintaining effective flood drainage systems and regulating construction. Policy SA 2-7 requires new critical facilities and essential public buildings, including hospitals and health care facilities, emergency shelters, emergency command centers, and emergency communications facilities to be outside of flood hazard zones to protect from any unreasonable risk of flooding. Policy SA 2-8 requires all development projects to demonstrate how storm water runoff will be detained or retained on-site, treated, and/or conveyed to the nearest drainage facility, and to demonstrate that project implementation would not result in increases in the peak flow runoff to adjacent lands or drainage facilities that would exceed the design capacity of the drainage facility or result in an increased potential for offsite flooding. Policy SA 2-9 disallows development in the 100-year flood zone unless requirements of the City’s Flood Damage Protection Ordinance criteria are met. Policy SA 2-10 ensures that the structural and operational integrity of critical facilities is maintained during flooding.

Additionally, the analysis identified that any development allowed within a flood hazard zone could potentially impede or redirect flood flows. All future projects would be required to comply with Title 15, Building and Construction, Chapter 15.16, Flood Damage Protection, of the Sebastopol Municipal Code, which contains requirements and standards for the placement of fill and elevated structures in special flood hazard areas.

The analysis determined that subsequent development, infrastructure, and planning projects would be subject to applicable GPU policies and actions. The analysis determined that the policies and actions contained in the Safety Element of the GPU represent a comprehensive and holistic approach by the City of Sebastopol to reduce the risks of flooding to city residents and properties to the greatest extent feasible. Furthermore, the analysis identified that numerous federal, state, and local agencies are responsible for maintaining flood protection features in the City of Sebastopol, including the U.S. Army Corps of Engineers (USACE), the California Department of Water Resources (DWR), and the California Department of Fish and Wildlife (CDFW) at the federal and state level, as well as the Sonoma County Water Agency at the local level. The analysis determined that areas prone to flooding within the Sebastopol Planning Area are largely built-out. However, the analysis determined that even with the implementation of the policies, actions, and requirements stated above, implementation of the GPU could result in Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 additional people and structures placed within a delineated flood hazard area. The analysis concluded that this impact is mitigated to the greatest extent feasible through GPU policies and actions; however, the impact is considered significant and unavoidable.

The proposed project (both the hotel site and parking lot site) is located in area with a FEMA flood zone AE, which is an area that is subject to 100-year flooding (FEMA, 2024). The proposed project would conform with Title 15, Building and Construction, Chapter 15.16, Flood Damage Protection, of the Sebastopol Municipal Code, which contains requirements and standards for the placement of fill and elevated structures in special flood hazard areas. All hotel rooms and most of the other square footage would be located a minimum of two feet above the 100-year flood elevation, in compliance with City requirements. Any non-residential areas below this level would be protected with flood barriers in the event of projected flooding. Both the hotel and parking lot would adhere to all applicable development standards and General Plan policies that address flood risk, including Policy SA 2-8, which requires all development projects to demonstrate how storm water runoff will be detained or retained on-site, treated, and/or conveyed to the nearest drainage facility and to demonstrate that project implementation would not result in increases in the peak flow runoff to adjacent lands or drainage facilities that would exceed the design capacity of the drainage facility or result in an increased potential for offsite flooding.

Consequently, the proposed project would not result in any new or more severe impacts than identified in the GPU EIR.
e) As discussed above under question (a) construction of the proposed project would be subject to coverage under the NPDES Construction General Permit, which would require the preparation and implementation of a SWPPP that would describe BMPs such as settlement basins, silt fences, and straw wattles to prevent sediment and other pollutants from leaving the work site and entering waterways, ensuring that impacts relative to water quality during construction would be less than significant. As also discussed under question (a), the project’s required compliance with applicable federal, state, and local regulations and policies would ensure that operational impacts related to water quality would be less than significant. As discussed above under question (b), the proposed project would construct a hotel on a currently developed (e.g., paved) site and a parking lot on the 2.9-acre site of the former concrete batch plant, much of which is paved. Both sites are urbanized and neither site allows for substantial rainwater infiltration and groundwater recharge.

In addition, as discussed in Section 19, Utilities and Service Systems, of this document, there are sufficient water supplies to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years. Consequently, the proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan, and this impact would be less than significant.

Conclusion
As discussed above, the proposed project would not result in effects related to hydrology and water quality that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
Federal Emergency Management Agency (FEMA), 2024. FEMA Flood Hazard and Risk Data Viewer.

Available at: https://experience.arcgis.com/experience/e492db86d9b348399f4bd20330b4b274.

Accessed May 29, 2024.

11. Land Use and Planning
LAND USE AND PLANNING — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Physically divide an established community? No No No No b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
No No No No
Discussion
a) The potential for implementation of the GPU to physically divide an established community was evaluated under Impact 3.10-1 on page 3.10-13 of the GPU DEIR. The analysis determined that the land uses allowed under the GPU provide opportunities for cohesive new growth at in-fill locations within existing communities, as well as new growth areas adjacent to existing communities but would not create physical division within existing communities. The analysis determined that new development and redevelopment projects would be designed to complement the character of the existing community and neighborhoods and provide connectivity between existing development and new development. The analysis determined that the GPU land use map designates sites for a range of urban and rural developed uses as well as open space. The analysis determined that the GPU does not include any new areas designated for urbanization or new roadways, infrastructure, or other features that would divide existing communities. The analysis concluded that the GPU would have a less than significant impact associated with the physical division of an established community.

The proposed project would construct and operate a hotel and associate parking lot on infill sites in downtown Sebastopol in consistency with the GPU land use designations for the project sites as evaluated in the GPU FEIR. The proposed project would not substantially alter existing circulation or access or impede movement in the project area compared to existing conditions. The proposed project does not include any features such as new roadways or other physical elements that would physically divide an established community. The impact would be less than significant. b) The potential for implementation of the GPU to cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect was evaluated under Impact 3.10-2 on page 3.10-13 to 3.10-14 Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 of the GPU DEIR. The analysis determined that the GPU was prepared in conformance with state laws and regulations associated with the preparation of general plans, including requirements for environmental protection. The analysis identified that discussion of the GPU’s consistency with state regulations, plans, and policies associated with specific environmental issues (e.g., air quality, traffic, water quality) is provided in the relevant chapters of the GPU DEIR. The analysis determined that, as set forth by state law, the GPU serves as the primary planning document for the City and focuses on ensuring that the City’s small-town quality of life is maintained, that conservation uses and activities are maintained and enhanced, that the majority of growth remains focused within the City, and that growth outside of the City’s current boundaries would remain within the adopted Urban Growth Boundary. The analysis determined that subsequent development projects would be required to be consistent with all applicable policies, standards, and regulations, including those land use plans, policies, and regulations adopted by the City to mitigate environmental effects as well as those adopted by agencies with jurisdiction over components of future development projects. The analysis determined that any potential environmental impact associated with conflicts with land use requirements would be less than significant. The analysis determined that implementation of the GPU could result in potential adverse environmental impacts, including to traffic, noise, water quality, biological resources, drainage and water quality, air quality, hazards, geology/soils, and cultural resources. The analysis determined that impacts to these resources, including consistency with applicable plans, policies, and regulations, are evaluated in the appropriate sections of the GPU Draft EIR.

Existing General Plan Land Use Designations and Zoning
The project site (both the hotel site and parking lot site) is designated as Light Industrial (LI) on the City of Sebastopol General Plan Land Use Map. The LI designation provides for a wide variety of commercial, wholesale, service, and processing uses (as further discussed below).

The purpose of the ESOS Combining District is to control land use within areas of great scenic or environmental value to the citizens of the Sebastopol General Plan area, to control any alteration of the natural environment and terrain in areas of special ecological and educational significance to the entire community as unique vegetative units or wildlife habitats or as unique geological or botanic specimens, and to enhance and maintain for the public welfare and well-being the public Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 amenities accrued from the preservation of the scenic beauty and environmental quality of Sebastopol. The ESOS Combining District is applicable to areas of great natural beauty, high visibility, or ecological significance such as areas bordering Atascadero Creek or the Laguna de Santa Rosa. The ESOS Combining District was established to implement the goals, policies, and objectives of the Conservation, Open Space and Parks Element of the General Plan. The ESOS Combining District allows parking that serves the open space as a conditional use and allows all uses allowed in the underlying zone with a conditional use. Here the M District allows parking with a conditional use so the parking lot is a conditionally allowed use.

Proposed Barlow Hotel Development Agreement
Development Agreements are used throughout California to permit a range of development, including complex and phased development projects. Development Agreements allow applicants and local governments to tailor the approval to the unique circumstances of a particular site or project, and to mutually agree to special conditions and allowances. A Development Agreement must be consistent with the General Plan but need not follow the letter of the Zoning Code.

However, it must be ‘compatible’ with the uses authorized in, and the use must be allowed in the zoning district in which the property is located. A proposed Development Agreement requires review by the Planning Commission and approval by the City Council in a public hearing process. If approved by City Council, the Development Agreement for the proposed project would allow an extended term for the project approval; allow the project components, including proposed variations from specific zoning standards or procedures; approve Design Review; provide some allowance and procedure for possible future modification of the project components; provide for streamlined plan checks; and modify the application or timing of some impact fee requirements.

General Plan Consistency
GPU Policy LU 1-4 specifies that the LI land use designation provides for a wide variety of commercial, wholesale, service, and processing uses that do not generate excessive adverse environmental impacts. Other uses allowed in this designation include office ancillary to industrial uses; warehousing and agricultural products sales and services; auto sales and repair; food and drink processing; construction yards; research and development, laboratories, light manufacturing; and similar uses. Residential uses are permitted as a secondary use to the primary light industrial uses allowed in this land use designation at a density of 12.1 to 25 units per acre.

Maximum floor area ration (FAR) shall not exceed 0.75 (not including the residential use).

The proposed project is consistent with Policy LU 1-4 in that it includes residential and ancillary uses (commercial uses in the hotel and required parking). Within the Barlow development, the residential uses would be secondary to the many other uses within the Barlow. With regard to density, hotel rooms are not dwelling units in that they lack kitchens, which under the City's definition, must be present for the use to count as a residential unit.16 Therefore, the residential unit density standards do not apply to the proposed project. As a residential use, the hotel is not 16 As specified in Section 17.08.060 of the City of Sebastopol Zoning Code, “Dwelling” or “dwelling unit” means a room or group of internally connected, habitable rooms that have sleeping, cooking, and sanitation facilities, but not more than one kitchen occupied by or intended for one household on a long-term basis. A “dwelling” is the same as an independent housekeeping unit.

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 subject to GPU FAR limits, and the parking lot has no FAR except for a small storage shed. The proposed project is consistent with the General Plan.

Consistency with Land Use Plans, Policies, or Regulations Adopted for the Purpose of Avoiding or Mitigating an Environmental Effect CEQA does not consider inconsistency with land use plans and policies to be a physical effect on the environment unless the plan or policy was adopted for the purpose of avoiding or mitigating a significant environmental effect. Adverse physical effects on the environment that could result from construction and operation of the proposed project are evaluated and disclosed in the appropriate topical sections of this document. As discussed in the analyses, the proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Conclusion
As discussed above, the proposed project would not result in effects related to land use and planning that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

12. Mineral Resources
MINERAL RESOURCES — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
No No No No
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan, or other land use plan?
No No No No
Discussion
a,b) Impacts related to the potential for implementation of the GPU to result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state; or 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 were evaluated under Impact 3.6-6 on pages 3.6-29 to 3.6-30 of the GPU DEIR. The analysis determined that mineral resources are extremely valuable because of their limited supply and their usefulness in modern construction and industrial processes. The analysis determined that Sonoma County has many mineral resources that have been valuable enough to justify commercial extraction and processing. The analysis Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 determined that if a use is proposed that might threaten the potential recovery of minerals from an area that has been classified as Mineral Resource Zone (MRZ)-2, the California Department of Conservation Surface Mining and Reclamation Act (SMARA) would require the jurisdiction to prepare a statement specifying its reasons for permitting the proposed use, provide public notice of these reasons, and forward a copy of the statement to the State Geologist and the State Mining and Geology Board (PRC Section 2762).17 The analysis determined that there are no major mineral deposits that are classified as MRZ-2 within Sebastopol. The analysis determined that the majority of lands within the City’s Planning Area are classified as MRZ-1 (areas where available geologic information indicates that little likelihood exists for the presence of significant mineral resources).

The analysis determined that small portions of eastern Sebastopol contain MRZ-3 designations (areas containing mineral occurrences of undetermined material resource significance). The analysis determined that the Planning Area (which includes the project site) is not mapped as having a known mineral resource of value to the region and is not designated as a locally important mineral resource recovery site, and this impact is considered less than significant.

Conclusion
As discussed above, the proposed project would not result in effects related to mineral resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
California Department of Conservation (DOC) Division of Mines and Geology, 2013. Update of Mineral Land Classification: Aggregate Materials in the North San Francisco Bay Production-Consumption Region, Sonoma, Napa, Marin, and Southwestern Solano Counties, California. 17 The California Geological Survey (CGS), formerly the California Division of Mines and Geology (DMG), classifies the regional significance of mineral resources in accordance with the California Surface Mining and Reclamation Act (SMARA) of 1975 and assists the CGS in the designation of lands containing significant aggregate resources. Mineral Resource Zones (MRZs) have been designated to indicate the significance of mineral deposits.

Agenda Item Number 10 Agenda Item Number: 10
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13. Noise and Vibration
NOISE — Would the project result in:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies?
No No No No
b) Generation of excessive groundborne vibration or
groundborne noise levels?
No No No No
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to
excessive noise levels?
No No No No
Discussion
a) GPU Operational Traffic Noise
Impacts related to permanent increases in noise from vehicle traffic that would result from implementation of the GPU were evaluated under Impact 3.11-1 on pages 3.11-20 to 3.11-30 of the GPU DEIR. The analysis determined that upon full buildout of the GPU and with implementation of the noise- and traffic-related policies and reduction measures contained in the GPU, the impact of localized noise increases within the city’s roadways would be significant and unavoidable as the result of increases exceeding 1.5 A-weighted decibels (dBA) along roadways where the existing noise levels already exceed 65 dBA, Ldn.18 Project Operational Traffic Noise
The intersection level of service assessment prepared for the proposed project (Fehr & Peers, 2024) determined that the proposed project would be expected to generate approximately 39 trips during the peak hour. These trips would reasonably be expected to use Sebastopol Avenue (SR-12) to access the project site, and this roadway would experience the greatest increase in traffic volumes compared to all other roadways.

The intersection level of service assessment indicates that SR-12 has an existing peak-hour volume of 1,624 cars and trucks. Using algorithms of the Federal Highway Administration’s 108 Traffic Noise Model, it was determined that the addition of 39 additional peak-hour trips to the existing traffic volume on SR-12 would increase noise levels by 0.1 dBA and would not result in a significant traffic noise impact.
18 Ldn – The Day/Night Average Sound Level is the 24-hour day and night A-weighed noise exposure level, which accounts for the greater sensitivity of most people to nighttime noise by weighting noise levels at night. Noise between 10:00 p.m. and 7:00 a.m. is weighted (penalized) by adding 10 dBA to take into account the greater annoyance from nighttime noise (also referred to as “DNL”).

Agenda Item Number 10 Agenda Item Number: 10
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Impacts related to permanent increases in noise from stationary noise sources19 that would result from implementation of the GPU were evaluated under Impact 3.11-2 on pages 3.1-30 to 3.11-35 of the GPU DEIR. The analysis determined that upon full buildout of the GPU and with implementation of the noise-related policies and actions contained in the GPU, the impact of stationary source noise would be less than significant. Policies and actions that would contribute to this less than significant finding include policies N 1-1, N 1-3, N 1-4, N 1-5, N 1-6, N 1-7, N 1-11, N-13, N 1-14, N-15, N-16, N-17, N-18, N 2-1, N 2-3 and Actions N-1a, N-1b, N-1c, N-1d, N-2a, and N-2b.

Project Operational Stationary Source Noise
Stationary noise sources that would be associated with the proposed project would include heating, ventilation, and air conditioning (HVAC) systems, and non-amplified music and human voices from the rooftop outdoor bar of the hotel.

With respect to stationary noise sources, Policy N 1-7 states that a significant impact will occur if a project results in an exceedance of the noise level standards contained in the GPU noise element, or the project will result in an increase in ambient noise levels by more than 3 dB, whichever is greater. The analysis determined that compliance with the requirements outlined in Action N1-d shall be sufficient to reduce noise impacts to a less than significant level.

Action N1-d requires acoustical studies for all new discretionary projects, including those related to development and transportation, which have the potential to generate noise impacts which exceed the standards identified in the noise element. The studies shall include representative noise measurements, estimates of existing and projected noise levels, and mitigation measures necessary to ensure compliance with this element and relevant noise standards in the Sebastopol Municipal Code.

Table N-2 of the GPU as well as Section 8.25.060 of the Municipal Code establish a daytime (7 a.m. to 10 p.m.) noise standard of 55 dBA, Leq at residential uses and a nighttime standard (10 p.m. to 7 a.m.) of 45 dBA, Leq. These standards are to be reduced by 5 dBA for sources consisting of speech or music. However, the GPU clarifies that in no case shall mitigation be required to a level that is less than existing ambient noise levels, as determined through measurements conducted during the same operational period as the subject noise source.

The existing noise level in the project site vicinity was measured at two locations over a 24-hour period and two additional short-term measurements were collected at the nearest residential areas (Figure NOI-1). The noise measurement data is presented in Tables NOI-1 and NOI-2 below.

Based on these data, the noise level in the immediate vicinity of the project site already exceeds the standards of Table N-2 of the GPU as well as Section 8.25.060 of the Municipal Code, and the applicable noise impact standard is a 3 dBA increase above existing levels, consistent with Policy N 1-7.
19 Stationary noise sources may include commercial area loading docks, equipment operations at industrial or agricultural uses, HVAC equipment, car washes, operations at auto repair facilities, as well as noises generated by recreational uses.

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LT-2
ST-1
ST-2
LT-1
Morris St
Laguna Park Way
McKinley St
Depot St
Brown St
Petaluma Ave
Sebastopol Ave
Laguna Park Way
Johnson St
Flynn St
Morris St
Morris St
Laguna Park Way
McKinley St
Depot St
Brown St
Petaluma Ave
Sebastopol Ave
Laguna Park Way
Johnson St
High St
Willow St
Flynn St
Laguna
de Santa Rosa
Laguna
de Santa Rosa
Parking Lot Site
Barlow Market
District
Hotel
Site
Figure NOI-1
Noise Measurement Locations
0 400
Feet N
SOURCE: Aldridge Development, 2024; ESA, 2024; Google Earth, 2024 Barlow Hotel Project 2023/D202301440.00 - Barlow Development Agreement Project/05 Graphics-GIS-Modeling/Illustrator Short-Term Noise Monitoring Locations
Long-Term Noise Monitoring Locations
ST-#
LT-#
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 TABLE NOI-1

LONG-TERM AMBIENT NOISE LEVELS IN THE PROJECT SITE VICINITY Measurement Location
Day-Night Noise level
(Ldn)
Noise Levels in dBA
Daytime hourly
average, Leq
Nighttime hourly average, Leq
LT-1 North side of Sebastopol Avenue at 6742 Sebastopol 76 71 69 LT-2 South side of Sebastopol Avenue at 6681 Sebastopol 73 73 65 NOTE: See Figure NOI-1 for noise measurement locations.

SOURCE: Environmental Science Associates, 2024
TABLE NOI-2

SHORT-TERM AMBIENT NOISE LEVELS IN THE PROJECT SITE VICINITY Measurement Location Time
Noise Levels in dBA
Leq Lmax
ST-1 6737 Sebastopol Avenue Multi-family residences
(275 feet south of Sebastopol Avenue)
9:16 a.m. 56 85
LT-1 (Comparison data point on Sebastopol Avenue) 9:00 a.m. 70 89 ST-2 Flynn Street Residences 9:43 p.m. 52 82
NOTES: See Figure NOI-1 for noise measurement locations.

Leq represents the constant sound level; Lmax is the maximum noise level.

SOURCE: Environmental Science Associates, 2024
Additionally, comparison of simultaneous noise monitoring data at locations LT-1 and ST-1 indicates that existing intervening commercial structures provide substantial noise attenuation of over 10 dBA between the noise sensitive receptors to the southeast and traffic on SR-12.

With respect to noise from HVAC equipment, such equipment commonly is provided in packaged units that are located on the rooftop of hotels. Such equipment operates at a noise level of 72–78 dBA at 30 feet without acoustical treatments (Trane, 2002). The nearest noise sensitive receptor to the hotel are multifamily residences located approximately 450 feet to the southeast and approximately 700 feet from the screened mechanical area on the rooftop. At this distance and assuming a conservative 5 dBA reduction for rooftop parapets, HVAC noise would be attenuated to 46 dBA which would be below the existing ambient nighttime noise levels shown in Table NOI-1 and, therefore, less than significant.

With respect to noise from non-amplified music from the rooftop bar, this bar would be located approximately 300 feet from the southern property line of the proposed project and approximately 750 feet from the nearest residences to the southeast. As stated earlier, noise monitoring indicates that existing structures provide substantial noise attenuation (more than 10 dBA) between the noise sensitive receptors to the southeast and traffic on SR-12.

It is noted that live amplified music performances are an existing regular occurrence at the Barlow. Therefore, non-amplified music from the rooftop bar would not represent a new source Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 of amplified noise that could combine with existing sources. As discussed in the Project Description, the rooftop bar would likely be open seven days a week from 12 p.m. up to 10 p.m., and non-amplified music at the rooftop bar would be limited to these hours daily.

As discussed above, pursuant to Section 8.25.060 of the Municipal Code, the applicable noise impact standard is a 3 dBA increase above existing levels. Given the intervening presence of traffic noise on SR-12 between the proposed bar and the nearest sensitive receptors, as well as the presence of intervening structures and given that human voices already occur during live music performances at the existing Barlow, it is reasonable to expect that noise from patron voices at the rooftop bar would not result in a significant noise impact which, as found by the court, should not be regulated under CEQA.

Construction Noise - GPU
Impacts related to temporary increases in noise that would result from construction activities from development under the GPU were evaluated under Impact 3.11-3 on pages 3.11-33 to 3.11-34 of the GPU DEIR. The analysis determined that upon full buildout of the GPU and with implementation of the noise-related policies and actions contained in the GPU, the impact of construction noise would be less than significant.

Construction Noise - Proposed Project
Construction of the proposed project would occur over a period of approximately 18 months starting in 2025. Project construction would result in temporary increases in ambient noise levels.

Onsite construction activities would require the use of heavy construction equipment (e.g., excavator, loader, crane) that would generate varying noise levels. Offsite construction noise sources would consist of passing trucks and other construction-related vehicles.

Table NOI-3 shows typical noise levels produced by various types of construction equipment that would operate during the construction of the proposed project.

TABLE NOI-3

TYPICAL MAXIMUM NOISE LEVELS FROM CONSTRUCTION EQUIPMENT Construction Equipment Noise Level (dBA, Lmax at 50 feet) Backhoe 78
Excavator 81
Compactor 83
Air Compressor 78
Dozer 82
Grader 85
Paver 77
Roller 80
Front-End Loader 79
Truck 76
NOTES: dBA = A-weighted decibels; Lmax = maximum, instantaneous noise level experienced during a given period of time
These are maximum field measured values at 50 feet as reported from multiple samples.

SOURCE: Federal Highway Administration, Roadway Construction Noise Model User Guide, 2006.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Consistent with the general assessment methodology of the FTA, the two noisiest pieces of construction equipment (grader and compactor) listed in Table NOI-3 were assumed to operate simultaneously. Using the Roadway Construction Noise Model of the Federal Highway Administration, the resultant noise level at the nearest campus receptor at a distance of 450 feet from the project site would be 64 dBA.

Section 8.25.060 of City’s Noise Control Ordinance (Sebastopol Municipal Code, Title 8, Health and Safety, Chapter 8.25) provides an exemption for construction equipment which is operated during daytime hours, defined as from 7:00 a.m. to 8:00 p.m. Monday through Friday, 8:00 a.m. to 5:00 p.m. on Saturdays, and from 8:00 a.m. to 5:00 p.m. on Sundays. Project construction would be conducted during these daytime hours and would, therefore, be exempt from the restrictions of the noise ordinance. Additionally, pursuant to Action N-1f of the GPU, the project would implement the following construction-related noise control measures:
• Noise-generating construction activities, including truck traffic coming to and from the construction site for any purpose, shall be limited as specified in the Noise Ordinance. • All equipment driven by internal combustion engines shall be equipped with mufflers, which are in good condition and appropriate for the equipment. • The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists.
• At all times during project grading and construction, stationary noise-generating equipment shall be located as far as practicable from sensitive receptors and placed so that emitted noise is directed away from residences.
• Unnecessary idling of internal combustion engines shall be prohibited. • Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction activities, to the extent feasible.

In light of the Sebastopol Noise Ordinance exemption for daytime construction noise and the construction-related noise control measures required by Action N-1f of the GPU, and consistent with the findings of the 2016 GPU FEIR, the construction-related noise impacts of the proposed project would be less than significant.
b) Impacts related to generation of vibration that would result from construction activities from development under the GPU were evaluated under Impact 3.11-4 on pages 3.11-35 to 3.11-36 of the GPU DEIR. The analysis determined that upon full buildout of the GPU and with implementation of the noise-related policies and actions contained in the GPU, the impact of construction vibration would be less than significant.

Construction activities could occur under the proposed project which could have the potential to expose sensitive land uses within the city to groundborne vibration. Construction activities would occur which may require activities or use of off-road equipment known to generate some degree of vibration. Activities that would potentially generate excessive vibration, such as blasting or impact pile driving, would not be expected to occur from the proposed project. Receptors sensitive to vibration include structures (especially older masonry structures), people, and Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 equipment (e.g., magnetic resonance imaging equipment, high resolution lithographic, optical and electron microscopes). Regarding the potential effects of groundborne vibration to people, except for long-term occupational exposure, vibration levels rarely affect human health.

The primary vibration-generating activities associated with the proposed project would occur during grading, placement of underground utilities, and construction of foundations.

Table NOI-4 shows the typical vibration levels produced by construction equipment at various distances. The most substantial source of groundborne vibrations associated with commercial development construction would be the use of drill rigs for foundation peers, if required.

TABLE NOI-4

VIBRATION LEVELS FOR CONSTRUCTION EQUIPMENT
Equipment
PPV (in/sec)a
At 25 Feet (Reference) At 50 feet
Large Bulldozer 0.089 0.042
Auger Drill Rig 0.089 0.042
Loaded Trucks 0.076 0.035
Jackhammer 0.035 0.016
NOTES:
a. Vibration amplitudes for construction equipment assume normal propagation conditions and were calculated using the following formula: PPV (equip) = PPV (ref) x (25/D)1.1 where:

PPV (equip) = the peak particle velocity in in/sec of the equipment adjusted for the distance PPV (ref) = the reference vibration level in in/sec from pp. 31–33 and Table 18 of the Caltrans Vibration Guidance Manual, as well as Table 12-2 of the FTA’s Noise and Vibration Guidance Manual D = the distance from the equipment to the receiver
SOURCES: Caltrans, 2020. Transportation and Construction Vibration Guidance Manual, April 2020; U.S. Department of Transportation (U.S. DOT), 2018. Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Manual, September 2018. Accessed May 6, 2024
According to the Caltrans Transportation and Construction Vibration Guidance Manual, the building damage threshold for historic and some older buildings is 0.25 PPV (in/sec) (Caltrans, 2020). As indicated in Table NOI-4, construction activities at distances of 25 feet or further from the nearest existing buildings would be well below the threshold of 0.25 PPV to avoid structural damage to historic and older buildings. For these reasons, project-related construction and operational groundborne vibration impacts would be less than significant. c) Impacts related to exposure of people to excessive noise levels from airports or private air strips were not evaluated in the GPU DEIR because the city is not located within an airport land use plan or within two miles of a public airport or public use airport. Therefore, similar to the findings of the GPU FEIR, this criterion is not applicable to the proposed project which would have no impact with regard to noise exposure from airports.

