St. Helena City Council
May 1, 2023

4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-86
Although Canada geese may periodically forage on the Project site, it is unlikely that the approximately 9.7 acres of mowed annual grassland without a nearby open water area represents critical foraging habitat for this highly adaptable species. This species is not a federal or state protected species but they are protected under the Migratory Bird Treaty Act, as are all migratory birds. Canadian geese are regionally abundant and have become resident in many areas (Mowbray et al. 2020)8. 14-4 The comment asserts that the Project would remove habitat and that reducing glare would only be valid mitigation measure for areas that retain habitat value.

The comment is correct and mitigation measure BIO-3 requires wetland permits (e.g., 404 Nationwide Permit, 401 Water Quality Certification, and 1602 Streambed Alteration Agreement, respectively) be obtained prior to any grading work to ensure no net loss of wetlands or other protected waters. This mitigation focuses on reducing operational indirect impacts to the riparian corridor such that it will continue to provide habitat after Project development. Refer to Response to Comment 14-3 regarding impacts to Canada geese.
14-5 The comment notes again that the Project would adversely affect Canada geese that may stopover to forage on the Project site.

Please refer to Response to Comment 14-3.
14-6 The comment summarizes the points raised in Comments 14-2 through 14-4.

Please refer to Responses to Comments 14-2 through 14-4. 14-7 The comment states the analysis of water impacts is long and difficult to follow and requests the City consider how to make future EIRs easier to understand.

The commenter’s request is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. 14-8 The comment refers to data presented in Table 3.13-8 of Section 3.13, Utilities and Service Systems, of the Draft EIR that references the City’s water supply and demand usage.

The comment provides an introduction to the following comments. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. Please refer to Response to Comment 14-9 that addresses water supply and demand.
8 Mowbray, T. B., C. R. Ely, J. S. Sedinger, and R. E. Trost (2020). Canada Goose (Branta canadensis), version

1.0. In Birds of the World (P. G. Rodewald, Editor). Cornell Lab of Ornithology, Ithaca, NY, USA. https://doi.org/10.2173/bow.cangoo.01
Agenda Item #5.8.

4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-87
14-9 The comment suggests that the City’s 2010 Water Supply Plan is inadequate and that the referenced long-term safe yield of 1,950 acre-feet does not consider climate changes since that plan was completed.

The City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code requires that "new development" shall be contingent upon the ability of the City to provide water without exceeding safe yield. In December 2010, the City Council appointed the Safe Yield Committee to determine the annual safe yield of the City’s potable water system. The ultimate goal of the Committee was to determine whether, at the present time, potable water usage was below, above, or equal to the safe yield of the potable water supply system. The Safe Yield Committee analyzed the reliability of the City’s water supplies in a 2010 study and determined that providing a total supply of up to 1,950 acre-feet was sustainable and has been adopted by the City as a policy limit. While climate change can create drier years in which precipitation is below annual averages, it can also result in very wet years.

The purpose of establishing a safe yield considers that precipitation can and likely will vary considerable from year to year and periods of extended droughts will occur.

Note that St. Helena Municipal Code (SHMC) Title 13 - Public Services, Chapter 13.04 Water Service System, Article 2 Water Shortage Emergencies, Drought and Water Conservation regulate the establishment of water emergency phases, water conservation, and regulations that can adapt to changing conditions and enact emergency requirements for users as appropriate. However, the main purpose for providing this information (i.e., the safe yield) is provided as part of establishing existing conditions and background for the City water supplies and policy limits adopted by the City. The Draft EIR analyzes the potential effects of the Proposed Project including its specific water demand and whether there would be a significant impact due to the effects of the Project. This analysis is included beginning on page 3.13-31 as well as on page 3.9-40 and compares the proposed demand by the Project against the past actual demand numbers for the City compared to the adopted policy limits. Please see also Master Response 2 that addresses water issues.
14-10 The comment challenges the conclusion made in the Draft EIR that water demands for the City are on a downward trend.

The commenter suggests that viewing data from between 2015 and 2020 instead of between 2013 and 2020, as presented in Table 3.13-1 in Section 3.13, Utilities and Service Systems, of the Draft EIR would change the conclusion of the recent trend.

As shown in Table 3.13-1 of the Draft EIR, the City’s water deliveries have varied from year to year but overall have decreased from 1,882 acre-feet in 2013 to 1,629 acre-feet in 2020. Looking at the longer trend from 2013 to 2020, instead of just from 2016 to 2020, reflects a downward trend in water deliveries. Please see also Master Response 2 that addresses water issues.

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14-11 The comment suggests that there is insufficient evidence to support the conclusion that water offsets or in-lieu payments would help limit water demands below 1,950 acre-feet.

The analysis on page 3.13-24 of the Draft EIR shows how the Proposed Project’s indoor water demands of 19.88 acre-feet would not combine with the highest City demand over the last 8 years (1,882 acre-feet) to be above the policy limit of 1,950 acre-feet. The 1,950 acre-feet figure represents what the City considers to be the safe yield for the water supply system and is not a “supply limit”. Note that St. Helena Municipal Code Title 13 - Public Services, Chapter 13.04 Water Service System, Article 2 Water Shortage Emergencies, Drought and Water Conservation regulate the establishment of water emergency phases, water conservation, and regulations that can adapt to changing conditions and enact emergency requirements for users as appropriate.
14-12 The comment concerns the validity of the City’s use of a safe yield of 1,950 acre-feet in the face of climate change.

As discussed in Response to Comment 14-9, the City is currently using the safe yield of 1,950 acre-feet developed by the Safe Yield Committee as a guideline policy but can also impose emergency measures (St. Helena Municipal Code Title 13, Chapter

13.04, Article 2) that can be used to emplace water conservation and regulations as necessary. The Project is also required to adhere to the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. As discussed in more detail on page 3.13-31 of the Draft EIR, a Water Neutral Report (Appendix J) was prepared for the Proposed Project (required by the City) to demonstrate compliance with the City’s Water Neutral Policy by providing in-lieu fees to fund conservations measures that offset the water demands of the Project. Therefore, the City’s safe yield value of 1,950 acre-feet is not the sole basis of the analysis as to whether the Proposed Project would have a significant effect on water supply during dry and critically dry years.

Please see also Master Response 2 that addresses water issues. 14-13 The comment takes issue with the effectiveness of the City’s Water Neutral Policy and how it is used in the analysis of the Project’s water demand.

Adherence to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code to fund such measures as fixing an existing leaking water conveyance pipe does offset demand by increasing water supplies compared to the existing conditions of water losses due to the leak. As a result, compliance with the Water Neutral Policy offsets new water demand with measures that reduce demand elsewhere or otherwise increase water supplies. Therefore, the City’s Water Neutral Policy and Municipal Code requirements is an appropriate and effective measure to include in the analysis of the Draft EIR. Please see also Master Response 2 that addresses water issues.

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4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-89
14-14 The comment suggests that the offset program [Water Neutral Policy] does not work as evidenced by an increase in the water demands in 2016 (1,465 acre-feet) as compared to 2020 (1,629 acre-feet).

As shown in Table 3.13-1 of the Draft EIR, the City’s water deliveries have varied from year to year but overall have decreased from 1,882 acre-feet in 2013 to 1,629 acre-feet in 2020. Looking at the longer trend from 2013 to 2020, instead of just from 2016 to 2020, indicates a downward trend in water deliveries. See also Master Response 2 that addresses concerns associated with available water supplies. 14-15 The comment suggests that "reasonably foreseeable future development” was not adequately considered in the analysis of Impact 3.13-2.

The analysis of Impact 3.13-2 beginning on page 3.13-31 of the Draft EIR, includes discussion of the long-term safe yield that was adopted by the City in 2011 that would apply to all future development. The analysis also discusses how future development is required to adhere to the state’s CalGreen requirements, as well as the City’s MWELO irrigation requirements for landscaping. In addition, all reasonably foreseeable future development would be required to adhere to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code and any emergency water conservation phases that may be enacted. In particular, the Water Neutral Policy requires that the Project, as well as reasonably foreseeable future development, must demonstrate a quantitative analysis of the Project’s water demand. For offsite improvements, the required number of retrofits have to be completed prior to the issuance of a certificate of occupancy for the new development. Inclusion of these regulatory requirements demonstrates how the Project, along with reasonably foreseeable future development would not significantly impact water supplies during normal, dry, and multiple dry years. 14-16 The comment claims that the water supply and demand analysis is insufficient, does not consider climate change, and that the water offsets required for the Project to be water neutral will not be realized.

As referenced in Response to Comment 14-9, the City adopted the safe yield as policy but also included conservation measures that can be employed during drought periods. The safe yield considers that multiple dry years are likely due to climate change and the additional measures as well as the Water Neutral Policy and Municipal Code requirements can be effective tools to adapt to variances in precipitation that is expected under normal conditions as well as what can be anticipated with climate change. Data documenting the City’s water deliveries since 2013, not long after adopting the Safe Yield Committee’s report as policy, indicates that a downward trend has occurred despite covering some very dry years during that timeframe. See also Master Response 2 that addresses water supply.

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4 – Response to Comments
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14-17 The comment recommends that the City re-evaluate the safe yield policy and get past the current emergency restrictions prior to approval of the Project.

The comment does not directly address the adequacy of the Draft EIR, but rather makes suggestions for the City related to its policies regarding water supply management. As detailed in the Draft EIR on page 3.13-3 in Table 3.13-1, the City’s water deliveries have been on a downward trend from 2013-2020. Through this period, the water deliveries have been below the safe yield and as noted on page 3.19-40 of the Draft EIR, the groundwater Subbasin, one of the sources of water supply, was recently found to be exhibit stable groundwater levels. The emergency restrictions have been enacted in order to continue effectively manage the water supply system during periods of low rainfall and combined with the Water Neutral Policy and Municipal Code requirements ensures that water supplies will meet demand.
14-18 The comment addresses cumulative traffic conditions in the City and notes that because the Project would result in a significant and unavoidable impact related to Vehicle Miles Traveled, the City should delay consideration of the Project until the underlying traffic and infrastructure issues are addressed.

The commenter’s opinion that approval of the Project should be delayed is noted and forwarded to the decision makers for their review.
14-19 The comment provides the commenter’s perspective on the City’s decision to construct a levee and floodwall along a portion of the Napa River.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration.

Please see Master Response 3 that addresses the history of the levee and floodwall. 14-20 The comment states that a scientific analysis of the effects of climate change on water supply need to be addressed along with an assessment of future development on water supply and traffic and the City’s Water Neutral Policy needs to ensure projects offset their water demand and not just pay a fee.

The comment does not identify any specific issues with the accuracy or adequacy of information provided in the Draft EIR. Regarding climate change, the Draft EIR evaluates the Project’s increase in greenhouse gas emissions (GHG) which contribute to global climate change in Section 3.7, Greenhouse Gases. The analysis reflects what the California Environmental Quality Act or CEQA requires be evaluated which includes quantifying the Project’s GHG emissions to determine if the Project exceeds adopted thresholds. The Project’s increase in demand for water is evaluated in Section 3.13, Utilities and Service Systems and traffic is evaluated in Section 3.14, Transportation and Circulation. The commenter’s opinion that the City’s Water Neutral Policy including Chapter 13.12, Water Use and Efficiency of the Agenda Item #5.8.

4 – Response to Comments
Hunter Subdivision Project EIR 10839
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Municipal Code needs to be reconfigured is noted and forwarded to the decision makers for their consideration.
14-21 The comment expresses an opinion that EIRs should not rely on old or incomplete data and residents of the City versus out of town developers need to be considered when making land use decisions.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.

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Response to Letter 15
Andree Bryan
October 30, 2021
15-1 The comment states a concern related to water availability. The comment also states opposition against the Project’s proposed water sharing component with Vineyard Valley.

Please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
15-2 The comment expresses concern over the Project’s impact on traffic.

Please see Response to Comment 10-2 that addresses traffic concerns. 15-3 The comment expresses concern regarding the Project's impact on the adjacent walking trail.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Response to Comment 106-3.

In addition, please see Chapter 3, Changes to the Draft EIR, for a new figure that shows the adjacent trails.
15-4 The comment states that the commenter has not obtained access to the Project’s “environmental impact study.”
The City sent notices to all residences within 300 feet of the Project site that an EIR was available for review, per City requirements and will also send notices for future public hearings.

The City also sent a Notice of Availability on September 23, 2021, to public agencies and interested parties that the City had released the Draft EIR for review and comment. Based on requests from the public, the City extended the public comment period from the required 45-days to 67-days to provide more time for review and comment. During this review period, the Draft EIR for the Project was available for review at (1) the St. Helena Public Library, 1492 Library Lane, St. Helena, CA 94574; (2) St. Helena Planning Department, 1572 Railroad Avenue, St. Helena, CA 94574; and (3) on the City’s website at https://www.cityofsthelena.org/planning/page/ ceqa-document-center.

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Response to Letter 16
Bernerd Buckley
October 26, 2021
16-1 The comment expresses concern over the Project’s water neutrality and the City’s water supply. The commenter requests that the Project be monitored for a year to ensure water neutrality is met.

Please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.

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Response to Letter 17
Bernerd Buckley
October 26, 2021
17-1 The comment raises concerns related to potential levee failure. Specifically, the commenter is concerned with emergency evacuation in the event of levee failure for those with a disability and the cost of levee failure. The comment also states that future homeowners should be notified of potential liabilities related to the levee. is addressing concerns regarding the levee and raises FEMA certification of the levee.

Please see Master Response 3 that addresses concerns associated with the levee and Master Response 1 that addresses emergency evacuation.

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Response to Letter 18
Bernerd Buckley
October 26, 2021
18-1 The comment expresses a concern regarding Project’s impact to parking availability.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements.

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Response to Letter 19
Bernerd Buckley
November 2, 2021
19-1 The comment expresses concern related to the proposed location of low-income housing. The commenter questions the appropriateness of the proposed location of these residential units.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the commentor believes the Draft EIR is inadequate; therefore, no further response is required. As described in Chapter 2, Project Description, prior to any development on the site occurring, additional discretionary approvals including a requirement that the Project applicant have an Affordable Housing Agreement approved by the City Council prior to Final Map recordation.

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Response to Letter 20
Bernerd Buckley
November 2, 2021
20-1 The comment letter expresses concerns related to the levee, including the event of a breach, water damage from a breach, the condition and material of the levee, and experience of levee maintenance professionals.

Please see Master Response 3 that addresses all concerns associated with the levee, including the event of a breach and the condition, material, and maintenance of the levee.

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Response to Letter 21
Bernerd Buckley
November 29, 2021
21-1 The comment expresses concern over the City’s water supply and the effectiveness of the City’s Water Neutral Policy. The commenter questions the number of new residents assumed for the Project and asks if there are other projects that have implemented similar water-saving measures.

Please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. As stated on page 3.13-24 of the Draft EIR, a Water Neutral Report was prepared for the Project that assumes a higher persons per household or PPH rate as compared to the City’s PPH assumptions to conservatively estimate Project population to calculate water demand. See Responses to Comments 7-3 and 7-4 that address the PPH assumptions to evaluate Project impacts.

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Response to Letter 22
Jeff Burton
November 8, 2021
22-1 The comment expresses opposition to the Project due to their opinion that affordable housing should not be confined to the east side of the City and in a flood zone.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

As noted elsewhere in these Responses, the Project site is not located in a flood zone which would preclude residential development.
22-2 The comment states that the City is limited on water resources and inquires about the source of water to serve the Project.

Please see Master Response 2 that addresses the issue of water supply. 22-3 The comment states that the Project would result in additional traffic congestion and that the parking situation in the City is inadequate.

The adequacy of parking supply and traffic congestion is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements.
22-4 The comment states that a popular walking path would be terminated by the Project without establishment of an alternate path.

The Project does not propose removing the existing trail or levee maintenance road, as explained in Section 3.12, Public Services and Recreation on page 3.12-17. The comment does not identify specific areas where the commentor believes the Draft EIR is inadequate; therefore, no further response is required. Please see Chapter 3, Changes to the Draft EIR for a copy of a trails map that shows the existing trails near the Project site.
22-5 The comment asks who would be held liable for damage and injury in the event of a 100- year flood.

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Determining legal liability for a potential future event is not within the scope of CEQA review; therefore, no further response is necessary
22-6 The comment states that approval of the Project would attract other proposals to develop the Adams Street property and expresses concern about the future of the City.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
22-7 The comment urges the City to consider the issues raised in the comment letter and to reject the Project.

The comment’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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COMMENT LETTER 23
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Response to Letter 23
Lynda Burton
October 31, 2021
23-1 The comment states general opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
23-2 The comment raises concerns related to the Project’s impact on the City’s water supply and generally challenges the Draft EIR’s proposed mitigation measures.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the mitigation measures in the Draft EIR; therefore, no further response is required. However, please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
23-3 The comment acknowledges the need for affordable housing and calls for smallerscale projects that are aimed to serve senior citizens and low-income families.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration.

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Response to Letter 24
Calie Candia
November 1, 2021
24-1 The comment expresses general concern over the property being developed. More specifically, the commenter is concerned about potential impacts to the floodplain in the event of a flood and stability of the levee.

Please see Master Response 3 that addresses City liability in the event of a flood and concerns related to the levee.
24-2 The comment raises concerns regarding traffic along roadways within the City.

Please see Response to Comment 10-2 that address general traffic concerns. 24-3 The comment states general opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 25
Bret Casten
October 30, 2021
25-1 The comment states that the commenter frequently uses the adjacent trail and expresses concerns over trail and open space access.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Regarding the trail, as noted in the Draft EIR in Chapter 2, Project Description, there is an existing City trail located in the northside of the levee maintenance road. A small portion of the levee maintenance road would be paved to accommodate construction of the Adams Street extension, but sidewalks would be provided along the extension of Adams Street to provide a safe connection to the remainder of the maintenance road and the pedestrian trail, which would remain unaltered by the Proposed Project. Please see Chapter 3, Changes to the Draft EIR for a new figure showing the adjancent trails.

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Response to Letter 26
Deanna Caudill
November 6, 2021
26-1 The comment expresses a desire to keep the City safe and small.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 27
Bob Childs and Nancy Carlson
November 6, 2021
27-1 This comment expresses general opposition over the Project, while acknowledging the need for additional affordable housing.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
27-2 The comment states a concern over Project’s water usage and impact on water availability.

The commenter’s concern is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
27-3 The comment expresses concern over the Project’s impact on the City’s sewer capacity.

The commenter’s concern is noted and forwarded to the decision makers for their consideration. As described in Section 3.13 of the Draft EIR, the Proposed Project would not exceed the City’s current permitted wastewater treatment plant capacity; also, pursuant to Municipal Code Section 3.32.020, the City collects development impact fees on new development to pay for public improvements related to sewer projects. The Project applicant would be required to pay these fees, which would help fund upgrades and improvement to the City’s sewer system.