Conclusion
As discussed above, the proposed project would not result in effects related to noise and vibration that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously Agenda Item Number 10 Agenda Item Number: 10
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References
California Department of Transportation (Caltrans), 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013.

Caltrans, 2020. Transportation and Construction Vibration Guidance Manual, April 2020, pp. 29–34.

Available at: http://www.dot.ca.gov/hq/env/noise/publications.htm. Accessed May 6, 2024.

Federal Highway Administration, 2006. Roadway Construction Noise Model User Guide.

Fehr & Peers, 2024. Intersection Level of Service Assessment for Barlow Hotel Project, May 2024.

Trane. 2002. Engineering Bulletin, Sound Data and Application Guide for New and Quieter Air-Cooled Series R Chiller.

U.S. Department of Transportation (U.S. DOT), 2018. Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Manual, September 2018.

14. Population and Housing
POPULATION AND HOUSING — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?
No No No No
b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
No No No No
Discussion
a) Impacts related to population growth that would result from implementation of the GPU were evaluated under Impact 3.10-3 on pages 3.10-14 to 3.10-16 of the GPU DEIR. The analysis determined that the GPU accommodates future growth in Sebastopol, including new businesses, expansion of existing businesses, and new residential uses. Infrastructure and services would need to be extended to accommodate future growth. Specifically, the analysis determined that buildout of the GPU could yield up to 750 new residential units, 341,159 square feet of new commercial space, 59,959 square feet of new industrial space, and 137,375 square feet of new office space within the city limits. The analysis determined that this new growth would increase the City’s population by approximately 1,658 residents. The analysis determined that the full development of the new commercial, office, and industrial uses would increase the employment opportunities in Sebastopol by approximately 1,545 employees.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 In addition, the analysis determined that cumulative buildout of the GPU within the city limits and the Sphere of Influence (SOI) and Urban Growth Boundary (UGB) could yield up to 1,185 new residential units, 341,159 square feet of new commercial space, 684,889 square feet of new industrial space, and 137,375 square feet of new office space. The analysis determined that this new cumulative growth would increase the City’s population by approximately 2,619 residents and would increase the employment opportunities in Sebastopol by approximately 2,632 employees. The analysis determined that growth under the GPU would remain within the general growth levels projected statewide and would not be anticipated to exceed any applicable growth projections or limitations that have been adopted to avoid an environmental effect. The analysis determined that the GPU is intended to accommodate the City’s fair share of statewide housing needs, which are allocated by the Association of Bay Area Governments, based on regional numbers provided by the California Department of Housing and Community Development. The analysis determined that the GPU includes policies and actions that mitigate environmental impacts associated with growth, such as air quality, noise, traffic, water supply, and water quality effects. The analysis determined that, with implementation of GPU policies and actions intended to guide growth to appropriate areas and provide services necessary to accommodate growth, the land uses allowed under the GPU, the infrastructure anticipated to accommodate proposed land uses, and the goal and policy framework would not induce growth that would exceed adopted thresholds. Therefore, the analysis concluded that population and housing growth associated with the GPU would result in a less than significant impact related to population growth.

Although, the City’s Zoning Code Section 17.08.100 states that “Hotel” means a residential building, the proposed project would not add new residences or new residential population to the project area. The hotel is anticipated to add up to 50 employees with up to 10 extra employees for events, and it is anticipated that there would be two employees for valet operations during the 12 staffed hours. It is likely that most of these employees would be existing residents of Sebastopol or Sonoma County. Even conservatively assuming that all project employees would relocate to the area from outside of the region, the increase of up to 62 employees represents 4 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. It is further noted that the increase of employees described above is conservative and does not factor in the approximately 20-30 workers employed at the Guayaki warehouse under existing conditions. Factoring in these employees, the net increase of employees with implementation of the proposed project compared to existing conditions would be 32-42 employees, or 2-3 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. Finally, the proposed project is consistent with the GPU land use designation for the project site, and therefore the proposed project uses and associated employment growth were evaluated in the GPU FEIR and determined to result in a less-than-significant impact related to population growth. b) There are no residential uses on the project site (both the hotel site and parking lot site).

Therefore, the proposed project would not displace existing people or housing. There would be no impact under this significance criterion.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Conclusion
As discussed above, the proposed project would not result in effects related to population and housing that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

15. Public Services
PUBLIC SERVICES —
Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in More
Severe Adverse
Impact than
Identified in the

GPU FEIR
a) Would the project result in substantial adverse
physical impacts associated with the provision of new
or physically altered governmental facilities, need for new or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the following public
services:
i) Fire protection? No No No No
ii) Police protection? No No No No
iii) Schools? No No No No
iv) Parks? No No No No
v) Other public facilities? No No No No
Discussion
a.i–v) The potential for implementation of the GPU to result in adverse physical impacts on the environment associated with governmental facilities and the provision of public services was evaluated under Impact 3.12-1 on pages 3.12-11 to 3.12-17 of the GPU DEIR. The analysis determined that development and growth in the city under the GPU would result in increased demand for public services, including fire protection, law enforcement, schools, parks, libraries, and other public and governmental services. The analysis determined that the GPU includes policies and actions to ensure that public services are provided at acceptable levels and to ensure that development and growth does not outpace the provision of public services. The analysis determined that, as future development and infrastructure projects, including new governmental facilities, are considered by the City, each project will be evaluated for conformance with the City’s General Plan, Municipal Code, and other applicable regulations. The analysis determined that subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. The analysis determined that the GPU includes a range of policies and actions to ensure that public services are provided in a Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 timely fashion, are adequately funded, are coordinated between the City and appropriate service agency, and that new development funds its fair share of services. The analysis determined that the GPU includes policies to ensure that fire protection and law enforcement services keep pace with new development and that school, library, and governmental services are adequately planned and provided. The analysis determined that the GPU DEIR addresses the potential impacts of development that may occur under the GPU, including residential, commercial, office, industrial, public facilities, and a range of other uses that are accommodated by the GPU. Where potentially significant or significant impacts are identified, the analysis determined that the GPU DEIR identifies mitigation measures to reduce the impact and discloses which impacts cannot be reduced to a less than significant impact. The analysis determined that there are no additional environmental impacts, apart from those disclosed in the relevant chapters of the GPU DEIR that are anticipated to occur. Therefore, the analysis concluded that this impact is considered less than significant, and no additional mitigation is necessary.

The proposed project is consistent with the GPU land use designation for the project site, and therefore impacts related to the provision of public services (including fire protection, police protection, schools, and parks) associated with the proposed project were analyzed within the GPU EIR and the proposed project is generally not anticipated to require additional services. In addition, as discussed in Section 14, Population and Housing, of this document, the proposed project would not add new residences or new residential population to the project area that would generate increased demand for public services. The hotel would add up to 50 employees with up to 10 extra employees for events, and it is anticipated that there would be two employees for valet operations during the 12 staffed hours. It is likely that most of these employees would be existing residents of Sebastopol or Sonoma County. Even conservatively assuming that all proposed project employees would relocate to the area from outside of the region, the increase of up to 62 employees represents 4 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. It is further noted that the increase of employees described above is conservative and does not factor in the approximately 20-30 workers employed at the Guayaki warehouse under existing conditions. Factoring in these employees, the net increase of employees with implementation of the proposed project compared to existing conditions would be 32-42 employees, or 2-3 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. The proposed project’s increase in employment or hotel guests would not result in a substantial increase in demand for public services.

With regard to fire protection service, while the LOS report raised concerns with staffing, it indicates that the Sebastopol Fire Department met the National Response Standard for volunteer fire departments, and therefore fire protection service would be sufficient to serve the proposed project. The proposed project would not result in the need for new or physically altered fire protection facilities.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 With regard to police protection, the GPU specifies an objective that the Sebastopol Police Department will respond to 70 percent of priority calls within 3 minutes. Due to staff vacancies and other factors, the LOS report noted that the response time under this standard was 3 minutes 33 seconds, thus not meeting the objective. The LOS report notes that this objective needs to be kept in perspective and should be used as a benchmark. The LOS report recommends that response time be monitored but does not recommend other actions. The proposed project would not create unusual demands on police services, and based on the above analysis, police protection service would be sufficient to serve the proposed project. The proposed project would not result in the need for new or physically altered police protection facilities.

With regard to parks, the LOS report indicates that the City has met the General Plan standard for the provision of park facilities.20 As noted above, the proposed project would not add new residences or new residential population to the project area that would generate increased demand for parks. The proposed project’s increase in employment or hotel guests would not result in a substantial increase in demand for parks. The proposed project would not result in the need for new or physically altered park facilities.

With regard to schools, the LOS report documents an overall trend of declining enrollment in Sebastopol schools. As noted above, the proposed project would not add new residences or new residential population to the project area that would generate increased demand for schools. The proposed project would not result in the need for new or physically altered school facilities.

Conclusion
As discussed above, the proposed project would not result in effects related to public services that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
City of Sebastopol, 2023. 2022 Annual Level of Service Report (LOS Report), December 19, 2023. 20 As discussed in the LOS report, with 7,489 residents in the city in 2022, the total parkland ratio is 6.14 acres for each 1,000 residents, which means that the City has met the parkland General Plan standard.

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16. Recreation
RECREATION —
Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated?
No No No No
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the
environment?
No No No No
Discussion
a,b) The potential for implementation of the GPU to result in adverse physical impacts associated with the deterioration of existing parks and recreation facilities or the construction of new parks and recreation facilities was evaluated under Impact 3.12-2 on pages 3.12-18 to 3.12-23 of the GPU DEIR. The analysis determined that growth accommodated under the GPU would include a range of uses that would increase the population of the city and also attract additional workers and tourists to the city. The analysis determined that this growth would likely also result in increased demand for parks and recreation facilities. The analysis determined that the GPU includes policies and actions that would ensure that existing parks and recreation districts are improved and maintained, by providing for a range of improvements appropriate to serve growth and ensure on-going improvement and maintenance of existing facilities and includes provisions to ensure that adequate parks and recreational facilities are provided at a pace adequate to serve new population growth. The analysis determined that the GPU DEIR addresses the potential impacts of development that may occur under the GPU, including residential, commercial, office, industrial, public facilities, and a range of other uses that are accommodated by the GPU. Where potentially significant or significant impacts are identified, the analysis determined that the GPU DEIR identifies mitigation measures to reduce the impact and discloses which impacts cannot be reduced to a less than significant impact. The analysis determined that there are no additional environmental impacts, apart from those disclosed in the relevant chapters of the GPU DEIR that are anticipated to occur. Therefore, the analysis concluded that this impact is considered less than significant, and no additional mitigation is necessary.

The proposed project is consistent with the GPU land use designation for the project site, and therefore impacts related to the provision of park and recreation facilities associated with the proposed project were analyzed within the GPU EIR and the proposed project is generally not anticipated to require additional park and recreation facilities. In addition, as discussed in Section 14, Population and Housing, of this document, the proposed project would not add new residences or new residential population to the project area that would generate increased demand for park and recreation facilities. The hotel would add up to 50 employees with up to 10 extra employees for events, and it is anticipated that there would be two employees for valet operations during the 12 staffed hours. It is likely that most of these employees would be existing residents of Sebastopol or Sonoma County. Even conservatively assuming that all proposed project Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 employees would relocate to the area from outside of the region, the increase of up to 62 employees represents 4 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. It is further noted that the increase of employees described above is conservative and does not factor in the approximately 20-30 workers employed at the Guayaki warehouse under existing conditions. Factoring in these employees, the net increase of employees with implementation of the proposed project compared to existing conditions would be 32-42 employees, or 2-3 percent of the increase of 1,545 new employees in Sebastopol projected with implementation of the GPU and evaluated in the GPU FEIR. The proposed project’s increase in employment or hotel guests would not result in a substantial increase in demand for park and recreation facilities.

In addition, the City of Sebastopol Planning Department produces an Annual Level of Service (LOS) Report to provide updates on a range of City services. The most recent LOS report was presented to the City Council on December 19, 2023, and covered the year 2022 (City of Sebastopol, 2023). With regard to parks, the LOS report indicates that the City has met the General Plan standard for the provision of park facilities.21 As noted above, the proposed project would not add new residences or new residential population to the project area that would generate increased demand for park and recreation facilities. The proposed project’s increase in employment or hotel guests would not result in a substantial increase in demand for park and recreation facilities. The proposed project does not include recreational facilities or require the construction or expansion of recreational facilities. Impacts related to recreation would be less than significant.

Conclusion
As discussed above, the proposed project would not result in effects related to recreation that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
City of Sebastopol, 2023. 2022 Annual Level of Service Report (LOS Report), December 19, 2023. 21 As discussed in the LOS report, with 7,489 residents in the city in 2022, the total parkland ratio is 6.14 acres for each 1,000 residents, which means that the City has met the parkland General Plan standard.

Agenda Item Number 10 Agenda Item Number: 10
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17. Transportation
TRANSPORTATION — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Conflict with a program plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
No No No No
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
No No No No
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
No No No No
d) Result in inadequate emergency access? No No No No
Discussion
The following analysis is based on the Barlow Hotel Project CEQA Transportation Assessment prepared for the proposed project by Fehr & Peers (2024) and included as Appendix F. The transportation assessment was prepared in accordance with current CEQA requirements for evaluation of transportation effects, as described in the analysis below.
a) The potential for implementation of the GPU to conflict with a program plan, ordinance, or policy addressing bicycle and pedestrian facilities was evaluated under Impact 3.13-8 on pages 3.13-31 to 3.13-35 of the GPU DEIR. The analysis determined that implementation of the GPU would improve the existing bicycle and pedestrian circulation infrastructure and require future development to provide multimodal circulation improvements. The analysis determined that the GPU includes a comprehensive list of policies and actions aimed at prioritizing multimodal circulation. Examples include Policies CIR 2-1 through 2-4 and Actions 2a and 2g, which call for the City of Sebastopol to establish, maintain, and implement a network of pedestrian and bicycle facilities that are consistent with the City’s Bicycle and Pedestrian Master Plan and its future updates. Policies CIR 2-4, CIR 2-5, and CIR 3-10, as well as Actions 1f and 2a, require development projects to construct pedestrian and bicycle improvements on- and off-site, consistent with the Bicycle and Pedestrian Master Plan. Policy CIR 1-10 and Action CIR 1f indicate that the City shall assess circulation impact fees that support facilities shown in the Bicycle and Pedestrian Master Plan. The analysis concluded that, given the GPU’s focus on enhancing Sebastopol’s multimodal circulation system; consistency with the Bicycle and Pedestrian Master Plan and any future updates of that Plan; requirements for future development to construct multimodal improvements; and commitment to fund larger bicycle and pedestrian improvement projects through impact fees, the potential impacts to pedestrian and bicycle circulation are considered to be less than significant.

Pedestrian facilities in the project vicinity include sidewalks, crosswalks, and pedestrian signals.

Crosswalks are provided at signalized and unsignalized intersections. Pedestrian push-button actuated signals are also provided at signalized intersections. Twelve-foot sidewalks are provided on both sides of Sebastopol Avenue, and eight- to nine-foot sidewalks are provided on both sides Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 of McKinley Street. The proposed project would create a significant impact related to the pedestrian system if it would disrupt existing pedestrian facilities; interfere with planned pedestrian facilities; or create inconsistencies with adopted pedestrian system plans, guidelines, policies, or standards. Existing sidewalks would remain intact with implementation of the proposed project. The project proposes no features that would be hazardous to pedestrian travel and does not conflict with any pedestrian facilities plans or programs. Therefore, the proposed project’s effect on the pedestrian system is less than significant.

With regard to bicycle facilities, Morris Street, Laguna Park Way, and Petaluma Avenue include Class II bicycle facilities while Sebastopol Avenue includes a Class III bike route. The proposed project would create a significant impact related to the bicycle system if it would disrupt existing bicycle facilities; interfere with planned bicycle facilities; or create inconsistencies with adopted bicycle system plans, guidelines, policies, or standards. While the proposed project does not propose any designated bicycle paths, bicycles would be permitted on site along with 12 bicycle parking spaces at the hotel and 20 bicycle parking spaces at the parking lot. The project proposes no features that would be hazardous to bicycle travel and does not conflict with any bicycle facilities plans or programs. The project’s effect on the bicycle system is less than significant.

With regard to site access and circulation, vehicle access to the project site would be provided via McKinley Street and SR-12. The proposed project would include demolition of portions of the existing parking lot directly east of the existing warehouse building, which would reduce the number of parking spaces on this parking lot from 87 to 73 (a reduction of 14 spaces). The project would add 232 parking spaces to the former batch plant site, which is currently vacant and includes no developed parking facilities. Therefore, the project would include 218 net new vehicle parking spaces. The posted speed limit along McKinley Street in the vicinity of the project is 15 miles per hour, while the posted speed limit along SR-12 in the vicinity of the project is 25 miles per hour. According to Table 201.1 of the Caltrans Highway Design Manual, the stopping sight distance is 100 feet at 15 miles per hour and 150 feet at 25 miles per hour.

The observed sight distance along both streets is greater than 100 and 150 feet in both directions.

The posted speed limit along Morris Street is 25 miles per hour, and the observed stopping sight distance is also greater than 150 feet in both directions. Additionally, per Table 405.1A of the Caltrans Highway Design Manual, the corner sight distance is approximately 165 feet for leftturning vehicles at 15 miles per hour and 143 feet for right-turning vehicles. The corner sight distance is approximately 275 feet for left-turning vehicles at 25 miles per hour and 238 feet for right-turning vehicles. Thus, the project site access points at the hotel site and the parking lot include sufficient stopping sight distance and corner sight distance so long as landscaping at the project site access intersections is maintained. It is recommended that the final site plan be reviewed prior to the issuance of building permits for potential sight distance impediments including new signs, above ground utility boxes, or landscaping proposed in the sight triangle.

Potential effects to transit systems resulting from implementation of the GPU were evaluated under Impact 3.13-7 on pages 3.13-29 to 3.13-31 of the GPU DEIR. The analysis determined that implementation of the GPU could lead to increases in the City’s population and employment that would increase the demand for transit services offered by Sonoma County Transit (SCT). The analysis determined that, while established standards regarding transit levels of service have not Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 been adopted by the City or transit agencies, the GPU includes policies that support transitoriented development patterns, strengthen ties between the pedestrian and bicycle networks to transit, promote enhancements to transit facilities, and support increased transit coverage and frequencies in Sebastopol. For example, Policies CIR 2-17 and CIR 2-20 indicate that the City shall seek funding for bus shelters and ensure that adequate lighting is provided at bus stops.

Policy CIR 2-19 calls for continued coordination with Sonoma County Transit to educate the public about using the transit system, and Policies CIR 2-21 through CIR 2-24 focus on improving park-and-ride facilities at major transit stops and continuing to monitor the need and locations for additional park-and-ride lots. Policy CIR 2-18 and Action CIR 2h state that the City of Sebastopol shall work with SCT to pursue improvements and funding to increase transit frequencies, hours of transit operation, and transit service areas in Sebastopol. Policy CIR-22 and Action CIR 2j call for the City to ensure that effective connections between Sebastopol and Sonoma–Marin Area Rail Transit (SMART) commuter rail stations in Santa Rosa and Cotati are in place. The analysis concluded that, given the GPU’s emphasis on increasing transit usage, improving transit facilities, and desire to fund future improvements to transit service, any potential impacts to transit are considered to be less than significant.

SCT and Mendocino Transit Authority both provide transit service in Sonoma and Mendocino Counties. The following routes operate in the vicinity of the project site:
● Sonoma County Transit: Route 20 (Russian River Area, Forestville, Sebastopol, Santa Rosa) ● Sonoma County Transit: Route 24 (Sebastopol Shuttle)
● Sonoma County Transit: Route 26 (Sebastopol, Cotati, Rohnert Park) ● Mendocino Transit Authority: Route 95 (South Coast/Santa Rosa) The SCT routes run along Sebastopol Avenue (SR-12), SR-116, Morris Street, McKinley Street, and Laguna Parkway, while the Mendocino Transit Authority route runs along Bodega Avenue and Sebastopol Avenue (SR-12). All transit stops are within one half-mile radius of the project site.

The proposed project would create a significant impact on transit if it would interfere with existing transit facilities or preclude the construction of planned transit facilities. The project proposes no features that would conflict with existing or planned transit services, and increases in ridership on local or regional transit facilities that would cause them to exceed their capacity are not expected to result with implementation of the proposed project. Therefore, the proposed project’s effect on the public transit system is less than significant. b) Senate Bill 743 (Steinberg 2013) instructed the State Office of Planning and Research (OPR) to update the CEQA Guidelines to eliminate congestion-based analysis (such as level of service analysis) from CEQA transportation analysis and replace it with a new metric (vehicle miles traveled, or VMT). The intent of SB 743 was to encourage infill development, promote healthier communities through active transportation (e.g., walking and bicycling), and align CEQA transportation analysis to aid California in meeting greenhouse gas reduction targets set by other pieces of legislation (i.e., AB 32). Ultimately, SB 743 shifted CEQA transportation analysis from measuring the effects of a project on drivers, to measuring the environmental effects of driving generated by a project. Adopted in December 2018, Section 15064.3 of the CEQA Guidelines Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 notes that VMT is the most appropriate metric for the analysis of impacts in the Transportation section of CEQA documents.

VMT measures the amount of driving a project generates. For example, a project generating 100 total (inbound and outbound) vehicle trips per day which travel an average of 5 miles per trip results in 500 project-generated VMT per day. VMT has historically been used in CEQA as an input for the Air Quality and Greenhouse Gas sections, but VMT can also be used to show how efficient the connection between the transportation system and existing or proposed land uses is.

The State Office of Planning and Research provided guidance in its Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018) as to how the analysis of VMT could be performed and what CEQA thresholds of significance could be applied. The guidance in the Technical Advisory is non-binding. The City of Sebastopol requirements (adopted in 2024) tier from the Technical Advisory and use the Sonoma County Transportation Authority (SCTA) countywide travel demand model and metrics, methods, and thresholds provided in the Technical Advisory. Based on direction from the City in its capacity as a lead agency for CEQA purposes, the VMT analysis is based on net change in VMT.

Adding hotel rooms would thus redistribute the demand across available hotel rooms. Because Sebastopol is does not have many hotels, local visitors currently use other nearby hotels and the new hotel rooms proposed as part of the Barlow Hotel project would shift demand away from these other nearby hotels located along the U.S. 101 corridor. If the Barlow Hotel is located closer to the goods and services desired by the public, the resulting net change in VMT would be a negative number because the Barlow Hotel is closer to these destinations than the hotels along the U.S. 101 corridor.

The following analysis assesses the impacts of shifting hotel demand on VMT. Nearby hotels along the US 101 corridor in Santa Rosa and Rohnert Park were identified based on characteristics such as location and amenities, and data on their trip distribution and trip length were collected from StreetLight Data’s database of “Big Data” location-based services. The analysis is conservative in that hotel data for similar hotels north of Santa Rosa, such as those in Healdsburg, were not used, which would have led to greater negative deltas in trip lengths, and consequently lower VMT calculations.

The “park-once” strategy for the Barlow also guides the analysis assumptions. Because the Barlow development (along with downtown Sebastopol as a whole) includes a diverse selection of land uses, including restaurants, stores, and parks, guests and visitors can park their vehicle once and easily walk or bike between their destinations. This contributes to a trip distribution pattern with reduced vehicle trips (and increased walk/bike trips) throughout the downtown area.

SCTA Model Regional VMT Analysis
Regional VMT by speed bin from the most recent version of the SCTA model were output for the Base Year (Year 2019), Base Year plus Project, Baseline Year (Year 2024, interpolated), Baseline Year plus Project (Year 2024, interpolated), Cumulative Year (Year 2040), and Cumulative Year plus Project scenarios. The traffic analysis zones of the selected hotels were Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 adjusted to reflect current hotel capacities and changes in hotel demand resulting from the construction of the Barlow Hotel. The results of the analysis are summarized below in Table TR-1.

TABLE TR-1

NET CHANGE IN REGIONAL VMT USING SCTA MODEL
Scenario Total Regional VMT Difference due to Project Impact? Base Year (Year 2019) 14,016,050
Base Year Plus Project 14,015,350 -700 No
Baseline Year (Year 2024) 14,534,400
Baseline Year Plus Project 14,533,830 -570 No
Cumulative (Year 2040) 16,193,050
Cumulative Plus Project 16,192,990 -60 No
Source: Fehr & Peers, 2024
As noted in Table TR-1, the proposed project results in a net decrease in VMT in all scenarios.

Therefore, the proposed project impact related to VMT is less-than-significant and no mitigation measures are required.

GIS/Big Data-Based Regional VMT Analysis
The GIS/Big Data-based VMT analysis approach considers the locations of comparable hotels to establish a sample trip distribution pattern for the hotel.22 Then, based on the relative distances between the sample hotels/ hotel and common destinations, a delta in trip length is computed. For many west county destinations, the trip length delta is negative (indicating that the trips for the hotel are shorter), but for other destinations (like San Francisco), the trip length delta is positive (indicating that trips for the hotel are longer).

Sample trip data was collected at the Census block group level. The block groups of the selected sample hotels were used as origins and destinations for typical hotel guest trips in the area, including both access trips (traveling between one’s home and the hotel) and tourist trips (traveling between the hotel and attractions in the area). The data included trip volumes and lengths in an origin-destination format, which were consolidated to create trip distributions for typical hotels in the area. Access and tourist trip distributions were developed and combined following the assumption that, on a typical average day, 20 percent of trips generated by the hotel would be access trips and 80 percent would be tourist trips. Following the “park once” strategy for the Barlow development, the analysis also assumed 25 percent of trips would remain within the Barlow area and would not directly contribute to VMT.

Project trip generation was calculated to be 664 daily weekday trips using ITE Land Use Code 310 from the 11th Edition of the ITE Trip Generation Manual, which reflects hotels with associated public uses interior to the hotel, such as meeting rooms and restaurants. This is in 22 Hotels analyzed include Hyatt Regency Sonoma Wine Country, Courtyard by Marriott Santa Rosa, AC Hotel by Marriott Santa Rosa Sonoma Wine Country, DoubleTree by Hilton Hotel Sonoma Wine Country, Oxford Suites Sonoma County – Rohnert Park, Graton Resort and Casino, and Fairfield Inn & Suites by Marriott Santa Rosa Sebastopol.

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 alignment with the SCTA model VMT assessment above, as the model also uses Code 310 for its hotel analysis. The ITE Trip Generation Manual includes additional codes for specific hotel types, but Code 310 contributes to a higher and more conservative trip generation calculation than other applicable codes such as Code 330 (Resort Hotel), so Code 310 is used in the Big Data analysis.

Shortest path trip lengths between block groups were calculated in GIS. As shown in Table TR-2, the final calculation was a reduction of 185 vehicle-miles, which suggests the addition of the hotel has the potential to reduce VMT in the area.

TABLE TR-2

NET CHANGE IN REGIONAL VMT
Scenario Difference due to project Impact?
Existing Plus Project -185 No
Source: Fehr & Peers, 2024
The proposed project would result in a net decrease in VMT in the existing plus project scenario.

Therefore, the proposed project’s impacts to VMT would be less than significant and no mitigation measures are required.
c) The potential for implementation of the GPU to substantially increase hazards due to a geometric design feature was evaluated under Impact 3.13-5 on page 3.13-27 of the GPU DEIR. The analysis determined that the City maintains improvement standards that guide the construction of new transportation facilities to minimize design hazards for all users of the system. Through the environmental review process, land use proposals that would add traffic to streets not designed to current standards are carefully evaluated. If needed, mitigations are identified, and the project is conditioned to construct or provide funding for an improvement that would minimize or eliminate the hazard. Typical improvements include shoulder widening, adding turn pockets, adding sidewalks or crosswalks, realigning sharp curves, prohibiting certain turning movements, and signalizing intersections. New and upgraded roadways needed to accommodate new development will be designed according to applicable federal, state, and local design standards.

The analysis identified that development and infrastructure projects in Sebastopol would be required to comply with the General Plan, Land Use Code, and applicable state and local regulations. The GPU also establishes several policies and actions that are intended to result in roadway designs that safely accommodate all users and reinforce lower driving speeds where appropriate to enhance safety. Specifically, GPU Policies CIR 1-11 and CIR 3-9 address the need to design circulation facilities to provide safe access for all users. Action CIR 1k requires the City to monitor collision reports and operation in order to prioritize implementation of safety improvements, and Action CIR 3c requires the City to review its adopted street standards and update as necessary to maintain safety for all users. Further, the analysis determined that GPU does not contain any provisions that would increase hazards due to design features of incompatible uses. Therefore, the analysis concluded that this impact is less than significant.

Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The project proposes no features that would increase hazards due to a geometric design feature, and this impact would be less than significant.
d) Emergency response within the City of Sebastopol is provided by the Sebastopol Fire Department. Emergency vehicle access to the site is provided by McKinley Street and Sebastopol Avenue (SR-12). As the project has multiple access points, and the width or access points and internal roadways appears to be sufficient to accommodate emergency vehicles, the proposed project’s effect on emergency vehicle access is less-than-significant.

Conclusion
As discussed above, the proposed project would not result in effects related to transportation that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

References
Fehr & Peers, 2024. Barlow Hotel Project CEQA Transportation Assessment, June 2024.

Agenda Item Number 10 Agenda Item Number: 10
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18. Tribal Cultural Resources
TRIBAL CULTURAL RESOURCES —
Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a
site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope
of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public
Resources. Code Section 5020.1(k), or
No No No No
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 Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.

No No No No
Discussion
a) Tribal cultural resources are: (1) sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are listed, or determined to be eligible for listing, in the California Register of Historical Resources (CRHR), or local register of historical resources, as defined in PRC Section 5020.1(k); or (2) a resource determined by the CEQA lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in PRC Section 5024.1(c). For a cultural landscape to be considered a tribal cultural resource, it must be geographically defined in terms of the size and scope of the landscape (PRC Section 21074[b]). A historical resource, as defined in PRC Section 21084.1, unique archaeological resource, as defined in PRC Section 21083.2(g), or non-unique archaeological resource, as defined in PRC Section 21083.2(h), may also be a tribal cultural resource.

Through background research at the Northwest Information Center of the California Historical Resources Information System, no known archaeological resources that could be considered tribal cultural resources, are listed or determined eligible for listing in the CRHR or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 21074(a)(1), would be impacted by the proposed project.

On May 7, 2024, the Native American Heritage Commission was contacted to request a search of their Sacred Lands file and a list of California Native American tribes in the vicinity of the proposed project. On May 13, 2024, the NAHC responded that no Sacred Lands are on file in the Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 immediate project vicinity. In addition, the following tribes were contacted for the General Plan and did not have any concerns about the Barlow site.
• Ms. Patricia Hermosillo, Chairperson, Cloverdale Rancheria of Pomo Indians; • Mr. Mario Hermosillo, Jr., Tribal Environmental Planner, Cloverdale Rancheria of Pomo Indians; Mr. Harvey Hopkins, Chairperson, Dry Creek Rancheria of Pomo Indians; • Ms. Marjorie Mejia, Chairperson, Lytton Rancheria of California; • Ms. Lisa Miller, Tribal Administrator, Lytton Rancheria of California; • Mr. Emilio Valencia, Chairperson, Stewarts Point Rancheria; • Ms. Nina Hapner, Environmental Planning Department, Stewarts Point Rancheria; • Mr. Otis Parish, Tribal Historic Preservation Office, Stewarts Point Rancheria; • Mr. Greg Sarris, Chairperson, The Federated Indians of Graton Rancheria; Mr. Gene Buvelot, The Federated Indians of Graton Rancheria; and
• Ya-Ka-Ama.

Based on the above discussion, the City did not identify any tribal cultural resources listed or eligible for listing in the CRHR, nor did they determine any resources to be significant pursuant to criteria set forth in Subdivision (c) of PRC Section 5024.1.

Conclusion
The proposed project would not result in effects related to tribal cultural resources that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

Agenda Item Number 10 Agenda Item Number: 10
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19. Utilities and Service Systems
UTILITIES AND SERVICE SYSTEMS — Would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
No No No No
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry, and multiple dry years?
No No No No
c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it
has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
No No No No
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
No No No No
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid
waste?
No No No No
Discussion
a) The potential for implementation of the GPU to require or result in the construction of new water treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects was evaluated under Impact 3.14-2 on pages 3.14-18 to 3.14-19 of the GPU DEIR. The analysis determined that development and growth in the city under the GPU would result in increased demand for water supplies, including water conveyance and treatment infrastructure. The analysis determined that the GPU includes policies and actions to ensure that water supplies are provided at acceptable levels and to ensure that development and growth does not outpace the provision of available water supplies. The analysis determined that, as described under Impact 3.13-1 of the GPU DEIR, the projected water supplies are adequate to meet demand that would be generated by buildout of the GPU. As such, the analysis determined that implementation and buildout of the GPU would not result in the need to construct or expand water supply and treatment facilities that have not already been described and accounted for the in the City’s relevant water master plans. The analysis determined that, as future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the City’s General Plan and other applicable regulations. The analysis determined that subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. The analysis determined that future development in the Planning Area would be required to connect to existing water distribution infrastructure in the vicinity of each site, pay the applicable water system connection fees, and pay the applicable water usage rates. The analysis determined that future projects may be required to implement site specific and limited offsite improvements to the water distribution Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 system in order to connect new project sites to the City’s existing water infrastructure network.

The analysis determined that any future improvements to the existing water distribution infrastructure would be primarily provided on sites with land use designations that allow for urbanized land uses, and the environmental impacts of constructing and operating the new water distribution infrastructure would likely be similar to those associated with new development, redevelopment, and infrastructure projects under the GPU. The analysis determined that these impacts are described in the relevant chapters of the GPU DEIR. The analysis determined that, where potentially significant or significant impacts are identified, the GPU DEIR identifies mitigation measures to reduce the impact and discloses which impacts cannot be reduced to a less than significant impact. The analysis concluded that there are no additional environmental impacts apart from those disclosed in the relevant chapters of the GPU DEIR that are anticipated to occur, and therefore, this impact is considered less than significant, and no additional mitigation is necessary.

As discussed in the Project Description, the City of Sebastopol would provide water service to the hotel building via an existing 8-inch water supply main in Sebastopol Avenue. No off-site improvements to the existing water mains are needed to serve the hotel building. No new water supply infrastructure is planned for the parking lot site. The water line to the hotel building would be slightly relocated as is shown on the project plans (Appendix A) but an 8-inch supply pipe would continue to serve the hotel building. As discussed below in item b), there are sufficient water supplies available to serve the project and reasonably foreseeable future development.

In accordance with City requirements, the proposed project would connect to existing water distribution infrastructure, pay the applicable water system connection fees, and pay the applicable water usage rates. Consequently, the proposed project would not require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects.

The potential for implementation of the GPU to require or result in the construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects was evaluated under Impact 3.14-4 on pages 3.14-30 to

3.14-32 of the GPU DEIR. The analysis determined that development under the GPU would result in increased wastewater flows, resulting in the need for additional wastewater treatment facilities and conveyance infrastructure. The analysis determined that the infrastructure and facilities necessary to serve new growth would involve development of some facilities on-site, some facilities off-site on appropriately designated land, and may also involve improvements to existing facilities and disturbance of existing rights-of-way. The analysis determined that, as future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the City’s General Plan, Municipal Code, and other applicable regulations. The analysis determined that subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. The analysis determined that the GPU includes policies and actions designed to ensure adequate wastewater treatment capacity is available to serve development, to minimize the potential adverse effects of wastewater treatment, and to ensure that development does not move forward until adequate wastewater capacity exists. GPU Policy CSF 4-2 ensures sewage system capacity is adequate to match the rate of development. Policy CSF 4-6 requires projects to Agenda Item Number 10 Agenda Item Number: 10
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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 demonstrate that existing services are adequate to accommodate the increased demand or that improvements to the capacity of the system to meet increased demand will be made prior to project implementation. Policy CSF 4-4 and CSF 4-7 ensures adequate funding is available for needed improvements to the wastewater conveyance infrastructure to provide necessary improvements and ensure coordination with wastewater treatment providers to plan for necessary improvements to accommodate growth. The analysis concluded impacts related to construction of new wastewater treatment facilities or expansion of existing facilities would be less than significant.

As discussed in the Project Description, wastewater generated by the hotel building would be collected by the City of Sebastopol’s sewer system via an 8-inch main located in Sebastopol Avenue. No off-site improvements to the existing sewer mains are needed to serve the hotel building. The 8-inch main located in Sebastopol Avenue would be slightly relocated as is shown on the project plans (Appendix A) but an 8-inch main would continue to serve the hotel building.

No new wastewater improvements are planned for the parking lot site.

With regard to wastewater treatment, the City of Sebastopol Planning Department produces an Annual Level of Service (LOS) Report to provide updates on a range of City services. The most recent LOS report was presented to the City Council on December 19, 2023, and covered the year 2022 (City of Sebastopol, 2023). As discussed in the LOS report, Sebastopol maintains a sanitary sewer collection system and pumping stations that transfer wastewater from Sebastopol to the Sub-regional Water Reclamation System Treatment Plant operated by the City of Santa Rosa on Llano Road. As a partner in the Sub-regional system, Sebastopol has an entitlement to treatment capacity up to 840,000 gallons, or 0.84 million gallons per day (mgd). Average dry weather sewer flow in 2022 was 0.393 mgd, or about 47 percent of treatment entitlement, and a reduction from the prior year. Accounting for this flow, a reserve factor, and approved and pending projects, there is an estimated 0.374 mgd of unused treatment capacity. According to the LOS report, this equates to 45 percent of treatment capacity and would support the development of 2,415 single family homes (a substantially higher sewer use than hotel rooms). Consequently, there would be adequate wastewater treatment capacity to serve the proposed project, and the proposed project would not require or result in the construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects.

With regard to storm water drainage, storm water drainage facilities that are owned and maintained by the City of Sebastopol would serve the hotel building (with facilities located in McKinley Street) and the parking lot site (with facilities located in Morris Street). Storm water on both the hotel building site and the parking lot site would be managed with a combination of Low Impact Development (LID), storm water quality treatment, and flood control measures. These measures would include, but are not limited to, planting new trees, handling roof downspouts, and installing bioretention areas. Storm water on the project site (i.e., the two locations that comprise the project site) would be directed to two on-site bioretention areas. One bioretention area would be in the center of the parking lot and the second bioretention area would be on the north side of the parking lot. No off-site improvements to the existing drainage infrastructure are needed to serve the proposed project.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 The hotel parcel is currently served by existing natural gas lines. The existing service to the building would be relocated as required by building code and PG&E requirements.

Electrical service to the hotel and parking lot site would be provided by PG&E via existing infrastructure in the project area. No off-site improvements to existing electrical infrastructure are needed at this time.
b) The evaluation of whether sufficient water supplies would be available to serve implementation of the GPU was provided under Impact 3.14-1 on pages 3.14-14 to 3.14-17 of the GPU DEIR.

The analysis determined that implementation of the GPU would result in increased population and employment growth within the City’s Planning Area and a corresponding increase in the demand for additional water supplies. The analysis determined that the GPU includes a comprehensive set of goals, policies, and actions to ensure an adequate and reliable source of clean potable water, and impacts associated with water supplies are less than significant.

As discussed above, the City of Sebastopol Planning Department produces an Annual LOS report to provide updates on a range of City services. The most recent LOS report was presented to the City Council on December 19, 2023, and covered the year 2022 (City of Sebastopol, 2023). As discussed in the LOS report, Sebastopol is dependent on its municipal wells for water to supply customers. The City does not have a backup system, nor does it have a connection to other water systems in the area, which makes it critical that the City’s water system is maintained and closely monitored. As discussed in the LOS report, the Sebastopol Public Works Department produces an annual report, which includes statistics for water production, usage, and wastewater flow. The report also contains information about groundwater levels in City wells. The report shows that in 2022 there was a decrease of approximately 7 percent in total annual water production, from 309 million gallons in 2021 to 286 million gallons in 2022. The LOS report determined that California had an extremely dry water year in 2022, which saw precipitation totals decrease below average for Sebastopol. The report identified that Sebastopol’s water demand remains significantly lower than when production peaked at 500 million gallons in 2004. The report determined that the estimated water demand from projects currently approved by the City but not yet constructed is

8.3 million gallons per year. This represents the equivalent of approximately 3 percent of total production in 2022. The report determined that the water demand for projects pending approval is estimated at an additional 10.6 million gallons per year. The LOS report determined that this is equivalent to an additional 4 percent of 2022 annual production.

Annual water demand for the proposed project is estimated to be approximately 3,320,588 million gallons per year. This includes approximately 3,120,020 gallons per year for domestic hotel uses, approximately 85,038 gallons per year for hotel landscaping irrigation, and approximately 115,530 gallons per year for parking lot landscaping irrigation. It is noted that water demand for parking lot landscaping irrigation is expected to be reduced by 50 percent (to approximately 57,765 gallons per year) after the first three years of plant establishment, thereby reducing total estimated annual project water demand to approximately 3,262,823 gallons per year (Emerald City Engineering, 2025; ZAC Landscape Architects, 2025).

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Based on actual production, historic production capability, and the estimated annual water demand for the proposed project, sufficient water supplies would be available to serve the proposed project.
c) As discussed above under item a), Sebastopol maintains a sanitary sewer collection system and pumping stations that transfer wastewater from Sebastopol to the Sub-regional Water Reclamation System Treatment Plant operated by the City of Santa Rosa on Llano Road. As a partner in the Sub-regional system, Sebastopol has an entitlement to treatment capacity up to 840,000 gallons, or 0.84 mgd. Average dry weather sewer flow in 2022 was 0.393 mgd, or about 47 percent of treatment entitlement, and a reduction from the prior year. Accounting for this flow, a reserve factor, and approved and pending projects, there is an estimated 0.374 mgd of unused treatment capacity. According to the LOS report, this equates to 45 percent of treatment capacity and would support the development of 2,415 single family homes (a substantially higher sewer use than hotel rooms). Consequently, there would be adequate wastewater treatment capacity to serve the proposed project.
d,e) The potential for implementation of the GPU to generate solid waste in excess of federal, state, or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals was evaluated under Impact 3.14-5 on pages 3.14-39 to

3.14-40 of the GPU DEIR. The analysis determined that development under the GPU will generate a population increase within the Sebastopol Planning Area of approximately 2,619 persons and an increase in employment of approximately 2,632 jobs upon cumulative GPU buildout. The analysis determined that the California Department of Resources Recycling and Recovery (CalRecycle) has established a per resident disposal target rate of 7.1 pounds per day (ppd) and a per employee disposal rate of 18.3 ppd for the Sonoma County Waste Management Agency (SCWMA). The analysis determined that cumulative growth under GPU buildout would result in an increase of approximately 34,169 pounds per day of solid waste (2,619 x 3.6) + (2,632 x 9.4), which equals 17.08 tons per day or 6,235.9 tons of solid waste per year. The analysis determined that the City’s annual increase in solid waste generation is well within the permitted capacity of the Central Disposal Site serving the City and does not exceed the daily permitted capacity of the landfill. The proposed project is consistent with the GPU land use designation for the project site, and therefore the proposed project uses and associated solid waste generation were evaluated in the GPU FEIR and determined to result in a less-than-significant impact related to solid waste.

Conclusion
As discussed above, the proposed project would not result in effects related to utilities and service systems that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

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CEQA Section 15183 Environmental Review Consistency Checklist The Barlow Hotel Project 96 ESA / D202301440
CEQA Section 15183 Environmental Review Consistency Checklist January 2025 References
City of Sebastopol, 2023. 2022 Annual Level of Service Report (LOS Report), December 19, 2023.

Emerald City Engineering, 2025. Estimated Domestic Water Usage for the Barlow Hotel Project.

ZAC Landscape Architects, 2025. Estimated Irrigation Water Usage for the Barlow Hotel Project.

20. Wildfire
WILDFIRE — If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Significant
Project Impact
(Peculiar to the
Project or
Parcel)
Project
Impact not
Identified by

GPU FEIR
Off-Site or
Cumulative
Impact not
Identified by

GPU FEIR
Substantial New
Information
Resulting in
More Severe
Adverse Impact
than Identified
in the GPU FEIR
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
No No No No
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
No No No No
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No No No No
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
No No No No
Discussion
a–d) Impacts related to the potential for implementation of the GPU to expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires were evaluated under Impact 3.8-6 on pages 3.8-26 to 3.8-29 of the GPU DEIR. The analysis determined that there are no Fire Hazard Severity Zones (FHSZs) within State Responsibility Areas (SRAs) or Very High Fire Hazard Severity Zones (VHFHSZs) within any Local Responsibility Areas (LRAs) in the City of Sebastopol.23 The analysis concluded that implementation of the GPU would have a less than significant impact with regards to this issue.

The project site (both the hotel site and the parking lot site) are both urban infill areas and are not located in or near SRAs or lands classified as VHFHSZ. Construction and operation of the proposed project would adhere to all applicable state and local regulations, codes, and policies that address fire safety, ensuring that impacts related to wildfire would be less than significant. 23 The state has charged CAL FIRE with the identification of Fire Hazard Severity Zones (FHSZ) within State Responsibility Areas. In addition, CAL FIRE must recommend Very High Fire Hazard Severity Zones (VHFHSZ) identified within any Local Responsibility Areas. The FHSZ maps are used by the state Fire Marshall as a basis for the adoption of applicable building code standards.

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CEQA Section 15183 Environmental Review Consistency Checklist January 2025 Conclusion
The proposed project would not result in effects related to wildfire that are peculiar to the project or the parcels on which the project would be located and were not analyzed as significant effects in the GPU FEIR; would not result in potentially significant off-site impacts or cumulative impacts that were not discussed in the GPU FEIR; and would not result in previously identified significant effects which, as a result of substantial new information that was not known at the time the GPU FEIR was certified, are determined to have a more severe adverse impact than discussed in the GPU FEIR.

Accessed May 26, 2024.

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RESOLUTION NUMBER: XXXX-2025

SEBASTOPOL PLANNING COMMISSION

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF SEBASTOPOL RECOMMENDING THE

CITY COUNCIL APPROVE A DEVELOPMENT AGREEMENT FOR THE BARLOW HOTEL DEVELOPMENT AND OFF-SITE PARKING AT 6782 SEBASTOPOL AVENUE AND 386 MORRIS STREET WHEREAS, Highway Partners LLC, Sebastopol lndustrial Park LLC, and Barlow Star LLC (collectively "Applicant") have proposed to develop a hotel at 6782 Sebastopol Avenue, with related overflow and valet parking facilities at 385 Morris Street (the "Project"); and WHEREAS, the Project will include a single, 69,934 square foot structure, consisting of up to 83 guest rooms, a meeting room and a conference room, retail space, spa, lobby restaurant, rooftop pool and deck, and rooftop cafe; and
WHERES, the structure will be up to 55 feet in height, except that a rooftop shade structure and certain mechanical facilities will be up to 55 feet in height; and WHEREAS, the Project will include 305 total parking spaces, including 73 spaces aL6782 Sebastopol Avenue (the "Hotel Site") and 242 new spaces at 385 Morris Street (the "Parking Lot Site"); and WHEREAS, the Project will involve the removal of one 27" dbh Valley Oak on the Hotel Site pursuant to Sebastopol Municipal Code Section 8.12.060(D)2 &4; and
WHEREAS, the Project will include the addition of 133 new native trees to the Parking Lot Site; and WHEREAS, the Applicant will be providing a publicly accessible promenade across the Parking Lot Site, connecting to a scenic overlock of the Laguna de Santa Rosa, which will include bicycle parking, benches, trash receptacles, and interpretive signage, and will dedicate a public access easement 10'wide to accommodate the existing AmeriCorps trail where it crosses the northeast corner of the Parking Lot Site; and
WHEREAS, the entire easterly portion of the Parking Lot site, from the 50' ESOS setback line to the easterly parcel boundary, will be dedicated as permanent open space through recordation of an open space easement; and
WHEREAS, the Project will replace the existing 36,402 square foot GuayakiYerba Mate buildingat6T32 Sebastopol Avenue; and
WHEREAS, the Project is situated within the Barlow market district, which is a destination for Sebastopol-area residents as well as visitors to the area; and WHEREAS, the Project Site has a land use designation of Limited lndustrial, which allows for a hotel development as well as parking facilities; and
WHEREAS, the Hotel Site is zone Commercial lndustrial which allows hotels, and accessory uses, as a conditionally permitted use; and
L
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WHEREAS, the Parking Lot Site is zoned lndustrial/Environmental & Scenic Open Space ("ESOS") Combining Zone, which allows off-site parking facilities as a conditionally permitted use; and WHEREAS, the Applicant has requested the City enter into a development agreement to govern the project pursuant to Government Code section 65864 et seq.; and WHEREAS, the proposed Development Agreement establishes the terms and conditions for development of the Project, and strengthens the planning process, encourages comprehensive planning, and reduces uncertainty and costs in the development review process; and WHEREAS, the proposed Development Agreement authorizes the Project, and incorporates each of the land use entitlements that would otherwise be required in absence of the Development Agreement, which consist of:
r A use permit for the hotel;
r A use permit for the sale of alcohol at the hotel;
o A tree removal permit for the removal of a tree on the Hotel Site; o A use permit for offsite parking and valet parking at the Parking Lot Site; r A use permit for the construction of a parking lot in the ESOS Zoning District and approval of ESOS setback reduction from 100'to 50';
o Design review for the Project;
WHEREAS, the proposed Development Agreement authorizes certain future elements of, and changes to, the Project to be approved administratively, notwithstanding anything to the contrary in the Municipal Code; and
WHEREAS, the Project is expected to generate substantial tax revenue for the City, through increased sales tax, transient occupancy taxes (TOT), and property tax receipts; and WHEREAS, guests at the hotel will shop locally, which will create an economic benefit for local businesses; and
WHEREAS, the proposed Development Agreement establishes impact fees for the Project that reflect that the Project is providing certain improvements and property in-lieu of paying the Parkland and Development Fee and a portion of the Traffic lmpact fee, and authorizes the fees to be paid over a fiveyear period, commencing upon opening of the Project; and WHEREAS, in2Ot6, the Sebastopol City Council certified an Environmental lmpact Report for the 20L6 Sebastopol General Update (SCH#2016032001) (the "General Plan ElR"), which is incorporated herein by reference; and
WHEREAS, a hotel of up to 90 rooms within the Limited lndustrial land use designation was anticipated and studied by the General Plan EIR; and
WHEREAS, pursuant to California Environmental Quality Act ("CEQA") Regulation Section 15183, when a project is consistent with a general plan for which an EIR was certified, no additional environmental 2 Agenda Item Number 10 Agenda Item Number: 10
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review is necessary, except to examine whether there are project-specific significant effects which are peculiar to the project or its site; and
WHEREAS, the Applicant retained Environmental Science Associates to review whether the Project included project-specific significant effects which are peculiar to the Project or its site and prepare a Section 15183 Checklist, and such documentation was reviewed by Rincon Consultants on behalf of the City; and
WHEREAS, the 15183 Checklist confirmed that there are no project-specific environmental effects which are peculiarto the project or its site, and all potentialsignificant effects were previously discussed by the General Plan EIR; and
WHEREAS, aMay 2024 Biological Assessment by WRA Consultants, provided as an attachment to the CEQA L5183 Checklist, provides substantial evidence that resources of potential concern do not occur on the Parking Lot Site in the area to be developed; and WHEREAS, the addition of 133 native trees and dedication of a permanent open space easement over the Laguna portion of the Parking Lot Site from the 50' setback line east clearly results in an environmentally and visually superior condition than currently exists on the site, which is a former concrete batch facility, and thus no additional visual and scenic analysis is necessary; and WHEREAS, the full scope of studies called for by Sebastopol Municipal Code section 17.46.050(D) are not required for the parking facilities to be constructed on the Parking Lot Site because specific resources of potential concern do not occur on the property or will not be affected by the Project, as specified herein; and
WHEREAS, a staff report dated March 25,2025, and incorporated herein by reference, described and analyzed the proposed Development Agreement and related Section 15183 Checklist for the Planning Commission; and
WHEREAS, on March 25,2025 the Planning Commission reviewed the staff report and the Section 15183 Checklist at a duly noticed public hearing on the Project, at which time all interested parties had the opportunity to be heard; and
WHEREAS, the Planning Commission has determined that the Development Agreement will (1) ensure the productive use of property and foster orderly growth and quality development in the City; (2)allow development of the Project tq proceed in accordance with the goals and policies set forth in the Sebastopol General Plan and will implement the City's stated General Plan policies; (3) facilitate the City receiving increased tax revenues that can be used for a variety of purposes; and (4) benefit local business by brining more visitors to the City.

NOW, THEREFORE, BE lT RESOLVED that the Planning Commission of the City of Sebastopol that the above recitals are true and correct and made part of this resolution.

BE lT FURTHER RESOLVED that the Planning Commission recommends that the City Council find that Project is consistent with the General Plan EIR previously certified by the City, that there are no impacts peculiar to the Project or its site that were not analyzed in the General Plan ElR, and that no additional environmental review is required for the Project pursuant to Pursuant to CEQA Guidelines Section L5183. 3 Agenda Item Number 10 Agenda Item Number: 10
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BE lT FURTHER RESOLVED THAT the Planning Commission hereby recommends that the City Council adopt an ordinance to approve the proposed Development Agreement, as shown in attached Exhibit A, based on the following findings and considering the staff report and the whole of the record related to the Project:

A. The Development Agreement is consistent with the objectives, policies, general land uses and programs specified in the General Plan and any applicable specific plan.

B. The Development Agreement is compatible with the uses. authorized in, and the regulations prescribed for, the district in which the real property is located.

C. The Development Agreement is in conformity with public convenience, general welfare and good land use practice.

D. The Development Agreement will not be detrimental to the public health, safety and general welfare.

E, The Development Agreement will not adversely affect the orderly development of property.