See also Master Response 4 that addresses concerns regarding the City’s sewer system. 27-4 The comment expresses a concern regarding the current condition of the levee and the impact the Project would have on it related to the floodplain and emergency evacuation.

Please see Master Response 3 that addresses City liability in the event of a flood and concerns related to the levee and Master Response 1 for further information on emergency evacuation.
27-5 The comment requests that the commenter be added to the list of public members opposed to the Project.

Agenda Item #5.8.

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The commenter has been added to a list of interested public members to receive notices regarding the Project; however, this list does not distinguish those who support or oppose the Project.

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COMMENT LETTER 28
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Response to Letter 28
Robb Cohen
November 1, 2021
28-1 The comment expresses general opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
28-2 The comment states that the Project would exacerbate existing water supply problems in the City.

Please see Master Response 2 that addresses concerns associated with the adequacy of water supplies.
28-3 The comment states that the risk of building on a flood plain will subject the City to numerous lawsuits.

Determining legal liability for a potential future event is beyond the scope of CEQA and is not required to be evaluated in an EIR; therefore, no further response is necessary. 28-4 The comment states that the Project should not be approved and suggests that approval of the Project would subject the City to legal challenges.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 29
Joseph Cole
October 30, 2021
29-1 The comment letter expresses general opposition to the project and provides anecdotes about the commenter’s experience as a resident of St. Helena.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 30
Arlene and Richard Corsetti
October 25, 2021
30-1 The comment references a 2016 article written about flooding and water issues in the City and flood-loss damages in the event of a catastrophic flood event.

The comment does not identify any specific issues with the accuracy or adequacy of information provided in the Draft EIR; therefore, no further response is required.

Please see Master Response 3 that addresses the levee and flood concerns. 30-2 The commenter states their opinion on current issues including the lack of a second bridge across the Napa River, traffic problems, and the Project’s compliance with the City’s Water Neutral Policy.

The commenter’s opinion does not identify any specific issues with the accuracy or adequacy of information provided in the Draft EIR. The Project’s increase in demand for water is evaluated in Section 3.13, Utilities and Service Systems and traffic is evaluated in Section 3.14, Transportation and Circulation. The commenter’s opinion on the need for another bridge across the Napa River is noted and forwarded to the decision makers for their consideration. Please see Master Response 2 that addresses the City’s Water Neutral requirements.
30-3 The commenter states that the City Council and Planning Commission must review and refute the article referenced in Comment 30-1 (above), receive a letter from FEMA guaranteeing that another flood in the area would be covered, and guarantee that the City would not be liable for further flood issues if housing is built in the area.

The comment does not identify any specific issues with the accuracy or adequacy of information provided in the Draft EIR. Regarding the referenced article, please see Response to Comment 30-1 above. This comment is noted and forwarded to the decision makers for their consideration.

Determining legal liability for a potential future event is beyond the scope of CEQA and is not required to be evaluated in an EIR.
30-4 The comment raises general concerns for the City to consider specific to traffic congestion absent another bridge across the Napa River.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration.

Agenda Item #5.8.

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30-5 The comment opines that the Project should have a better water mitigation plan because current City residents should not be asked to save more water than they currently are.

Please see Master Response 2 regarding City water supply and requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
30-6 The comment states an opinion that the Project is too risky to be left to the vote of Planning Commission and City Council. The commenter opines that the Project needs in-person debate rather than using the Zoom platform.

The City has recently returned to in-person Planning Commission and City Council meetings. During the COVID-19 pandemic, holding meetings virtually was consistent with Government Code Section 54953, as amended by AB 361, which authorizes teleconference meetings under the Brown Act during proclaimed states of emergency. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.

Agenda Item #5.8.

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COMMENT LETTER 31
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Response to Letter 31
Carroll and Ellen Cotten
31-1 Without providing specific examples, the comment challenges the Draft EIR analysis of potential flood impacts due to climate change dynamics.

Because this comment does not provides specific criticism of the analysis, no response is possible. Please see Master Response 3 which provides a general response to concerns related to flooding and the levee near the Project site. 31-2 The comment takes issue with the effectiveness of the City’s Water Neutral Policy and how it is used in the analysis of the proposed Project’s water demand.

Adherence to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code to fund such measures as fixing an existing leaking water conveyance pipe does offset demand by increasing water supplies compared to the existing conditions of water losses due to the leak. As a result, the Water Neutral Policy does offset new demands with measures that reduce demand elsewhere or otherwise increase water supplies. Therefore, compliance with the City requirements is an appropriate and effective measure to include in the analysis of the Draft EIR. See also Master Response 2.
31-3 The comment generally asserts that the Project would negatively impact the City’s sewer system.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no response is required. Please see also Master Response 4 that addresses concerns regarding the City’s wastewater system. 31-4 The comment expresses concern that the Project would negatively impact the emergency evacuation plans within the area.

Please see Master Response 1 that addresses concerns associated with emergency evacuation.
31-5 The comment expresses general concerns regarding traffic congestion in the City and along the Pope Street Bridge.

The comment does not identify any specific issues with the accuracy or adequacy of information provided in the Draft EIR; therefore, no further response is required.

However, the comment is noted and forwarded to the decision makers for their consideration. The operational aspects of the Proposed Project that contribute to Agenda Item #5.8.

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delay and congestion on local roadways is no longer considered an environmental impact under CEQA. Please also see Response to Comment 10-2.

Agenda Item #5.8.

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COMMENT LETTER 32
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Response to Letter 32
Richard Crebs
November 2, 2021
32-1 The commenter states the Project is flawed because it is proposed on fill placed on the site as part of the City’s Flood Protection Project; would be subject to seismic events and flooding; would increase demand for water; and would increase traffic congestion. The comment recommends the site be left as open space.

Consistent with the recommendations in the Geotechnical Report, the existing fill/soils on the site would be removed, re-compacted and returned to the site along with additional fill. The site would be graded and leveled to ensure a stable base for new development (DEIR p. 2-31).

Potential hazards associated with seismic events is addressed in Section 3.6, Geology and Soils. As noted on page 3.6-12, the Project site is not crossed by an active earthquake fault zone, nor is it crossed by any potentially active faults. The closest earthquake fault zones are the Rodgers Creek Fault, located about 15 miles to the southwest of the Project site and the southern part of the West Napa Fault, located approximately 17 miles southeast of the Project site. Development would be required to comply with the California Building Code which sets forth structural design requirements associated with seismic loads. As part of this process, a designlevel geotechnical investigation would be completed (in addition to the existing geotechnical investigation already completed) to assess site conditions at a greater level of detail and make geotechnical recommendations to be incorporated into the site development plan, grading plan and building plan. The City requires that such geotechnical recommendations be verified at time of grading and building construction prior to issuance of a certificate of occupancy. In addition, mitigation measure GEO-1 is imposed to ensure preparation of a design-level geotechnical report that includes specific design criteria to ensure the Project is designed to meet all current seismic safety standards (DEIR pp. 3.6-22 and 3.6-23).

Please see Master Response 3 that addresses flooding concerns and Master Response 2 that addresses water supply concerns and Response to Comment 10-2 regarding traffic.

The Project site is not owned by the City and is not public open space but designated by the General Plan and zoned for Medium Density Residential development. The commenter’s desire to see the site left undeveloped is noted and forwarded to the decision makers for their consideration.
32-2 The comment references the analysis of potential flooding due to a levee failure and suggests residents should purchase flood insurance in the event of a flood event and Agenda Item #5.8.

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the City should require the Project applicant post a bond to “hold the City harmless” in the event of a flood.

The Draft EIR evaluates flood risks due to a 200-year flood event as well as due to failure of the levee starting on page 3.9-8 in Section 3.9, Hydrology and Water Quality. As noted on page 3.9-8, The City’s Flood Protection Project, specifically the levee and floodwall along the Napa River and Sulphur Creek, was constructed to provide protection from a 200-year flood event. The levee was designed and constructed in accordance with all applicable U.S. Army Corps of Engineers Engineering Manuals and has been reviewed by the Federal Emergency Management Agency or FEMA. The flood control system was also evaluated for stability during a seismic event and was found to be stable by two engineering firms. The Project site is outside of a FEMA special flood hazard area; therefore, purchase of flood insurance would be required. However, because there remains residual risk of flooding from catastrophically large floods (such as a 500-year flood) or levee failures, residents in flood-prone areas, even if outside of a regulatory flood zone, have the option to purchase optional flood insurance. Regarding the applicant’s liability in the event of a flood and purchase of a bond to absolve the City of any responsibility to residents in the event of a catastrophic flood event, please see Master Response 3. 32-3 The comment opines that the EIR ignores issues associated with availability of water and believes the Project should not use groundwater for landscape irrigation in lieu of capturing and treating all domestic wastewater or “grey water” for irrigation and goes on to state a grey water system should be mandated for every residence.

The Project is required to off-set its water demand, per the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. In compliance with these requirements the Project applicant prepared a Water Neutral Report (see Appendix J). The City requires all new projects to be water neutral and not consume water without offsetting the demand. Please see Master Response 2 that addresses the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code requirements.
32-4 The comment is referring to the City’s wastewater system and whether the Project would increase wastewater conveyance in the same infrastructure that also serve the Vineyard Valley Mobile Home Park and states if the Project is approved the applicant should be required to fund any improvements to the City’s wastewater system.

The Project’s connection to the City’s wastewater (or sewer) system is described on page 2-29 in Chapter 2, Project Description. Wastewater flows from the western end of the Project site are proposed to drain into an existing public manhole at the corner of Starr and Hunt Avenue via new 8-inch sewer pipes. The area east of Starr Avenue is proposed to drain east through the Project site via new 8-inch sewer pipes into an existing public manhole on the adjacent parcel in the Vineyard Valley Mobile Home Park. The City’s system is sized to accommodate wastewater flows from the Project and there is adequate conveyance capacity within the existing lines. The Project Agenda Item #5.8.

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would not require any modifications to the City’s system and impacts were determined to be less than significant (DEIR p. 3.13-29). Please see Master Response 4 that provides additional details regarding the City’s sewer system and ability to serve the Project.
32-5 The comment questions if the Project’s estimated in-lieu fee is adequate based on the City’s current Capital Improvement Projects (CIP) budget.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, please see Response to Comment 2 that addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. 32-6 The comment expresses general concerns regarding traffic congestion in the City and would like the Project to pay for a new bridge to connect Adams Street to the Silverado Trail.

The Proposed Project does not include the construction of a new bridge and does not involve any further extension of Adams Street, east of Starr Avenue. Any extension of Adams Street connecting to Silverado Trail would require further study and approval by the City and the City’s Public Works Department has determined is not required for this Project.

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Response to Letter 33
Nicole Dale
October 28, 2021
33-1 The comment states general opposition to the Project and explains that the commenter shares a property line with the Project. The commenter expresses general concerns over traffic, water, flooding, and the adjacent walking trail.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, to address the commenters’ general concerns regarding water and flooding, please see Master Responses 2 and 3.
33-2 The commenter opposes the Project’s proposed ADUs and claims the ADUs should not be used to fulfill the affordable housing requirement.

The City’s Inclusionary Housing Ordinance requires a minimum level of affordability in the housing which is ultimately developed on the Project site. The Project applicant will submit a detailed proposal regarding how the Project will meet this requirement which will be part of a subsequent discretionary approval (Affordable Housing Agreement) at or prior to the recordation of the Final Map. This must be approved by the City Council before development of homes can take place. Staff will review the applicant’s proposal before making a recommendation to the City Council on the Affordable Housing Agreement. A determination of consistency will be made at the time that subsequent application is submitted and reviewed (DEIR pp. 2-18 and 2-32).

The commenter’s opinion is noted and forwarded to the decision makers for their consideration.

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Response to Letter 34
Gayle Davies
November 29, 2021
34-1 The comment suggests that the Project did not comply with AB 52 requirements for consultation with Native American tribal representatives affiliated with the area including Scott Gabaldan, tribal chairman of the Mishewal Wappo Tribe of Alexander Valley.

Section 3.5, Cultural and Tribal Cultural Resources of the Draft EIR describes the Project’s compliance with AB 52 requirements. Pursuant to AB 52, the City sent letters to all tribes (who have requested notification) who are traditionally or culturally affiliated with the geographic area of the Project site. A letter was sent to Vincent Salsedo with the Mishewal-Wappo Tribe of Alexander Valley on April 23, 2018. No response was received from the Mishewal Wappo Indian Tribe in response to the AB 52 letter. All records of correspondence related to AB 52 notification and any subsequent consultation are on file with the City.

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Response to Letter 35
Priscilla Dell
November 15, 2021
35-1 The comment discusses how climate change is addressed in Section 3.9, Hydrology and Water Quality and questions why current rainfall conditions post 2016 were not included in the Environmental Setting section, as the City has been experiencing drought conditions since 2016. The comment goes on to note that climate change is contributing factor to drought.

Information from the Western Regional Climate Center, which provides rainfall data dating from 2016 was the most current rainfall information available at the time the Draft EIR was being compiled in 2019. The information in Section 3.3, Air Quality has been updated based on more recent data from the National Oceanic and Atmospheric Administration and the revised text is provided in Chapter 3, Changes to the Draft EIR. Climate change is recognized to be a contributing factor to drought conditions and the commenter’s request that this be factored into the City’s decision making process is noted and forwarded to the decision makers for their consideration. 35-2 The comment suggests that the Project proponent should do their own engineering studies related to the City’s Comprehensive Flood Control Project. In addition, the comment suggests that the City should more clearly direct the public to current studies.

The Project applicant is not required to conduct independent engineering studies to evaluate the City’s Flood Control Project. The City of St. Helena along with a team of consultants designed, permitted, and constructed the multi-objective flood control and habitat restoration project which was constructed in 2009 and 2010, and provides 200-year flood protection for residential properties along the Napa River as well as restores important floodplain and aquatic habitat. See also Master Response 3 for further information regarding the levee and flood protection.

Regarding recent documents related to the City’s Comprehensive Flood Control Project, recent inspection reports and summary reports can be found on the City’s website here: Flood Control and River Restoration Project | City of St Helena. 35-3 The comment questions the conclusion of the Draft EIR that the Proposed Project will not exacerbate flood hazards.

As stated in Section 3.9 of the Draft EIR on pages 3.9-7 and 3.9-8, the Project site is not located within a FEMA special flood hazard area based on mapping that is provided by FEMA. The Project site is protected by the recently constructed levee that is designed to provide 200-year flood protection with additional freeboard protection. As a result, by definition, using the most recent mapping provided by Agenda Item #5.8.

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FEMA in 2012, the Project would not encroach upon a flood zone, redirect flood flows, or place habitable structures in an area with reasonable risk of flooding.

See Master Response 3 for further discussion of the levee system. 35-4 The comment claims that excessive storm drainage from the site would flow toward Vineyard Valley Mobile Home Park. In addition, the comment suggests that the Project applicant include blue or purple (recycled water) pipes to direct water to the Water Treatment Plant for use as non-potable water after treatment.

As stated in the Draft EIR on pages 3.9-44 and 3.9-45, the additional stormwater runoff created by the Proposed Project would be directed to the City-owned off-site detention basin, adjacent to the Project site, which has been designed to store the increase in storm water runoff from the Project site during a 100-year storm event. In fact, the detention basin was designed assuming that the Project site would be developed with 70% impervious surfaces; however, the Project would develop less of the site (58%) with impervious surfaces. In addition, the Project would require compliance with the City’s Municipal Code and improvement standards associated with approval of tentative subdivision maps, which currently do not require recycled water infrastructure be provided. Therefore, since the off-site detention basin was designed with adequate capacity to accommodate stormwater flows from the Proposed Project there would be a low likelihood of excess flows draining from the Project site into the adjacent Vineyard Valley Mobile Home Park.

Please see Master Response 4 for further information on the City’s wastewater system. 35-5 The comment suggests that the City’s detention basin was not designed appropriately and did not correctly factor in the Project’s contribution of stormwater runoff. The comment goes on to note using words like “estimated” and “assumed” are not scientific.

As stated in the Draft EIR on page 3.9-45, the City’s detention basin was designed to accommodate future development of the Project site assuming the City would be developed with up to 70% impervious surfaces. However, the Proposed Project would develop less of the site with impervious surfaces (58%) which would produce lower runoff volumes, and therefore the detention basin would have more than sufficient capacity to accommodate stormwater flows from the Project site.

Regarding the terminology used to describe development of the site it is virtually impossible to determine with 100% certainty the exact outcome of various engineering studies. For example, development of the Project site with impervious surfaces could fall between 57.38% to 58.23%; therefore, it is proper to estimate or assume approximately 58% of the site would be developed with impervious surfaces.

This is an accepted approach in scientific and engineering studies.

Agenda Item #5.8.

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35-6 The comment suggests that the Project build its own detention basin and contends that the Project is not consistent with the language in Napa County’s Measure A Ordinance, which states that flood control projects in the County should not be designed to encourage population growth.

The City’s detention basin, as noted on page 3.9-45 of the Draft EIR, was designed with the knowledge that the Project site could be developed and introduce as much as 70% impervious surface coverage due to development of the site. The Project, as designed, would introduce 58% impervious surface coverage. Therefore, as proposed, there is adequate capacity in the City’s existing detention to accommodate the Project and there is no need to construct an additional basin. Measure A, as described on page 3.9-6 of the Draft EIR, was passed in 1998 by Napa County and provided the basis for a number of flood improvement projects, whereas the Project site has been designated and zoned for future residential development dating as far back as the City’s 1975 General Plan, as stated on page 2-12 of the Draft EIR. The Project is not funded in any part with Measure A funds and the City’s Flood Control Project, which did receive Measure A funds, was designed to provide flood protection for both developed areas within the City as well as areas already planned for future development, including the Project site.
35-7 The comment claims that the Project would not adequately direct stormwater runoff and would ‘endanger’ Valley Vineyard Mobile Home Park.

Please see Response to Comment 35-4.
35-8 The comment suggests that the City’s detention basin was designed under different circumstances and the Project could endanger Vineyard Valley Mobile Home Park residents.

As stated in Responses to Comments 35-4 and 35-6, the detention basin was designed assuming that the Project site would be developed with 70% impervious surfaces. The Proposed Project would develop only 58% impervious surfaces, and therefore the City’s detention basin, which was planned to accommodate development of the Project site, would have more than enough capacity to handle runoff volumes from the Project site.
35-9 The comment refers to dust and dirt affecting the quality of life over a two to threeyear period of development.