F. The Development Agreement will provide sufficient benefit to the City to justify entering into the agreement.

BE lT FURTHER RESOTVED THAT the Planning Commission's recommendation is based on the following findings for the issuance of entitlements that otherwise would be required for the Project in absence of the Development Agreement, and considering the staff report and the whole of the record related to the Project:

Use Permit for the Project
A. The proposed use is consistent with the General Plan and allapplicable provisions of this title.

B. The establishment, maintenance, and operation of the use applied for will not, under the circumstances of the particular case (location, size, design, and operating characteristics), be detrimental to the health, safety, peace, morals, comfort, or general welfare of persons residing or working in the area of such use or be detrimental or injurious to property and improvements in the neighborhood or to the general welfare of the City.

AlcoholUse Permit
A. The'sale of alcohol as part of the Project will not adversely affect the health, safety or welfare, result in undue concentration of alcoholic beverage outlets, or detrimentally affect nearby communities.

Use Permit for Parking Facilities
A. The number of parking spaces conveniently available to the use will be sufficient for the Project's safe, convenient and efficient operation.

B. A greater number of parking spaces than required by the Development Agreement will not be necessary to mitigate adverse parking or traffic impacts of the use on surrounding properties.

C. The use of valet parking is appropriate due to the type of use, scale of use, or other factors.

D. The configuration of parking spaces and operation of the parking facility will ensure that the use has adequate parking availability.

E. The proposed parking facilities will not create an impairment to public safety, impede safe and efficient pedestrian or vehicle traffic flow, or otherwise interfere with the operation of area uses or functions.
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IJse Permit for Parking Facilities in ESOS Zone ond Fifty Foot (50') Setback from the Loguno de Sonta Rosa wetl o n d/ri pa ri a n bou nda ry:

A. The required resource analysis is consistent with the requirements of Sebastopol Municipal Code Chapter !7.4O
B. The proposed project complies with all applicable standards required by Sebastopol Municipal Code Chapter t7.40
C. No wetlands or vernal pools will be eliminated
D. There are no Project specific impacts to identified resources, so no mitigation measures are proposed.

E. Due to the existing character of the property or the size, nature, or scope of the proposed project or previous development of the property, the full scope of studies called for by Sebastopol Municipal Code section L7.46.050(D) is not necessary, on the basis of substantial evidence provided by a qualified professional, that specific resources of potential concern do not occur on the Parking Lot Site or will not be affected by the Project' F. The addition of 133 native trees and dedication of a permanent open space easement over the Laguna portion of the Parking Lot Site from the 50'setback line east results in an environmentally and visually superior condition than currently exists on the site.

The above and foregoing Resolution was duly passed, approved, and adopted at a special meeting by the Sebastopol Planning Commission on the 25th day of March, 2025 by the following vote:

VOTE:4-0-1-0
Ayes: Planning Commissioners Koelemeijer, Hanley, Oetinger, Acting Chair Fernandez Noes: None
Abstain: Planning Commission Chair Paul Fritz

Absent: None
APPROVED:

Chair
ATTEST:

Planning Commission SecretarY

4. I, zS
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1 City of Sebastopol Design Review Guidelines
Approved by the Design Review Board May 5, 2010
These guidelines are intended to provide guidance to owners, builders, architects, landscape architects, engineers, designers and others involved in developing proposals for new buildings, additions, and other site improvements in the City of Sebastopol. In addition, they are intended to assist the Design Review Board in reviewing applications to promote a high quality of design, and consistency in the design review process.

These guidelines are intended to be used and interpreted with flexibility by the Design Review Board and City staff, and are not intended to be strict standards such as code requirements in the Zoning Ordinance, Sign Ordinance, or other ordinances. It is recognized that not all guidelines will be applicable or appropriate for all projects, and balancing of a variety of concerns and objectives will be required in review of applications.

I. SITE PLANNING
A. Neighborhood context

1. Infill development should be sensitively designed to respect existing patterns, and reinforce the character and context of existing neighborhoods consistent with applicable development regulations. The project incorporates design features of the existing buildings within The Barlow.

2. Significant natural site features such as natural ground forms, significant trees, large rock outcroppings, water and significant view corridors should be identified and addressed. The parking lot at the previous batch plant site will include a natural buffer from the parking areas to the Laguna de Santa Rosa and provide a promenade and overlook for viewing.

This parcel will also include a 10’ wide dedication for the existing AmeriCorps Trail along the northeastern corner of the property, and a permanent Open Space easement over the Laguna portion of the site.

3. In areas where there are changes in land use or density, new development should be designed to provide a transition between current and planned future uses through the use of setbacks, site plan, building massing and height, landscaping, driveways locations, etc. While the project does not include any changes to land use or density it does provide a building height increase that scales from two stories along the perimeter and up to three stories in the middle of the building to provide a better pedestrian experience along Sebastopol Ave and McKinley Street.

B. Building orientation

1. Buildings should generally be oriented parallel to the streets they face. The project is utilizing the existing footprint of a building that already is oriented towards the street frontages.

2. Buildings should relate to the street and should be located on the site so that they reinforce existing street frontages and setback patterns. The project is utilizing the existing footprint of a building that already is oriented towards the street frontages.

3. Commercial buildings should be located at the sidewalk or required setback to promote pedestrian orientation. The project is utilizing the existing footprint of a building that already is located at the sidewalks.

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2 4. The first floor should relate to the street by providing pedestrian-scale elements, design features, and amenities. The street facing side of McKinley Ave provides a pedestrian scale look into the building with large windows and inviting front entrance to the main lobby area.

5. All site facilities and amenities should be universally accessible. The project will be required and conditioned to meet all ADA accessibility requirements.

6. Buildings and landscaping should be located to maximize solar access during cooler months and to control it during warmer months. Natural ventilation, sunlight and views should be maximized for each building and residential unit. The project is utilizing the existing footprint of an existing building.

C. Circulation and parking

1. Vehicular – Commercial and Multi-family
a. An access plan should be designed for the site that logically and safely accommodates pedestrians and vehicles, as well as providing visual access to the site from the street.

Circulation routes should focus upon main entries and exits and also identify secondary access points. The project utilizes the existing streetway network along with providing an update to an existing parking lot between the Hotel and Community Market. This change to the parking lot will provide for a better flow of traffic through the entirety of the site for both vehicles and pedestrians.
b. Elements of the site design should accommodate access requirements of emergency vehicles and services. As the project was reviewed by both the Police and Fire departments of Sebastopol, their comments and concerns were addressed during the application process and project conditions of approval are included. c. Service functions should be integrated into the circulation pattern in a manner that minimizes conflicts with vehicles and pedestrians. The project offers a valet parking service to hotel customers. With this service, it will allow for controlled vehicle movement from the hotel site to the parking lot site on Morris Street. d. Parking lots should be located primarily at the rear or side of the site to ensure that the view of parking, garages, carports, and driveways from the public right-of-way is minimized. Parking areas may be considered in front of the site when site, access, use or other constraints merit such placement, provided appropriate landscaping and setbacks are incorporated into the parking design. The parking on the hotel site is to the east of the building and the majority of the remaining parking will be off site on Morris Street.

Both sites include a variety of landscaping materials to soften and enhance the parking areas.
e. In larger projects, the benefits of providing multiple small parking areas in lieu of one large lot should be assessed. Multiple parking lots are utilized, including a lot shared with Community Market and an additional new lot to be developed on Morris Street.

Together, the project provides parking for hotel guests, hotel employees, and employees of the larger Barlow complex at their off site parking lot on Morris Street. f. New driveways should be sited away from or immediately opposite street intersections, and the number of driveways should be minimized, consistent with traffic safety. The project utilizes existing access from Sebastopol Ave.

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3 g. The width of curb cuts should be minimized, but meet the requirements of emergency service vehicles. As conditioned the project will meet this. h. Redundant circulation which unnecessarily reduces the amount of site available for landscaped areas should be minimized. As conditioned the project will meet this.

2. Vehicular – Single-family
a. Detached garages or carports should be set back from main structures.

3. Pedestrian
a. In general, pedestrian circulation should take precedence over vehicular circulation. As the Barlow property is pedestrian oriented the hotel provides a “park once” opportunity for customers to experience the Barlow and other parts of Sebastopol without relying on using their car to go from place to place. A new, high visibility crosswalk is provided across Morris Street at Laguna Park Way, and new pedestrian pathways are provided leading to and along the Laguna de Santa Rosa.
b. Provide pedestrian accessibility to the street and adjacent uses with pathways, gates, pedestrian walkways, crossings, etc. See Above. As conditioned, the project will meet this.
c. Where pedestrian circulation crosses vehicular routes, a change in grade, materials, textures or colors should be provided to emphasize the conflict point and improve its visibility and safety. As conditioned the project will meet this with a new high-visibility crossing.
d. Pedestrian-only circulation areas should be provided where the scale or type of development permits. As conditioned the project will meet this. A new, high visibility crosswalk is provided across Morris Street at Laguna Park Way, and new pedestrian pathways are provided leading to and along the Laguna de Santa Rosa. e. In residential developments, pedestrian access which is separate from driveways should be provided directly from the sidewalk to the front door. f. In commercial developments, frequent street-facing pedestrian entrances should be provided. The project provides points of entry at both street frontages and on the site from the shared parking area.
g. Empty spaces between commercial buildings should be developed as open and attractive pedestrian passageways where feasible. Not applicable.

4. Bicycle
a. Any bicycle parking should be located close to the building in readily visible areas. As conditioned the project will meet this. Bicycle parking is provided both at the hotel building, and near the trail/overlook on the Morris Street parking lot site.

D. Open space

1. Private
a. Each residential household should be provided with some form of useful private open space, such as a patio, porch, deck, balcony, or yard.
b. Private open space should be easily accessible – physically and visually – from individual units.

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4 c. Screening should be provided to insure privacy and to help define boundaries between public, common, and private open space.

2. Public
a. Where identified as appropriate or where required by the Zoning Ordinance, development should include public plazas, courtyards, landscaping, and similar amenities or public assembly areas that are accessible and visible from the street. Such amenities should be provided in a scale appropriate to the size and location of the project. The project includes a front lobby area with a large public courtyard as well as two smaller courtyards. The project also features a Laguna promenade and overlook at that Morris Street parking lot site.
b. The design of outdoor spaces should recognize and incorporate views, climate, solar angles, and the nature of outdoor activities that could occur in conjunction with the project. The promenade and overlook will incorporate all of these features and will feature views of the Laguna de Santa Rosa as well as interpretive signage. c. Outdoor spaces should be designed as “outdoor rooms”. Undifferentiated or empty spaces should be avoided. The public courtyard/lobby functions as an outdoor room.

There are no empty spaces.
d. Required common open spaces should be designed to provide for play, recreation, or other social activities. As conditioned the project will meet this. e. Semi-public common open spaces should be located so that they can be viewed from individual residential units or tenant spaces.
f. Utilize clear glass facing streets, courtyards and other public or semi-public areas; avoid use of mirrored, black or other opaque glass. As conditioned the project will meet this. g. Outdoor seating and dining areas that face onto the street should be encouraged for restaurants and other commercial uses. The project features outdoor restaurant seating within the lobby courtyard, and also includes large windows on the restaurant ground floor that faces McKinley St.
h. Seating areas should be provided in public or semi-public courtyards or plazas. The project features outdoor restaurant seating in the lobby courtyard, as well as at the rooftop café bar.
i. Common facilities should be centrally located and linked to common outdoor space. j. Play area(s) should be centrally located to allow for adult supervision from dwelling units and/or from a central facility such as a laundry.

E. Grading and Storm Water Management

1. Grading
a. Grading should be minimized to the extent feasible to reflect existing topography and protect significant site features, including trees. As conditioned the project will meet this.

There are also minimal trees being removed from this project but intends to replant a significant number of trees on both sites.

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5 b. When designing a grading plan, balancing the cut and fill is encouraged when it does not result in further adverse effects to the natural topography. As conditioned the project will meet this.
c. Terracing should be considered as an alternative to the use of tall or prominent retaining walls. Not applicable.
d. Proposed grading under the drip line of protected trees must be clearly identified on plans and will be reviewed by the City Arborist prior to issuance of a grading permit. As conditioned the project will meet this.

2. Storm Water management
a. Within the context of the design, the amount of impermeable surfaces on a site should be minimized. As conditioned the project will meet this.
b. Measures that will promote absorption of building, parking area, and other impervious area runoff through use of detention basins, ponds, vaults, trenches, dry wells, porous pavement, grid pavers, grassy swales fed through intermittent curb cuts, and vegetative buffers, etc., should be incorporated into site designs. The addition of bioswales in the parking lot site this will help with run off water and allow that water to be treated before its dispersed into the City storm water system and the Laguna.

F. Auxiliary Structures

1. Trash enclosures
a. Trash and recycling areas should be located and screened to limit visibility from the street and pedestrian areas as well as neighboring uses. Such areas should be readily accessible to building users and waste haulers. As conditioned the project will meet this. b. Trash enclosures should include adequate areas for collecting and loading recyclable materials. As conditioned the project will meet this.

2. Walls, Fences, and Screens
a. Screening should be designed as an integrated part of the site improvements. Screening is provided through planting materials, and with a low, solid fence at the Morris Street parking lot site.
b. Long or tall sound walls, masonry walls or fences should be designed to minimize visual monotony though changes in plane, height, material or significant landscape massing where appropriate. Not applicable to this project.
c. The height and length of retaining walls should be minimized and screened with appropriate landscaping. Retaining walls should incorporate design elements of other architectural or natural features of the project. Not applicable to this project. d. Chain link fencing is discouraged in areas visible from a public right-of-way. Project will not include chain link fencing.
e. Exterior trash and storage areas, service yards, loading docks and ramps, wood service poles, electric and gas meters, fire sprinkler valves, irrigation backflow prevention devices, transformers, etc., should be screened from view in a manner that is compatible with the building and site design. Screening materials should be opaque, substantial and durable. Such elements should be located to the rear or side of the site and/or away from a major street. As conditioned the project will meet this.

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6 f. Code required elements, such as parapet walls and screen walls, should be treated as an integral part of the architecture design. The project meets this.

3. Utilities and mechanical equipment
a. The visibility of rooftop equipment should be minimized by generally grouping plumbing vents, ducts and rooftop mechanical equipment away from the public view as feasible.

Rooftop mechanical equipment should be screened behind parapets or recessed behind architectural features. As conditioned the project will meet this. b. Residential air conditioning units should be located to have the minimum visual and noise impacts on adjacent residential neighbors.
c. Electrical transformers installed as part of a new project should be located to the rear of the site or undergrounded. Existing transformers located at the front of the site should be screened by substantial landscaping and/or an architectural barrier. As conditioned the project will meet this.
d. In commercial developments, utility meters should be located in screened areas. As conditioned the project will meet this.
e. All utilities from the public right-of-way to the project site should be undergrounded. As conditioned the project will meet this.

4. Site lighting
a. Lighting from a variety of sources which is no brighter or higher than is necessary should be incorporated to provide adequate visibility and security. As conditioned the project will meet this.
b. The style, intensity and orientation of lighting should be designed to limit glare for vehicular traffic, pedestrians, or project neighbors, and to minimize upward glare. As conditioned the project will meet this. Lighting plans include dark sky compliant fixtures and cut-offs shields as needed.
c. Lighting fixtures should be shielded or otherwise designed to minimize upward glare. As conditioned the project will meet this. Lighting plans include dark sky compliant fixtures and cut-offs shields as needed.
d. Provide energy-efficient exterior lighting. Solar-powered lights should be utilized whenever possible. As conditioned the project will meet this.

G. Noise and Privacy

1. The location of the building(s) on the lot, windows, orientation, building height, and location of on-site open spaces should consider preservation of the privacy of adjacent development.

The project utilyzes the footprint of an existing building within a vibrant downtown.

Adjacent land uses are parking lots.

2. Private yard or common open space areas, bedrooms, decks, and other main living areas should be oriented away from high noise sources and should take advantage of view opportunities and solar orientation.

II. ARCHITECTURE
A. Relationship to surrounding architecture
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7 1. Architectural design should be compatible with the developing character of the area, and should complement the unique aspects of the site. Design compatibility includes complementary building style, form, size, color and materials. Consider architectural styles of existing structures on the site, as well as other structures in the area when designing a new building and provide for a harmonious integration of the new improvements. The project as designed incorporates the surrounding design aspects of the Barlow buildings. While colors and materials change throughout the Barlow, the theme of metal siding and neutral tones is within this project design.

2. In subdivisions, houses with identical or similar building elevations and/or floor plans should not be located on adjacent lots or directly across the street from each other. Where a single house design is used repeatedly, materials and detailing of major facade elements should be varied.

B. Massing

1. Large structures should be designed to reduce their perceived height and bulk by dividing the building mass into smaller-scale components. The project street scape is 2 stories and goes up to 3 stories with additional features on top towards the center of the building. This approach provides a smaller scale building at the pedestrian level while the overall building is still up to 3 stories with a rooftop pool deck and covered café bar.

2. Buildings over two stories high should "scale down" their street-facing facades to reduce apparent height. The project street scape is 2 stories and goes up to 3 stories with additional features on top towards the center of the building. This approach provides a smaller scale building at the pedestrian level.

3. Box-like forms with extensive unarticulated facades or large, unvaried roofs should be avoided. The project meets this guideline.

4. A variety of levels and planes should be encouraged to reduce the massing of larger buildings. As conditioned the project will meet this.

5. Multiple buildings on the same site should be designed to create a cohesive visual relationship between the buildings. Not applicable to this project.

6. When possible, individual, street-oriented, ground level entries to commercial tenant spaces and dwellings should be provided. As conditioned the project will meet this.

7. When feasible, provide each building and residential unit with its own visual identity and individual address.

8. Façades of horizontal buildings should be broken up into smaller components by utilizing vertical elements. The project meets this guideline.

C. Elements

1. Architectural details
a. Exterior building design and detail on elevations should be coordinated with regard to color, types of materials, number of materials, architectural form, and detailing to achieve harmony and continuity of design. The project appears to meet this guideline. b. Design elements and detailing should be continued completely around the structure. Such design elements should include window treatments, trim detailing, and exterior wall materials. The project appears to meet this guideline.

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8 c. Separate structures on the site should have consistent architectural detail and design elements to provide a cohesive project site. Not applicable to this project. d. Building facades should be articulated by using color, arrangement, or change in materials to emphasize the facade elements. The planes of the exterior walls may be varied in height, depth or direction. The project appears to meet the guideline. e. Additions to existing structures should be designed to complement the existing structure.

Additions should carry through roof lines, materials, colors, and /or other architectural features that are primary features of the original building. Not applicable. The project replaces the existing structure.
f. Elements such as bay windows, balconies, porches, arbors, awnings, arcades and courtyards should be utilized to add variety and break up facades. Materials and elements are used to break up facades. The project appears to meet the guideline. g. Porches, stairs, railings, fascia boards, and trim should be used to articulate a consistent architectural style. The project appears to meet the guideline. h. Trim, fascia, rafter tails, etc. should be of a sufficient dimension to create visual interest.

The project appears to meet the guideline.
i. Vents, gutters, downspouts, flashing, electrical conduits, etc., should generally be painted to match the color of the adjacent surface, unless being used as a trim or accent element.

The project appears to meet the guideline.
j. Building entries should be prominent and visible. The project appears to meet the guideline.
k.
l. Rhythm, size and proportion of openings (windows, doors) should create a consistent and harmonious design. The project appears to meet the guideline. m. Windows facing the street should be operable. The project has been conditioned to meet the building code, which does not allow all windows to be operable. n. Garage doors should be designed as a secondary feature to the main entrance of the house.
o. When a large portion of the front elevation is devoted to driveways and walkways, the hardscape area should be constructed with visually contrasting paving surfaces. Not applicable to this project.
p. Buildings that are stylized in an attempt to use the building itself as advertising are discouraged, particularly where the proposed architecture is the result of a franchise style.

Not applicable to this project.
q. The architecture and other features of “formula” franchises or other similar businesses should be reflective of these guidelines and of the unique character of Sebastopol. The architectural style and exterior materials of each proposed structure shall be designed based upon the architectural traditions of Sebastopol and Sonoma County, the architectural styles prevalent in the site vicinity, and the characters of the site, as determined by the Design Review Board. Proposed designs having architectural features substantially similar to those found in other communities on buildings operated by the same corporate or franchise entity are discouraged unless the Design Review Board Agenda Item Number 10 Agenda Item Number: 10
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9 determines that the similar features are also reflective of local architectural traditions and styles. Not applicable to this project.

2. Materials
a. Building materials and color should be complementary to the design and to the surrounding area. The project appears to meet the guideline. b. Exterior materials should be durable and of high quality. The project appears to meet the guideline.
c.
d. Highly reflective mirrored glass or roofing materials should be avoided. The project appears to meet the guideline.
e.

3. Roofs
a. Large, flat roofs should be avoided. Instead, rooflines should be varied vertically and horizontally to provide greater visual relief. The project appears to meet the guideline.. b. In visible areas, roof materials and the backsides of parapets should be painted with a neutral, non-reflective paint. The project appears to meet the guideline.

4. Solar Access/Energy Conservation
a. Designs should provide adequate natural lighting opportunities, and may incorporate skylights, light wells, or solar tubes. Interior courtyards will serve as light wells. b. Solar equipment should be designed to avoid reflecting onto nearby buildings, streets, open space or pedestrian areas. As conditioned the project will meet this. c. Solar hot water and solar electrical generation systems should be accommodated on rooftops and other building areas. As conditioned the project will meet this. d. Wherever possible, designs that promote use of natural ventilation should be provided.

The project appears to meet the guideline.
e. Where feasible, provide shade trees on southwest-oriented building facades to regulate heat gain and reduce air-conditioning needs. Not applicable to this project.

III. LANDSCAPING
A. General

1. Landscaping should be designed to complement the architecture and create and define both public and private spaces. The project appears to meet the guideline.

2. Landscaping and/or architectural treatments should be provided to screen unattractive views and features such as storage areas, trash enclosures, transformers, generators, and other similar elements. The project appears to meet the guideline.

3. When plant materials are used to screen areas such as mechanical equipment, parking lots, loading docks, or storage areas, the plant materials should be massed in groups to create strong accent points, rather than planted in a straight line. The project appears to meet the guideline.

4. All plant materials should be sized so that the landscaping has an attractive appearance at the time of installation and a mature appearance within 3 years of planting. No large areas should be left unplanted. The project appears to meet the guideline.

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10 5. Seating should be provided in landscaped areas. Seating is provided in the Laguna overlook area and along the promenade.

6. Paths should be included to accommodate pedestrians. As conditioned the project will meet this.

7. Energy conservation within structures should be addressed by recognizing the sun exposure on the site and providing appropriate tree species (deciduous trees on the southern exposure, coniferous and broadleaf evergreen trees along the eastern and western exposures, and evergreens along the northern exposure.) As conditioned the project will meet this.

B. Plant types

1. Achieve long-term soil stabilization by permanent growth of native vegetation, including but not limited to native grass, sod, tree planting, shrubs, vines and /or other ground covering.

The project appears to meet the guideline.

2. Lawns and high-water use ornamental shrubs and trees should be limited. No lawn areas or ornamentals are proposed.

3. Promote use of native and drought-resistant plants. The project makes use of mostly native plantings.

C. Trees

1. Trees should be carefully selected and located where they will complement the building elevation and should not block all retail storefront signage from view. The project appears to meet the guideline.

2. Tree species should be selected with root growth habits that will not cause damage to sidewalks, and linear root barriers should be installed adjacent to paved areas or foundations.

As conditioned the project will meet this.

3. Unless unusual circumstances prevail, all street trees or parking lot trees shall be a minimum of 24” box size. In prominent areas, the Design Review Board may require trees larger than 24” box size. The project will meet this for street trees.

4. New residential subdivisions should include street trees.

5. No irrigated landscaping should be allowed within the driplines of existing oak trees or other native species which will be adversely affected. Not applicable to this project.

D. Parking lot landscaping

1. Trees and shrubs should be planted to soften the overall impact of parking areas and to provide shade. The project appears to meet the guideline.

2. Landscaping should permit adequate sight distance for motorists and pedestrians entering and exiting a site and should not interfere with circulation patterns. The project appears to meet the guideline.

3. Landscaped berms around parking lots are encouraged. The Morris Street Parking lot is already elevated and screening landscape is proposed.

4. Landscape planting areas in parking lots should have a minimum clear inside width of 4’. As conditioned the project will meet this.

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11 5. Trees installed in parking lots should be protected from vehicle damage by concrete curbing which surrounds the landscape pocket. The project will balance this need with current LID requirements.

E. Hardscape

1. Trellises, arbors and similar features should be used to break up and soften building massing and to provide shade. The project appears to meet the guideline.

IV. SPECIAL DEVELOPMENT GUIDELINES
Staff Note: While the project sites are not located within one of the applicable zones names below, some provisions may be applicable and the DRB may wish to review. In addition to the guidelines identified above, the following shall be considered during review of these specific development types:

A. Downtown and Pedestrian-Oriented Commercial Frontages and Facades

1. Purpose: This Section is intended to provide for pedestrian orientation in the pedestrianoriented commercial areas of the City. A principal objective is for the street frontages in these areas to have continuous building facades with as few interruptions as possible in the progression of stores and other buildings, creating attractive, pedestrian-oriented streetscapes.

2. Applicability: The requirements of this Section apply to proposed development within the CD, CO, and CG districts, except where otherwise indicated in the Zoning Ordinance.

Variations may be approved by the Design Review Board as deemed appropriate, provided that the variation will still produce a building that complies with the intent of these guidelines.

3. Building placement: Each building should generally be designed so that its front façade occupies most of its front property line. Exceptions to this guideline should be considered for:
a. A driveway that is necessary because no side street, alley, or easement can provide access to required parking on the rear of the lot;
b. The initial phases of a multi-phased building project that will occupy the entire frontage upon completion;
c. A project proposed with a pedestrian-only plaza , entry courtyard, or other pedestrian feature occupying a portion of the street frontage;
d. A pedestrian corridor;
e. A view corridor to on- or off-site natural features, pedestrian area on the rear portions of the site; or,
f. Other site constrictions, existing improvements, or where the neighborhood context merits an alternate placement.

4. Building design and architectural elements. Each building should be designed to comply with the following requirements.
a. Elevation of first floor. Wherever reasonably feasible, the first floor should be at substantially the same elevation as the adjacent sidewalk. Most of the street-fronting length of the first habitable floor of a nonresidential structure should be located no more than approximately two vertical feet above or below the sidewalk elevation at any point along the street property line.
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12 glass should not be used except as an architecture or decorative accent. After installation, clear glass windows should not later be treated or so as to become opaque, or to be blocked so as to prevent visibility of the ground floor interior from the sidewalk. c. Security gates. Generally, security gates or grilles should not be installed on the exterior of any structure within approximately 10 feet of any sidewalk.

5. Pedestrian access to buildings. Generally, the primary entrance of each ground floor use should be located within the primary building frontage, and should be recessed a minimum of approximately three feet when accessed from the public right-of-way. Walk-up facilities and entries shall be recessed and provide adequate queuing space to avoid interruption of pedestrian flow.

B. Laguna de Santa Rosa

1. Purpose: The following guidelines are intended to help balance urban development with the protection of natural resources and open spaces of the Laguna, two important objectives identified in the General Plan.