There is no evidence that dust attributed to construction activities would measurably affect the quality of life. The comment does not identify any specific areas where the Draft EIR is inadequate; therefore, no further response is required. 35-10 The comment alleges the Project is in direct conflict with Measure A and this should prohibit the Project from moving forward.

Agenda Item #5.8.

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Please see Response to Comment 35-6 and Master Response 3. 35-11 The comment is referring to an increase in traffic associated with the Project that would create a safety hazard and would make emergency evacuation impossible.

The comment does not elaborate on what safety hazards the Project would create nor does the comment indicate where the analysis in the Draft EIR may be deficient or inadequate regarding safety. Therefore, a response is not required.

Master Response 1 provides further information on concerns regarding emergency evacuation.
35-12 The comment refers to prior concerns raised specific to the use of information from the City’s Flood Control Project; adequacy of the detention basin to accommodate the Project’s stormwater; and terminology describing information from technical studies.

Please see Responses to Comments 35-3 through 35-6.

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COMMET LETTER 36
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Response to Letter 36
Nancy Dervin
October 23, 2021
36-1 The comment expresses concern regarding traffic congestion at the intersection of Adams Street and Railroad Avenue, and potential traffic safety issues due to egress and ingress for the parking lot currently used by businesses near the intersection.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. The intersection of Adams Street and Railroad Avenue was thoroughly analyzed in Section 3.14, Transportation and Circulation of the Draft EIR and Project impacts at this intersection were found to be less than significant. Additionally, vehicular collisions within the City were also analyzed on page 3.14-47 of the Draft EIR and again Project impacts were determined to be less than significant. 36-2 The comment expresses general concern regarding traffic congestion along the Adams Street corridor, specifically near the east side of Main Street near the intersection of Adams Street and Main Street.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, as explained on page 3.14-1 in Section 3.14, Transportation and Circulation, “the California Environmental Quality Act (CEQA) Guidelines were updated to remove evaluation of the delay that vehicles experience at intersections and on roadway segments, which is often measured using a level of service (LOS) metric. Therefore, the operational aspects of the Proposed Project that contribute to delay and congestion on local roadways is no longer considered an environmental impact under CEQA. These concerns are discussed in the Proposed Project’s Traffic Impact Study (TIS) in relation to consistency with General Plan policies (see Appendix K).” The analysis of vehicular queuing and congestion were addressed in Appendix K and also in Section 3.14. Project impacts were concluded to be less than significant for this section of Adams Street and Main Street. 36-3 The comment refers to a conservation easement designed to preserve land and protect habitat and provide public access consistent with the City’s Flood Protection Project and questions how the Project would not affect the land, habitat and access provided for under the conservation easement.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no response is required. The City has confirmed that the easement noted by the commenter does not include any part of the Project site. Please see Chapter 3, Changes to the Draft EIR for a trails map showing adjacent trails near the Project site.

Agenda Item #5.8.

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36-4 The comment states a concern related to emergency evacuation due to wildfires, specifically for Vineyard Valley residents.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, emergency evacuation was analyzed in Section 3.14 of the Draft EIR and Project impacts were determined to be less than significant. Please also see Master Response 1, that provides more details specific to emergency evacuation for both Vineyard Valley residents and Project residents. 36-5 The comment expresses concern over the Project’s parking supply and the parking supply of the surrounding neighborhood.

The CEQA Guidelines do not require that parking be evaluated in an EIR; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested City staff shall confirm the Project complies with the residential parking requirements in the St. Helena Zoning Code.
36-6 The comment expresses concern related to the effectiveness of the City’s Water Neutral Policy.

Please see Master Response 2 that addresses the City’s ability to supply water to the Project and also address concerns regarding the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.

Agenda Item #5.8.

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COMMENT LETTER 37
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Response to Letter 37
Julie Dickson
October 15, 2021
37-1 The comment generally states that the Proposed Project would compound existing community challenges and recalls a previous flooding event.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 37-2 The comment refers to ‘profound’ existing traffic issues, especially related to the Pope Street Bridge.

The comment does not address the accuracy or adequacy of the Draft EIR, and the assertion of “profound” issues is the commentor’s unsupported opinion; therefore, no further response is required. Potential Project impacts, as well as impacts related to the Pope Street Bridge are analyzed in detail in Section 3.14 Transportation of the Draft EIR and within Appendix K, Traffic Impact Study. The comment is noted and forwarded to the decision makers for their consideration. 37-3 The commenter opines that practical and safety considerations of developing the Project should be weighted more than profits and that the Project should not be approved.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 38
Chris Echols
October 17, 2021
38-1 The comment states his general concerns related to noise, traffic, water, sewer capacity, and property devaluation.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, the Project’s impact on noise, transportation, water, and sewer capacity are analyzed in Sections 3.11, Noise and Vibration; 3.14, Transportation and Circulation; and 3.13, Utilities and Service Systems in the Draft EIR. The commenter’s concern related to property devaluation is an economic concern that is not required to be evaluated in an EIR. As described in Section 3.13, the Proposed Project would not exceed the City’s current permitted wastewater treatment plant capacity; also, pursuant to Municipal Code Section 3.32.020, the City collects development impact fees on new development to pay for public improvements related to sewer projects. The Project applicant would be required to pay these fees, which would help fund upgrades and improvements to the City’s sewer system.

Please see Master Response 2, related to water concerns and Master Response 4 that addresses sewer issues.

The analysis of noise associated with Project construction and operation is included in Section 3.11, Noise. Noise associated with construction activities is often the most annoying to nearby residents. As discussed on page 3.11-16, the City exempts construction activity noise if conducted during specific limited daytime hours. The City’s Health and Safety Code (Chapter 8.24 of Title 8, the Health and Safety Code) requires noise generating construction activities (including demolition, excavation, and building construction), be restricted to the hours between 8:00 a.m. and 5:00 p.m., Monday through Saturday, and prohibited on Sunday and holidays (City of St.

Helena Chapter 8.24). This ensures that sensitive receptors are not disturbed by early morning or late night activities. However, the City’s 1993 General Plan includes Implementing Policy 8.3.11, which states “Require construction operations to use noise suppression devices and techniques and limit noisy construction activities to the least noise sensitive times (8 a.m. to 5 p.m., Monday through Friday).” Note, the City’s 2019 General Plan does not include this requirement. Due to the proximity of residences to the Project site and the potential for construction noise to be an annoyance, the impact is considered potentially significant and mitigation measure NOI-1 is required. This mitigation requires administrative controls, engineering controls, and/or installation of sound abatement. Installation of an effectively placed storage container or a temporary plywood or blanket barrier on a portion of the site boundary that blocks line-of-sight between the source(s) of noise emission and the receptor of concern (e.g., residence) would be expected to provide a minimum of 3-5 dBA of noise reduction. Compliance with the City’s Health and Safety Code and mitigation measure NOI-1 would address construction noise (p. 3.11-16). Noise Agenda Item #5.8.

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associated with Project operation which primarily is related to an increase in traffic was modeled to determine if the City’s noise standards would be exceeded. Projectrelated traffic noise increases along roadways where the Project would contribute trips would in all cases be less than 1 dBA, as shown in Table 3.11-8. Such increases would be well below the 3 dB perceptible increase threshold and below the City’s noise standards (p. 3.11-20). Thus, impacts are less than significant.

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COMMENT LETTER 39
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Response to Letter 39
Cindy and John Ford
November 1, 2021
39-1 The commenters express their general opposition to the Project and Draft EIR.

The commenters’ opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. 39-2 The comment raises concerns about the City’s water supply and Draft EIR’s assessment of water supply impacts. The commenter takes issue with the effectiveness of the City’s Water Neutral Policy and how it is used in the analysis of the proposed Project’s water demand. The comment also questions whether existing groundwater resources could sufficiently serve the Project.

The City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code requires new development to “completely offset its water requirement” by identifying residential or non-residential properties eligible for retrofitting with water efficient hardware and verifying that the required number of retrofits have been completed prior to the issuance of a certificate of occupancy (DEIR p. 3.13-21). To accomplish this the City requires all applicants to prepare a Water Neutral Report identifying compliance. Adherence to the City’s Water Neutral Policy and Municipal Code to fund such measures as fixing an existing leaking water conveyance pipe would offset demand by increasing water supplies compared to the existing conditions of water losses due to the leak. As a result, compliance with these requirements offsets new water demands with measures that reduce demand elsewhere or otherwise increase water supplies. Therefore, compliance with the City requirements is an appropriate and effective measure to include in the analysis of the Draft EIR. See also Master Response 2.

As discussed on page 3.9-43 of the Draft EIR, the aquifer where the Project is located on is known to be a productive alluvial aquifer, and therefore, there would be sufficient yield available from the on-site well to supply the Project’s landscape irrigation demand as also demonstrated by the findings of the site-specific well pump test conducted on the existing agricultural well on the Project site. The proposed rate of pumping is relatively low and the resulting radius of influence would be highly localized, and greatly overshadowed by the radius of influence associated with the much higher producing agricultural and municipal supply wells in the surrounding vicinity.
39-3 The comment expresses concerns related to the Project’s proximity to the levee and the event of potential flooding. The comment specifically expresses concerns related to the current condition of the levee in terms of its inspections and certifications by Agenda Item #5.8.

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FEMA or the Army Corps of Engineers. The comment also questions who would be responsible for costs in the event of a major flood and subsequent potential property damage.

Please see Master Response 3 that addresses concerns associated with the levee and flooding.
39-4 The comment expresses general concerns regarding traffic congestion along Hunt Avenue and Starr Avenue, as well as traffic connecting to Highway 29.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, the comment is noted and forwarded to the decision makers for their consideration and no further response is required. 39-5 The comment expresses concern regarding landslides as well as the potential for emergency evacuation routes to be congested. The comment states that the sentence within the Executive Summary of the Draft EIR that states the “Project site is flat so fire hazards due to proximity to hilly terrain or landslides due to post-fire conditions would not be a concern” is false since there are presumably closures to Silverado Trail currently due to landslides caused by rain.

In 2018 the CEQA Guidelines, Appendix G, were updated to include a separate evaluation of wildfires. Appendix G focuses on those areas located “in or near state responsibility areas or lands classified as very high fire hazard severity zones.” On page E-3 of the Executive Summary, it explains the Project site is not located within a state responsibility area and not designated as being within a very high fire hazard severity zone. Because the Project site is flat potential fire hazards associated with spread of wildfire due to sloped or hilly terrain would not be a factor. The closure of Silverado Trail due to mudslides associated with loss of vegetation is not applicable to this Project. Because the Project site is flat there would not be any hazards associated with mudslides. Please see Master Response 1 which addresses concerns regarding emergency access and evacuation routes. 39-6 The comment thanks the City for the opportunity to comment on the Proposed Project and asks the City to review the Project’s impact on the whole of the community.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.

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COMMENT LETTER 40
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Response to Letter 40
Chris Fowler
October 30, 2021
40-1 The comment expresses interest in exploring “Option 4.” It is assumed that “Option 4” is a reference to Alternative 4, which is described beginning on page 5-14 of the Draft EIR. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. The comment does not identify any components of Alternative 4. Therefore, no further response is required.

However, the commenter’s interest in Alternative 4 is noted and forwarded to the decision makers for their consideration.
40-2 The comment expresses interest in providing low and affordable housing in the City.

The Project proposes affordable housing as described in Chapter 2, Project Description. The Project applicant is also required to prepare an Affordable Housing Agreement for City review and approval. The comment does not identify any specific areas where the commenter believes the Draft EIR analysis is inadequate.

Therefore, no further response is required. However, the commenter’s interest in providing affordable housing is noted and forwarded to the decision makers for their consideration.

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Response to Letter 41
Pat Friday
November 8, 2021
41-1 The comment expresses support only for the affordable housing component of the Project.

The commenter’s support of the affordable housing component is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required.
41-2 The comment acknowledges water use considerations and general opposition to the Project; but indicates additional housing is needed and would support the City.

The commenter’s opposition to the Project but support for additional housing is noted and forwarded to the decision-makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required.
41-3 The comment includes a correction to Comment 41-1. The comment is requesting an edit to Comment 41-1 to clarify that the commenter is encouraging the City to proceed with the Project, specifically the affordable housing component.

The commenter’s support of the Project, including the affordable housing component is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required.

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Response to Letter 42
Pat Friday
November 8, 2021
42-1 The comment expresses support for the Project and the affordable housing component of it. The commenter states that worker housing is needed in the City.

The commenter’s support for the Project and desire for affordable housing is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required.
42-2 The comment acknowledges water use considerations and general opposition to the Project; the commenter states that the additional housing would support the City.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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Response to Letter 43
Alan Galbraith
December 9, 2021
43-1 The comment notes that the points raised in the letter are specific to the water supply discussion and address factual issues as well as the Project applicant’s water neutrality proposal.

Please see Master Response 2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. 43-2 The comment refers to information specific to the average historical yield from the Bell Canyon reservoir and potable water deliveries available to the City and questions the accuracy of the information provided.

The reported average historical yield of 1,800 acre-feet per year is the accurate figure that was used in the Draft EIR for the 2040 St. Helena General Plan Update and was based on reporting by Luhdorff and Scalmanini in their Groundwater Sustainability Report in 2016 (found here:
https://www.napawatersheds.org/managed_files/
Document/8266/Napa%20Valley%20Subbasin%20Basin%20Analysis%20Report_20 16_sm.pdf). This reported historical average is not be confused with the more recent numbers that are listed in Table 3.13-1 of the Draft EIR. The more recent average is indeed much less than the historical average as reported by Luhdorff and Scalmanini in 2016.
43-3 The comment cites to a technical document prepared by the city’s Water and Sewer Infrastructure Committee that address deliveries to Bell Canyon reservoir prior to 2007.

Please see Master Response 2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. 43-4 The comment is referring to why there was a decline in water deliveries to Bell Canyon (after 2007) due to compliance with state permit requirements.

Please see Master Response 2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. 43-5 The comment refers to information in the Draft EIR noting that Napa County purchased water that was expected to add to the overall water supply but ended up only replacing water that had been misappropriated.

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Please see Master Response 2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. 43-6 The comment is noting that the historical yield of Bell Canyon reservoir fluctuates annually depending on rainfall amounts and cites to a report prepared by the city’s Water and Sewer Infrastructure Committee. This challenges the City to supply water during successive dray water years.

Please see Master Response 2. The comment does not identify any specific areas where the EIR or analysis is inadequate. Therefore, no further response is required 43-7 The comment states information in the Draft EIR addressing the amount of water the City is authorized to divert and store is incorrect.

The commenter correctly notes that the amount of water the City is authorized to divert and store from Bell Canyon Reservoir is 1,800 acre-feet or AF. The Draft EIR text on page 3.13-3 will be corrected to read 1,800 AF and is included in Chapter 3, Changes to the Draft EIR. Note that the water supply analysis (see Impact 3.13-2 on p. 3.13-31), does not rely on either the 3,800 AF number or 1,800 AF. The analysis uses the more conservative “safe yield” of 1,000 AF for a normal dry year (see Table

3.13-7). Therefore, this comment does not result in any change to the impact analysis and significance finding.
43-8 The comment is providing background on the storage capacity of Bell Canyon reservoir and the amount the City’s storage rights.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. See Response to Comment 43-7. No further response is required. 43-9 The comment is referring to a 2010 Subcommittee Report which notes the City’s storage right of 1,800 AF.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. See Response to Comment 43-7. No further response is required. 43-10 The comment describes where the 3,800 AF amount was derived from and references Permit 14810 that authorized raising the dam at Bell Canyon reservoir to 105 feet to permit more water storage.

Please see Response to Comment 43-7. The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required.
43-11 The comment dismisses the need to discuss the City of Napa’s water sources and states it is not relevant because the City has a “take or pay” contract with the City of Agenda Item #5.8.

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Napa so the source of the City of Napa’s water is of no consequence to the City of St. Helena.

The commenter’s opinion regarding the information contained in the environmental setting for water supply source in Section 3.13, Utilities and Service Systems is noted. The information provided in the Draft EIR regarding the City of Napa’s water sources is provided because the City of St. Helena has a contract with the City of Napa for water and this is part of the environmental baseline. 43-12 The comment refers to the amount of groundwater the City obtains from the Stonebridge Well Complex.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. Please see Master Response 2 for additional information.
43-13 The comment explains why the City limits extracting groundwater from the Stonebridge Well Complex to minimize impacting the Napa River The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. Please see Master Response 2 for additional information.
43-14 The comment indicates that based on information provided on the City’s website, the City has increased its allotment of groundwater from the Stonebridge Well Complex by approximately 35% in 2021, which the commenter opines is not sustainable.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, no further response is required. Please see Master Response 2 for additional information.
43-15 The comment references Table 3.13-7 in the Draft EIR and compares the information in this table to information provided by the Safe Yield Committee.

The comment does not draw any conclusions or question the data provided in Table

3.13-7 (DEIR p. 3.13-8). Therefore, because the comment does not identify any specific areas where the Draft EIR is inadequate, no further response is required.

Please see Master Response 2 that addresses water supply. 43-16 The comment discusses the ‘net safe yield’ as defined by the Safe Yield Committee and notes that this net safe yield could affect the availability of water during critical dry years.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. Please see Master Response 2 for additional information.

Agenda Item #5.8.

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43-17 The comment addresses changes that could affect the ‘safe yield’ calculation due to changes in water availability.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. Please see Master Response 2 for more information on water availability.
43-18 The comment suggests that the City is under “environmental and legal pressure” to reduce groundwater pumping from the Stonebridge Well Complex and suggests that the City should reassess the ‘safe yield’ and ‘net safe yield’ water assumptions.

The comment does not identify any specific areas where the EIR or analysis is inadequate; therefore, no further response is required. Please see Master Response 2 for additional information.
43-19 The comment references conclusions of the Safe Yield Report which requires annually recalculating the average total water usage and account for changes in water supply. The comment notes the Draft EIR does not cite work prior to 2011 that speaks to these conclusions.

Water supply deliveries for the years 2013 through 2020 are included in Table 3.13-1 on page 3.13-3 of the Draft EIR.
43-20 The comment states the Draft EIR incorrectly characterizes the location of the Louis Stralla Treatment Plant as being within the City limits.

See Chapter 3, Changes to the Draft EIR for a text change to page 3.13-8 of the Draft EIR to more accurately describe the location of the water treatment plant. This text change does not affect the analysis of this issue in the Draft EIR. 43-21 The comment opines that a recommendation from the City’s 2010 Water Supply Plan is not consistent with a 2015 court case that eliminated the ability to use tiered rates to incentivize water conservation.

The referenced bullet point in the Draft EIR on page 3.13-10 is merely providing background information related to the 2010 Water Supply Plan and recommendations that were contained within that document. The analysis within the Draft EIR does not rely on whether the referenced recommendations have legal viability. However, the comment is noted and forwarded to the decision makers for their consideration.
43-22 The comment opines that the Project’s water demand of 20 AFY (rounded up) is not a small amount to be offset through water efficiency improvements.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 Agenda Item #5.8.

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addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.
43-23 The comment is referencing the Project applicant’s Water Neutral Report, included as Appendix J and notes that retrofitting 333 off-site residences or paying an in-lieu fee would meet the requirements of the City’s policy.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.
43-24 The comment opines that payment of the in-lieu fee would be more practical than trying to find 333 residences to retrofit.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.
43-25 The comment states a concern that payment of an in-lieu fee without identifying where that money would be spent to off-set the Project’s increase in water demand is needed for the City to meet the intent of the policy.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.
43-26 The comment addresses how the City calculates the in-lieu fee and notes the fee should be in an amount that is sufficient to off-set a 20 AFY increase in water demand.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.
43-27 The comment states an opinion that the in-lieu fee be sufficient to off-set the Project’s increase in water demand to meet the intent of the City’s Water Neutral Policy.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. However, Master Response 2 addresses the Project’s compliance with the City’s Water Neutral Policy and Chapter

13.12, Water Use and Efficiency of the Municipal Code.

Agenda Item #5.8.

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43-28 The commenter notes the Project intends to use the existing well for landscaping but states that the County’s Groundwater Sustainability Plan (GSP) has not yet been adopted by the County, Department of Water Resources, or the City.

The Project is proposing to use the on-site agricultural well for all public and private landscape irrigation. As discussed in the Draft EIR on page 3.9-42, the total water demand of the Proposed project that would likely be sourced from groundwater including both the onsite well and water that would be supplied from the Stonebridge Complex would only represent 0.9% increase in demand. Of that, the water from the onsite well would be less than half that amount. Otherwise, the GSP for the Subbasin which has not yet been completed, as the comment notes, and suggesting that there could be a potential conflict with that document would be considered conjecture which is outside the scope of CEQA. However, as stated on page 3.9-40 of the Draft EIR, in a recent assessment of the groundwater conditions, Napa County and its technical consultant have determined that the Subbasin is not exhibiting significant and unreasonable impacts with regard to the applicable sustainability indicators defined by the Sustainable Groundwater Management Act (SGMA). As a result, there is sufficient evidence to support a conclusion of a less-than-significant impact related to use of the onsite groundwater well.

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COMMENT LETTER 44
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Response to Letter 44
Dottie Gingerelli
October 30, 2021
44-1 The comment generally mentions the Project’s potential impact to water supply, vehicle emissions, and bicycle and pedestrian facilities.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
44-2 The comment expresses concern related to emergency evacuation for Vineyard Valley residents.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, emergency evacuation was analyzed Section 3.14 of the Draft EIR and Project impacts were concluded to be less than significant. Please also see Master Response 1, for more details related to emergency evacuation for both Vineyard Valley residents and Project residents.
44-3 The comment poses a question related to the potential loss of life due to the Project.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

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Response to Letter 45
Diane Green, Daniel Wheaton, Mark Arnett, Carl Barnes, Gary Oncina, James Pelligri
45-1 The comment states that it is important to note the history of the Project and actions by the Project applicant, including litigation and refusal to supply documentation requested by City staff.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

Please see Responses to Comments 45-2 and 45-4 regarding compliance with the City’s Inclusionary Housing Ordinance and Response to Comment 84-3 regarding the density bonus.
45-2 The comment states that the Project violates the "HCD-approved" St. Helena Housing Element through the segregation of low-income housing from market rate housing and not spreading the units throughout the Project site and including units for sale.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the project. However, as part of the applicant’s future Affordable Housing Agreement proposal, as required under the City’s Inclusionary Housing Ordinance, there must be demonstration that the Project be consistent with the City’s Affordable Housing Ordinance and be “spread throughout the Project” (Municipal Code 17.146.050 (I)). Housing Element Implementing Action HE4.A would require that affordability levels of inclusionary units in a project be “further distribut[ed] … within the various income categories.” Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. Such an Agreement will need to be approved by the City Council following the Tentative Subdivision Map approval but prior to the Final Map being recorded and before any development of homes can take place.
45-3 The comment suggests that the segregation of low-income housing from market rate neighborhoods only within the eastern area of the City limits the possibility for diverse housing and socioeconomic and racial diversity in those neighborhoods (in the western area of the city).

Please see Response to Comment 45-2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

The comment is noted and forwarded to the decision makers for their consideration.

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45-4 The comment opines that the Project strategically places the affordable units adjacent to the existing multi-family housing along Adams Street rather than distributing units throughout the rest of the market rate housing, as required by the St. Helena Housing Element.

Please see Response to Comment 45-2.
45-5 The comment references an article about housing segregation in St. Helena.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
45-6 The comment alleges that the City and Planning Commissioners may face discrimination claims and lawsuits due to housing and racial segregation by not requiring affordable housing in the western area of the City in violation of City ordinances and state law.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
45-7 The comment refers to Zoning Code sections 17.144 and 17.146, the Housing Element and General Plan as well as new California laws to prevent housing discrimination and segregation.

Please see Response to Comment 45-2. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 45-8 The comment suggests that the Project does not propose enough affordable housing relative to the impacts on traffic, water supply, housing segregation, and liability due to flooding. The comment also references that the Project eliminates the proposed Adams Street extension connecting to Silverado Trail.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 2 regarding water to serve the Project and Master Response 3 that addresses concerns regarding the levee. The Proposed Project does not eliminate the future extension of Adam’s Street connecting to Silverado Trail. The Project does not require Adam’s Street be extended any farther east of Starr Avenue. Any extension of Adams Street connecting to Silverado Trail would require further study and approval by the City and is not required for this Project.

An attachment to this letter can be found in Appendix B Agenda Item #5.8.

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COMMENT LETTER 46
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Response to Letter 46
Diane Green, Daniel Wheaton, Mark Arnett, Carl Barnes, Gary Oncina, James Pelligri
November 2, 2021
46-1 The comment states that it is important to note the history of the Project and actions by the Project applicant, including litigation and refusal to supply documentation requested by City staff. The comment further states the EIR is insufficient because it is not possible to do an EIR without knowing the size of homes and without any density bonus information.

The comment regarding the history of the Project and Project applicant is noted and forwarded to the decision makers for their consideration. Regarding the Draft EIR, the analysis used the assumption that single-family lots would range in size between 7,000 and 12,000 square feet with most lots in the 7,000 to 8,000 square foot range, and the attached multifamily housing units would comprise 30,000 to 45,000 total square feet of building area. The construction of these units would require approval by the planning commission and attached residential units would also require a conditional use permit. The Medium Residential (MR) zoning district also contains a density bonus that may be given for affordable housing projects; however, the applicant has not requested consideration of a density bonus as part of the Proposed Project application. This information is included within the Draft EIR. Therefore, no further response is required; and the comment is noted and forwarded to the decision makers for their consideration.
46-2 The comment opines that the Project violates the St. Helena Housing Element and housing laws 17.144 and 17.146 through the segregation of low-income housing from market rate housing and the lack of availability of “for sale” units listed below market rate.

Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. Such an Agreement will need to be approved by the City Council following the Tentative Subdivision Map approval but prior to the Final Map being recorded and before any development of homes can take place. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
46-3 The comment suggests that the segregation of low-income housing from market rate neighborhoods outside of the eastern area of St. Helena limits the possibility for diverse housing, socioeconomic and racial diversity in those neighborhoods. The comment also suggests that City intervention and enforcement of anti-segregation Agenda Item #5.8.

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requirements is necessary in order to ensure a mix of housing types for varying family incomes.

Please see Response to Comment 45-2. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

The comment is noted and forwarded to the decision makers for their consideration. 46-4 The comment opines that the 25 new affordable housing are specifically placed adjacent to the existing lower income, multi-family housing on Adams Street rather than placed among market rate housing, as required by City and state laws. The comment also states that none of these units are for sale which is also required by law.

Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 46-5 The comment references an article about housing segregation in St. Helena.

The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
46-6 The comment suggests that the City and Planning Commissioners may face discrimination claims and lawsuits if violations to City ordinances and state law continue. The comment also suggests that realtors benefit from advertising the west side of St. Helena as preferred or more desirable.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
46-7 The comment states that the City should comply with its ordinances, the Zoning Code, the Housing Element and General Plan as well as new state laws to prevent housing discrimination and segregation. The comment further states that the Project Applicant has no intention to follow laws or contribute to the City’s goal of minimizing housing segregation.

Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. The comment does not identify any specific areas where the Draft EIR Agenda Item #5.8.

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analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 46-8 The comment states that the Project Applicant will claim he is helping the housing situation in the City when he is only providing five units of very low income housing and the ADUs will be at market rate.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
46-9 The comment opines that the Project would not help the City because it would further segregate the City and result in impacts related to traffic, water supply, and liability to flooding. The commenter asks the Planning Commissioners to protect the City.

The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

An attachment to this letter can be found in Appendix B.

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Response to Letter 47
Diane Green, Daniel Wheaton, Mark Arnett, Carl Barnes, Gary Oncina, James Pelligri
November 2, 2021
47-1 The comment states that it is important to note the history of the Project and actions by the Project applicant, including litigation and refusal to supply documentation requested by City staff.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
47-2 The comment opines that the Project violates the City’s Housing Element through the segregation of low-income housing from market rate housing and the lack of availability of “for sale” units listed below market rate. The comment suggests that the segregation of low-income housing from market rate neighborhoods outside of the eastern area of the City limits the possibility for diverse housing, socioeconomic and racial diversity in those neighborhoods.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the Project. Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. Such an Agreement will need to be approved by the City Council following the Tentative Subdivision Map approval but prior to the Final Map being recorded and before any development of homes can take place. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 47-3 The comment opines that the 25 new affordable housing are placed adjacent to the existing lower income, multi-family housing on Adams Street rather than placed among market rate housing, as required by City and state laws.

Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 47-4 The comment references an article about housing segregation in St. Helena.

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The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
47-5 The comment opines that the City and Planning Commissioners may face discrimination claims and lawsuits if violations to City ordinances and state law continue. The comment also suggests that realtors benefit from advertising the west side of St. Helena as preferred or more desirable.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
47-6 The comment states that the City should comply with its ordinances, the Zoning Code, the Housing Element and General Plan as well as new California laws to prevent housing discrimination and segregation.

Please refer to Response to Comment 45-2. Any determination of compliance with the City’s requirements for affordable or inclusionary housing will be made at the time that the applicant submits a formal application for an Affordable Housing Agreement. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 47-7 The comment opines only five units of very low income housing are provided and the ADUs will be at market rate. The comment suggests that the Project would not help the City because it would further segregate the City and result in impacts related to traffic, water supply, and liability to flooding. The commenter asks Planning Commissioners to protect the City.

As noted elsewhere in these Responses, any future Affordable Housing Agreement specifying the type and number of affordable housing units will be reviewed and approved at a future date. It is not correct that a specific number of very low income units has been proposed or approved. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

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Comment Letter 48
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Response to Letter 48
Elizabeth Green
November 3, 2021
48-1 The comment provides a picture of the Vineyard Valley property after a rain and shows an electric panel and diesel pump and expresses concern about flooding.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please also refer to Master Response 4.

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Response to Letter 49
Elizabeth Green
November 5, 2021
49-1 The comment expresses concern over the condition of the levee and suggests that the project site is not a safe place for residences. The commenter requests maintenance records for the levee.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 which addresses concerns associated with the levee and flooding.

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Response to Letter 50
Elizabeth and Rodney Green
November 1, 2021
50-1 The comment states general opposition to the Proposed Project and notes that the commenters reside in close proximity to the Project, in Vineyard Valley.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 50-2 The comment expresses a general concern related to the Project’s water supply; that the current supply is not adequate to serve the proposed residential development.

Please see Master Response 2 that addresses water availability to serve the Project in addition to existing City residences and businesses. 50-3 The comment expresses concern over the Project’s impact on emergency evacuations, specifically in the event of fire or flooding.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, emergency evacuation was analyzed Section 3.14 of the Draft EIR and Project impacts were concluded to be less than significant. Please see Master Response 1, that provides more details specific for emergency evacuation for both Vineyard Valley residents and Project residents.
50-4 The comment raises concerns related to construction traffic; specifically, the commenter is concerned with potential impacts to Highway 29, Pope Street, and the Pope Street Bridge and also notes the temporary closure of Silverado Trail.

Potential Project impacts, as well as impacts related to the construction of the Project, along Highway 29, Pope Street, and the Pope Street Bridge are analyzed in detail within Section 3.14 Transportation of the Draft EIR and within Appendix K, Traffic Impact Study. The comment describes portions of the Silverado Trail that were temporarily closed creating additional congestion along the Pope Bridge; however, the exact location and reason for the closure is not stated. Since the closure is not expected to be permanent, no further response is required. 50-5 The comment expresses a general concern with the Project’s potential impact to parking.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Agenda Item #5.8.

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Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements.
50-6 The comment expresses a concern related to the sewer system that would serve the Project. The commenter believes that the current sewer system does not have capacity to serve the Project and that additional construction would be required to meet the needs of the Project.

The comment does not identify any specific areas where the Draft EIR analysis is Inadequate; therefore, no response is required. Please see Master Response 4 that addresses capacity concerns with the existing wastewater system and Chapter 3, Changes to the Draft EIR for revised language regarding the results of a sewer capacity study.
50-7 The comment expresses a concern that certain City residents would have views that would be negatively impacted by the proposed development.

The Draft EIR analyzes potential changes in views associated with development of the Project under Impact 3.1-2. The Proposed Project is within the City’s Urban Limit Line and would be consistent with the type and character of residential development adjacent to the site. The design of the subdivision maintains the existing street pattern and maintains existing street views of the surrounding area, consistent with the 1993 and 2019 General Plan Policies. The Project would modify long-range views of existing vineyards located to the west and on the Project site as well as views of rolling hillsides which would be partially blocked by development of new residences. However, although long-range views of hillsides and views of the on-site vineyard and open space are available in the vicinity of the Project site, and these views are not unique in that views of these features are available throughout the City.

To illustrate how development of the site could look and how it could affect public views and the existing visual character, visual simulations were prepared (see DEIR pp. 3.1-29, 3.1-30, 3.1-35, 3.1-37, 3.1-39). It was determined that because the Proposed Project would not conflict with applicable regulations governing scenic quality or substantially degrade the existing visual character or quality of public views of the site and its surroundings and impacts would be less than significant. 50-8 The comment raises a concern about the Project’s effect on a secondary emergency access gate for Vineyard Valley residents.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Please also see Master Response 1, that provides more details specific for emergency evacuation for both Vineyard Valley residents and Project residents.

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50-9 The comment requests the City “very seriously consider” the issues raised in this comment letter.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. The comment is noted and forwarded to the decision makers for their consideration.

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Response to Letter 51
Rodney and Elizabeth Green
November 3, 2021
51-1 The comment raises concerns related to the access road along the levee and the Project’s impact on emergency access for Vineyard Valley residents. Specifically, the comment is concerned with access and construction zone for construction trucks and vehicles and how construction might impact emergency evacuation.

Construction activities are not permitted to block access to the levee maintenance road and in the event of an emergency access to the levee would be available. All construction vehicles and equipment would access the site from either Starr Avenue or Adams Street. No truck access would be permitted on the levee maintenance road. Please see Master Response 1 that addresses emergency evacuation concerns for Vineyard Valley residents.
51-2 The comment expresses a concern related to the possible extension of Adams Street to access the Silverado Trail. The comment questions whether Vineyard Valley residents, along with new residents from the Project, could use the access road for emergency evacuation under this scenario.

The Project does not include the future expansion of Adams Street connecting to Silverado Trail. This is a separate City project and is not required for the Project. 51-3 The comment states a concern related to the maintenance and condition of emergency access roads. The commenter is concerned that construction would negatively impact the condition of emergency access roads.

The City is responsible for maintaining roads within the City’s jurisdiction. Please see Response to Comment 51-1 regarding the levee maintenance road and also Master Response 1 that addresses emergency evacuation concerns. 51-4 The comment expresses a concern related to the Project’s impact on emergency response services and the ability of the Fire Department to serve the Project.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, the Draft EIR evaluates the ability of the City’s police and fire departments to accommodate the increase in demand for service in Section 3.12, Public Services and Recreation. As noted on page 3.12-1, the closest police and fire station to the Project site is located 0.2 miles to the southwest. Development of the site was assumed in the City’s 1993 General Plan as well as the recently adopted 2019 General Plan. The addition of new residences would not adversely affect the ability of the City’s police and fire personnel to serve the site. The City’s police and fire departments have adequate staff to accommodate the increase in demand for Agenda Item #5.8.

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services and do not anticipate a decline in response times to the site. Please see Master Response 1.
51-5 The comment questions whether the Napa River levee has been maintained since it was constructed.

Please see Master Response 3 that addresses concerns associated with the levee maintenance and flooding.
51-6 The comment asks who would be held liable for damage and injury in the event of a flood.

Please see Master Response 3 that addresses issues related to the levee and flooding. Determination of legal liability for a potential future event is outside the scope of CEQA. The comment does not identify any specific areas where the Draft EIR is inadequate; therefore, no further response is required. 51-7 The comment expresses general opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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Response to Letter 52
Gale Greisen
November 2, 2021
52-1 The comment asks whether the sewer plant upgrade of 16.2 million would be completed before Project construction, and whether it would affect the $57,000 fine.

The comment references a separate sewer plant upgrade project and does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The new wastewater treatment plant will have the same dryweather treatment capacity at the existing plant. The comment is noted and forwarded to the decision makers for their consideration. 52-2 The comment states that the City’s sewer infrastructure was constructed based on housing to be served at that time. The comment asks whether the existing sewer system would be re-engineered to handle the increased load from the Project.

Please see Master Response 4 that provides more details regarding the Project’s wastewater infrastructure and the ability of the City to convey and treat the Project’s wastewater. See also revisions to the text of the Draft EIR in Chapter 3, Changes to the Draft EIR.
52-3 The comment asks whether the Water Audit lawsuit, which calls for the decommissioning of existing water wells not in use would have any effect on the Project.

The comment asks whether a new permit would be required for the out-of-use well.

The comment is speculating what the outcome of the Water Audit litigation could be on the City and the Project. Please see Master Response 2 that addresses concerns regarding water including the ongoing Water Audit lawsuit. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
52-4 The comment asks what effect the increase of residential units by the Project would have on the Water Audit lawsuit, which cites sustainability goals for existing wells providing domestic water.