2. Special attention should be paid to any proposed construction on properties which are adjacent to the western edge of the Laguna de Santa Rosa. In particular, development should generally be discouraged in the following buffer zones, except as allowed by the development guidelines for the SOS: Scenic Open Space district:
a. For properties north of the Joe Rodota trail, the buffer zone shall be a minimum of 50’ from the edge of the riparian dripline or other wetland habitat. The dripline begins at the edge of the tree canopy.
b. For properties south of the Joe Rodota trail, the buffer zone shall be a minimum of 50’ from the 100 year flood contour.

3. Visual Impact
a. Visual impact from publicly accessible areas within the Laguna. The visual impact of new construction from publicly accessible areas within the Laguna should be addressed through the control of building height, provision of increased building setbacks, and the development and installation of appropriate landscaping. b. Visual impact of new construction on existing development to the west. Views of the Laguna from existing development to the west of the Laguna shall be considered when a development proposal is being evaluated.
c. Encourage clustering to increase open space that physically and visually relates to the Laguna (General Plan Policy 66 - Chap. III).

4. Building Orientation
a. Active use spaces should be oriented towards the Laguna to encourage visual and physical interactions with the open space, and to reduce the potential for vandalism and littering.

5. Landscaping
a. New landscaping should be designed with the express purposes of reducing sedimentation or soil erosion, maintaining or increasing the native riparian vegetation, and enhancing the visual buffer between any new buildings and the public open space. b. Landscaping plans should incorporate native species adjacent to the Laguna. c. Landscaping should be designed to insure that outdoor spaces are viable, usable spaces.

C. Fast Food Restaurants
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13 1. Franchise or corporate style architecture and/or highly contrasting color schemes are discouraged. A new free-standing restaurant building should be sited and designed to be compatible with the character of the surrounding neighborhood. If the restaurant will occupy a pad within a shopping center, the building should be designed to be consistent with the "theme" or design of the center. (See D. Shopping Center Guidelines.)

2. Drive through elements should generally be discouraged. Where drive though elements are appropriate, they should be architecturally integrated into the building, rather than appearing to be applied or "stuck-on" to the building. Drive through elements should not be located on the street side of the building or should be heavily screened from view.

3. The site design should accommodate a logical and safe vehicle and pedestrian circulation pattern through the site. Circulation should allow for adequate length of queuing lines for drive through elements which do not interfere with the on-site parking for patrons entering the restaurant, nor result in traffic queuing into the street.

4. Free-standing restaurant buildings should be designed and detailed consistently on all sides, including the rear and side elevations.

5. Outdoor seating areas, play equipment, and perimeter fencing should all be reviewed for compatible and attractive design that is integrated with the main building architecture.

6. Trash enclosures and other service spaces should be constructed of materials and finishes which are consistent with the main restaurant building.

7. Businesses should not be "over-signed." Sign Ordinance limitations shall be strictly enforced.

8. Excessive illumination of the signage, building or site should be avoided. Roof lighting, down-lighting washing the building walls, or illuminated awnings are all strongly discouraged.

9. Cooking odors should be eliminated to the extent feasible by installation of best available ventilation technology. Project applications should include information on proposed ventilation systems and odor scrubbing technology to be used.

10. Remodel of existing structures for restaurant uses should also require a review of the entire site and circulation plan to ensure that the project is updated to current design review standards for the City. This may include requirements to improve and/or expand the existing landscaping, fencing, parking area or other site design issues.

D. Shopping Centers

1. A unified architectural design intention should be incorporated into each commercial center.

2. The appearance of a "sea of asphalt" parking lot in the front of the center should be avoided.

Both perimeter and interior parking lot trees should be provided for shade and visual relief in the parking area while maintaining view corridors to the store front areas.

3. On larger commercial sites, a portion of the total building area should be located at the street perimeter, preferably on a corner location. Such siting, together with substantial landscape treatment reinforces and strengthens the streetscape and helps to screen off-street parking areas.

4. The architectural design of freestanding pad buildings should be consistent with the design of the remainder of the shopping center. Where centers require updating, pad buildings should be remodeled in conjunction with an upgrade of the entire shopping center.

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14 5. Shopping center sign programs should be established and enforced for remodeling of the centers.

6. Truck delivery and circulation routes should be separated from customer circulation through the site. Delivery and service activities should be designed to take access from the least traveled street adjacent to the project.

7. Textured or colored paving materials are encouraged to identify pedestrian circulation areas, especially within the parking lot.

8. Shopping cart storage areas should be incorporated into the building design to provide a visual screen of carts from the parking area.

9. Outdoor gathering areas and public eating areas are encouraged.

10. Landscaping trees should be allowed to achieve their natural form. Pruning to reduce the natural diameter of the trees shall not occur.

E. Auto Dealerships

1. Special attention should be directed toward the site landscaping which is visible from the street. Trees to provide both shade and visual relief should be located within the dealership (insofar as it is reasonably practical with auto display) as well as on the site perimeter. The vehicle display parking areas may remain relatively open, if balanced by substantial landscaping and tree planting on other visually prominent areas of the site.

2. Landscaping, special paving treatments, setbacks, and building orientation should be used to provide an attractive appearance from the front property line.

3. The architecture of the dealership buildings should be well-designed to provide a strong and unique visual identity for the auto dealership.

4. The service area and/or service bays should be screened or sited so they are not visible from the street.

5. Vehicles under repair should be kept either inside a structure or in an area which is screened from views from the street.

6. Service areas should provide adequate queuing space that does not impede vehicle circulation through the site or result in vehicles stacking into the street.

7. Perimeter fencing, security fencing, or gateways should be constructed of attractive materials which are compatible with the design and materials used throughout the project. Razor wire or electric fencing shall not be allowed and chain link fencing is strongly discouraged.

8. Night lighting and security lighting should be sensitively designed to ensure that no off-site glare is directed to neighboring parcels and that the overall intensity of the site lighting is not excessive. The use of excessive night-time security lighting is discouraged. Other security measures should instead be considered.

F. Auto Service Station Guidelines

1. The site design for projects located at street corners should provide some structural or strong design element to anchor the corner. This can be accomplished using a built element or with strong landscaping features.

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15 2. The on-site circulation pattern should include adequate driving space to maneuver vehicles around cars parked at the pumps, with special attention to the circulation of vehicles not involved in the purchase of fuel.

3. The amount of unrelieved pavement or asphalt area on the site should be limited through the use of landscaping, contrasting colors and banding or pathways of alternate paver material.

Extensive expanses of light grey concrete pavement should be avoided.

4. Building architecture should be designed to provide an attractive appearance which is compatible with the surrounding area. Prefabricated buildings are discouraged. Where allowed, such buildings should be substantially modified and embellished to create a project which meets the community standards. All architectural details should be related to an overall architectural theme.

5. Separate structures (canopy, carwash, cashiers booth, etc.) on the site should have consistent architectural detail and design elements to provide a cohesive project site.

6. Tall (13'-14') tank vents should be completely screened or incorporated into the building architecture.

7. A car wash which is incorporated into the project shall be well integrated into the design. The car wash opening should be sited so that it is not directly visible as the primary view from the street into the project site. The site design should also address the issues of off-site noise exposure, provision of adequate on-site underground drainage systems to keep water off public streets and improvements, and circulation/vehicle stacking.

8. Signage should be limited as defined in the Sign Ordinance. All signs should have a consistent character and design details (such as trellis, brick, river stone, etc.) that reflect the design of the project. The amount of price sign square footage required as the state regulated minimum size will not count towards the signage calculation. If price signs are larger than this minimum, the incremental square footage difference will be counted as part of the total allowable signage for the station.

9. Illumination should be concentrated on specific signage. Canopies should not be illuminated.

Light fixtures should be recessed into the canopy and no glare should be visible from the fixture. Yard lights should be oriented downward.

10. Dumpsters and service areas should have solid metal doors and the wall materials and building styles should match those used for the station buildings.

V. SIGNAGE
Sign Programs
Staff Note: The project is located within The Barlow, and as such will be subject to the Barlow Sign Program. The Barlow is currently in the process of updating their Master Sign Program, which will come before the Design Review Board. When signage is submitted for the Barlow Hotel project it will be subject to the Barlow Sign Program; if it is consistent, it can be approved at the administrative level.

If not consistent with the approved Barlow Sign Program, the Sign Program for the hotel will need to come back to the Design Review Board prior to installation and occupancy.

The best sign programs are integrated so that they become a natural part of the building façade.

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16 Sign Design
A. New signs should be architecturally integrated with their surroundings in terms of size, shape, color, texture, and lighting so that they are complementary to the overall design of the building and are not in visual competition with other signs in the area.

B. Signs should complement their surroundings without competing with each other, should convey their message clearly and legibly and should be vandal- and weather resistant.

C. New signs proposed for existing buildings should provide a compatible appearance with the building signage of other tenants. With multiple signs on a single building, new signs should provide a unifying element (such as size, location, or color), where no sign program exists.

D. Standardized or corporate signing which does not relate to the building architecture is discouraged.

E. Sign text should be limited.

F. Signs should be proportionate to the dimensions of their location.

G. Symbolic three-dimensional signs such as barber shop poles and appropriately-sized projecting signs are encouraged, particularly in the downtown and pedestrian-oriented commercial areas.

Sculpture features or unique street furniture to compliment (or in lieu of) building and tenant signage should be considered.

H. Signs should be professionally constructed using high quality natural materials and or creative materials such as:
• Stone and hard wood
• Inset or decorative tile work.
• Cast, carved, or inset in some form of plaque attached to the wall. • Wrought iron or ceramic
• Individual letters pegged out from the surface.
• Signage suspended within the openings of an arcade if height and configuration will allow it.
• Signs incorporated into a primarily artistic mural are encouraged.

The use of plastic as a principal material is discouraged.

I. Signs should be visually balanced within their borders.

J. Wall mounted signs should be framed to create a clearly defined edge, provide shadow relief and a substantial appearance. The effect is generally difficult to achieve by painting the sign directly on the building. For this reason, painted signs are generally discouraged.

K. The design of the sign structure and text should express high quality design.

L. Repetitious signage information on the same building frontage should be avoided.

M. Visible raceways and transformers for individual letters are strongly discouraged. Sign installation details should indicate where the transformer and other mechanical equipment will be located.

N. Sign materials should be durable to withstand extended exposure to the elements.

O. Signs should creatively express the character of the business.

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17 P. Freestanding monument signs may be appropriate for certain office and retail locations within the City. Monument sign materials should reflect the character of the use and the building the sign identifies.

Q. Free-standing sign bases should be made of permanent, durable materials such as concrete or brick.

R. Landscaping and irrigation should be designed around the base of freestanding signs to integrate the sign with the ground plane and screen out any low-level floodlights. Irrigation should be designed so it does not damage the sign.
a. Signs should be visually balanced within their borders. b. Wall mounted signs should be framed to create a clearly defined edge, provide shadow relief and a substantial appearance. This effect is generally difficult to achieve by painting the sign directly on the building. For this reason, painted signs are discouraged. c. Repetitious signage information on the same building frontage should be avoided. d. Exposed supports or guy wires to stabilize signs are discouraged.

Sign Placement
S. New construction design should anticipate signage and, where required, include a sign program.

New building design should provide logical sign areas, allowing flexibility for new users as the building is re-tenanted over time. Designs that provide for convenient and attractive replacement of signs are encouraged.

T. Sign placement should be sensitive to other building elements such as windows, doors, columns, etc.

Illumination of Signage
U. Exterior lighting should generally be used for signs. Where internal illumination is proposed, the background should be opaque so that light shines through the lettering and images only.

V. Arrange any external spot or flood lighting so that the light source is screened from direct view by passersby, and so that the light is directed against the sign and does not shine into adjacent property or blind motorists and pedestrians.

W. Where individual letter signs face nearby residential areas, a low level of brightness should be maintained.

X. Where the design of the sign results in a large field of illuminated background, the use of white or off-white as a background color should be avoided.

Y. Freestanding “can” type signs with interior illumination are discouraged.

Z. Illumination systems should include a timer so that lights will be turned off during late night and early morning hours.

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City Council
Mayor Stephen Zollman
Vice Mayor Jill McLewis
Councilmember Neysa Hinton
Councilmember Sandra Maurer
Councilmember Phill Carter
City Manager
Don Schwartz
[email protected]
Assistant City Manager/City Clerk, MMC
Mary Gourley
[email protected]

General Plan Consistency Analysis for
Barlow Hotel Project
January 2025
The following General Plan Goals and Policies are applicable to the Barlow Hotel project:

LAND USE ELEMENT
GOAL LU 7: Emphasize and Advance Sebastopol’s Role as a Market and Service Center for the West County by Providing for a Vibrant Downtown, Diversified Uses, and Community Services and Facilities Policy LU 7-2: Maintain the Downtown as a focal point for West County- serving commercial, civic, and cultural uses.

Policy LU 7-3: Provide and maintain opportunities for community gathering and social interaction through cultural and art centers, park facilities, the Laguna, and community centers.

Policy LU 7-6: Encourage mixed-use developments throughout the city.

Policy LU 7-7: In mixed use, commercial, office, and other non-residential developments, encourage non-residential uses on the ground floor while allowing residential uses on the ground floor where appropriate.

Analysis of Project Consistency with Land Use Element: The Barlow Hotel project provides consistency with the Land Use Element of the Sebastopol General Plan. It advances Sebastopol’s role as a market and service center for the west county by bringing visitors downtown; provides non-residential uses on the ground floor; provides community gathering spaces; and increases the diversity of uses downtown.

CIRCULATION ELEMENT
GOAL CIR 5: Reduce Vehicle Miles Traveled (VMT) in Order to Reduce Congestion and Help Achieve Regional Efforts to Reduce Greenhouse Gas (GHG) Emissions Policy CIR 2-4: Require development projects to construct frontage sidewalks, missing sidewalk sections, paths, and nearby enhanced crosswalks in a manner that is consistent with the City’s goals and policies in this General Plan and the Sebastopol Bicycle and Pedestrian Plan, and as dictated by the location of other activity centers, transit stops and common pedestrian destinations.

Policy CIR 2-5: Evaluate opportunities for pedestrian or other circulation and mobility connections to the circulation network in review of major development projects and require appropriate improvements.

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2 Policy CIR 2-14: Provide secure bicycle racks in places such as the Downtown, at commercial areas, park and ride transit facilities, schools, multiple unit residential developments, and other locations where there is a concentration of residents, visitors, students, or employees.

Policy CIR 2-15: Ensure that all crossings where trails and roads meet include best practices for crossing design for these conflict points.

Policy CIR 3-10: Require new development to include effective linkages to the surrounding circulation system for all modes of travel, to the extent feasible.

Policy CIR 5-3: Support the establishment and expansion of a regional network of electric vehicle charging stations and encourage the expanded use of electric vehicles.

Policy CIR 6-1: Maximize the use of existing downtown parking areas, emphasizing the use of shared parking wherever possible, including provision of multi-purpose parking facilities that serve both residential and commercial uses.

Analysis of Project Consistency with Circulation Element: The Barlow Hotel project consistent with the Circulation Element of the Sebastopol General Plan. It utilizes shared parking and a “park once” strategy to combine vehicle trips and thus reduces vehicle miles traveled, or VMT, in the local area and the region. As proposed and conditioned, it provides bike racks at both parking lot locations, including at the Laguna Overlook. It provides a new Laguna promenade, makes new trail connections, provides a new high-visibility pedestrian crosswalk and makes appropriate ADA improvements to the existing crossing at Morris Street and Laguna Park Way.

COMMUNITY SERVICES & FACILITIES ELEMENT
Policy CSF 1-7: Require the payment of impact fees for all new development.

Policy CSF 1-12: Encourage new large-scale development projects to incorporate community features such as meeting spaces/rooms that may be used by the City, community organizations, local non-profits, etc. for little to no cost.

Analysis of Project Consistency with Community Services Element: The Barlow Hotel project is consistent with the Community Services & Facilities Element of the Sebastopol General Plan. As proposed and conditioned, it would pay impact fees towards the future provision of community facilities, with partial offsets for the provision of specific facilities including the provision of a community meeting room; the Laguna promenade and overlook, with benches, bicycle parking and interpretive signs; a new ADAaccessible high visibility crosswalk at Morris Street and Laguna Park Way; new pathways; a dedication of land over the existing AmeriCorps trail; and the provision of a permanent open space easement over the Laguna de Santa Rosa.

CONSERVATION & OPEN SPACE ELEMENT
GOAL COS 4: Proactively Manage, Protect, and Restore the Laguna de Santa Rosa Policy COS 2-6: Maintain Zoning Ordinance provisions to ensure that development proposals for land which is located within, or adjacent to, an environmentally sensitive area include a resources analysis that contains all of the information required in order for the City to determine that impacts to sensitive habitat and natural resources have been reduced, avoided, or mitigated to the greatest extent feasible.

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3 Policy COS 3-6: Require the use and site design integration of natural features such as bioswales, vegetation, retention ponds, and other measures to remove surface water pollutants prior to discharge into surface waters.

Policy COS 3-9: New development adjacent to creeks and streams should include opportunities for beneficial uses, such as flood control, ecological restoration activities, public access trails, and walkways.

Policy COS 4-2: Protect, enhance, and restore sensitive habitats in the Laguna, and recognize that the Laguna provides a myriad of environmental benefits to the region’s ecosystem.

Policy COS 4-3: Preserve and enhance the visual character of the Laguna.

Policy COS 4-5: Continuously seek opportunities to expand Laguna protection and preservation efforts through the acquisition of land within and adjacent to the Laguna.

Analysis of Project Consistency with Conservation & Open Space Element: The Barlow Hotel project provides consistency with the Conservation & Open Space Element of the Sebastopol General Plan. A licensed biologist has provided the requisite resource analysis determining that any impacts to sensitive habitats and natural resources have been avoided, and that the existing poor condition of the batch plant site will be improved by the project, as conditioned. Staff has determined that the purpose and intent of the ESOS District are met. The project incorporates bioswales and native vegetation to remove surface water pollutants and improves stormwater quality. A land dedication is made over the existing AmeriCorps trail and a new Laguna promenade with an overlook featuring benches and interpretive signage is provided to encourage visitors to learn about the Laguna’s important ecological benefits. Finally, a permanent open space easement is placed over the Laguna itself from the 50’ ESOS setback to the property line.

COMMUNITY DESIGN ELEMENT
GOAL CD 4: Support Art of All Types Throughout the Community Policy CD 1-2: Ensure that new residential and commercial development is sensitive to the surrounding architecture, topography, landscaping, character, scale, and ambiance of the surrounding neighborhood.

Policy CD 1-9: Promote an attractive system of public and quasi-public spaces throughout the community that support public gatherings and social interaction. Encourage new development to include accessible and attractive common areas including unique courtyards, pocket parks, and plazas.

Policy CD 4-1: Support and encourage public art of all types that reflects the cultural values of the community.

Policy CD 4-3: Continue to implement and periodically update as necessary the Percent-for-Art Program.

Analysis of Project Consistency with Community Design Element: The Barlow Hotel project provides consistency with the Community Design Element of the Sebastopol General Plan. As proposed and conditioned, its architectural style is in keeping with the immediate neighborhood of The Barlow and provides a pedestrian emphasis important to both The Barlow and to the adjacent downtown. It includes a series of courtyards and will art that is accessible to the public. The Laguna overlook, landscaping, and interpretive signs reflect the value of this important community asset. The project has been conditioned to either provide suitable public art or pay into the Percent-for-Art Program.

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4 ECONOMIC VITALITY ELEMENT
GOAL EV 1: Encourage Economic Development that Broadens the City’s Employment Base, Attracts HighQuality Jobs, Provides Services and Goods that Reflect the City’s Values, and Increases the City’s Tax Base GOAL EV 4: Emphasize Sebastopol's Role as a Market, Service, and Tourism Hub for the West County and as a Gateway to the Coast
GOAL EV 7: Maintain a Stable and Self-Sustaining Fiscal Base in Order to Generate the Resources Necessary to Provide Desired City Services and Support New Growth that is Consistent with the City’s Values and Goals
Policy EV 4-3: Encourage amenities needed to support tourism, including hotels, bed-and-breakfasts, eco-lodging, and a variety of restaurants, shopping, and services.

Policy EV 4-4: Encourage the development of civic amenities, entertainment venues, retail and restaurants, and services that increase visitation, spending, and tourism.

Policy EV 4-5: Promote both the City, and the City’s open space and natural resources, with emphasis on the Laguna Wetlands Preserve, as a tourist destination.

Analysis of Project Consistency with Economic Vitality Element: The Barlow Hotel project provides consistency with the Economic Vitality Element of the Sebastopol General Plan. It meets the goals of this element by increasing the City’s tax base, increases its role as a tourism hub for the west county by providing accommodations for visitors, and increases the City’s fiscal base. It provides the amenities necessary to support tourism in a location and with a pedestrian orientation that is designed to increase spending both in The Barlow and within the adjacent Downtown. It promotes the Laguna de Santa Rosa as an important natural resource and tourism destination.

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EXHIBIT xxx

BARLOW HOTEL PROJECT CONDITIONS OF APPROVAL

DEVELOPMENT AGREEMENT
Inclusive of Use Permits and Design Review for
Hotel, Parking Lot, Valet Parking, ESOS Setback Modification, and Alcohol Sales 6872 Sebastopol Avenue and 385 Morris Street
File Number 2024-010

1. This approval is not valid unless and until the Development Agreement is approved by the City Council and signed by the City. In the event of a conflict between the Development Agreement and these conditions of approval, the Development Agreement shall control.

2. All submitted grading/improvement plans and building permit plan check sets shall include a plan sheet incorporating these conditions of approval.

3. Except as otherwise noted in these conditions of approval, the plans submitted to the Planning, Engineering and Building Departments for plan check shall be in substantial conformance to those approved by the review body. If any changes are made to submitted plans which were approved by the review body, the Applicant shall work with the Planning Department and City Manager to determine the appropriate body for reviewing the changes, in accordance with the requirements of the Development Agreement. Any changes that have not been approved by the relevant authority are not approved. Construction or demolition work that does not conform to the Planning approval is not valid and shall be subject to stop work orders and may require removal.

4. Acceptance of the construction drawings and specifications does not release the applicant and owner from correction of mistakes, errors, or omissions contained therein. If, during the course of construction, the field conditions or other previously unknown conditions require a modification or a departure from the accepted plans, the applicant shall provide the modifications or departure and specify the correction of mistakes, errors, or omissions in compliance with the CBC and City Standards.

5. The City of Sebastopol and its agents, officers and employees shall be defended, indemnified, and held harmless from any claim, action or proceedings against the City, or its agents, officers and employees to attach, set aside, void, or annul the approval of this application or the environmental determination which accompanies it, or which otherwise arises out of or in connection with the City’s action on this application, including but not limited to, damages, costs, expenses, attorney’s fees, or expert witness fees.

6. A Construction Management Plan (CMP) shall be submitted to the City as part of the Grading/Improvement Plans and Building Plans and shall be incorporated into the plans, unless waived by staff. Revisions to the CMP to increase or add time to the construction timeline shall be coordinated with the Building Official and any additional requests will be the Applicant’s responsibility.

This CMP shall be a binding document. Failure to adhere to the CMP may result in a “Stop Work Notice” being placed on the project. An electronic copy of the APPROVED CMP shall be submitted to the City and may be posted to the City’s website. The CMP shall be updated as project conditions warrant. Updates to the CMP shall be requested by the Applicant and provided to the City for review and approval. The CMP shall include but not be limited to:

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a) Work schedule (start of construction date, road or lane closure intent/dates, important milestones and proposed final dates)
b) Construction Hours
c) Travel routes and turn-around locations with staff approval • Impact to state highways
d) Road and/or lane closures (Applicant to provide information on how many anticipated road closures, and the reasons for each road closure). e) Worker auto parking space locations/construction parking f) Phasing of both parking and hotel construction components, and coordination between the two components
g) If construction improvements are located in areas of slopes 15% or greater, the Contractor shall provide safe temporary hard surface stair access to the improvements, unless waived by the Building Official. This access shall be shown on the CMP.
h) Projects that require a grading permit shall comply with the City’s grading ordinance.

The CMP may be more stringent if the project is located close to schools or in impacted neighborhoods. A CMP may be required to be modified if a neighborhood becomes “impacted” during the course of the construction. Impacted neighborhoods are defined as areas in geographic proximity (i.e. using the same streets for access) with a significant number of simultaneous construction projects.

Unless modified by other specific approvals granted by City, the hours of construction activity shall be limited to 7:00 a.m. to 8:00 p.m., Monday through Friday. Construction may be extended to Saturday from 8:00 a.m. to 5:00 p.m. with staff approval.

A24-inch by 36-inch weatherproof copy with items A-F shall be posted on site so as to be visible without entering the construction area. The remaining Construction Management Plan shall be made available on site. The Construction Management Plan shall be posted on the site as part of the job site signage and must include:
a) Address of the project site.
b) Permitted hours of construction and of deliveries/off-haul. c) Name, e-mail address and direct phone number of the General Contractor. d) Name, e-mail address and direct phone number of the person responsible for managing theproject.
e) Name and direct phone number of the party to call in case of an emergency. f)City of Sebastopol Building Department (707-823-8597).

7. All portions of the job site shall be maintained in an organized and professional condition. All trash, debris, construction scraps and broken/deteriorated machinery shall be removed from the site by the end of each week. If off loaded construction materials are not used within 2 weeks, they shall be screened from public view. All sidewalks, driveways and public/private roadways fronting the subject site shall be broom cleaned at the end of each business day.

8. A pre-construction meeting is required prior to initiation of any ground-disturbing work.

Contact the Building Department at (707) 823-8597 to schedule the pre-construction meeting at least 5 working days in advance of the requested meeting date. The Building Official will arrange for other City personnel to attend the pre-construction meeting as needed.

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being granted unless otherwise stipulated by the City.

10. All required construction signage and any required tree protection shall be in place and available for City inspection at the time of the pre-construction meeting. If these measures are not in place at the time of the pre-construction meeting, a re- inspection fee will be required, and issuance of the grading or building permit(s) will be delayed.

11. The Community Development Director shall interpret applicable requirements in the event of any redundancy or conflict in conditions of approval.

12. Appropriate Business Licenses are required for each use and shall be obtained prior to operation of each use.

Community Development (Planning) Department Conditions of Approval:

13. This approval is valid for a period of time specified in the Development Agreement, during which time the rights granted must be exercised.

14. Onsite parking lot lighting shall be installed at the parking lots. The lighting shall limit 'night sky' impacts and fixtures shall be subject to the approval of the Community Development Director after review and input is provided by the Police Department to ensure adequate lighting for public safety.

15. The light source for all exterior lighting fixtures shall be shielded from adjacent properties. Cut sheets for all exterior lighting, including cut-off shields near the edges of properties and near sensitive land uses, shall be submitted as part of the Administrative Design Review.

16. Site landscaping shall be consistent with the project Landscape Plan on file with the Sebastopol Planning Department. The final landscape plan shall be stamped by a licensed landscape architect and filed with the Planning Department prior to occupancy. Plans for irrigation of the site shall be incorporated into the landscape plan.

All planting shown on the approved plan shall be installed prior to occupying the proposed project. Upon the request of an Applicant to receive a Temporary Certificate of Occupancy and at discretion of the Community Development Director, landscape installation may be suitably guaranteed by posting a cash bond equal to l00% of the cost and installation of any landscape improvements.

17. A minimum of 17 electric vehicle charging spaces accessible to EV charging stations shall be provided in the project parking lot, as reflected in the application submittal materials and approvals. Building and Grading/Improvement plans shall specify the location of these facilities.

18. For projects with new foundations or retaining walls less than 10’ away from a required setback, property lines shall be physically identified (string line or equal), and the applicant shall submit a letter or certificate from a licensed surveyor that confirms that the structure complies with the approved setbacks prior to placing the foundation. For any project that includes new foundations or retaining walls more than 10’ away from a required setback, the applicant may request a waiver from this requirement from the City Engineer and Planning Department.

19. Prior to issuance of any permit for grading or construction on the Morris Street (batch Agenda Item Number 10 Agenda Item Number: 10
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plant) parking lot, Applicant shall record a permanent open space easement over the Laguna portion of the site from the 50’ Environmental and Science Open Space Combining District (ESOS) setback line to the easterly edge of the property, as shown on the documents dated August 1, 2024. No construction activities shall occur in this area, and any existing improvements shall be removed, except that a landscaped trail area of up to 20 feet wide may be maintained.

20. Prior to issuance of any permit for grading or construction on the Morris Street (batch plant) parking lot, applicant shall provide a dedication of easement across the existing AmeriCorps trail as shown on the Barlow Hotel Batch Plant grading and Drainage Plan (sheet C4.0) dated August 7, 2024.

21. Prior to submittal of application for a Building Permit, applicant shall submit a redesign of the Sebastopol Avenue facade to the City Manager or designee demonstrating that the following recommendations of the Planning Commission and the Design Review Board have been considered in the design of this façade:
• Update the Sebastopol Avenue façade to make it feel more welcoming. • A simple facade is acceptable, but it should not feel like the back of the building. • Better integrate the railings into the project design, as allowed by ADA and approved by the Building Official.
• Incorporate design aspects or physical additions to better engage the street and to improve the pedestrian experience.

If the City Manager or designee determines that the façade has not been redesigned to address these recommendations, the City Manager shall cause the design to return to the next available Design Review Board meeting and review and approval will be required prior to issuance of the Building Permit (except for Grading, Improvement, or Foundation Only permits).

22. Compliance with the Public Art Ordinance shall be demonstrated prior to issuance of a certificate of occupancy for the project, either by payment of an in-lieu fee, or by obtaining City approval for an on- site artwork. If on-site public art is proposed, it shall be considered by the Public Art Committee at a single public meeting, at which meeting the Public Art Committee shall make a recommendation to the City Council, which shall thereafter approve or reject the proposed public art.

23. A Secretary of Interior-qualified archaeologist shall be retained to prepare a Monitoring Plan prior to demolition of the existing foundations on the hotel site. The Monitoring Plan shall include a research design following the OHP's Guidelines for Archaeological Research Designs and outline the specific methods and procedures to follow in the event that archaeological deposits are identified during construction. The Monitoring Plan shall include onsite worker training for all construction personnel prior to demolition of the existing foundations on the hotel site. The training shall teach all construction personnel to understand what archeological and historical resources are, which types of artifacts may be encountered during ground disturbance, and measures used to protect potential artifacts in compliance with CEQA. Construction personnel shall also be trained in the procedures to be followed upon the discovery of any potential artifact or materials without a monitor onsite and to stop work and contact the archaeologist.

Personnel shall be instructed that unauthorized collection or disturbance of fossils is unlawful and can result in criminal penalties. Additionally, an archaeological monitor shall be present during the demolition of the existing foundation on the hotel site and the initial ground disturbing activity in the location of the existing foundations. The archaeological monitor shall be empowered to halt construction activities at the location of a discovery to review possible archaeological material and to protect and secure the Agenda Item Number 10 Agenda Item Number: 10
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resource while it is being evaluated. Monitoring shall continue until, in the archaeologist's judgment, cultural resources are not likely to be encountered.

24. If archaeological materials are encountered during project activities, all work within 25 feet of the discovery shall be redirected until the archaeologist assesses the finds, consults with the appropriate agencies, and makes recommendations for the treatment of the discovery following procedures outlined in the Monitoring Plan. If avoidance of the archaeological deposit is not feasible, the archaeological deposit shall be evaluated for its eligibility for listing in the California Register of Historical Resources. If the deposit is determined not to be eligible for listing, mitigation will not be necessary. If the deposit is determined eligible for listing, adverse effects on the deposits shall be mitigated. Mitigation may include excavation of the archaeological deposit in accordance with a data recovery plan (see CEQA Guidelines Section 15126.4(b)(3)(C)) and standard archaeological field methods and procedures; laboratory and technical analyses of recovered archaeological materials; preparation of a report detailing the methods, findings, and significance of the archaeological site and associated materials; and accessioning of archaeological materials and a technical data recovery report at a property curation facility. Upon completion of the assessment, the archaeologist shall prepare a report to document the methods and results of the assessment. The report shall be submitted to the City of Sebastopol and the NWIC upon completion of the project.

25. All uses involving alcohol sales shall be in substantial conformance with the operations as described in the project application materials on file at the City of Sebastopol Planning Department and in the Development Agreement, except as modified herein.

26. Hours of operation shall be consistent with the hours stated in the application materials. The City Manager, or designee, shall have the authority to modify the hours of operation when such modifications are consistent with the allowances for minor changes set for in the Project’s Development Agreement.

27. Food must be made available during all times that alcohol is served. This may include meals or incidental food items.

28. Any minimum purchase requirement may be satisfied by the purchase of food or beverages.

In no case shall a “drink minimum” be imposed.

29. The business owner shall ensure that employees are drug and alcohol free while on duty.

30. The applicant shall be responsible for implementing an Alcohol Awareness and Security Plan, which shall be submitted to the Police Department for review and approval within 120 days from approval of a building permit for the hotel. The Plan shall describe building security and fire safety; how the operation will address staff training relative to alcohol consumption and operational security; and how the operation will coordinate with the Police Department.

31. The establishment is not approved as an entertainment venue. Regular live music shall not be permitted on the premises without prior City approval. As an incidental use, recorded background music may be utilized inside the building and non-amplified acoustic music may be utilized outdoors, subject to the noise ordinance. The Police Department or Community Development Director may require termination or modification of such activity in the event of undue noise impacts or other adverse effects.

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32. The business owner shall ensure that exterior areas, including the sidewalk, are free of trash and other debris that may be generated by patrons.

33. The business owner shall be responsible for removing any graffiti on the outside of the establishment.

34. A copy of the conditions of approval for the Alcohol Use Permit must be kept on the premises of the establishment and posted in a place where any member of the general public may readily view it.

35. All landscape and irrigation plans must be designed in accordance with the most current City of Sebastopol landscape requirements. Prior to providing water service for new landscape areas, or improved or modified landscape areas, the Planning Department must review and approve the project’s working drawings for planting and irrigation systems. Any question regarding the City of Sebastopol current water conservation and Landscape Ordinance should be directed to the Planning Department.

36. Any street trees planted within 10 feet of a public street curb shall include a root barrier acceptable to the City Engineer and the City Arborist.

37. Hotel guests and guests shall be encouraged at check-in and in reservation communications to use the valet parking area so as to maintain on-site parking for other commercial patrons and the general public.

Engineering and Public Works Department Conditions of Approval:

38. An Encroachment Permit is required from the Public Works Department for any and all work within the public right-of-way. For all work in CalTrans right-of way, an Encroachment Permit from CalTrans shall also be procured by the applicant.

Encroachment Permit shall not be issued until the City Engineer approves the applicant’s site improvement plans.

39. Construction within the public right-of-way is limited to that necessary to support the development. This may include but is not limited to: driveways, sidewalks and any utility connections. For all improvements within the public right of way, the applicant shall submit plans to adequately describe the work. Plans shall include but not be limited to drainage details, cross-sections, driveway/roadway grades and utility locations as necessary.

40. Construction staging shall not be allowed within public right of way unless expressly authorized by the City Engineer. In no case shall construction staging in Hwy. 12 right of way be permitted.

41. The applicant shall prepare and submit site improvement plans for the construction of all improvements including water, sanitary sewer, storm drain, water quality facilities, roadway improvements, curbs, gutters, sidewalks, elevated or structural pedestrian walkways, landscaping, landscape irrigation, signing, striping, joint trench and streetlights. All design and construction shall conform to the latest edition of the City of Sebastopol Design and Construction Standards and other applicable codes, standards, guidelines and specifications. Public improvement drawings shall be drafted in the City-approved sheet format.

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42. Once approved by the City Engineer, the applicant shall submit PDF files of the signed improvement plans. During construction the development contractor shall maintain current redline drawings of the work. At conclusion of construction and prior to completion acceptance by the City, the development Engineer shall prepare and submit to the City ‘As-Built’ record drawings that are based on the contractor’s redlines. The record drawings shall be submitted in PDF and CAD format.

43. No deviations from City Standards and applicable Code requirements shall be allowed unless expressly approved by the City Engineer. The applicant’s engineer shall request all design exceptions in writing.

44. Any improvements, public or private, damaged during construction shall be repaired by and at the sole expense of the applicant, and shall be in-kind or with new improvements. All cracked, broken, or uplifted sidewalk, driveway and/or curb and gutter fronting the property shall be replaced. Applicant shall coordinate with the Public Works Department prior to the first submittal of project improvement plans to identify the extents and limits of replacement.

45. An erosion and sediment control plan is required as part of the building permit application. The plan shall be prepared by a certified erosion control specialist and in full compliance with CASQA standards, The plan is subject to review and approval by the Engineering Department prior to the issuance of the building or grading permit. No modifications to the approved plans shall be made without approval of the City Engineer.

46. Mailbox plans and locations shall be approved by the Sebastopol Postmaster prior to improvement plan approval. The developer shall provide a letter and exhibit showing mailbox locations from the Sebastopol Postmaster approving mailbox locations.

47. All public utility easements necessary to support the development shall be submitted for review and approval by the City Engineer.

HOTEL SITE:

48. The Applicant shall submit for review and approval of the City Engineer Site Improvement Plans prepared by a registered Civil Engineer including but not limited to grading, paving, onsite and offsite utilities improvements and modifications, drainage, storm water low impact development measures, erosion and sediment control, traffic control, public frontage improvements and modifications, etc., and in compliance with Public Works Standard Details.

49. Improvement plans for the proposed abandonment and relocation of the existing public water and sanitary sewer systems shall be prepared as a separate (standalone) plan set from, and shall be submitted together with, the development site improvements. The Applicant shall prepare and submit sewer and water modeling studies of the proposed realignments for review and approval by the City Engineer.

50. Due to periodic flooding of the area of proposed development all new public and private utilities shall design to prevent or eliminate the inflow and/or infiltration of floodwaters into the utility systems.

51. Prior to approval of the Site Improvement Plans, the Applicant shall revise the Preliminary Drainage Analysis (dated August 1, 2024) for 6782 Sebastopol Avenue & 385 Morris Street to address all prior review comments and resubmit the revised Final Analysis for review and final approval by the City Engineer.

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52. Prior to approval of the Site Improvement Plans, the Applicant shall revise the Initial Storm Water Low Impact Development Submittal (SWLIDS dated August 1, 2024) for 6782 Sebastopol Avenue & 385 Morris Street to address all prior review comments and resubmit the revised Final SWLIDS for review and final approval by the City Engineer.

53. Prior to approval of the Site Improvement Plans, the Applicant shall submit for review and approval by the City Engineer, proposed public utility easement documents prepared by a License Land Surveyor including but not limited to legal descriptions (exhibit ‘A’), easement diagram (exhibit ‘B’), together with other documentation such as draft grant deed, preliminary title reports, closure calculations, reference record documents, etc.

54. Prior to approval of the Improvement Plans, the Applicant shall submit for review and approval by the City Engineer, proposed vacation and/or relocation of public utility easement documents prepared by a License Land Surveyor including but not limited to legal descriptions (exhibit ‘A’), easement diagram (exhibit ‘B’), together with other documentation such as preliminary title reports, closure calculations, reference record documents, etc.

55. Prior to approval of the Site Improvement Plans, the Applicant shall submit written verification, including copies of recorded documents, that all existing private easements proposed for modified and/or quitclaim have been completed accordingly.

PARKING LOT SITE:

56. The Applicant shall submit for review and approval by the City Engineer Site Improvement Plans prepared by a registered Civil Engineer that include but are not limited to grading, paving, utilities improvements and modifications, drainage, storm water low impact development measures, erosion and sediment control, traffic control, public frontage improvements and modifications, new pedestrian crossing, etc., and in compliance with Public Works Standard Details.

57. The new pedestrian crossing shall retain the prior-approved temporary crossing location on the north leg of Morris Street at the intersection with the Laguna Park Way and shall consist of:
• Pavement markings, yield markings, and red curbing from the prior-approved temporary crossing.
• Reconstructing the west side corner and extending six feet into the parking lanes on Morris Street and Laguana Park Way.
• Adding new ADA-compliant curb ramps to serve both the crossing of Morris Street (east-west) and the crossing of Laguna Park Way (north-south). • Reconstructing the east side crosswalk landing and extending six feet into the parking lane on Morris Street and adding new ADA-compliant curb ramps. • Re-installing the double-sided, high-visibility W11-2 pedestrian crossing signs on both sides of the street within the curb extension areas.
• Adding new pedestrian scale lighting to illuminate both new pedestrian landing areas.

Proposed style of the lighting shall be submitted for review and accept by the City prior to approval of the Plans.
• Adding new pedestrian-activated warning beacons.

58. Prior to approval of the Site Improvement Plans, the Applicant shall revise the Preliminary Drainage Analysis (dated August 1, 2024) for 6782 Sebastopol Avenue & 385 Morris Street to address all prior review comments and resubmit the revised Final Analysis for review and final approval by the City Engineer.

59. Prior to approval of the Improvement Plans, the Applicant shall revise the Initial Storm Water Low Impact Development Submittal (SWLIDS dated August 1, 2024) for 6782 Sebastopol Agenda Item Number 10 Agenda Item Number: 10
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Avenue & 385 Morris Street to address all prior review comments and resubmit the revised Final SWLIDS for review and final approval by the City Engineer.

60. The Applicant shall provide to the City an irrevocable offer of easement dedication for public access over the existing portion of the AmeriCorps Trail located in the northeasterly corner of the property (APN 004-011-017).

61. Prior to approval, the applicant shall provide the City the lighting plan for the Morris Street Parking Lot. The plan shall comply with all environmental requirements to mitigate lighting impacts on the Laguna environs and will be reviewed by the Police Department and other applicable City departments to ensure compliance and provide for adequate lighting to ensure public safety.

Roadway Improvements:

62. Sidewalk warps shall be provided to allow a clear five-foot walkway at all locations, including areas where mailboxes, street furniture, streetlights, street signs and fire hydrants are to be installed, or as otherwise approved by the City Engineer.

63. The structural section of the private on-site drive aisles and parking areas shall meet the requirements and recommendations of the geotechnical report for the project.

64. Pedestrian curb ramps meeting City standards and current accessibility requirements shall be provided at all intersections and crosswalks where public sidewalks and access are proposed.

Drainage Improvements:

65. All project related flooding impacts shall be mitigated by the project developer.

Drainage improvements shall be designed by a Civil Engineer registered in the State of California in accordance with the Sonoma County Water Agency's Flood Management Design Manual (FMDM). Public and private drainage improvements shall be shown on the improvement plans and the City Engineer may require the applicant to acquire the review and recommendations by the Sonoma County Water Agency (Sonoma Water) prior to approval by the City Engineer. Private storm drain easements will be required for any portions of the private storm drain not entirely located with the lot being served or for any portion of a private utility located on an adjacent parcel.

66. No lot-to-lot drainage will be allowed between the project site and any adjacent parcels.No concentrated drainage may discharge across sidewalks. All site drains must be connected to the public storm drain system or discharged through the face of curb or to an established waterway.

67. Plans and certifications shall demonstrate compliance of all improvements, including finished floor elevations, with the City's Flood Ordinance, to the satisfaction of the Building Official and City Engineer. Building finished floor elevations shall be constructed at a minimum of 2 foot above the 100-year storm event water surface elevation as determined by the City and certified by the project engineer. The Engineer of Record shall provide a signed and stamped letter indicating the project meets the requirements of the Ordinance before plan approval.

Stormwater Quality:

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68. This Project is subject to the design and construction requirements of the most recent edition of City of Sebastopol Low Impact Development (LID) Technical Design Manual. Improvement plans with required LID design features shall be approved by the City Engineer.

69. For required LID features constructed on private property or on street frontage, the owner shall provide a Declaration Letter to the City Manager regarding the owner’s commitment to ongoing maintenance of said LID features (LID Declaration) prior to occupancy.

Grading:

70. (Applicable to Parking Lot Site) The improvement plans shall include a site-grading plan prepared by a Civil Engineer registered in the State of California as part of the required improvement drawings. The site shall be generally designed to drain to public street or parking areas, unless otherwise approved in the interest of tree preservation or other unusual circumstances.

71. (Applicable to Parking Lot Site) A Tree Protection Plan (TPP) Sheet shall be submitted as a part of the Grading Plans showing all protected trees and approved Tree Protection measures including the placement and type of tree protection fencing as well areas of required hand digging, if applicable.

72. When required by the Building Official the applicant shall submit to the City for review and approval, a detailed Geotechnical Report prepared by a Geotechnical Engineer registered in the State of California. The grading plan shall incorporate the recommendations of the approved Geotechnical Report.

73. (Applicable to Parking Lot Site) Existing wells, septic tanks and/or underground fuel storage tanks that are defective or will no longer be in use shall be permanently destroyed or removed under permit and inspection by the Sonoma County Permit and Resource Management Department, Well and Septic Division and/or Sonoma County Environmental Health or other designated agency. Underground fuel storage tanks are subject to UST regulations of the State Water Resources Control Board.

74. The grading plan shall clearly show all existing survey monuments and property corners and shall state that they shall be protected and preserved. Should monuments be damaged or destroyed during construction, they shall be replaced by and at the sole expense of the Applicant.

75. Improvements plans shall include an erosion control (winterization) plan. The plan shall include an order of work and staging/scheduling component indicating when facilities must be installed and when they may be removed.

76. Sewer services and laterals that are intended for re-use shall be CCTV inspected to determine if the service needs to be removed and replaced. A copy of the CCTV report shall be provided to the City Engineer. CCTV inspection may be waived by the City Engineer, if the sewer lateral has been replaced within ten years of the submittal of the improvement plans. A copy of the documentation evidencing such replacement shall be included in the submittal package.

77. (Applicable to Parking Lot Site) If the proposed project is located in or adjacent to a Agenda Item Number 10 Agenda Item Number: 10
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waterway, within an area designated as habitat for threatened or endangered species, or other special status area, it possibly falls under the jurisdiction of another agency such as the United States Army Corps of Engineers, the California Regional Water Quality Control, or the California Department of Fish & Wildlife, U. S. Fish & Wildlife Service, etc. These agencies shall be contacted to determine if the project lies within their respective jurisdictions. All necessary permits and/or approvals shall be obtained prior to the City issuing any permits. If permits are not required, a letter stating so shall be submitted to the City as part of the record.

78. Trees and vegetation shall be trimmed according to Section 8.12 of the Sebastopol Municipal Code. Trees and shrubs shall be kept trimmed so that the lowest branches projecting over public properties provide a clearance of not less than eight (8) feet over sidewalks and not less than twelve (12) feet over streets.

Fire Department Conditions of Approval:

79. The address shall be posted in accordance with requirements of the California Building Code and California Fire Code. The Fire Chief shall review and approve all requests for new addresses. Inspection and signoff of address posting shall be coordinated through Building Department.

80.Smoke and CO detectors shall be installed in accordance with the California Building Code. Final inspection and signoff of smoke detectors shall be coordinated through Building Department.

81. Noncombustible roofing shall be provided for:
a. All new roofs shall be non-combustible.
b. Roof Repairs or replacement:
i. Less than 25% - no requirement
ii. 25Hr to 50% - Class C minimum
iii. 50% or more — Non-Combustible
c. In no case shall the roofing material used to be less fire resistive than the existing roof.

NOTE: A "noncombustible" roof is a Class A roof (for other than Group R Occupancies, a Class A or Class A assembly) as defined in the California Building Code and approved by the Building Department.

82. Prior to occupancy, a 3/8” mesh minimum spark arrester shall be installed on any chimney(s).

Building Department Conditions of Approval:

83. All construction shall comply with all applicable Title 24 Codes in effect at the time of building permit submittal. It is the responsibility of the designer(s) to ensure that all applicable Title 24 codes, as well as any applicable Sebastopol Municipal Codes are incorporated into the design.

84. The project shall comply with the Green Building regulations contained in the Sebastopol Municipal Code that are in effect at the time of Building Permit application submittal.

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4770 Baseline Road, Suite 360 • Boulder, CO 80303 • 303/449-6558 • FAX 303/449-6587 • www.rrcassociates.com April 22, 2024
Barney Aldridge and Justin Allamano
Aldridge Development
6780 Depot Street #110
Sebastopol, CA 95472
Via email: [email protected], [email protected] Dear Barney and Justin:

This letter summarizes the estimated economic and tax impacts of the proposed Barlow Hotel to the City of Sebastopol and Sonoma County. The analysis has been conducted by RRC Associates, and is based on a review of the proposed hotel development; tourism, economic, and fiscal information for Sebastopol and the region; and other data and specified assumptions.

Development Program and Operating Assumptions
The project would be a boutique, full-service hotel with 83 hotel rooms in an array of sizes, along with retail, restaurant, bar, spa, meeting room, rooftop pool and bar, and other spaces and amenities. The hotel would be located at 6782 Sebastopol Avenue in The Barlow district.

The hotel would replace a 36,402 square foot industrial building which is currently leased by Guayaki Yerba Mate and is not open to the public. The existing building is currently primarily used for storage by the tenant and its sublessee tenants. Redevelopment of the property into a hotel is unlikely to displace much employment, sales, or other economic activity, given that the space is not intensively used, the primary tenant has expressed interest in moving regardless of the redevelopment, and business activity by subtenants which is displaced may be relocated to other spaces in The Barlow.

It is also assumed that the Barlow Hotel would not displace economic activity occurring at other businesses in Sebastopol, due to the uniqueness of development and its offerings within the marketplace. Indeed, by adding vibrancy to the area, the Hotel will likely have positive externalities that simulate additional incremental economic activity in The Barlow and the downtown area.

As such, it is assumed that economic activity generated by the Barlow Hotel would be fully incremental, and there is not need to net out any displaced economic activity.

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Barlow Hotel Economic and Tax Impact April 22, 2024
RRC Associates 2
Based on an April 2024 market study conducted by HVS, this economic analysis assumes that the Barlow Hotel would have an annual average occupancy rate of 70% upon project stabilization in 2030, and an average daily rate of $575 (expressed in 2023 dollars; see Figure 1 to follow).

Figure 1: Barlow Hotel Operating Assumptions Upon Project Stabilization (2030)* *Average Daily Rate is expressed in 2023 dollars (as if project were stabilized in 2023). Source: HVS.

Hotel Guest Spend and Economic Impact
Upon project stabilization, guests staying at the Barlow Hotel are projected to spend $31.4 million annually (net of taxes), including $23.4 million in Sebastopol and $8 million elsewhere in Sonoma County.

This spending by Barlow Hotel guests is projected to directly generate $9.8 million in labor income and support 210 jobs in Sonoma County (Figure 2). These estimates are derived from income:sales and income:job ratios for Sonoma County which are available from federal statistical data sources.

Figure 2: Barlow Hotel – Projected Annual Direct Economic Impacts in Sonoma County Upon Project Stabilization (2030)*
*Visitor spend and personal income are expressed in 2023 dollars (as if project were stabilized in 2023).

Source: RRC. Personal income and jobs are derived from guest spend using income:receipts ratios and jobs:income ratios by industry sector in Sonoma County, as estimated from datasets from the US Bureau of Economic Analysis, US Economic Census, and US Census County Business Patterns.

Spending by Barlow Hotel guests is projected to occur across an array of commodities, including rooms and resort fees ($12.9 million), food and beverage services ($7.1 million), retail stores ($4 million), arts/entertainment/recreation ($3.8 million), local transportation and gas ($2.2 million), food stores ($1 million), and air transportation ($400,000). Spend is projected to occur both within the hotel and at other businesses in Sebastopol and Sonoma County.

Barlow Hotel
Operating Assumptions
83 Rooms
70% Occupancy Rate
$575 Average Daily Rate
21,207 Annual Room Nights
Measure Direct Impact
Visitor spend (net of taxes) $31,400,000
Personal Income $9,800,000
Jobs 210
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Barlow Hotel Economic and Tax Impact April 22, 2024
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Figure 3: Barlow Hotel – Projected Annual Guest Spend (Net of Taxes) Upon Project Stabilization (2030)*
*Guest spend is expressed in 2023 dollars (as if project were stabilized in 2023). Source: RRC, as informed by 2022 Sonoma County visitor economic impacts (Dean Runyan Associates) and 2024 HVS Barlow Hotel Study.

In addition to this spend by guests, the Barlow Hotel itself is also expected to generate spending by non-lodging guests (including Sebastopol residents and visitors not staying in the hotel), on items like food, beverage and spa services provided by the Barlow Hotel. For conservatism, however, these additional impacts are excluded from the analysis.

In addition to the direct impacts summarized above, the Barlow Hotel is also projected to generate additional economic impacts, including the following:
• Ongoing multiplier impacts triggered by the direct economic impacts summarized above.

These include indirect impacts (associated with supply chain activity) and induced impacts (i.e. household spending effects). Estimation of multiplier effects is beyond the scope of this analysis, but such effects within Sonoma County are likely to be 50% of the size of the direct effects (or more).
• One-time economic impacts from the construction of the Barlow Hotel. • By adding to the vibrancy of the Barlow District and downtown Sebastopol, and expanding the array of offerings in the area (e.g. rooftop experiences at the hotel), the Barlow Hotel may also stimulate additional incremental visitation and spending in these areas by residents and other visitors not staying at the hotel, and potentially additional investment by downtown property owners.

Tax Generation for the City of Sebastopol
Barlow Hotel guests are projected to generate in excess of $2 million in tax revenues annually for the City of Sebastopol. As summarized further in the tables to follow, these revenues include:
• $1.548 million in annual TOT taxes (Figure 4)
• $350,000 in annual sales taxes (Figure 5)
• $180,000 in annual property taxes (Figure 6)
Commodity In Sebastopol Elsewhere in county Sonoma Co. Total Accommodations $12,200,000 $0 $12,200,000
Resort Fee $700,000 $0 $700,000
Food Service $5,000,000 $2,100,000 $7,100,000
Arts, Entertainment & Recreation $1,900,000 $1,900,000 $3,800,000 Retail Sales $2,000,000 $2,000,000 $4,000,000
Local Transportation & Gas $1,100,000 $1,100,000 $2,200,000 Food Stores $500,000 $500,000 $1,000,000
Visitor Air Transportation $0 $400,000 $400,000
TOTAL $23,400,000 $8,000,000 $31,400,000
Barlow Hotel: Annual Guest Spend
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Barlow Hotel Economic and Tax Impact April 22, 2024
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Combined, these projected tax revenues are equivalent to 19.3% of the City’s total expected General Fund revenue in the 2023/24 approved budget (Figure 7), and 24.3% of the City’s total expected TOT, sales and property tax revenues (Figure 8).

As such, the Barlow Hotel could have a dramatic positive impact on the City’s revenues and financial health. Expanding the City’s financial capacity has been a longstanding goal of the City.

Figure 4: Barlow Hotel – Projected Annual TOT Tax for Sebastopol Upon Project Stabilization (2030)* *Revenues and taxes are expressed in 2023 dollars (as if project were stabilized in 2023).