Please see Master Response 2 that addresses concerns regarding water including the ongoing Water Audit lawsuit. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. 52-5 The comment asks whether the “new well and the current one in use by the City of St. Helena” are serviced by the same aquifer.

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It is not clear what the “new well” is that is referred to in this comment. As discussed in the Draft EIR, the Project is not proposing to drill a new well to serve the water needs of new residential units. The Project is proposing to use an existing onsite agricultural well to irrigate the Project’s public and private landscaping. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
52-6 The comment asks whether it would be more appropriate to retrofit homes with water-saving devices prior to adding the Project’s increase in demand. The commenter is concerned that few residents would agree to have water-saving devices installed in their homes and that the Project would be constructed and occupied prior to offsetting the Project’s increase in demand. The comment asks whether the homes to be retrofitted with water-saving devices would only be on the east side of the City.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. Please see Master Response 2 that addresses water supply concerns.

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Response to Letter 53
Henry Gundling
October 12, 2021
53-1 The comment finds fault with the claim that the Project would be “water neutral” and that the Draft EIR does not calculate the amount of water supplied from the City’s aquifer upstream of the municipal wells.

The Proposed Project is required to be in compliance with the City’s Water Neutral Policy. Appendix J of the Draft EIR provides the required Water Neutral Report for the Project as the first step in compliance. The Draft EIR provides an analysis of the sources of water to supply the Project’s water demand beginning on page 3.9-40 and also on pages 3.13-35 and 3.13-36. See also Master Response 2 for further details on the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
53-2 The commenter claims any water used for landscaping would have an impact on the City’s groundwater supplies.

The Draft EIR analyzes the potential impact of the Project’s water demand sourced from groundwater on pages 3.9-40 through 3.9-43 and also on pages 3.13-35 and

3.13-36. The Draft EIR concludes that the Project’s demand on groundwater supplies is relatively small and, in part, would be addressed via adherence to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. See also Master Response 2.
53-3 The comment questions the ability of the Project to be able to meet the Water Neutral Policy requirements to offset the proposed water supply demand for the indoor water usage.

The Proposed Project is required to adhere to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the City’s Municipal Code. See further discussion of the City’s Water Neutral Policy and Municipal Code requirements in Master Response 2.
53-4 The commenter cites an example project (Las Alcobas Hotel) as one where funds from the developer may not have resulted in the intended outcome.

The comment is referring to a different project and does not identify any specific areas where the Draft EIR analysis is inadequate. See also Master Response 2. 53-5 The comment states that the Draft EIR is inadequate because it does not disclose groundwater impacts for residents and wildlife and that the City should insist on verifiable conservation benefits.

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The Draft EIR analyzes the potential impact of the Project’s water demand sourced from groundwater on pages 3.9-40 through 3.9-43 and also on pages 3.13-35 and

3.13-36. The potential impacts to wildlife are analyzed in Section 3.4 Biological Resources. The reference to conservation benefits likely refers to the efficacy of the Water Neutral Policy and Municipal Code which is beyond the scope of CEQA in relation to the Proposed Project. See Master Response 2 for additional information specific to water supply.
53-6 The comment expresses a concern related to the City’s current and future water restrictions and states the Project should not be approved due to its impact on water supply.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Please see Master Response 2 that addresses water availability to serve the Project in addition to existing City residences and businesses.

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Response to Letter 54
Henry Gundling
October 12, 2021
54-1 The commenter does not believe the project would be “water neutral” and the Draft EIR does not calculate the amount of water that supplied from the City’s aquifer upstream of the municipal wells. The commenter claims any water used for landscaping would have to have an impact on the City’s groundwater supplies. The comment further questions the ability of the Project to meet the Water Neutral Policy requirements and cites an example project (Las Alcobas Hotel) as one where funds from the developer may not have resulted in the intended outcome.

See Response to Comment 53-4 and Master Response 2 for further details on the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
54-2 The comment claims that the Draft EIR is inadequate because the Draft EIR does not disclose groundwater impacts for residents and wildlife and that the City should insist on verifiable conservation benefits.

See Response to Comment 53-5 and Responses to Comment 14-4 regarding impacts to wildlife.
54-3 The comment expresses a concern related to the City’s current and future water restrictions and states that the Project should not be approved due to its impact on water supply.

See Response to Comment 53-6.

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Response to Letter 55
Kathleen Guneratne
November 29, 2021
55-1 The commenter indicates her support of affordable housing but does not consider this to be an affordable housing project.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please refer to Chapter 2, Project Description of the Draft EIR, which describes the Project. See page 2-18 that addresses affordable housing. At this time the only request by the Project applicant is to subdivide the lots consistent with the General Plan and Zoning. The Project will need to fulfill the code required inclusionary housing requirements which will be specified in a future affordable housing agreement.
55-2 The comment opines that the Project will result in negative impacts to the neighborhood due to being within a flood plain, limited water resources, increase in population and traffic, and opposes the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.

Please see Master Response 3 that addresses concerns associated with the levee and flooding; and Master Response 2 that addresses the adequacy of water supplies. 55-3 The comment notes concern for adequate preservation of protected wildlife.

Direct and indirect impacts to federal and state protected wildlife are addressed in Section 3.4, Biological Resources of the Draft EIR. Mitigation is included to conduct pre-construction surveys to ensure these species are not disturbed if present. The Draft EIR provides for adequate protection of protected wildlife species. 55-4 The comment asks if the Project would affect any sacred burial sites of the Wappo Indian Tribe and references an article in a local newspaper.

Pursuant to AB 52, the City sent letters to all tribes requesting notification and received responses from the Federated Indians of Graton Rancheria and the Yocha Dehe Wintun Nation. No response was received from the Wappo Indian Tribe. Neither the Federated Indians of Graton Rancheria nor the Yocha Dehe Wintun Nation tribe requested formal consultation with the City. The analysis of potential impacts to cultural resources is included in Section 3.5, Cultural and Tribal Cultural Resources.

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Response to Letter 56
Mariam Hansen
October 18, 2021
56-1 The comment suggests methods to achieve water neutrality, including installing water meters, but also states that this approach did not work in Vineyard Valley.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Master Response 2 that addresses compliance with the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
56-2 The comment notes that other projects were required to retrofit toilets in the City and questions how many are still needed to be retrofitted.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Master Response 2 that addresses compliance with the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
56-3 The comment suggests that Vineyard Valley residents will object to building an emergency exit from the Project’s proposed cul-de-sac. The commenter has concerns related to emergency evacuation.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, emergency evacuation was analyzed Section 3.14 of the Draft EIR and Project impacts were concluded to be less than significant. Please also see Master Response 1, that provides more details specific for emergency evacuation for both Vineyard Valley residents and the Proposed Project. 56-4 The comment states opposition to a “freeway off-ramp style bridge” at the existing Pope Street bridge over the Napa River and a preference to extend Adams Street to Silverado Trail.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
56-5 The comment raises a general concern about the public comment period and outreach efforts.

The Draft EIR was released for the required 45-day public review period on September 23, 2021 through November 8, 2021. In response to numerous requests, the City extended the comment period through November 30, 2021 for a total of 67 days.

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Response to Letter 57
Donna Hardy
November 1, 2021
57-1 The comment asks whether the City has enough water in drought years to serve the Project and whether water neutrality could be achieved by water conservation and retrofitting old fixtures. The comment goes on to ask whether an agricultural well should be used for landscape watering to help the Project achieve water neutrality.

The Project is proposing to use the existing on-site well to supply water for landscaping, as explained on page 2-26 in Chapter 2, Project Description. Please see Master Response 2 that addresses water supply.
57-2 The commenter interprets the City’s 1993 General Plan as requiring that Adams Street be extended to the Silverado Trail and questions why this extension is not required by the Project as a condition of approval.

The Project does not include the future expansion of Adams Street connecting to Silverado Trail. The City’s Public Works Department reviewed the tentative subdivision map and determined the extension of Adams beyond the new intersection with Starr Avenue is not required. This is a separate City project and is not required for the Project.

The comment is noted and forwarded to the decision makers for their consideration. 57-3 The comment states that the project site was within a flood plain before the Napa River levee was built and that after levee construction, the flood zone designation was changed. The comment states the City could be held responsible in the event of a levee failure. The comment goes on to ask whether the City would be held in noncompliance of the Measure A agreement if the Project is developed and if the levee changed the buildability of the site.

Measure A, as described on page 3.9-6 of the Draft EIR, was passed in 1998 by Napa County and provided the basis for a number of flood improvement projects.

The Project site has been designated and zoned for residential development dating as far back as the City’s 1975 General Plan, as stated on page 2-12 of the Draft EIR.

The Project is not funded in any part with Measure A funds. The City’s Flood Control Project, which did receive Measure A funds, was designed to provide flood protection for both developed areas within the City, as well as areas already planned for future development, including the Project site. For further detail, please see Master Response 3 for more information concerning the levee.
57-4 The comment asks whether the Project would be required to retrofit fixtures in the City and implement other water saving features, in compliance with the Water Neutral Policy. The comment also expresses concern given the City’s current water supply and water saving requirements.

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As stated in the Draft EIR on page 3.9-41, the Proposed Project is required to comply with the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. See also Master Response 2 for more information on water supply. 57-5 The comment opines that the Project would use groundwater from an on-site well for exterior (landscaping) uses and that the well is within a subbasin that may include the pumping influence zone of the Stonebridge Complex, which supplies some City water.

The on-site well was evaluated in the referenced well capacity and sustainability assessment (Appendix L of the Draft EIR) and was determined to have sufficient capacity to meet the proposed demand. The assessment conducted a 24-hour pumping test at a rate (40 gallons per minute [gpm]) of approximately four times the proposed rate (10.6 gpm) which only produced one foot of drawdown in the pumping well. The proposed average pumping rate of 10.6 gpm is relatively small compared with existing agricultural wells (DEIR p. 3.9-43). Therefore, the Draft EIR correctly identifies that the proposed use of the well would have a less-than-significant impact on the subbasin and as a result also on the City’s Stone Bridge wells. 57-6 The comment states that the City is currently under litigation by a corporation, Water Audit California, for its use of wells in the Stonebridge Complex and pattern of issuing new permits for wells. The commenter raises a concern that the Project would further raise issues given the ongoing litigation.

See Master Response 2 for details related to the litigation involving the Water Audit. 57-7 The comment opines that there is insufficient groundwater supply to meet the Project’s demand and that use of the on-site well could result in further litigation.

See Master Response 2 for further details regarding the City’s water supplies and ability to meet future demands. As noted in the Draft EIR on page 3.9-41, the Proposed Project would be required to adhere to the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code which requires conservation measures or fees to fund the City’s conservation measures commensurate with the Project’s demand. Otherwise, whether use of the existing onsite well could be the subject of litigation is outside the scope of CEQA and does raise any issue as to the adequacy of the analysis in the Draft EIR. 57-8 The comment raises concerns regarding peak hour traffic at the intersection of Pope Street and Starr Avenue and states that Starr Avenue serves more than residential users because many motorists use it as a shortcut and further claims the EIR does not represent this street correctly in terms of the types of its users.

Starr Avenue is classified as a “residential street” per the Circulation Element of the City’s 2019 General Plan, which is defined predominantly as a roadway that provides Agenda Item #5.8.

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residential access and support for local trips. The Proposed Project would not alter the existing or General Plan classification of Starr Avenue or alter the way the road is used. Section 3.14 of the Draft EIR, as well as Appendix K, Traffic Impact Study, analyzes the intersection of Pope Street and Starr Avenue, both in terms of potential level of service (LOS) impacts and vehicular queuing. The analysis concludes that the impact to this intersection, with or without Project traffic, in every analysis scenario, would be less than significant and would not require improvements to the intersection. An analysis of LOS or traffic congestion and queuing is no longer required to be evaluated in an EIR as by law, an increase in LOS can no longer be considered an environmental impact under CEQA.
57-9 The comment states her personal observation that Railroad Avenue is used by motorists as a shortcut street to avoid Main Street and claims the EIR does not represent this street correctly because it does not mainly serve industrial and commercial uses.

Railroad Avenue is classified as a “downtown/mixed-use street” per the Circulation Element of the City’s 2019 General Plan, which is defined predominantly as a roadway that supports all travel modes and promotes multimodal access. The Proposed Project would not alter the existing or General Plan classification of Railroad Avenue or alter the way the road is used. Further, Section 3.14 of the Draft EIR, as well as Appendix K, Traffic Impact Study, thoroughly analyzes several intersections along Railroad Avenue (intersections with Fulton Lane, Adams Street, and Hunt Avenue), both in terms of potential LOS impacts and vehicular queuing.

The analysis concludes that the impact to these intersections, with or without Project traffic, in every analysis scenario, would be less than significant and would not require improvements to the intersection. An analysis of LOS and queuing is no longer required to be evaluated in an EIR as. by law, an increase in LOS can no longer be considered an environmental impact under CEQA. 57-10 The commenter offers an observation that Adams Street is a busy downtown street and raises a concern related to the Draft EIR’s description of the users of this street and others in the area.

Adams Street is classified as a “downtown/mixed-use street” per the Circulation Element of the City’s 2019 General Plan, which is defined predominantly as a roadway that supports all travel modes and promotes multimodal access. The Proposed Project would not alter the existing or General Plan classification of Adams Street or alter the way the road is used. Further, Section 3.14 of the Draft EIR, as well as Appendix K, Traffic Impact Study, thoroughly analyzes several intersections along Adams Street (intersections with Main Street, Railroad Avenue, and Library Lane), both in terms of potential LOS impacts and vehicular queuing. The analysis concludes that the impact to these intersections, with or without Project traffic, in every analysis scenario, would be less than significant and would not require improvements to the intersection. An analysis of LOS and queuing is no longer required to be evaluated in an EIR, as. by law, an increase in LOS can no longer be considered an environmental impact under CEQA .

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All roadways analyzed within Section 3.14 of the Draft EIR, as well as Appendix K, Traffic Impact Study, utilized descriptions and characterizations as described in the Circulation Element of the City’s 2019 General Plan.
57-11 The comment opines an extension of Adams Street to the Silverado Trail would alleviate traffic created by the Project and provides excerpts from the 1993 General Plan that stipulates this extension.

The City acknowledges that the extension of Adams Street to Silverado Trail is included in the adopted Circulation Element of the General Plan. See Response to Comment 57-

2. The comment is noted and forwarded to the decision makers for their consideration. 57-12 The comment offers an opinion that the Project should be conditioned to extend Adams Street to the Silverado Trail to reduce traffic on the Pope Street Bridge, Pope Street, and Starr Avenue. The commenter believes the Project uses objectives from the General Plan that support the Project but overlooks the Adams Street extension.

Please see Response to Comment 57-11. The comment is noted and forwarded to the decision makers for their consideration and no further response is required. 57-13 The comment states that the project site was originally within a floodplain until the City constructed the Napa River levee. The commenter questions whether the Project would result in the City violating the terms of the Measure A agreement by allowing homes to be built on land that was previously within a floodplain. The comment also asks if Measure A changed the buildability of the Project site.

Measure A, as described on page 3.9-6 of the Draft EIR, was passed in 1998 by Napa County and provided the basis for a number of flood improvement projects.

The Project site has been designated and zoned for future residential development dating as far back as the City’s 1975 General Plan, as stated on page 2-12 of the Draft EIR. The Project is not funded in any part with Measure A funds. The City’s Flood Control Project, which did receive Measure A funds, was designed to provide flood protection for both developed areas within the City as well as areas already planned for future development, including the Project site. For further detail, please see Master Response 3 for more information on Measure A. 57-14 The commenter states an opinion that homes should not be built in areas that have a “low ... possibility” of flooding. The comment also raises a concern regarding the City’s responsibilities and liabilities in the event of major flood event and states the Project should not be approved.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Master Response 3 that addresses the City’s liability in the event of a major flood event.

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Response to Letter 58
Carla Holm
November 3, 2021
58-1 The commenter shares personal history and her relief that the City completed the levee along the Napa River.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
58-2 The comment expresses a general concern that the Project will cause significant erosion.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, erosion impacts were analyzed in Section 3.9 of the Draft EIR; and impacts were determined to be less than significant because the Project would be required to comply with existing state and city permitting requirements and conditions of approval that regulate erosion.
58-3 The comment expresses a general concern regarding the City’s sewer system capacity.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Section 3.13 of the Draft EIR discusses sewer system capacity in the City. Additionally, pursuant to Municipal Code Section 3.32.020, the City collects development impact fees on new development to pay for public improvements related to sewer projects. The Project applicant would be required to pay these fees, which would help fund future improvement projects. Please see Master Response 4 that addresses sewer concerns.
58-4 The comment expresses a general concern regarding the Project’s water usage.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, Master Response 2 addresses water supply concerns.
58-5 The comment expresses a general concern that the Project would create a negative impact on police and fire protection services.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, the Draft EIR evaluates the ability of the City’s police and fire departments to accommodate the increase in demand for service in Section 3.12, Public Services and Recreation. Development of the site was assumed in the City’s 1993 General Plan as well as the recently adopted 2019 General Plan. As discussed Agenda Item #5.8.

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in the Draft EIR, the City’s police and fire departments have adequate personnel to serve the Project and expansion of existing stations would not be required. 58-6 The comment states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 59
Suzanne James
November 22, 2021
59-1 The comment states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
59-2 The comment expresses a general concern over the Project’s impact to traffic congestion.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. Please also see Response to Comments 10-2 and 36-2 for additional information.
59-3 The comment expresses general concerns over pollution, noise, and safety for pedestrians.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Therefore, a general overview of impacts addressed in the Draft EIR specific to air quality, noise, and pedestrian traffic safety is provided. The Draft EIR addresses direct and indirect impacts associated with construction and operation of the Project. Section 3.3, Air Quality, identifies sensitive receptors and notes close proximity to residences. The Bay Area Air Quality Management District (BAAQMD) establishes thresholds for the evaluation of potential impacts, which are established to be protective of human health. The EIR concluded that construction and operation of the Proposed Project would not result in emissions that exceed the BAAQMD emission thresholds for any criteria air pollutants, including reactive organic gases (ROG), nitrogen dioxide and nitric oxide (NOx), particulate matter (PM10, or PM2.5). ROG emissions would be associated with motor vehicles, construction equipment, and architectural coatings (paint). The analysis also addresses if the Project would expose sensitive receptors to substantial pollutant concentrations. The BAAQMD has adopted project and cumulative thresholds for three risk-related air quality indicators to sensitive receptors: cancer risks, noncancer health effects, and increases in ambient air concentrations of PM2.5. This includes exposure to PM2.5 and other toxic air contaminants (TAC) which would occur during construction activities. The primary TAC is diesel particulate matter (DPM) which is emitted from emissions associated with construction equipment operations and heavyduty trucks during construction activities, and the associated health impacts to sensitive receptors. Based on the modeling conducted for the Project construction activities would not exceed the BAAQMD thresholds resulting in exposure of sensitive receptors in the vicinity of the Project site to substantial TAC concentrations (see DEIR Tables 3.3-8 and

3.3-9, p. 3.3-33).

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Please see Response to Comment 38-1 for more information on noise impacts.

Pedestrian safety along with transportation impacts are analyzed in Section 3.14 of the Draft EIR. This section analyzes Project impacts related to consistency with plans or policies addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. As noted on page 3.14-40, the Project includes the extension of Adams Street and Starr Avenue to provide vehicle, bicycle and pedestrian access to the site, consistent with the 1993 General Plan Policy 5.8.1 and Policy CR1.1 from the City’s 2019 General Plan. Sidewalks would be provided along both sides of the street allowing safe pedestrian access to the site from adjacent areas. Sidewalks are also available connecting the Project site to downtown St.

Helena, including neighborhood services along Main Street, retail and grocery stores, and the City’s Public Library. The Proposed Project would provide adequate sidewalks and would not conflict with any plans or policies supporting either the development of these facilities or the use of these facilities; therefore, impacts are less than significant.
59-4 The comment expresses concern over the Project’s impact to the City’s water supply and their belief that the Draft EIR underestimates the Project’s water demand.

Please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. As stated on page 3.13-24 of the Draft EIR, a Water Neutral Report was prepared for the Project that assumes a higher and more conservative persons per household (PPH) rate as compared to the City’s PPH to determine population to calculate water demand.
59-5 The comment states the Project would tie into the City’s existing stormwater infrastructure and sewer lines that also serve Vineyard Valley Mobile Home Park and opines that adequate capacity is not available in the existing stormwater and sewer infrastructure to serve the Project.

The ability of the City’s existing stormwater and wastewater infrastructure to serve the Project is addressed in the Draft EIR in Section 3.13, Utilities and Service Systems. As indicated in this section, the City’s detention basin was designed to accommodate stormwater runoff assuming 70% of the Project site would be developed with impervious surfaces (i.e., roads, sidewalks, homes), which is more than the amount of impervious surface area to be developed under the Project.

Pursuant to Municipal Code Section 3.32.020, the City collects development impact fees on new development to pay for public improvements related to stormwater drainage projects. The Proposed Project applicant would pay these fees, which would help offset any increased demands on the City’s stormwater drainage system. Therefore, the Proposed Project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities and the impact would be less than significant.

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Wastewater flows from the western portion of the Project site are proposed to drain into an existing public manhole at the corner of Starr Avenue and Hunt Avenue via new 8- inch sewer pipes. The area east of Starr Avenue, lower in elevation, is proposed to drain east through the Project site via new 8-inch sewer pipes within a public easement and into an existing public manhole in the Vineyard Valley Mobile Home Park. All new sewer mains and lines are sized to accommodate Project flows, per City standards. Please see also Master Response 4 that provides more details regarding the Project’s wastewater infrastructure and the ability of the City to convey and treat the Project’s wastewater. 59-6 The comment raises a concern related to emergency evacuation for Vineyard Valley residents.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Emergency evacuation was analyzed Section 3.14 of the Draft EIR and Project impacts were concluded to be less than significant. Please also see Master Response 1, that provides more details related to emergency evacuation for both Vineyard Valley residents and the Proposed Project
59-7 The commenter is concerned about the construction timeline and devaluation of properties.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The commenter’s concern related to property devaluation is not required to be evaluated in an EIR. 59-8 The comment raises general concerns related to the cost of the Project for the City and re-iterates issues raised in Comments 59-2 through 59-7.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not introduce new issues related the accuracy or adequacy of the Draft EIR; therefore, no response is required. Please see Responses to Comments 59-2 through 59-7.
59-9 The commenter is opposed to the Project and urges the City to reject the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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Response to Letter 60
Frank and Tracy Jonelis
November 1, 2021
60-1 The comment states opposition to the Project due to its proposed size and density.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 60-2 The comment raises concerns regarding the Project’s increase in water demand and believes that the Draft EIR underestimates the Project’s water usage.

Please see Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
60-3 The comment raises general concerns related to the Project’s generation of traffic, stating that Project traffic will generate pollution, noise, and congestion.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Please also see Response to Comment 59-3 for information on pollution and noise impacts.
60-4 The comment states a general concern regarding the Project’s increase in impervious surfaces.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. However, as stated in the Draft EIR on pages 3.9-44 and 3.9-45, the additional stormwater runoff created by the Proposed Project would be directed to the City-owned off-site detention basin, adjacent to the Project site, which has been designed to store the increase in storm water runoff from the Project site during a 100- year storm event. The detention basin was designed assuming that the Project site would be developed with 70% impervious surfaces; however, the Project would develop less of the site (58%) with impervious surfaces. Therefore, the stormwater runoff from the proposed Project would be adequately served by the off-site detention basin. 60-5 The comment states that the Project is proposed on a flood plain and could be subject to historical storms, which could be even more severe due to climate change.

Flooding and flood hazards as a result of storms are addressed in the Draft EIR starting on page 3.9-5 of Section 3.9, Hydrology and Water Quality. As shown in Figure 3.9-2, the Project site is not within a Special Flood Hazard Areas but is mapped as being in an area with reduced flood risk due to a levee (FEMA 2012). By being within an area of reduced risk due to levee, the Project site is considered Agenda Item #5.8.

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mapped within the 500-year flood zone (FEMA 2012). Based on the levee design, the Project site would be subject to a flood exceeding a 200-year recurrence interval, equivalent to less than a 0.5% annual chance. FEMA has established the Project site is not subject to any floodplain development restrictions such as the requirement to purchase flood insurance (FEMA 2012). The likelihood of a serious flood affecting the Project site (as well as those areas also protected by the levee/flood wall) is very low. In addition, the levee provides greater than the often standard 100-year flood with a 200-year flood design to account for other factors such as climate change.

Please see Master Response 3.
60-6 The comment opines that the City does not have consistent water supply to serve its residents and that the Project would use more water than what is assessed in the Draft EIR.

Please see Response to Comment 60-2 and Master Response 2 that addresses the City’s ability to supply water and the requirements of the Water Neutral Policy. 60-7 The comment opines that there is no way to guarantee future extreme weather events would be contained by the Napa River levee and that the City would be liable for any damage.

Please see Response to Comment 60-5 and Master Response 3 that addresses City liability in a flood event.
60-8 The comment raises general concerns related to the Project’s impact on water supply, traffic, noise, and flood risk.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Responses 2 and 3 regarding water supply and levee concerns and Response to Comment 38-1. 60-9 The commenter states their opposition to the Project and urges the City to reject the Project.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

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Response to Letter 61
Sherri Kelly
October 27, 2021
61-1 The comment is an introduction to the concerns presented in the comment letter.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
61-2 The commenter states their concerns related to Project construction exacerbating existing noise and air quality conditions within the area including generation of fugitive dust.

As discussed in the Draft EIR in Section 3.3, Air Quality, in developing thresholds of significance for air pollutants, the Bay Area Air Quality Management District (BAAQMD) considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be considered cumulatively considerable, resulting in a significant adverse air quality impact to the region’s existing air quality conditions.

Construction and operation of the Project would not result in an exceedance of the BAAQMD significance thresholds as presented in Tables 3.3-8 and 3.3-9.

Furthermore, the Project would implement the BAAQMD’s Best Management Practices (BMPs) for fugitive dust control during construction.

Please also see Response to Comment 38-1 regarding noise impacts. 61-3 The commenter opines that the Draft EIR verifies that the Project would result in the probable worsening of existing air quality issues resulting in significant impacts.

Please see Response to Comment 61-2. The Draft EIR concluded that the Project would not result in exacerbating existing air quality conditions and would not result in the exceedance of the BAAQMD thresholds of significance for both construction and operations. Furthermore, heavy-duty equipment on the Project site during construction would emit odors. However, construction activity would be short-term and would cease to occur after construction is completed. Regarding operations, the Project would develop residential uses which is not a typical land use associated with the generation of a source of odors.
61-4 The comment asks whether the City or the Project applicant would be legally and financially responsible for the loss of health, life, or property resulting from the degradation of air quality and the environment under the 6-year Project construction period.

Legal and financial concerns regarding a project are not environmental impacts under CEQA and are not evaluated in an EIR. The comment does not identify Agenda Item #5.8.

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specific areas where the Draft EIR is inadequate; therefore, no further response is required.
61-5 The comment suggests that the City is in a water emergency and upgrades would be necessary to ensure water service is provided to existing residents. The comment also states that the City has contributed to the worsening of the water shortage and many residents incurred fines for excessive water use as a result of City water rationing regulations.

Please see Master Response 2 for information on adequate water supplies. 61-6 The comment describes their personal experiences that suggest ongoing issues with the quality of water provided by the City, and malfunctions at the City sewage treatment plant and goes on to describe their experience with possible water contamination.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
61-7 The comment asks how the City or Project applicant can approve the Project due to the City’s water concerns.

Please see Master Response 2 for information on water availability in the City. 61-8 The comment asks whether the City or Project applicant would be held legally and financially responsible for future injury to health, life, or property resulting from the exacerbation of the City’s water supply and water quality issues from the Project.

The comment is noted and forwarded to the decision makers for their consideration.

Legal liability for a potential future event is not within the scope of CEQA. 61-9 The comment opines that the Project does not adequately address the City’s water issues.

Please see Master Response 2 for further information on water supply and availability to serve the Project.
61-10 The comment opines that, due to potential liquefaction/settlement issues of weak soils, the Project could expose residences to significant impacts.

The impact analysis of potential liquefaction hazards at the site is addressed in the Draft EIR beginning on page 3.6-21. The analysis concludes that this hazard is potentially significant. However, Mitigation Measure GEO-1 ensures that a designlevel geotechnical report be completed prior to issuance of a grading or building permit. Adherence to this mitigation measure and City Building requirements would Agenda Item #5.8.

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reduce the potential impact to less than significant by incorporating design measures that can reduce potential impacts from liquefaction/settlement to less-than-significant levels.
61-11 The comment asks whether the Napa River levee was constructed according to accepted engineering and safety standards, and whether the City or Project applicant would be responsible for future damage to life, health or property if the levee were to fail.

Legal liability for a potential future event is not within the scope of CEQA.

Please see Master Response 3 for more information on the levee. 61-12 The comment asks for a mitigation measure to address the potential impact of the levee overtopping or flooding from a 200-year flood event.

As discussed on page 3.0-1 of the Draft EIR, the purpose of the CEQA analysis is to identify the potential impacts of a project on the environment and not the effects of the environment on the project. However, as noted on page 3.9-12 of the Draft EIR, the potential for failure of the levee has less than a 0.5% chance of occurring in any given year and there would be no substantive risk to human health. Nonetheless, CEQA does not require mitigation for a potential impact of the environment on the Project. Please see Master Response 3 for more information specific to the levee and the Project’s Conditions of Approval.
61-13 The comment opines that the Project has legal and financial consequences to the City, and possible public safety consequences. The comment suggests that the Project should not be built in the proposed location because it would be unsafe for future residents.

See Master Response 3 for further information on City liability and Response to Comment 61-4 regarding legal and financial concerns. The comment is noted and forwarded to the decision makers for their consideration. 61-14 The comment asks whether the City or the Project applicant would be legally and financially responsible for any future loss of health, life, or property resulting from a levee break or earthquake damage to the Project.

Determinations of legal liability for a potential future event is outside the scope of CEQA. Please see Master Response 3 for information regarding the levee.

Additionally, please see Response to Comment 61-10 regarding how any potential earthquake hazards would be mitigated.
61-15 The comment opines that the Proposed Project would result in inadequate emergency access.

Please see Master Response 1 that addresses emergency access concerns.

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61-16 The comment notes the conclusion in the Draft EIR that the Project would be in conflict with CEQA Guidelines Section 15064.3(b).

Traffic is evaluated in Section 3.14 of the Draft EIR, which analyzes the Project’s increase in vehicle miles traveled (VMT), consistent with CEQA Guidelines Section 15064.3(b). The analysis concludes that the Project would have a significant and unavoidable impact due to an increase in VMT. Since the comment does not elaborate, or provide any substantial evidence to support the claim that the Draft EIR is inadequate, no further response is required.
61-17 The comment re-states the text on page 2-23 of the Draft EIR regarding the extension of Adams Street and Starr Avenue onto the Project site to provide two points of ingress and egress.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
61-18 The comment states an opinion that parking is congested in the neighborhood and that overall traffic congestion will hinder emergency evacuation in the area.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. Please see Master Response 1 for information regarding emergency vehicle access.
61-19 The comment opines that the addition of more than 80 new households must require several additional entry and exit points, in addition to the two cited in the Draft EIR.

The comment also questions whether there will be a bridge built crossing the river at the intersection of Adams Street and Silverado Trail.

The Project provides two points of access along with emergency evacuation access, consistent with City requirements for this type of development. The commenter’s opinion that additional points of access area required is noted and forwarded to the decision makers for their consideration. Additionally, please see Master Response 1 regarding emergency evacuation. The Proposed Project does not include the construction of a new bridge and does not involve any further extension of Adams Street, east of Starr Avenue. Any extension of Adams Street connecting to Silverado Trail would require further study and approval by the City and is not required for this Project.

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61-20 The comment notes that the Draft EIR acknowledges the historic frequency of floods and wildfires in the Project vicinity and states the commenter’s opinion that the limited points of egress on the east side of the City have a history of creating crisis situations.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. However, please see Master Response 1 for additional information regarding emergency evacuation. 61-21 The comment asks why increased housing density is being considered in an area of the City with few points of safe entry and exit and why the recommendations of the California Department of Transportation regarding development of safe evacuation routes have not been followed.

Please see Master Response 1 for information regarding emergency evacuation. 61-22 The comment references a past media campaign promoting the ZoneHaven evacuation management platform and asks why the City is considering endangering the safety of residents by introducing new households to an area with few evacuation routes.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. However, please see Master Response 1 for additional information regarding emergency evacuation. 61-23 The comment asks whether the City or the Project applicant would be legally and financially responsible for any future loss of health, life, or property resulting from evacuation failures around the Proposed Project.

Legal liability for a potential future event is outside the scope of CEQA. Please see Master Response 1 regarding emergency evacuation and Master Response 3 regarding City liability and Response to Comment 61-4.
61-24 The comment states an opinion that most high-density and low-income housing in the City has been constructed east of Main Street and that these actions qualify as discrimination under the jurisdiction of the U.S. Office of Fair Housing and Equal Opportunity.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the Project. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

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61-25 The comment asks when a comparative number of high-density or low-income housing units, or a project similar in size and scope to the Proposed Project would be built west of Main Street in order to mitigate for past "discrimination.” The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
61-26 The comment states an opinion that the Project would pose an imminent threat to public health and safety and therefore qualifies as an exception to the California Housing Crisis Act of 2019 (SB 330), which prohibits the City from restricting housing development.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the Project. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
61-27 The comment supports Alternative 2, the Park Preserve alternative, as the best use of the Project site.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.

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COMMENT LETTER 62
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Response to Letter 62
Sherri Kelly
November 3, 2021
62-1 The comment provides the commenter’s personal history as a resident of the City and requests that the Project be studied in order to gain complete understanding of its consequences.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
62-2 The commenter states they have not been able to review and understand the Draft EIR in the public review timeframe provided.

The public was provided a 67-day period ending on November 30, 2021, exceeding the required 45-day period. The commenter’s request for additional time to review the EIR is noted.
62-3 The commenter requests that the 45-day public review timeframe be extended.

Please see Response to Comment 62-2.

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Response to Letter 63
Pat Kenealy
November 2, 2021
63-1 The comment states general opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 63-2 The comment expresses general concern regarding the Project’s impact on traffic, the City’s sewer system, and flood protection.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate. The Project’s impact on transportation and circulation is addressed in Section 3.14, Transportation and Circulation. Master Response 3 addresses concerns related to flooding and flood protection and Master Response 4 addresses wastewater. 63-3 The comment states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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Response to Letter 64
Susan Kenward
64-1 The commenter states their opposition to the Project. In particular, the commenter raises concerns related to water neutrality, conservation easements, traffic and the Project’s compliance with the City’s Municipal Code.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, please refer to Master Response 2 regarding water neutrality, Response to Comment 45-2 regarding affordable housing and the City’s Municipal Code, and Responses to Comments 32-6, 57-9 and 61-10 regarding traffic on Railroad Avenue and building a new bridge over the Napa River. Please see Response to Comment 36-3 regarding the easement.
64-2 The comment expresses concern related to the Napa River levee. In particular, the comment claims that the levee project was financially mismanaged and that there are ongoing concerns related to flood-risk management. The comment claims the levee was built wider than intended or needed and that the Project conflicts with a provision in the City’s Measure A agreement.

The comment does not identify any specific areas where the Draft EIR is inadequate; therefore, no further response is required. Please see Master Response 3 for more information regarding the levee and Measure A.
64-3 The comment expresses concern related to future homeowner’s ability to purchase flood insurance and also questions who would be liable for damages associated potential levee failure.

The Project site is outside of a FEMA special flood hazard area; therefore, purchase of flood insurance would not be required. However, because there remains residual risk of flooding from catastrophically large floods (such as a 500-year flood) or levee failures, property owners would have the option to purchase flood insurance.

Regarding the liability for damage in the event of a catastrophic flood event, please see Master Response 3.
64-4 The comment provides an unreferenced quote that states levee failure is a possibility and urges the City to assess long term risks associated with levee protection.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, please refer to Master Response 3 for more information specific to the levee and potential flood risks.

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64-5 The commenter requests the City’s Planning Commission and City Council perform due diligence when reviewing the Project.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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COMMENT LETTER 65
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Response to Letter 65
Grace Kistner
November 23, 2021
65-1 The comment states a concern related to the Project’s compliance with Measure A.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, please refer to Master Response 3 and Response to Comments 35-6 and 57-3 regarding Measure A. 65-2 The comment provides an excerpt from Measure A stating that projects funded under this Measure are not intended to encourage population growth.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, please refer to Master Response 3 and Response to Comments 35-6 and 57-3 regarding Measure A. 65-3 The comment states there would “significantly” increase the population of St. Helena.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. The Draft EIR projects that the Project would add 213 residents to the existing population (6,049 as of 2020), an increase of 3.5% that is within the population growth estimates in the adopted 2040 General Plan.
65-4 The comment claims that flood protection to existing residents would decrease due to the Project because of an increase in impervious surfaces. The comment also states that an increase in impervious surfaces would also produce more sediment flowing into the Napa River.