Figure 5: Barlow Hotel – Projected Annual Sales Tax for Sebastopol Upon Project Stabilization (2030)* *Revenues and taxes are expressed in 2023 dollars (as if project were stabilized in 2023).

Figure 6: Barlow Hotel – Projected Annual Property Tax for Sebastopol Upon Completion of Construction (2027)*
*Revenues and taxes are expressed in 2023 dollars (as if project were stabilized in 2023). $12,900,000 Gross annual room revenue & resort fees
12% Sebastopol TOT tax rate
$1,548,000 Barlow Hotel TOT tax generation for Sebastopol TOT Tax
$23,400,000 Aggregate guest spend in Sebastopol
85% Share of sales which are taxable

1.75% Sebastopol sales tax rate
$350,000 Barlow Hotel sales tax generation for Sebastopol Sales Tax Operation Value Measure
$90,300,000 Barlow Hotel cost (HVS 4/15/2024)
- $2,289,684 Current assessed value of Guayaki parcel improvements & personal property = $88,010,316 Net incremental value of Barlow Hotel
/ $1,650,626,000 Total assessed valuation in Sebastopol, assessment year 2023 to 2024 = 5.5% Barlow Hotel share of City assessed valuation
* $3,241,600 Sebastopol property tax collections, 2023/24 budget = $180,000 Barlow Hotel property tax generation for Sebastopol Agenda Item Number 10 Agenda Item Number: 10
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Barlow Hotel Economic and Tax Impact April 22, 2024
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Figure 7: Barlow Hotel – Summary of Projected Annual Tax Generation for Sebastopol Note: Barlow Hotel tax generation is reflective of stabilized operations, expressed in 2023 dollars.

Figure 8: Barlow Hotel –Projected Annual Tax Generation as a Percentage of Sebastopol General Fund Revenues
Note: Barlow Hotel tax generation is reflective of stabilized operations, expressed in 2023 dollars. *Barlow Hotel may generate small amounts of additional revenues, e.g. license and permit revenue.

Selected Background Tourism Information
Following are selected notable datapoints that illustrate the large size of Sonoma County’s tourism industry, and the potential for Sebastopol to capture a larger slice of this economic activity via the Barlow Hotel. The information presented here is by no means exhaustive, but rather is intended to provide a bit of additional context.

As illustrated in Figure 9 to follow, Sonoma County generated an estimated $2.127 billion in visitor travel spending in 2022, including $657 million in spending on accommodations. Spend has climbed substantially over the long term, notwithstanding a sharp contraction during the Covid pandemic.

As of February 2024, Sonoma County’s lodging base included 124 hotel properties with an aggregate of 7,862 rooms, according to STR and as republished by Visit California. As of Q3 2023, an additional 26 lodging properties with 1,742 rooms were in various states of planning and development in Sonoma County, an indication that developers see additional market potential. In addition to hotels, Sonoma County’s lodging inventory also includes a large number of short-term rentals.
$1,548,000 TOT tax
$350,000 Sales tax
$180,000 Incremental Property tax
$2,078,000 Sum: Barlow Hotel tax generation for Sebastopol $10,758,460 Total revenues: Sebastopol 2023/24 approved General Fund budget

19.3% Barlow Hotel tax generation as a share of General Fund revenues Barlow Hotel: Sebastopol Tax Generation
Tax Generation Barlow Hotel
2023/24 City
Budget
Barlow
Hotel as a
% of City
TOT tax $1,548,000 $500,000 309.6%
Sales tax $350,000 $4,794,560 7.3%
Property tax $180,000 $3,241,600 5.6%
Sum $2,078,000 $8,536,160 24.3%
Other Sebastopol municipal revenues $0* $2,222,300 0.0% Total Sebastopol municipal revenues $2,078,000 $10,758,460 19.3% Agenda Item Number 10 Agenda Item Number: 10
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Barlow Hotel Economic and Tax Impact April 22, 2024
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Figure 9: Sonoma County Visitor Travel Spending by Commodity Purchased, 2012-2022 Source: Dean Runyan Associates. 2022 data is preliminary.

As illustrated in Figure 10, Sebastopol captured just $4.4 million in taxable lodging spending in the most recent four quarter period, or 0.8% of total taxable lodging sales in Sonoma County as a whole. The Barlow Hotel would likely roughly triple that transient occupancy spending and associated TOT taxes in Sebastopol.

Figure 10: Sonoma County TOT Collections by Community, Q4 2022 – Q3 2023 Source: Sonoma County Economic Development Board.

It is worth noting that Sebastopol has a large and growing restaurant industry. Restaurants and drinking places account for the largest source of taxable sales in Sebastopol, and sales have been growing steadily for several years (Figure 11). As tourists are an important market for restaurants, and culinary experiences are a key element of the Sonoma County tourism draw, Community TOT Tax rate Amount Share Amount Share
Cloverdale 10% $227,037 0.4% $2,270,370 0.4%
Healdsburg 14% $8,836,634 14.3% $63,118,814 12.1%
Petaluma 10% $3,479,985 5.6% $34,799,850 6.7%
Rohnert Park 12% $3,892,713 6.3% $32,439,275 6.2%
Santa Rosa 9% $5,985,250 9.7% $66,502,778 12.7%
Sebastopol 12% $531,512 0.9% $4,429,267 0.8%
Sonoma 13% $6,166,611 10.0% $47,435,469 9.1%
Windsor 12% $2,792,215 4.5% $23,268,458 4.5%
Unincorporated County 12% $29,730,818 48.2% $247,756,817 47.5% SONOMA COUNTY TOTAL $61,642,775 100.0% $522,021,098 100.0% TOT Revenue Taxable Lodging Sales
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Barlow Hotel Economic and Tax Impact April 22, 2024
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there is a natural synergy between the local hotel and restaurant sectors. The Barlow Hotel is likely to further enhance the economic success of Sebastopol’s restaurants by bringing additional visitors to town.

Figure 11: Sebastopol Taxable Sales by Industry Sector, 2015 – 2023* *Note: Hotels and other lodging accommodations are not subject to sales tax.

Source: California Department of Tax and Fee Information.

Conclusion
As summarized above, the Barlow Hotel project is likely to generate substantial economic and tax benefits for the City of Sebastopol. While Sonoma County has a large and vibrant accommodations industry, Sebastopol currently has a minimal presence in that industry. The City is likely to benefit substantially economically and financially with one or more hotel offerings, including the Barlow Hotel.

Regards
RRC Associates
David Becher
Director of Community and Travel Research
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D RAFT M EMORANDUM
To: Don Schwartz and Emi Theriault, City of Sebastopol
From: Jason Moody and Rosanna Ren; Economic & Planning
Systems, Inc.

Subject: Sebastopol Barlow Hotel Fiscal Impact Analysis; EPS #241116
Date: March 7, 2025
This memorandum evaluates the impact of the proposed Barlow Hotel on the City of Sebastopol’s annual General Fund budget.

Economic & Planning Systems, Inc. (EPS) prepared the analysis to support the City as it seeks to execute a Development Agreement (DA) with the project Applicant (Aldridge
Development). Among other considerations, the Applicant has requested a reduction and delay in the payment of its
development impact fee obligations, concessions it maintains will be more than offset by the substantial increase in tax benefits received by the City during hotel operations.

The EPS fiscal analysis estimates the effects of the proposed 83- room hotel project on the City’s annual budget by comparing the estimated change in General Fund revenues and expenditures.

EPS developed a model that considers the projects’ fiscal impact at stabilization, recognizing the hotel’s performance will fluctuate over time. The model is based on the most recent development program submitted by the Applicant and the City’s adopted General Fund budget for FY 2024-2025. The EPS analysis
considers two scenarios based on pending sales tax rates in Sebastopol.1
1 Measure U, passed by voters in the 2024 general election, establishes a half-cent sales tax in Sebastopol. However, this rate is pending legal review given statewide limits on sales taxation and the City may potentially be able to receive a quarter-cent sales tax revenue. The scenarios consider the halfcent and quarter-cent sales tax revenue options.

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Project Description
The proposed hotel project will be integrated into “The Barlow”, a 12-acre, mixed-use development just east of Sebastopol’s Downtown Plaza. As summarized in Table 1, current plans indicate that the Barlow Hotel will include 83 rooms with ground-floor dining and retail, meeting space, a full-service spa and fitness center, and a rooftop pool and bar. Presently, Sebastopol has only one hotel, the Fairfield Inn, located outside of the downtown area. The subject site is currently occupied by a light-industrial/office building that is leased to Guayaki. The Applicant proposes to demolish the structure and relocate the existing tenant within The Barlow.

Table 1 Summary of Proposed Development Program
Key Findings
The key findings from this analysis are described below and summarized in Table 2. All estimates are provided in 2025 dollars.

1. EPS estimates that the Barlow Hotel will generate more than $925,000 in annual net new General Fund revenues once it is fully operational.

Depending on whether a recently approved citywide sales tax measure is upheld, EPS estimates the Barlow Hotel will generate between $926,000 and $930,000 in annual net General Fund revenues. If achieved, the fiscal impact would represent a roughly five percent (5%) increase on the City’s FY 2024-2025 General Fund revenues. These impacts account for additional public service costs and deduct the net tax benefits from the existing industrial/office use. Actual fiscal impacts may vary due to the timing of Project buildout and changes in economic and budgetary conditions.

Existing Industrial / Office Space1 31,571 sq. ft.

Proposed Hotel Project
Hotel (Rooms) 83 rooms
Retail2 4,311 sq. ft.

Total Sq. Ft. 77,794 sq. ft.
[1] As reported by Costar.

Source: Costar; City of Sebastopol; Economic & Planning Systems Item Amount
[2] Includes ground floor retail, restaurant, bar, spa, pool, and other amenities, as reported by Applicant
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Table 2 Sebastopol Barlow Hotel Summary of Fiscal Impacts (2025$)

2. EPS projects the Barlow Hotel will contribute about $890,000 in transient occupancy tax (TOT) revenues to the City’s General Fund, based on the current 12 percent tax on hotel room rates. TOT revenue represents by far the most significant projected impact on the City’s General Fund from the Barlow Hotel.

Given that the Barlow Hotel is proposed as a luxury and highly amenitized boutique facility integrated into a popular downtown Sebastopol destination, and convenient access to the Sonoma wine country, it will likely command average room rates at the upper end of the market. The EPS fiscal analysis assumes an average annual room rate of $350 per night and a 70 percent occupancy rate, comparable to that of similarly positioned hotel offerings in the region. Under these assumptions, Sebastopol’s current 12 percent TOT rates would generate an estimated $891,000 in TOT revenue, approximately 87 percent of the project’s total General Fund revenue contributions. The actual TOT revenue will depend fundamentally on the execution and operation of the Barlow Hotel and regional market conditions, among other factors. Given the high level of uncertainty associated with these outcomes, EPS has taken a relatively conservative approach, applying room rates that are below the top of the market but well above the average across all hotel types in the County (estimated at $200 / night).

3. Even without any TOT revenue, the Project would still generate a positive net impact on the City’s General Fund budget.

Non-TOT General Fund revenues are expected to be between $128,000 and $132,000, about $40,000 to $44,000 greater than the expected $88,000 in General Fund expenditures (attributable primarily to increased demand on services provided by the City Police and Public Works departments). This is General Fund Existing Proposed Net
Revenues and Expenditures Industrial/Flex Hotel New
Option A - Half-Cent Sales Tax
Annual General Fund Revenues $9,000 $1,022,900 $1,013,800 Annual General Fund Expenditures $4,800 $88,400 $83,600 Annual Net Impact on General Fund $4,200 $934,500 $930,200 Option B - Quarter-Cent Sales Tax
Annual General Fund Revenues $9,000 $1,018,800 $1,009,900 Annual General Fund Expenditures $4,800 $88,400 $83,600 Annual Net Impact on General Fund $4,200 $930,400 $926,300 Values shown are rounded to the nearest hundred.

Source: Economic & Planning Systems
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partially due to the projected Barlow Hotel property assessed value, estimated to be about $35 million. At such a valuation, the City’s General Fund would receive about $54,000 annually as its share of the 1 percent property tax. Furthermore, because the proposed Barlow Hotel would be integrated within a popular retail and dining district, the City can expect to receive an estimated $32,200 to $36,200 in additional sales tax revenue.

4. The EPS estimated annual General Fund revenues generated by the Barlow Hotel, while substantial, fall well below the projections provided by the Applicant, primarily due to their more aggressive assumptions about the hotels’ operating characteristics and value.

The applicant supplied a memo prepared by their consultants (RRC Associates) showing the Barlow Hotel generating over $2 million in TOT, sales tax, and net new property tax, compared to the $973,000 calculated by EPS for the same categories. The large discrepancy stems from the generally aggressive assumptions used by RRC for room rates, visitor spending, and property valuation. For example, RRC assumed an average room rate of $575 per night (compared to $350 per night for EPS), well above the average for luxury hotels in the County (about $370 per night) and almost 3 times higher than the County average for all hotels (about $200 per night). Meanwhile, RRC’s assessed value assumption (used to calculated property tax) of about $1.1 million per room (compared to $427,000 for EPS), is significantly higher than even the most upscale properties in Sonoma County. Finally, RRC assumed that hotel guests will spend about $500 per day in Sebastopol on taxable retail, (compared to $70 by EPS), a level that will be difficult to achieve, even with the Barlow Market's more upscale options, given that guests are likely to patronize options throughout the County and beyond.

Fiscal Impact Methodology
This section describes the methodology and key assumptions used to calculate the fiscal impact of the proposed Barlow Hotel on Sebastopol’s General Fund budget once fully operational. The fiscal impact analysis identifies and estimates specific annual General Fund revenues (e.g., sales, property, and hotel taxes) and expenditures (e.g. from additional City services) that would likely be generated by the hotel.

Barlow Hotel “Service Population”
“Service Population” is a concept that allows the fiscal impacts of both residents and employees to be estimated, acknowledging that employees who work but do not live in the City do not require City services to the same degree residents. An employee is only likely to create demands on the City’s public services during work hours and therefore has a lower impact than a resident who spends most of their time in the City. In a fiscal impact analysis, the relative impacts of employment and population are compared and used to estimate the City’s service population. Table 3 provides data on the City’s existing population, jobs, and service population.

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Table 3 City of Sebastopol Demographic Assumptions
The citywide estimates of population and jobs in Sebastopol are used to estimate the Project’s service population at buildout, as shown in Table 4. For the purpose of estimating fiscal impacts, a hotel guest at the Barlow Hotel is assumed to have the same service impact as a resident in Sebastopol, while an employee is estimated to have 0.4 of the service impact, based on current job commute patterns (calculated in Appendix Table A-1).

For the baseline scenario, the number of full-time equivalent jobs generated by the current industrial / office use is estimated assuming an employment density assumption of 0.4 workers per 1,000 square feet, matching the estimate that the City has assumed for industrial land uses in nexus studies. This results in a total baseline employment of

13. Applying the employee-to-resident ratio of 40 percent results in a final baseline service population of 5.

The population of the proposed hotel is comprised of hotel guests and employees, plus employees serving the retail portion of the site. For hotel guests, EPS assumes 1.25 occupants per room and applies an occupancy rate of 70 percent. Employee density assumptions are 0.8 employees per room and 1.82 employees per 1,000 square feet, as defined by the City in its development impact fee nexus study. In total, the Project is estimated to generate a service population of 82, for a net increase of 87 over the baseline.

Sebastopol
Item Total Source
Population 7,295 Department of Finance 2024
Primary Jobs 4,277 LEHD OnTheMap 2022
Service Population 8,997 Appendix Table A-1
Source: California Dept. of Finance; Census ACS; LEHD; Economic & Planning Systems Agenda Item Number 10 Agenda Item Number: 10
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Table 4 Program Description and Service Population

Average Revenue/Expenditure Approach
There are two common ways to estimate General Fund revenue and expenditures in a fiscal impact analysis. The first method, the average revenue or expenditure approach, calculates average revenues or expenditures per the City’s current service population and applies that factor to the project’s anticipated growth in service population. For this analysis, revenues and expenditures use the City’s FY 2024-25 Adopted Budget.

Case Study Approach
The second method is a case study approach that incorporates specific assumptions or estimating factors of the development program. Revenue items estimated using a case study approach in this analysis include property tax, sales tax, transient occupancy tax, and business license tax.

Fixed vs. Variable Expenditures
Most City departments operate with some fixed amount of overhead that does not vary as the City’s service population grows or contracts. For example, even as the City grows, the City only needs one City Manager or one City Clerk. In projecting General Fund expenditures, EPS applies a percent variable factor to each General Fund department to estimate the project’s likely impact on public service costs.

EPS applies a percent variable factor to departmental expenditures to represent the proportion of expenditures that are assumed to vary and therefore would scale with increases in service population. Expenditures assumed to be fixed would include overhead costs, director salaries, or other costs that would not scale with service population and Program Occupancy
Rate
Employees
or Guests
Existing
Industrial 31,571 sq.ft. 0.4 employees/1,000 sq. ft. 100% 13 40% 5 Proposed Project
Hotel 83 rooms 1.25 occupants/room 70% 73 100% 73

0.8 employees/room 70% 46 40% 19
Retail 4,311 sq.ft. 1.82 employees/1,000 sq. ft. 95% 7 40% 3 Total 127 92
Net New 114 87
[1] Proposed development program provided in applicant submittal. Existing use sourced from CoStar. See Table 3.

Sources: City of Sebastopol; Harris & Associates; Costar; Economic & Planning Systems. [2] Employment density assumptions from impact fee nexus study completed by Harris & Associates for the City of Sebastopol (2021). Hotels occupants per room assumption from EPS. Hotel occupancy rate estimated based on the 12-month occupancy rate for comparable luxury boutique hotels in Sonoma County.
[3] Service population is calculated by adding total residential population and 40 percent of in-office employment, per Appendix Table A-1. It represents a measure of public service demand in which employees are given a fraction of the weight of residents because of more modest service demands. Hotel guests are assumed to have the same population equivalency as a resident while staying in Sebastopol.

Service
Population
Equivalency3
Total1
Estimated Total Population2
Service
Population Assumption
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therefore would be unaffected by new developments such as the Project. Typically, departments with more administrative functions have more fixed operating costs and therefore lower variable expenditures than those that provide citizen-facing services or infrastructure.

Not Impacted
Some budget items are not estimated because their revenues or expenditures are not expected to be directly or materially impacted by the Project. These include items such as intergovernmental revenues and interest revenues, as further detailed in Table 5 and Table 11.

General Fund Revenues
This section describes the methodology and assumptions used for each revenue item estimated in this analysis. Table 5 below displays a summary of Sebastopol’s General Fund revenue items based on the adopted FY 2024-2025 budget, with details on how each impacted revenue item is estimated. Several General Fund revenue items are not forecasted because the Project is not expected to affect them on an annual basis. For example, the Project will generate real property transfer taxes as a one-time revenue, so its impact is not considered for this analysis.

Charges for Services are the cost recovery revenues in the General Fund that directly offset the cost to the City of providing specific services for the user. These revenues are not forecasted for the Project but netted out of General Fund expenditures in Table 11.

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Table 5 City of Sebastopol FY 2024-25 General Fund Revenue Summary Property Tax
Property taxes are based on the assessed value (AV) of land and project improvements.

Table 6 shows the calculations of property tax and property tax in-lieu of vehicle license fees (VLF) revenue. EPS obtained the AV of the existing industrial building from the Sonoma County Assessor’s Office. The current AV of the land parcel is $3.3 million.

EPS uses a capitalized income approach to estimate a value for the proposed hotel, based on assumptions from comparable boutique luxury hotels in Sonoma County, detailed in Appendix Table A-2. The AV of the Project’s development is estimated to be about $35 million (about $427,000 per room), or an increase of $32.1 million over the current level.

Sonoma County currently collects property tax based on 1.0 percent of the assessed value, and Sebastopol receives 16.83 percent of the property tax revenue after accounting for the ERAF-shift. This share is assumed fixed going forward. The resulting property tax revenue is around $54,000, compared to $5,600 for the existing office. This is almost ten times more property tax revenue than the existing land use.

It is worth noting that the Applicant’s consultant (RRC Associates) provided an estimate of the Barlow Hotel’s expected assessed value of about $90.3 million (or about $1.1 million per room), significantly higher than the EPS assumption. RRC did not provide back FY 2024-25
Adopted Budget Table
Description Gen. Fund Revenues Reference
Property Tax $2,595,000 16.83% of 1% of base assessed value (post-ERAF) Table 6 Property Tax in Lieu of VLF $1,025,000 2.07% of Citywide assessed value increase Table 6 Sales Taxes $4,563,925 1.75% of estimated taxable sales Table 7 Transient Occupancy Tax $519,000 12% of gross room revenue Table 8 Licenses & Permits $1,442,500
Business Licenses $140,000 $3.00 per room Table 9
Business License Late Fees $2,500
Building Permits $1,300,000
User Taxes $887,175 $98.60 per service population Table 10 Franchise Fees $502,250 $55.82 per service population Table 10 Fines & Special Assessments $66,700 $7.41 per service population Table 10 Real Property Transfer Tax1 $40,000
Intergovernmental Revenues $22,890
Interest & Rents $132,250
Charges for Services2 $136,800
Miscellaneous Revenue $183,225
Cost Allocation Plan $1,761,797
Transfers In $425,951
Total Revenues $14,304,463
[1] While the City will receive transfer tax revenue from the sale and transfer of the property, it is a one-time revenue source and therefore not estimated with annual fiscal impacts.

Source: City of Sebastopol FY 2024-25 Budget; Economic & Planning Systems Not estimated
Not estimated
Not estimated
Not estimated
Not estimated
[2] Includes fees charged for cost recovery of planning, public works, and police services and netted out from General Fund expenditures in Table 11.

Impact Estimating Factors
Not estimated
Not estimated
Not estimated
Not estimated
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up data supporting this assumption and the value is significantly higher than even the most upscale hotel properties in Sonoma County.

Table 6 Property Tax and Property Tax In-Lieu of VLF Estimate Property Tax in Lieu of VLF
The Barlow Hotel would also increase City revenues from property tax in-lieu of vehicle license fees (VLF), since this general fund source also increases with assessed value (AV).

In 2004, the State of California adjusted the method for sharing VLFs with local jurisdictions. State budget changes replaced the VLF with property tax, which grows proportionate to increases in the total AV of cities and towns. Property tax in-lieu of VLF is calculated by taking the percent increase that the proposed project adds to the City’s AV and applying that percentage increase to the amount of property tax in-lieu of VLF collected in the most recent year. Assuming no other assessed value growth, the Project would increase the City’s current assessed value by 2.07 percent and result in $21,100 revenue, or $19,200 net new (Table 6).

Sales Tax
Sales tax generation for the Project is based on estimates of taxable sales generated by the new population in the City attributable to the Project. Therefore, Sebastopol would receive sales tax revenue from the spending activity of both hotel guests and employees of the proposed Project. To forecast new sales, EPS estimate spending on taxable items, and the portion of spending captured in the City. Overall, EPS estimates the proposed Barlow Hotel to generate between $32,200 to $36,200 in sales tax revenue for the City (Table 7).

Item
Property Tax
Assessed Value (Land and Improvements)1 $3,304,913 $35,416,771 Property Tax Revenue 1.0% Base Property Tax Rate $33,049 $354,168 Sebastopol City General Fund Revenue 16.83% Allocation to General Fund2 $5,561 $59,595 Net New Property Tax $54,034
Property Tax In-Lieu of VLF
Existing Citywide Property Tax In-Lieu of VLF3
Citywide Assessed Value4
Project Site Net Assessed Value Increase5 0.19% 2.07%
Net Property Tax In-Lieu of VLF Revenue6 $1,977 $21,184 Net New Property Tax In-Lieu of VLF $19,208
Existing Industrial/
Flex Facility
Sources: City of Sebastopol; Sonoma County Assessor's Office; California State Board of Equalization; Economic & Planning Systems Proposed Barlow
Assumption Hotel
See Footnote.
$1,025,000
$1,713,621,000
[1] See Appendix Table A-2 for estimation of proposed project AV. Existing FY 2024-25 AV received from Sonoma County Assessor's Office. [2] Post-ERAF allocation derived by taking the base 19.7% allocation to Sebastopol's General Fund for TRA 005-014, less 17.7% for ERAF shift derived from $2.5M total Sebastopol ERAF tax revenue divided by $17M in total city property tax collected in FY2024. [3] See Table 5.
[4] FY 2024-25 Locally Assessed Value per California State Board of Equalization. [5] Calculated by dividing the current and proposed assessed values by the citywide assessed value. [6] Calculated by multiplying existing property tax in-lieu of VLF by the project's proportionate increase to the Citywide assessed value.

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For employees in both the baseline and proposed development, sales tax is derived from an estimate of the annual taxable spending of in-office workers. EPS uses inflationadjusted worker spending data from an International Council of Shopping Centers (ICSC) survey for “Suburban Limited” geographies. Taxable spending is estimated at $71 spent per employee per week for 48 work weeks. EPS estimates a 50 percent capture rate from worker retail sales. This results in around $485 in sales tax revenue from workers in the baseline use and $2,100 from the proposed hotel.

For hotel guests, taxable spending is based on estimates from the Sonoma County Economic Development Board survey on travel impacts in the region. Taxable spending is estimated at $76 per person per day. This is applied to an average hotel guest population of 73 guests per day for 365 days. The capture rate for hotel guest spending is estimated at 75 percent, higher than the worker capture rate, due to the hotel’s proximity to the many shopping and dining options at the Barlow Market.

The City’s General Fund currently receives sales and use tax revenue equal to 1.75 percent of taxable sales (1 percent from the State’s 7.25 percent levy, and additional

0.75 percent in previously passed citywide taxes). In 2024, voters passed Measure U, which adds an additional 0.5 percent to fund citywide services. However, the City may only be to levy up to 0.25 percent to remain within the legally allowable limit on local sales taxation; the revenue may be split with the County, which also passed its own sales tax in 2024. It is pending review by the County and State.

It’s worth noting the estimates provided by the Applicant’s consultant (RRC Associates), which suggest significantly higher spending by hotel guests on taxable retail items in Sebastopol than EPS. In particular, the RRC estimates guests will spend over $1,000 per occupied room night. However, the supporting documentation for this assumption includes numerous items that are not taxable (including room costs). Even when room costs are excluded, the RRC’s estimates of $500 in retail spending per occupied room night captured in Sebastopol will be difficult to achieve given Sebastopol's retail economy, even with the Barlow Market's more upscale options, and the fact that guests are likely to patronize options throughout the County and beyond.

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Table 7 Sales Tax Estimate
Transient Occupancy Tax
The City collects transient occupancy tax on the revenue the hotel earns from room rentals based on a rate of 12 percent. EPS estimates that the Barlow Hotel’s room rates to be approximately $350 per room per night, with an average annual occupancy rate of 70 percent. This would generate TOT revenue of $891,000 per year (Table 8).