Please see Response to Comment 35-4. Regarding increased sediments flowing into the Napa River, the Draft EIR addresses this concern in Chapter 3.9, Hydrology and Water Quality. Specifically, on page 3.9-45 the Draft EIR concludes the impact water quality would be less than significant, because compliance with existing permitting requirements and conditions of approval (i.e., MS4 Permit and the City’s Stormwater and Runoff Pollution Control Ordinance) are sufficient to avoid water quality degradation (including erosion and siltation).
65-5 The comment raises a concern related to the Project’s proposed use of well water and its impact on groundwater supply.

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Please refer to Response to Comment 57-5 and Master Response 2 regarding the use of well water and the reliability of water supply.
65-6 The comment states that Measure A should be grounds for denying the Project.

Please refer to Master Response 3 regarding Measure A.

An attachment to this letter can be found in Attachment B.

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Response to Letter 66
Grace Kistner
November 29, 2021
66-1 The comment states an opinion that the Project is not compliant with Chapter 17.146 of the City’s Municipal Code, which requires a percentage of new dwelling units to be affordable units.

The comment does not address the adequacy of the Draft EIR and is referencing requirements of the City’s Inclusionary Housing Ordinance. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. Please see Response to Comment 2-3 that addresses the Project’s affordable housing requirement.
66-2 The comment provides an excerpt of Chapter 17.146 of the City’s Municipal Code which describes requirements for owner-occupied and rental affordable units under the City’s Inclusionary Housing Ordinance.

The comment does not address the adequacy of the Draft EIR and is referencing requirements of the City’s Inclusionary Housing Ordinance. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no further response is required. See Response to Comment 66-1.
66-3 The comment summarizes the Project’s proposed residence types and expresses that the Project should be denied because, in the commentor’s opinion, it is not compliant with Chapter 17.146 of the City’s Municipal Code.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the Project. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. Please see Response to Comment 2-3.

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Response to Letter 67
Pamela Koussa
November 6, 2021
67-1 The comment states opposition to the Project because two-story residences are proposed.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.

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Response to Letter 68
Laurel Krsek
November 2, 2021
68-1 The comment states opposition to the Project and requests community-wide issues related to traffic and emergency access should be addressed The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The Project’s impact on transportation and circulation is addressed in Section 3.14, Transportation and Circulation. The analysis includes consideration of motorized vehicle traffic impacts on roadway capacity, vehicle-miles traveled (VMT), and potential impacts to transit, bicycle, and pedestrians. Please also see Master Response 1, that provides more details specific to the maintenance road for emergency evacuation for both Vineyard Valley residents and Project residents. 68-2 The comment states a concern that the Project will negatively impact traffic conditions.

Potential Project traffic impacts are analyzed in detail within Section 3.14 Transportation of the Draft EIR and within Appendix K, Traffic Impact Study. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no additional response is required. 68-3 The comment states the commentor’s concern related to emergency evacuation and states the Project should not be approved.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. Please see Master Response 1 that addresses emergency access concerns.

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Response to Letter 69
Gail Lane
October 30, 2021
69-1 The commenter states their history as residents of the City.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
69-2 The comment raises general concerns related to the Project’s impact on traffic and the City’s water supply.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 2 related to water supply. The Project’s impact on transportation and circulation is addressed in Section 3.14, Transportation and Circulation. Please see Responses to Comments 57-8, 57-9, and 57-10 regarding traffic concerns. 69-3 The comment states agriculture should be a priority for the area.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
69-4 The comment raises a general concern related to the Project’s impact on the City’s water supply.

Please see Master Response 2.
69-5 The comment acknowledges the need for affordable housing but indicates another project could meet this need.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
69-6 The comment raises a concern related to the Project’s impact on local parking.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Agenda Item #5.8.

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Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. 69-7 The comment states opposition to the Project due to its impact on water, the City’s sewer system, and traffic.

Please see Response to Comment 69-2 and Master Responses 1 for water supply and 4 for concerns regarding wastewater. Traffic impacts are evauated in Section

3.14 of the Draft EIR.

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Response to Letter 70
Marina and Jenna Lavagnino
November 29, 2021
70-1 The commenter thanks the City for extending the Draft EIR comment period and states the commenters did not receive prior noticing.

Please see Response to Comment 15-4 regarding noticing. The comment does not identify any specific areas where the Draft EIR or analysis is inadequate, therefore, no response is required.
70-2 The comment raises concerns regarding the City’s water supply and states that the City should not allow for new residential development.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 2 that addresses water supply and the City’s Water Neutrality Policy. 70-3 The comment raises concern related to the Project’s impact on wastewater and stormwater drainage.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 4 that addresses wastewater concerns and Response to Comment 35-4 which addresses general stormwater drainage concerns.
70-4 The comment notes that the 2.45 persons per household used to calculate park and recreation facility demands is different from the eight persons per 4-bedroom home estimate used to calculate demand for utilities. Additionally, the comment states an opinion that the Project’s estimate of 12 elementary school students seems to be low. The commenter is interested to know the number of elementary students at Hunt Street residences.

See Response to Comment 7-3, regarding household size calculations.

Student generation rates were derived from the St. Helena Unified School District (SHUSD) Facility Master Plan, which outlines expected growth in demand for school facilities associated with projected development and plans how to fund and respond to such growth. Each school district develops their own student generation rates.

Residences at Hunt Street are not a part of this Project; thus, no response is needed.

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70-5 The comment states an opinion that the City’s parkland ratio would fall short of the City’s goal of 5 acres of parkland per 1,000 residents and the nationally recommended standard of 10.5 acres of parkland per 1,000 residents. The comment states that City residents desire and deserve to have the nationally recommended parkland ratio standard.

As stated on page 3.12-16 of the Draft EIR, based on the City’s 2018 population of 6,196 residents and park acreage of 27.43, the City’s parkland to resident ratio is

4.43 acres per 1,000 residents. This parkland to resident ratio is lower than the City’s goal and lower than the nationally recommended standard, even without development of the Proposed Project. Assuming the addition of 213 new residents to the City, the City would have a ratio of 4.28 acres of parkland per 1,000 residents.

Park and recreational impact fees would be imposed on the Project and these impact fees would be used to cover the cost of parkland acquisition and park improvements.

The Project applicant would pay these impact fees as stipulated in the City’s Municipal Code Chapter 3.32, consistent with the Quimby Act. These park fees would be used by the City to purchase land to construct new parks or upgrade existing recreation facilities. The comment is noted and forwarded to the decision makers for their consideration.
70-6 The comment states an opinion that the Public Services and Recreation section of the Draft EIR does not acknowledge the recreational land that will be removed by the Proposed Project. The commenter suggests that the levee maintenance road could be considered a recreational facility.

As stated on page 3.12-5 of the Draft EIR, the levee maintenance road is not a City recreational trail but is used informally as a trail by local residents. Additionally, the maintenance road is not a part of the Proposed Project. There is an existing City trail located on the northside of the levee maintenance road that would not be affected by the Project. A small portion of the maintenance road would be paved to accommodate construction of the Adams Street extension, but sidewalks would be provided along the extension of Adams Street to provide a safe connection to the remainder of the maintenance road and the trail, which would remain unaltered by the Proposed Project. Please see Chapter 3, Changes to the Draft EIR for a figure that shows the adjancent trails.
70-7 The comment states an opinion that the Project would not add any recreational or common space areas, and asserts that nearby existing affordable housing developments provide these areas.

The commenter is correct that the Project does not include any on-site parks or - recreational facilities. However, as stated in Response to Comment 70-5, the Project applicant would pay park fees which would be used by the City to purchase land to construct new parks or upgrade existing recreation facilities. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is Agenda Item #5.8.

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required. However, the comment is noted and forwarded to the decision makers for their consideration.
70-8 The commenter reflects on the purpose of the City’s Planning Department and states that the Project gives the community an opportunity to evaluate what will best serve the community.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 71
Lou Lavigne and Nancy Rothman
November 29, 2021
71-1 The comment provides personal history of the commenters, stating they built their home on Fulton Lane after considering the history of the Project site. The commenter recommends the Project not be approved.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
71-2 The comment raises a concern related to the Project’s location due to its proximity to the levee and asks who would assume liability in the event of a flood.

Please see Master Response 3 regarding the levee and liability in the event of a flood.

Determinations of legal liabiloity for a potential future event is not within the scope of CEQA.
71-3 The commenters expresses their concern that the Napa River levee could be compromised. The commenter is specifically concerned about two drainage ditches along Fulton Lane, stating that they could be overwhelmed and flood water could back up to Fulton Lane. The commenters assert that these drainage ditches are currently overwhelmed during heavy rain events due to congested connection and poor maintenance.

Please see Master Response 3 regarding the levee. As stated on page 3.9-12 of the Draft EIR, the modern design and construction of the levee (along with the City’s ongoing inspection and maintenance of the levee) substantially reduces its potential to fail in a 200-year flood or in the event of an earthquake. The Proposed Project would not result in any changes to the drainage ditches along Fulton Lane or exacerbate existing flood risk, as explained in Section 3.9, Hydrology and Water Quality. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
71-4 The comment expresses a concern with the Project’s impact on the City’s water supply and states that retrofitting of plumbing fixtures and/or payment of in lieu fees is not adequate (per the City’s Water Neutral Policy).

Please see Master Response 2 regarding the City’s water supply and Water Neutral Policy.

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71-5 The comment opines that the City has limitations on obtaining more water supply and mentions the Project’s proposed use of groundwater for landscaping. The comment questions the location of the proposed well and whether use of the well would jeopardize other wells in the area.

Please see Master Response 2 regarding the City’s water supply and Response to Comment 57-5 regarding use of the existing well for landscaping. 71-6 The comment raises concern related to the City’s sewer system, specifically the commenter’s opinion that the City does not have capacity to treat additional sewage generated by the Project.

Please see Response to Comment 38-1 and Master Response 4 regarding City wastewater conveyance and system capacity.
71-7 The comment opines that the extension of Adams Street to the Project site may increase cut-through traffic along Starr Avenue and Adams Street and asserts that stop lights along this route would not be feasible.

Section 3.14, Transportation and Circulation of the Draft EIR analyzes traffic congestion and vehicular queuing along Starr Avenue and Adams Street, and concludes that impacts would be less than significant. This includes future year analysis scenarios with and without the traffic of the proposed project. Further, the Draft EIR does not recommend stop lights along any stretch of Starr Avenue or Adams Street. 71-8 The comment states an opinion that the Proposed Project would result in traffic congestion and pollution within the neighborhood.

Please see Response to Comment 71-7. The comment is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. 71-9 The comment opines that the Project would create additional parking capacity issues.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. 71-10 The comment states an opinion that the Project would replace the view of vineyards from the adjacent trail with houses and streets, which would destroy the rural charm of the City.

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The commenter is correct that the Proposed Project would remove a majority of the existing vineyard and open space that characterize the site. However, views of agricultural features in the City are not unique to the Project site such that the Proposed Project would substantially impact publicly available views. As stated on page 3.1-26 of the Draft EIR, the Project applicant is required to comply with the City’s Design Review Ordinance (Chapter 17.164 of the City’s Zoning Ordinance) and undergo design review to ensure the proposed development is visually consistent and compatible with the applicable General Plan and with adjacent areas as well as the existing environment. The comment is noted and forwarded to the decision makers for their consideration.
71-11 The comment suggests that the City should explore other alternatives for affordable housing.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
71-12 The comment questions the financial stability of the applicant to complete the Project and is concerned what would happen if only a portion of the Project was constructed.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The finances and economic viability of a project are not within the scope of CEQA and not subject to analysis in an EIR. The commenter’s concern is noted and forwarded to the decision makers for their consideration.
71-13 The comment states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 72
Sandra Lowry
November 4, 2021
72-1 The comment explains the commenter’s personal history and general opposition to the Project.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
72-2 The comment states an opinion that Starr Avenue is “parked up every afternoon, through the night an on weekends” and suggests that future residents of the Proposed Project would not be able to find parking along Starr Avenue.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. . 72-3 The comment states an opinion that Starr Avenue has several safety issues including speeding, aggressive drivers, and a lack of pedestrian amenities.

As stated in Section 3.14 of the Draft EIR, Starr Avenue was analyzed in regard to vehicular collisions and overall safety along the roadway. The conclusion of the Draft EIR were that the Proposed Project would not increase hazards due to a geometric design feature or incompatible use that would contribute to an increase in collisions or create visual obstructions that would impede vehicles, bicyclists, and pedestrians from having safe access to and from the Project site. An EIR is not required to evaluate aggressive drivers.
72-4 The commenter disagrees with the Draft EIR conclusion that the Proposed Project would not result in inadequate emergency access and states that Starr Avenue is already very congested.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. For additional information regarding emergency access, please refer to Master Response 1.
72-5 The comment states that there is a lack of roadway connections to Highway 29 and Silverado Trail, and roadways would be backed up during an emergency.

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The commenter’s opinion regarding the lack of roadway connections to Highway 29 is noted for the decision makers. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. For additional information regarding emergency access, please refer to Master Response 1. 72-6 The commenter asks for the location of the third emergency exit stated in the Draft EIR.

As described on page 2-24 in Chapter 2, Project Description, “[e]mergency vehicle access would be provided via the extension of Adams Street, Starr Avenue, and an emergency vehicle access (EVA) to the existing gravel maintenance road that borders the north/northwest boundary of the Project site.” For additional information regarding emergency access, please refer to Master Response 1. 72-7 The comment expresses the commenter’s opinion regarding congestion of the levee access (maintenance) road for purposes of emergency evacuation.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. For additional information regarding emergency access, please refer to Master Response 1.
72-8 The comment addresses the Proposed Project’s trip generation and its effect on roadway congestion and asks for additional mitigation measures.

Section 3.14, Transportation and Circulation of the Draft EIR analyzes all transportation impacts as mandated by CEQA. All mitigation measures and potential mitigation measure that would be needed, are discussed in detail within Section

3.14. Further, Appendix K, Transportation Impact Study, identifies several recommended roadway improvements. However, as explained on page 3.14-1 in Section 3.14, Transportation and Circulation, the CEQA Guidelines were updated (December 2018) to remove evaluation of the delay that vehicles experience at intersections and on roadway segments, which is often measured using a level of service (LOS) metric. Therefore, the operational aspects of the Proposed Project that contribute to delay and congestion on local roadways is no longer considered an environmental impact under CEQA. Therefore, the recommended roadway improvements are not identified as mitigation measures. The recommended roadway improvements are for informational purposes as to how the project could address LOS deficiencies.
72-9 The commenter expresses concern about with Project traffic and potential fugitive dust emissions associated with construction activities.

The Project would not result in exacerbating existing air quality conditions and would not result in the exceedance of the Bay Area Air Quality Management District (BAAQMD) thresholds of significance for both construction and operations.

Furthermore, the BAAQMD’s CEQA Guidelines contain feasible control measures to reduce fugitive dust emissions from construction activity. The measures in the CEQA Guidelines are divided into three categories: (1) basic control measures, (2) Agenda Item #5.8.

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enhanced control measures, and (3) optional control measures. The BAAQMD recommends that all construction incorporate basic control measures, regardless of the size of the site. Therefore, the Project would implement necessary precautions to reduce fugitive dust emissions such as implementing the BAAQMD’s Best Management Practices (BMPs) for fugitive dust control during construction. Please see Response to Comment 72-8 regarding traffic.
72-10 The comment states opposition to the Project and the impact conclusions in the Draft EIR.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not specify where the Draft EIR is inadequate; therefore, no further response is required.

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Response to Letter 73
Isobel Luria
November 2, 2021
73-1 The comment states an opinion that the Hydrology, Water Quality, and Drainage section of the Draft EIR ignores the potentially adverse effects of climate change and dismisses the consequences of a catastrophic flood.

Please see Response to Comment 31-1.
73-2 The comment states the commenter’s personal observation that the Proposed Project has been controversial and that the current City administration will be held responsible for their decisions.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 73-3 The comment explains the commenter’s understanding of the history of acquisition of the Project site and construction of the levee.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 that provides information specific to the levee. 73-4 The comment states that the levee and adjacent floodwall protects much of the eastern side of the City.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 that provides information specific to the levee. 73-5 The comment states an opinion that the Draft EIR does not include a due diligence examination of the current condition of the levee.

The Project does not have an impact on the levee’s effectiveness or on flood hazards for surrounding communities, either directly or indirectly. California Supreme Court’s decision in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369 held that “agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project’s future users or residents” but they must analyze hazards the project Agenda Item #5.8.

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might risk exacerbating. Accordingly, comments regarding the levee, that will not be directly or indirectly impacted the Project, are outside the scope of CEQA review for this Project.
73-6 The comment asserts that the Draft EIR does not mention any contact to FEMA to ascertain whether residents will be able to obtain flood insurance and low interest flood mitigation loans.

As stated on page 3.9-8 of the Draft EIR, because the Project site is outside of a FEMA Special Flood Hazard Area (SFHA), no flood insurance would be required. However, because there remains residual risk of flooding from catastrophically large floods (such as a 500-year flood) or levee failures, residents in flood-prone areas, even if outside of a regulatory flood zone, have the option to purchase optional flood insurance. Additionally, please see Master Response 3 for more information about flood insurance. 73-7 The comment states an opinion that the country is experiencing more frequent extreme weather events resulting in a burden of claims to FEMA.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, please see Master Response 3 for information about the role of FEMA.
73-8 The comment references a statement from FEMA which states that levees deteriorate over time and if failure or overtopping occurs, flood damage can be greater than if the levee had not been built. The comment goes on to suggest that since flood insurance is optional, the Project would not be fully insured against flood damage.

Please see Response to Comment 73-5 and also Master Response 3 regarding the levee and the need for flood insurance.
73-9 The comment disagrees with the Draft EIR conclusion that Project residents would have ample time to evacuate in the event of a flood. The comment also states that FEMA may refuse to pay for flood damage and repair because the Project was built close to an existing levee.

Please see Response to Comment 73-5. However, the Draft EIR states on page 3.9- 12 that in the unlikely situation the levee is overtopped, Project residents would have ample warning to evacuate prior to flooding. The same existing measures implemented to respond to flood emergencies within the region would continue to be used and would serve to provide residents with the means to avoid personal harm in the event of a catastrophic flood. This includes flood watches, advisories, and warnings from the National Weather Service, reporting by local news outlets, announcements and communications via Integrated Public Alert and Warning System, text alerts, and other means of communication that would be increasingly Agenda Item #5.8.

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used in the event of a severe flood threat. Please see Master Response 3 for more information regarding flood protection and potential for levee failure. 73-10 The comment states an opinion that if FEMA withholds aid in the event of a flood event, Project residents would likely sue the Project applicant and the City.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Master Response 3 for more information regarding flood protection and the potential for levee failure. 73-11 The comment opines that the east side of the City lacks the infrastructure to evacuate residents in the event of an emergency.