Item
Worker-Generated Retail Sales
Employee Population1 13 54
Weekly Taxable Retail Spending2 $71 per employee per workweek $897 $3,832 Annual Worker Taxable Retail Spending 48 working weeks per year $43,068 $183,934 Total Citywide Captured Worker Generated Retail Spending 50% of Retail Expenditures3 $21,534 $91,967 Hotel Guest Generated Retail Sales
Hotel Guest Population 73
Total Taxable Spending3 $76 per person per day $5,545
Annual Hotel Guest Taxable Spending 365 days per year $2,023,746 Total Citywide Captured Retail Spending 75% of Retail Expenditures3 $1,517,810 Total Citywide Retail Spending $21,534 $1,609,777
Base Retail Sales Tax Revenue5 1.75% of Taxable Sales $377 $28,171 Measure U Sales Tax Option A6 0.50% of Taxable Sales $108 $8,049 Measure U Sales Tax Option B6 0.25% of Taxable Sales $54 $4,024 Total Sales Tax Generated
Measure U Sales Tax Option A $485 $36,220
Measure U Sales Tax Option B $431 $32,196
[1] Includes employee count for both hotel and retail portions of the proposed development. [3] EPS assumption.

Source: City of Sebastopol; Sonoma County Economic Development Board; International Council of Shopping Centers; Economic & Planning Systems [4] Based on visitor spending survey data collected by the Sonoma County Economic Development Board (2023), adjusted to present-day dollars. [4] Measure U, passed in Sebastopol in November 2024, adds a half-cent sales tax on all taxable spending in the city. Pending review by the County and State, the City may only be able to levy up to a quarter-cent tax to remain with a legally allowable limit on local sales taxation. The options consider the two possible scenarios for sales tax revenue generation in Sebastopol.

Proposed Barlow
Assumption Hotel
[2] Based on ICSC survey on office worker spending for Suburban Limited geography, adjusted to present-day dollars.

Existing Industrial/
Flex Facility
See Table 4.
[5] Includes 1% Bradley-Burns base sales tax rate and 0.75% in additional citywide taxes.

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Table 8 Transient Occupancy Tax Estimate
Ultimately, the average room rate for the Barlow Hotel will depend on market conditions and its competitive position with the regional. Room rates and occupancy rates vary greatly depending on project execution, market conditions, and seasonality. To reflect this potential variability, EPS prepared a sensitivity analysis of the estimated TOT revenue the City would receive based on different room rate and occupancy assumptions, as shown in Figure 1. For example, if occupancy rates averaged 75 percent, as they did pre-pandemic in 2019, then a $300 room rate would generate $818,000 in TOT revenue.

By comparison, an average annual room rate of $350 per night with a 60 percent occupancy rate would generate $763,000 in annual TOT revenue.

Based on rates at comparable downtown-area boutique hotels in the county, EPS uses a room rate of $350 and 70 percent occupancy rate in this analysis, as illustrated in Figure

1. These assumptions, while more conservative than those provided by the Applicant, still suggest a more optimistic outlook than the current hotel market countywide. Across all Sonoma County hotel properties, room rates currently average $200 per night with 62 percent occupancy.2 For luxury-class hotels in the county, room rates are currently averaging $372 per night with 60 percent occupancy.

It is worth noting that EPS estimates are well below those provided in a study submitted to the City by RRC on behalf of the Applicant. This study estimated the Barlow Hotel 2 As reported by Costar in February 2025 for hotel properties in Sonoma County. Estimates reflect the 12- month performance trend.

Item
Total Hotel Rooms 83
Average Daily Rate (ADR)1 $350
Occupancy Rate2 70%
Annual Hotel Room Revenues $7,422,275
General Fund TOT Revenue 12% of Revenue3 $890,673
Source: City of Sebastopol; CoStar; Economic & Planning Systems [3] City of Sebastopol Municipal Code Ch. 3.12
Proposed Barlow
Assumption Hotel
[1] EPS estimate based on ADR rates from comparable luxury-class hotels in Sonoma County. [2] Occupancy rate for Sonoma County luxury-class hotels, retrieved from Costar. a
b
c
a * b * c * 365
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would achieve an average daily rate (ADR) of $575 and occupancy rates of 70 percent.

EPS was unable to independently verify or replicate these estimates and the RRC study does not provide detailed documentation. However, EPS review of this study suggests that these estimates are based on luxury hotel properties in Sonoma County with different amenities and room formats than the proposed hotel’s. For example, in Sonoma and Napa counties, vineyard resort properties that are situated in more rural settings and offer villa-style accommodations generally attract higher room rates than upscale hotels in downtown settings.

Figure 1 Barlow Hotel TOT Revenue Scenarios
Source: Economic & Planning Systems, RRC Associates
Business License Tax
The Project is expected to pay an annual business license tax, which for hotels includes a base rate of $60 for the first four rooms and $3 for each additional room, up to a maximum of $112.50. The retail portion of the Project for an estimated seven employees would pay a tax of $135. Combined, this amount is $308 per year, compared to an estimated $200 paid by the existing use (Table 9).

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Table 9 Business License Fee
Other Revenues
User taxes, franchise fees, and fines are calculated using the average revenue approach.

Together, these are estimated to be around $162 per service population (Table 10). The Project would generate a combined $15,000 from these other revenues, compared to $810 in the baseline use.

Table 10 Other Service Population-based General Fund Revenue Estimates Category Assumption
General License1
Employee Population See Table 4. 13 7
Fee
1 to 3 persons $90
4 to 7 persons $135 $135
8 to 14 persons $200 $200
15+ persons $140
Rental Units (incl. Hotels)2
Hotel Base Fee (first four rooms) $60 $60
Additional Fee per Room $3
Number of Additional Rooms 79
Additional Fee Based On Room Count $237
Maximum of $112.50 $112.50 $113
Total Annual Business License Fee Revenue $200 $308
Source: City of Sebastopol; Economic & Planning Systems [2] For rental units in excess of four units, the fee is $3 per additional room not to exceed a total of $112.50. For the proposed project, the maximum additional fee is added to the hotel base fee and the General License business fee. [1] General License Business License Fee applies to retailing, wholesaling, maufacturing, processing, and services. For the proposed project, the fee is based on employee count of the retail portion only.

Existing Industrial/
Flex Facility
Proposed Barlow
Hotel
FY 2024-25
Item GF Revenues1
City Service Population2 8,997 Service Pop.

Project Service Population 5 92
User Taxes $887,175 $98.60 per service population $493 $9,072 Franchise Fees $502,250 $55.82 per service population $279 $5,136 Fines & Special Assessments $66,700 $7.41 per service population $37 $682 Total $161.84 per service population $809 $14,889
[1] See Table 5.
[2] See Table 2.

Source: Economic & Planning Systems
Proposed Barlow
Assumption / Estimating Factor Hotel
See Table 4.

Existing Industrial/
Flex Facility
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General Fund Expenditures
This section describes the methodology and key assumptions for calculating General Fund expenditure items. All Departments consist of both fixed and variable costs. While fixed costs are independent of new development, variable costs are assumed to increase based on added growth in the City. Only variable costs are used to project the General Fund expenditures in this analysis.

Table 11 shows the City’s FY 2024-25 General Fund Expenditures by category and its associated percent variable assumption, which determines the cost per service population. This cost is applied to the Project’s anticipated service population to estimate its annual General Fund expenditures in Table 12. Some expenditures are not impacted as they are not expected to change with service population. For example, EPS assumes that most hotel guests will not use City services like the Senior Center or Ives Pool.

Therefore, these costs are not impacted by the project’s service population growth. Fire & Prevention expenditures are also not estimated as the City is currently undergoing fire district consolidation; thus, future fire costs will be separated from the City’s budget.

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Table 11 City of Sebastopol FY 2024-25 General Fund Expenditures Summary and Estimates Percent Annual Variable Per Service Pop.

Item Total Offsetting1 Net Variable2 Expenses GF Expense General Government $3,413,104 $6,000 $3,407,104 25% $851,776 8,997 Service Pop. $94.67 City Council $198,625 $198,625
City Manager $698,885 $698,885
City Attorney $647,900 $647,900
City Clerk $430,771 $430,771
Finance $1,436,923 $1,436,923
Planning $616,426 $40,000 $576,426 75% $432,320 8,997 Service Pop. $48.05 Building $302,220 $302,220 75% $226,665 8,997 Service Pop. $25.19 Engineering $553,020 $31,000 $522,020 75% $391,515 8,997 Service Pop. $43.51 Police $5,366,488 $31,300 $5,335,188 100% $5,335,188 8,997 Service Pop. $592.97 Public Works $1,769,079 $7,500 $1,761,579 80% $1,409,263 8,997 Service Pop. $156.63 Fire & Prevention3 $1,535,910 $1,535,910 - - -
Senior Center4 $41,038 $41,038 - - -
Community Center4 $169,724 $169,724 - - -
Ives Pool4 $297,301 $297,301 - - -
Non-Departmental $191,645 $191,645 - - -
Debt Service Payments $446,094 $446,094 - - -
Transfers Out $300,000 $300,000 - - -
Total $15,002,049 $115,800 $14,886,249 $961.03
[1] Offsets applicable Charges for Services shown in Table 5, including finance fees, planning fees, public works, and police services. [4] EPS assumes that hotel guests will not use these City services and costs will not be impacted by service population growth.

Source: City of Sebastopol FY 2024-25 Budget; Economic & Planning Systems Estimating
Factors
[2] The variable percents included within this column represent the proportion of department expenditures that are not assumed to be fixed and therefore would scale with increases in service population. Expenditures that are assumed to be fixed would include overhead costs, director salaries, and other costs that would not scale with service population. not impacted
not impacted
not impacted
not impacted
not impacted
not impacted
FY 2024/25 Adopted GF Expenditures
not impacted
[3] Not estimated due to future fire district consolidation.

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Table 12 General Fund Expenditures Estimates
General Government
In Sebastopol, the General Government category includes the following functions, as defined by EPS:
• City Attorney
• City Clerk
• City Council
• City Manager
New development of the Project’s scale typically affects administrative and legislative government costs by only a fraction of these departments’ operating budgets. As a result, EPS assumes that 25 percent of the cost of General Government services is variable and affected by growth in service population. This yields a per service population estimate of about $94.67. The resulting expenditure for General Government departments is therefore estimated at about $8,700 annually at Project buildout compared to about $500 under the baseline.

Planning, Building, and Engineering
These departments provide Sebastopol with services like development review, building code compliance, and engineering support. For the Planning, Building, and Engineering departments, EPS assumes that their costs are 75 percent variable and yield a perservice population estimate of the following:
• Planning: $48.05
• Building: $25.19
• Engineering: $43.51
In total, these expenditures at buildout sum to about $10,700 for the proposed Project compared to about $600 under the baseline.

Item
Service Population 5 92
Estimated Expenditures
General Government1 $94.67 per service population2 $473 $8,710 Planning $48.05 per service population2 $240 $4,421
Building $25.19 per service population2 $126 $2,318
Engineering $43.51 per service population2 $218 $4,003
Police $592.97 per service population2 $2,965 $54,553
Public Works $156.63 per service population2 $783 $14,410 Total General Fund Expenditures $961.03 per service population2 $4,805 $88,415 [2] See Table 11.

Source: Economic & Planning Systems
Factors Applied to Estimate Proposed Barlow
Project Expenditures Hotel
[1] General Government is EPS-defined and includes City Council, City Manager, City Attorney, City Clerk, and Finance.

Existing Industrial/
Flex Facility
See Table 4.

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Police
Sebastopol’s Police Department provides a number of essential public safety services. The Police Department receives the largest General Fund allocation of $5.4 million in the FY 2024-25 budget. While there are some fixed administrative services, police costs are largely expected to scale closely with population growth. Therefore, the Police Department receives a greater percent variable expenditure estimate of 100 percent.

Using the per-service population estimate of $592.97, Police expenditures at buildout are projected to be $55,000. The baseline scenario has an estimated $3,000 in Police costs.

Public Works
Public Works provides maintenance of streets, parks, and parking lots. The Department’s costs are assumed to scale closely with changes in service population and are therefore given a variable expenditure assumption of 80 percent. Additional population attributable to the Project will add additional wear on Public Works’ maintained infrastructure and facilities.

The Public Works department receives approximately $1.8 million from the General Fund.

This total is multiplied by the 80 percent variable assumption, resulting in an annual perservice population expenditure of $156.63. This equates to an estimated $783 in annual General Fund expenditure under the baseline, increasing to $14,400 under Project buildout.

Net Annual Fiscal Impact on General Fund
Based on the assumptions and analysis described above, development of the proposed Barlow Hotel is estimated to result in annual net new fiscal revenue of approximately $926,000 to $930,000, depending on the Measure U sales tax rate. Under a 0.5-cent sales tax scenario (Option A in Table 13) the hotel is only expected to generate about $4,000 more than the 0.25-cent sales tax scenario (Option B). Rather, it is the addition of TOT from the hotel project that contributes most of the new General Fund revenue, around 87 percent of the total revenue generated by the Proposed project. Among General Fund costs, Police make up the greatest portion (62 percent), followed by Public Works (16 percent).

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Table 13 Detailed Summary of Fiscal Impacts (2025$)

General Fund Revenues and Expenditures
Annual General Fund Revenues
Property Tax $5,561 $59,595
Property Tax In-Lieu of VLF $1,977 $21,184
Sales and Use Tax (Option A) $485 $36,220
Option B $431 $32,196
User Taxes $493 $9,072
Transient Occupancy Tax $0 $890,673
Franchise Fees $279 $5,136
Licenses & Permits - Business Licenses $200 $308
Fines & Special Assessments $37 $682
Total Annual General Fund Revenues (Option A) $9,032 $1,022,869 Option B $8,978 $1,018,845
Annual General Fund Expenditures
General Government1 $473 $8,710
Planning $240 $4,421
Building $126 $2,318
Engineering $218 $4,003
Police $2,965 $54,553
Public Works $783 $14,410
Total Annual General Fund Expenditures $4,805 $88,415
Annual General Fund Net Impact (Option A) $4,227 $934,455 Option B $4,173 $930,430
Net New GF Fiscal Impact from Project (Sales Tax Option A) $930,228 Option B $926,258
Source: Economic & Planning Systems
[1] Option A adds a half-cent sales tax in the City of Sebastopol. Option B adds a quarter-cent sales tax. [2] General Government includes City Council, City Manager, City Attorney, City Clerk, and Finance.

Existing Industrial/ Flex
Facility Proposed Barlow Hotel
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APPENDIX A
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Appendix Table A-1 Service Population Factors based on Resident-to-Employee Equivalencies Item # %
Employment Status of
Sebastopol Residents1 Formula: a = b * 7,295 b 1 c = b * c Not in Labor Force 4,345 59.6% 100% 59.6%
Employed in the City3 331 4.5% 50% 2.3%
Employed Outside of the City 2,619 35.9% 67% 24.1%
Total Residents 7,295 100.0% 85.9%
Residence Status of Sebastopol
Employees1 Formula: a = b * 4,277 b 1 c = b * c
Live in the City3 331 7.7% 50% 3.9%
Live Outside the City 3,946 92.3% 33% 30.3%
Total Jobs 4,277 100.0% 34.2%
Employee to Resident Equivalency Factor 4 (34.2% / 85.9%) = 39.8% Service Population Calculation
Amount Attributable to Residents (@ 100%) 7,295 81.1%
Amount Attributable to Employees (@ 39.8%) 1,702 18.9%
Total Service Population 8,997 100.0%
Sources: LEHD OnTheMap 2022, Department of Finance, and Economic & Planning Systems, Inc. [1] Distribution and total jobs based on data from U.S. Census (OnTheMap 2022). Total residents based on 2024 estimates provided by DOF in Table E-5.
[2] Represents EPS estimate of how various types of residents and employees relate to each other in terms of demand for City Services. [3] The number of residents who are employed in the City and the number of employees in the City who are residents are the same, representing the same group of unique individuals. This group is reflected both in the Total Residents and the Total Jobs to demonstrate the composition of the totals, with their weighting split evenly between the resident and employee groups. [4] Equals weighted average of residents divided by weighted average of employees.

Existing Weight2 Weighted
Average
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Appendix Table A-2 Estimated Assessed Value for Proposed Barlow Hotel Item Total
Number of Rooms 83 rooms
Gross Potential Room Revenue1 $350 ADR $10,603,250
(less) Vacancy2 30% average vacancy ($3,180,975)
Net Room Revenue $7,422,275
Restaurant and Retail Square Footage 4,311 sq. ft.

Restaurant and Retail Revenue3 $250 per sq. ft. $1,077,750 (less) Operating Expenses4 70% of room & retail revenue ($5,950,018) Total Annual Net Operating Income $2,550,008
Total Proposed Development New Assessed Value 7.20% Cap Rate5 $35,416,771 AV per room $426,708
[2] See Table 4.

Assumption/Source
[1] EPS estimate based on ADR rates from comparable luxury hotels in Sonoma County. See Table 8. [3] EPS assumption.
[5] Cap rate for upscale and luxury hotels in Sonoma County as reported by Costar. [4] EPS assumption.

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FEASIBILITY STUDY
Proposed Hotel Barlow
6770 MCKINLEY STREET

SEBASTOPOL, CALIFORNIA
SUBMITTED TO:PR OPOSED
Mr. Barney Aldridge
Aldridge Development
6780 Depot Street #110
Sebastopol, California 95472
+1 (707) 484-8020
PREPARED BY:

HVS Consulting & Valuation
Division of TS Worldwide, LLC
1733 Woodside Road, Suite 210
Redwood City, California 94061
+1 (281) 381-3456
June-2024
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August 12, 2024
Mr. Barney Aldridge
Aldridge Development
6780 Depot Street #110
Sebastopol, California 95472
Re: Proposed Hotel Barlow
Sebastopol, California
HVS Reference: 2024020454
Dear Mr. Aldridge:

Pursuant to your request, we herewith submit our feasibility study pertaining to the above-captioned property. We have inspected the real estate and analyzed the hotel market conditions in the Sebastopol, California, area. We have studied the proposed project, and the results of our fieldwork and analysis are presented in this report.

We have also reviewed the proposed improvements for this site. This report is not an appraisal but has been prepared in accordance with the Uniform Standards of Professional Appraisal Practice (USPAP), as provided by the Appraisal Foundation and as applicable for this consulting assignment.

We hereby certify that we have no undisclosed interest in the property, and our employment and compensation are not contingent upon our findings. This study is subject to the comments made throughout this report and to all assumptions and limiting conditions set forth herein.

Sincerely,
TS Worldwide, LLC
John Berean
Senior Vice President
Hawaii & Northern California Region Leader
[email protected], +1 (281) 381-3456

HVS SAN FRANCISCO
1733 Woodside Road, Suite 210
Redwood City, California 94061
+1 (281) 381-3456
www.hvs.com
Superior results through unrivaled
hospitality intelligence. Everywhere.

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Executive Summary
Proposed Hotel Barlow – Sebastopol, California 4

1. Executive Summary
The subject of the feasibility study is a site measuring 50,530 square feet (1.16 acres) that is planned to be improved with a full-service, boutique lodging facility; the hotel is anticipated to operate independent of a brand affiliation. The property, which is expected to open on January 1, 2027, will feature 83 rooms, a restaurant & bar, and a rooftop bar, 3,200 square feet of meeting space, a rooftop pool, a fullservice spa, a fitness center, and a retail outlet/boutique. The hotel will also contain the appropriate parking capacity and all necessary back-of-the-house space.

RENDERING OF PROJECT
The Barlow is a twelve-acre, mixed-use development located just east of Sebastopol’s Downtown Plaza and features distilleries, breweries, wineries, restaurants, eateries, and retail boutiques. The abundant landscaped outdoor spaces and collaborative environment have made The Barlow highly desirable for prospective tenants, thereby allowing rent to be at a premium compared to other markets. The Barlow offers free parking and regularly hosts public events, such as live music performances and tasting tours. The proposed subject hotel is expected to elevate The Barlow as a destination for tourists and groups visiting Sonoma County by allowing them convenient access to explore the vibrant local community.

The subject site’s location is 6770 McKinley Street, Sebastopol, California 95472.

Subject of the
Feasibility Study
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Executive Summary
Proposed Hotel Barlow – Sebastopol, California 5
The effective date of the report is August 12, 2024. The subject site was inspected by Jason Lee and John Berean on April 2, 2024. In addition to the inspection, Jason Lee participated in the research for this assignment and assisted in the report’s preparation. John Berean participated in the analysis and reviewed the findings.

The developer of the proposed subject hotel is Aldridge Development. As mentioned previously, the subject site is currently improved with a light-industrial/office building that is leased to Guayaki. The tenant will be relocated within The Barlow, and the existing structure will be demolished as part of the proposed subject hotel's development.

Details pertaining to management terms were not yet determined at the time of this report; however, we assume that the proposed hotel will be managed by a professional hotel-operating company, with fees deducted at rates consistent with current market standards. Our projections reflect a total management fee of 3.0% of total revenues.

The proposed hotel will reportedly remain independently operated throughout the forecast period; therefore, it will not be subject to franchise fees.

Our supply and demand analysis comprises all hotels identified by STR, both reporting and non-reporting, located in West Unincorporated Sonoma County and the City of Sebastopol. West Unincorporated Sonoma County includes the following cities, towns, and census-designated places: Bodega Bay, Forestville, Guerneville, Jenner, Monte Rio, Occidental, The Sea Ranch, and Sebastopol. We note that the Vintners Resort was included in this sample given its location in Unincorporated Sonoma County, although the hotel's civic address is in Santa Rosa. Our analysis incorporates estimates of market demand and rooms revenue based on our review of an STR Trend comprising all reporting properties in West Unincorporated Sonoma County, historical transient occupancy tax data for Unincorporated Sonoma County and Sebastopol, and STR data for the entirety of Sonoma County.

In the latter years of last decade, occupancy ranged from 71.0% to 76.0%, with ADR having surpassed the $238 mark in 2019, as the market benefited from the increase in discretionary spending and the economic expansion in the San Francisco Bay Area. We note that wildfires influenced the market between 2017 and 2020, and flooding along the Russian River also affected lodging demand in 2019. In March 2020, the COVID-19 pandemic began to affect the local market, similar to the rest of the nation, resulting in decreased business activity, inclusive of the hospitality, tourism, and wine-making industries; leisure travel was suspended in Sonoma County between late March and mid-June. While visitor volume to Sonoma Valley began to improve in the summer, the Glass Fire in September significantly affected the market. Tourism was again suspended in December 2020, as a temporary stayPertinent Dates Ownership of the
Subject Site
Management and
Franchise Assumptions
Summary of Hotel
Market Trends
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Executive Summary
Proposed Hotel Barlow – Sebastopol, California 6
at-home order was issued for the greater San Francisco Bay Area; however, a rebound commenced in 2021, with the occupancy increasing through 2022.

Heightened inflation, strong pent-up demand for drive-to leisure destination markets, and local hoteliers' commitment to maintaining rate integrity contributed to a full recovery in ADR in 2021 and continued growth in 2022.

Year-end 2023 data illustrate occupancy just under the 60.0% mark. Local hoteliers note that demand has contracted somewhat because of an increase in travel to European destinations following the removal of all pandemic-related restrictions.

As a result, ADR growth began to normalize, declining from the heightened levels of years prior, but remaining nevertheless favorable in 2023. In 2022, market RevPAR well surpassed the pre-pandemic levels, peaking above the $200 mark, in line with the corresponding high ADR for the year, but then decreased accordingly in 2023.

In general, the near-term outlook for the competitive market is cautious given the recent moderation in RevPAR. However, the long-term outlook is optimistic because of the region's popularity as a destination market, its proximity to the San Francisco Bay Area, and its high barriers to entry.

The following table provides a historical perspective on the supply and demand trends for West Sonoma County.

FIGURE 1-1 HISTORICAL SUPPLY AND DEMAND TRENDS
Year
Average Daily
Room Count
Available
Room Nights Change
Occupied
Room Nights Change Occupancy
Average
Rate Change RevPAR Change
2016 1,042 380,330 — 282,139 — 74.2 % $215.74 — $160.04 — 2017 1,042 380,330 0.0 % 286,859 1.7 % 75.4 225.80 4.7 % 170.31 6.4 % 2018 1,076 392,740 3.3 298,600 4.1 76.0 236.77 4.9 180.02 5.7 2019 1,076 392,740 0.0 278,958 (6.6) 71.0 238.86 0.9 169.66 (5.8) 2020 1,076 392,740 0.0 206,677 (25.9) 52.6 200.69 (16.0) 105.61 (37.8) 2021 1,076 392,740 0.0 241,896 17.0 61.6 304.88 51.9 187.78 77.8 2022 1,076 392,740 0.0 248,484 2.7 63.3 316.40 3.8 200.18 6.6 2023 1,076 392,740 0.0 228,650 (8.0) 58.2 301.90 (4.6) 175.76 (12.2) Average Annual Compounded Change:
2016 – 2019 1.1 % (0.4) % 3.5 % 2.0 %
2016 – 2023 0.5 (3.0) 4.9 1.3
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Executive Summary
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FIGURE 1-2 HOTELS INCLUDED IN WEST SONOMA COUNTY
Location Hotels Included in Sample Class
Bodega Bay The Lodge at Bodega Bay Luxury Class 83 1960 Bodega Bay Bodega Harbor Inn Economy Class 17 1941
Bodega Bay Bodega Coast Inn Upscale Class 44 1987
Bodega Bay The Inn at the Tides Upscale Class 86 1984
Bodega Bay Sonoma Coast Villa Upper Upscale Class 19 1992 Bodega Bay Bodega Bay Inn Upscale Class 14 1977
Forestville Farmhouse Inn Luxury Class 25 2009
Guerneville West Sonoma Inn & Spa Upper Midscale Class 34 1948 Guerneville The Creekside Inn Upscale Class 28 1939
Guerneville The Stavrand Luxury Class 21 1922
Guerneville Fern Grove Cottages Upscale Class 21 1940
Guerneville Dawn Ranch Luxury Class 73 1905
Guerneville Cottages on River Road Midscale Class 19 1935 Guerneville The Woods Hotel Upscale Class 19 1951
Guerneville Boon hotel and spa Upscale Class 15 1957
Guerneville Highlands Resort Economy Class 17 1948
Guerneville R3 Hotel Economy Class 23 1930
Guerneville The Rio Nido Lodge Economy Class 8 1935
Guerneville Johnson's Beach Economy Class 14 1950
Guerneville Surrey Resort Russian River Upper Upscale Class 31 1948 Guerneville The Guerneville Lodge Upscale Class 12 1945 Guerneville AutoCamp Russian River Upscale Class 34 2018 Jenner Timber Cove Resort Luxury Class 46 1963
Jenner Ocean Cove Lodge Midscale Class 16 1962
Jenner Jenner Inn Upper Upscale Class 18 1962
Jenner Fort Ross Lodge Upscale Class 22 1982
Monte Rio Casa Secoya Upscale Class 26 1977
Monte Rio Highland Dell Lodge Upper Midscale Class 13 1906 Monte Rio Rio Villa Beach Resort Economy Class 12 1946
Monte Rio Boho Manor Upscale Class 14 1905
Occidental Occidental Lodge Economy Class 24 1860
Occidental Inn @ Occidental Upper Upscale Class 18 1860 The Sea Ranch The Sea Ranch Lodge Upper Upscale Class 19 1965 Santa Rosa Vintners Resort Luxury Class 78 1984
Sebastopol Fairfield Inn & Suites Santa Rosa Sebastopol Upper Midscale Class 82 1998 Sebastopol Sebastopol Inn Upper Midscale Class 31 1999
1,076
Year
Opened
Source: STR
Number
of Rooms
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Executive Summary
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We have identified seven luxury hotels in Sonoma County that are anticipated to be fully competitive with the Proposed Hotel Barlow. These primary competitors are listed in the following table.

Sebastopol City CouncilApril 15, 2025

Sebastopol City Council
April 15, 2025