Please refer to Master Response 1 regarding emergency evacuation plans. 73-12 The comment states an opinion that a lawsuit from the Project applicant in the event the City rejects the Project would cause less bad publicity than if the City were to be sued by residents.

The comment is noted and forwarded to the decision makers for their consideration.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
73-13 The comment states the commenter’s opinion that the City should not approve the Proposed Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.

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Response to Letter 74
Isobel Luria
74-1 The comment states an opinion that due to climate change and extreme weather events, including a flood event, development of the Proposed Project is not recommended.

The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the Project. The comment does not identify any specific areas where the EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. However, please see also Master Response 3 regarding the protection provided by the Napa River levee in the event of a flood. 74-2 The comment states an opinion that the Draft EIR relies on untested data and underestimates the Project’s potential impacts without providing adequate mitigation.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, the analysis in the Draft EIR relies on technical studies prepared for the Project as well as other substantial evidence required to determine any potential Project impacts. The comment is noted and forwarded to the decision makers for their consideration. 74-3 The commenter is concerned about traffic congestion increasing as a result of the Proposed Project.

The Project’s impact on transportation and circulation is addressed in Section 3.14, Transportation and Circulation. The analysis includes consideration of motorized vehicle traffic impacts on roadway capacity, vehicle-miles traveled (VMT), and potential impacts to transit, bicycle, and pedestrians. The comment does not identify any specific areas where the Draft EIR or analysis is inadequate; therefore, no further response is required. Please see also Response to Comment 36-2. 74-4 The comment states an opinion the Project’s trip generation is inaccurate.

Trip generation estimates for the Project were provided in Section 3.14 of the Draft EIR. Estimates were calculated based upon trip rates provided in the Institute of Transportation Engineers’ (ITE) Trip Generation, 10th Edition. In September 2021 the 11th Edition of the ITE manual was released. It does not change the Project’s trip rates derived from the 10th Edition. Average trip generation rates represent weighted averages from studies conducted throughout the United States and Canada since 1980 that surveyed the identified use. Single-Family and multi-family land uses are based on surveys and weighted averages. Rates are not based on a specified Agenda Item #5.8.

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number of bedrooms or vehicles per household. The rates provided in the Draft EIR are based on accepted industry standards for this type of project. 74-5 The comment expresses the commenter’s concern about lack of parking availability in the neighborhood.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. 74-6 The comment expresses the commenter’s concern regarding the effect the Proposed Project would have on pedestrian safety and vehicular collisions at the intersection of Starr Avenue and Hunt Avenue.

As stated in Section 3.14 of the Draft EIR, Starr Avenue and Hunt Avenue were analyzed in regard to vehicular collisions and overall safety along both roadways.

The conclusion of the Draft EIR was that the Proposed Project would not increase hazards due to a geometric design feature or incompatible use that would contribute to an increase in collisions or create visual obstructions that would impede vehicles, bicyclists, and pedestrians from having safe access to and from the Project site.

Additionally, vehicular collisions within the City were also analyzed within Section

3.14 of the Draft EIR and Project impacts were concluded to be less than significant.

Therefore, no mitigation measures would be required.
74-7 The comment states the commenter’s opposition to the Project and the effect on emergency access routes and evacuation in case of emergencies.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Section 3.14 of the Draft EIR analyzed emergency vehicle access in detail. For additional information regarding emergency vehicle access and evacuation, please see Master Response 1. 74-8 The commenter q asks why the City would approve the Project prior to improving the existing infrastructure and a reliable evacuation route is created.

Please see Master Response 1 regarding emergency evacuation. 74-9 The comment opines that the Hydrology and Water Quality section of the EIR is based on vague and untested information and does not consider extreme weather conditions caused by climate change. The commenter quotes a statement from page

3.9-10 of the EIR regarding groundwater levels.

Please see Response to Comments 14-9 through 14-17 and Master Response 2, regarding water supply.

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74-10 The comment states an opinion outdoor water needs are not accurately portrayed in Table 3.13-9 of the Draft EIR because new trees and plants require a significant amount of water to get established, and homeowners will also require water for landscape irrigation.

Please see Responses to Comments14-9 through 14-17 and Master Response 2. 74-11 The comment states that the Draft EIR’s conclusion on page 3.9-48 is inaccurate because climate change will likely cause the need for groundwater to exceed the projected figure of 0.9%.

Please see Responses to Comments 14-9 through 14-17 and Master Response 2. 74-12 The comment states an opinion that the discussion on pages 3.13-24 through 3.13- 33 of the Draft EIR underestimates the quantity of indoor water that the Project will require and “tests” should be run to determine how to accurately measure water usage by Project residents.

Please see Responses to Comments14-9 through 14-17 and Master Response 2. 74-13 The comment states an opinion that retrofitting houses will not save enough water for the Project to be considered water neutral.

Please see Responses to Comments14-9 through 14-17 and Master Response 2.

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Response to Letter 75
Isobel Luria
November 8, 2021
75-1 The commenter requests copies of the City’s levee maintenance records.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The City posts levee maintenance records available to the public on the City’s website here: https://www.cityofsthelena.org/ publicworks/page/flood-control-and-river-restoration-project Please refer to Master Response 3 for additional information specific to the levee.

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Response to Letter 76
Isobel Luria
76-1 The comment states an opinion the Project should not be approved due to the existing drought and potential for increased flooding as a result of climate change.

The comment does not raise does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 for information regarding climate change and the status of the Napa River levee.
76-2 The comment states an opinion that the Draft EIR relies on vague and untested data that dismisses Project impacts and the need for mitigation.

The comment does not raise does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. The comment is noted and forwarded to the decision makers for their consideration. 76-3 The comment states an opinion the Project’s trip generation estimates are inaccurate and underestimated because families increase in size the number of cars can increase.

Please see Response to Comment 74-4.
76-4 The comment states an opinion that parking in the neighborhood is over capacity.

The adequacy of parking supply is not an environmental impact under CEQA; therefore, the commenter’s concern is noted for the decision makers and no further response is required. However, at the time building permits are requested, as required by the Municipal Code, the City will confirm the Project complies with Section 17.124.030.A.1 of the City’s Zoning Code that addresses residential parking requirements. . 76-5 The comment asks what the Proposed Project would do to lessen parking capacity concerns.

Please see Response to Comment 76-4.
76-6 The comment expresses the commenter’s concern about the safety of the Starr Avenue and Hunt Avenue intersection.

Please see Response to Comment 59-3.

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76-7 The comment states an opinion that an extension of Starr Avenue to Adams Street could increase traffic and the potential for accidents and asks what can be done to mitigate this impact.

Please see Response to Comment 59-3.
76-8 The comment states an opinion that the Draft EIR does not consider that the City does not have efficient means for emergency evacuation, which would be further impacted by the Project and asks what can be done to improve emergency evacuation.

Section 3.14 of the Draft EIR analyzed emergency vehicle access in detail. For additional information regarding emergency vehicle access and evacuation, please see Master Response 1.
76-9 The comment states an opinion that the Draft EIR fails to note that a part of the Project site was burned in the September 2020 Glass Fire. The commenter asks what mitigation measures are planned to protect the Project area from wildfires.

The Draft EIR notes on page 3.8-5 that the hills visible from the Project site experienced fire damage. The Project site did not experience any fire damage from the 2020 Glass Fire. The discussion under Impact 3.8-4 on page 3.8- 21 describes how best management practices, BAAQMD regulations, and properly irrigated landscapes would reduce fire risk.
76-10 The comment states an opinion that the Hydrology and Water Quality analysis reaches faulty conclusions about the Project’s impact on groundwater because it does not consider the effects of climate change.

Please see Response to Comments 35-4 through 35-6.
76-11 The comment states an opinion that outdoor water needs are not accurately portrayed in Table 3.13-9 of the Draft EIR because new trees and plants require significant amounts of water to get established and landscape irrigation for the new homes is not included.

Please see Responses to Comments14-9 through 14-17 and Master Response 2. 76-12 The comment states an opinion that because the City is experiencing a severe drought and the Project would increase impervious surface area, there may be a negative impact on the local groundwater subbasin.

Please see Master Response 2 and Responses to Comments 35-4 through 35-6. 76-13 The comment suggests that the Draft EIR should not assume the Project would be water neutral based on one 24-hour well test. The comment also states an opinion Agenda Item #5.8.

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that it is not reasonable to conclude that Project’s irrigation would have no impact on the groundwater subbasin or Napa River without further testing.

Please see Responses to Comments 14-9 through 14-17, 57-5 and Master Response 2. 76-14 The commenter asks how much additional water would be required to irrigate privately owned lots and where the water will come from.

Please see Response to Comments 14-9 through 14-17 and Master Response 2. 76-15 The commenter asks what additional testing should be required of the Project applicant to determine a more accurate impact on the groundwater subbasin.

Please see Responses to Comments 35-4 through 35-6, 57-5 and Master Response 2. 76-16 The comment states an opinion the discussion on pages 3.13-24 through 3.13-33 of the Draft EIR underestimates the quantity of indoor water that future residents of the Project will use, including landscape irrigation. The comment goes on to state that tests should be done to determine how to accurately measure water usage by individuals.

Please see Responses to Comments 14-9 through 14-17 and Master Response 2. 76-17 The comment states an opinion that retrofitting houses will not save enough water for the Project to be considered water neutral. The commenter asks how the in-lieu fee would satisfy the water neutral condition.

Please see Responses to Comments 14-9 through 14-17 and Master Response 2. 76-18 The commenter asks if there is a better method to determine the indoor water usage of future residents.

Please see Responses to Comments 14-9 through 14-17 and Master Response 2. 76-19 The commenter asks how the Project’s water demand would impact the City and its residents.

Please see Responses to Comments 14-9 through 14-17 and Master Response 2.

Agenda Item #5.8.

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INTENTIONALLY LEFT BLANK
Agenda Item #5.8.

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COMMENT LETTER 77
Agenda Item #5.8.

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January 2023 4-400
Agenda Item #5.8.

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January 2023 4-401
Response to Letter 77
Norm Manzer
November 7, 2021
77-1 The commenter provides their history as City residents and states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 77-2 The comment provides their history of previous flood events in the City, particularly at the Vineyard Valley Mobile Home Park. The comment also describes their understanding of several previous engineering projects to control and manage flooding in the Project area.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 that addresses flooding concerns.
77-3 The comment provides a general statement about flood events and levee failure and provides Hurricane Katrina as an example.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 3 that addresses flooding concerns.
77-4 The comment states an opinion that the Napa River levee should not be relied on to protect Project residents and references previous flood events discussed in Comment 77-

2. Please see Response to Comment 73-5. Please also see Master Response 3 addresses issues associated with flooding and the levee. 77-5 The comment state opposition to the Project and requests the City not approve the Project based on the potential for levee failure and requests that the Project applicant be liable for potential levee failure should the Project be approved.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Response to Comment 73-5 and Master Response 3 that addresses concerns specific to the levee.

Agenda Item #5.8.

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INTENTIONALLY LEFT BLANK
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COMMENT LETTER 78
Agenda Item #5.8.

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INTENTIONALLY LEFT BLANK
Agenda Item #5.8.

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Response to Letter 78
Beth and David Marks
October 30, 2021
78-1 The comment states opposition to the Project.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
78-2 The comment states that it is the commenters’ plan to attend future Project hearings.

The comment does not identify any specific areas where the EIR or analysis is inadequate. Therefore, no response is required; the comment is noted and forwarded to the decision-makers for their consideration.
78-3 The comment states an opinion that “high density housing” (the commenter’s term) will further impact limited resources, including water.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. To clarify, the Project is proposing residential development consistent with the “medium density” designation of the St Helena General Plan. Please see also Master Response 2 regarding water supply.

Agenda Item #5.8.

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COMMENT LETTER 79
Agenda Item #5.8.

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January 2023 4-408
Agenda Item #5.8.

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January 2023 4-409
Agenda Item #5.8.

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Agenda Item #5.8.

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Agenda Item #5.8.

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Agenda Item #5.8.

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Response to Letter 79
Tracy McBride
November 28, 2021
79-1 The commenter states their support for more housing in the City but opines that the Draft EIR includes inaccurate information.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
79-2 The commenter asks, “... why does no one in town support this project?” The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.
79-3 The commenter calls for the extension of Adams Street to connect to the Silverado Trail and for the extension to be suitable for trucks. The comment also states an opinion that emergency evacuation would be affected by the Proposed Project.

The Project does not include the future expansion of Adams Street connecting to Silverado Trail. This is a separate City project and is not required for this Project. The comment is noted and forwarded to the decision makers for their consideration. For additional information regarding emergency vehicle access and evacuation, please see Master Response 1.
79-4 The comment states an opinion that the size of the Starr Avenue extension is narrower than the Adams Street roadway extension and that these roadways are important to the neighborhood since they accommodate many uses.

Section 3.14 of the Draft EIR describes the extension of both Starr Avenue and Adams Street. Both roadways would be constructed consistent with City street standards and would accommodate emergency service vehicles, and maintain accessibility for pedestrians and bicyclists, according to the City’s street design standards.
79-5 The comment states an opinion that overhead electrical lines should be undergrounded to prevent fire hazards.

The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. The City will require, per policy, that all utilities in the Project be placed underground.

Agenda Item #5.8.

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January 2023 4-414
79-6 The comment states an opinion that the Draft EIR does not address financial impacts to City residents in order to complete the Adams Street extension to Silverado Trail.

The extension of Adams Street to Silverado Trail would require further study and approval by the City and is not required for this Project. Additionally, CEQA does not require a discussion of financial impacts because they are not considered an impact to the environment.
79-7 The comment states the commenter’s observation that truck traffic in the neighborhood is using residential streets currently and opines that the Project would worsen truck traffic.

The Proposed Project is not expected to generate any additional truck traffic other than the temporary truck traffic as a result of Project construction. The City’s Municipal Code, Chapter 10.36, defines the City’s truck traffic routes that apply to heavy trucks in general.
79-8 The comment states an opinion that the extension of Adams Street would not be suitable for large trucks and that both Starr Avenue and Adams Street should be redesigned.

Please see Responses to Comments 79-4 and 79-7.
79-9 The comment states an opinion that there needs to be an additional route into and out of the City.

The comment does not identify any specific areas where the EIR or analysis is inadequate. Therefore, no response is required; the comment is noted and forwarded to the decision-makers for their consideration. However, please see Master Response 1 regarding emergency evacuation routes.
79-10 The comment states an opinion that faucet, shower head, and toilet retrofits would not mitigate the water impact from the Project.

Please see Master Response 2.
79-11 The comment states an opinion that the Project needs to pay the true cost of added water consumption, including new infrastructure, instead of a “fake” in-lieu fee.

Please see Master Response 2.
79-12 The comment states an opinion that the calculations in Appendix J which state an estimate of 34.9 gallons of water per person per day is inadequate.

Please see Master Response 2.

Agenda Item #5.8.

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January 2023 4-415
79-13 The comment states an opinion that there is an inconsistency between Table 5-1 in the Draft EIR which states the need for 15,509,215 gallons of water per year, versus the 6,479,480 gallons per year stated in Appendix J.

Please see Master Response 2.
79-14 The comment states an opinion that Appendix J contains an inadequate analysis of Project water impacts and is only used to calculate the cost of water fixtures for an in-lieu fee. The commenter states that households are unable to save more water than they are currently.

Please see Master Response 2.
79-15 The comment states an opinion that Appendix J does not account for the ADUs included in the Project.

Please see Master Response 2.
79-16 The comment states, without providing support, that per capita water use in the City is around 65 gallons per person per day, which is inconsistent with the Draft EIR statement that water use in 2015 was approximately 220 gallons per day.

Please see Master Response 2. Without a source for the “<65 gallons per person per day” figure, no additional response can be provided.
79-17 The comment states an opinion that lawns are inappropriate for landscape design.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-18 The comment states an opinion there is no data to support that there are any nonconserving water fixtures still present in the City.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. Please see Master Response 2.
79-19 The comment states an opinion that the Draft EIR does not address the additional costs to City residents for water rate increases.

CEQA does not require a discussion of financial impacts as they are not considered impacts to the environment; Therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration.

Agenda Item #5.8.

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January 2023 4-416
79-20 The comment states an opinion that the Project plans are outdated and should instead include multi-story, high-energy efficient housing with an elevator, native community garden, and compact private outdoor space.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-21 The comment states an opinion that the City should not segregate low-income housing from the rest of the neighborhood and that the Project would perpetuate housing segregation.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-22 The comment states an opinion that the Draft EIR does not address the impact on neighborhood perceptions on real estate value resulting from “low-income” housing.

The commenter suggests that low-income housing should look the same as other housing in the neighborhood.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required However, the comment is noted and forwarded to the decision makers for their consideration. 79-23 The comment states an opinion that low-income housing should include homes for purchase.

The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-24 The comment states an opinion that the Draft EIR does not account for the added cost of administering low-income housing.

CEQA does not require a discussion of financial impacts; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration.
79-25 The comment states an opinion that the addition of more attached homes would conserve land and energy and suggests that buildings should be 3 stories tall with elevators.

Agenda Item #5.8.

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January 2023 4-417
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-26 The comment asks where ADUs are proposed and suggests that condominiums should be constructed to increase the range of housing prices.

The Project applicant proposes to construct 11 ADUs on 11 of the 51 single family lots created by the proposed Tentative Subdivision Map. The specific lots have not been identified at this time. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. However, the comment is noted and forwarded to the decision makers for their consideration. 79-27 The comment states an opinion that housing for people with mobility impairments should be included and suggests that multi-level housing with elevators be provided.

At this time, Project applicant is only seeking approval of the Tentative Subdivision Map. The City will review proposed maps and building plans to ensure ADA compliance. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. 79-28 The comment states an opinion that the Draft EIR lacks HOA information and requests information on the Project’s financing. The commenter also questions if there is a flood how low-income housing would be affected if the HOA does not have financial reserves.

The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. CEQA does not require a discussion of financial impacts as they are not considered an impact on the environment. The comment is noted and forwarded to the decision makers for their consideration. 79-29 The comment states an opinion that the Draft EIR does not contain information explaining if the homes would be applicable for VA loans, FHA loans, or accessible for first time homebuyers.

CEQA does not require information regarding financing options available for future homebuyers be evaluated. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. 79-30 The comment states an opinion that the Draft EIR does not address how the Project will provide affordable housing and how many bedrooms/units each home or building will have. The commenter suggests that low-income housing not be limited to twobedroom residences.

Agenda Item #5.8.