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On page 2-18 of the Draft EIR it is explained that the Project’s affordable housing is still being discussed by the City and the Project applicant and is not proposed or required for review and approval with the Tentative Subdivision Map. A final Affordable Housing agreement, approved by the City Council, would be required prior to recordation of a final subdivision map. The commenter’s opinion on lowincome housing is noted and forwarded to the decision makers for their consideration and no further response is required.
79-31 The comment asserts that there is no analysis of parks in the Draft EIR and that the Project should include parks and improvements to the river trail as part of the Project.
The need for parks and recreation facilities is addressed and analyzed in Section
3.12 of the Draft EIR. Additionally, park and recreational impact fees are imposed upon all residential development within the City. These impact fees are used to cover the cost of land acquisition and park improvements. The commenter’s opinion is noted and forwarded to the decision makers for their consideration and no further response is required.
79-32 The commenter states that they have personally seen native artifacts at the Project site and there is no recognition of these resources in the Draft EIR.
Cultural and tribal cultural resources are discussed in Section 3.5 of the Draft EIR.
The potential for cultural (prehistoric or historic-era resources) including human remains and tribal cultural resources to be present on the site was thoroughly evaluated as part of the Draft EIR analysis. Please also see Response to Comment 55-4.
79-33 The comment asserts that the electronic copy of the Draft EIR was reduced and figures cannot be fully zoomed in or are of poor resolution.
The Draft EIR was posted for public review on the City’s website and as noted on page 1-4 of the Draft EIR, a copy of the document was also available at the City offices during normal business hours (Monday through Friday, 8:30 a.m. to 5:00 p.m.).
79-34 The comment asserts that Hunt’s Grove and Vineyard Valley projects are not identified on Figure 2-4 and goes on to state Figure 2-4 should show the bed/bath count for multi-family units to indicate the direct impacts to Hunt’s Grove and other adjacent parcels. The commenter also states that the size of adjoining agricultural parcels to the north of the Project site should be identified as well as the number of bedrooms and residences.
Figure 2-3 identifies adjacent land uses, including the Hunt’s Grove apartments and the Vineyard Valley Mobile Home Park. A more detailed discussion of adjacent or surrounding land uses is discussed starting on page 2-1 in Chapter 2, Project Agenda Item #5.8.
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Description. The surrounding agricultural lands are identified. Figure 2-4 shows the Project’s proposed Tentative Map. The number of bedrooms/baths are not required to be provided or analyzed in an EIR. An EIR evaluates the “project footprint” or area of disturbance along with the demand for services and utilities new residents would create. The number of bedrooms/baths has no bearing on the analysis. There is no requirement that an EIR identify the number of bedrooms/baths in any adjacent or nearby residential uses, including any residences located in the County. 79-35 The commenter asserts that the Draft EIR should note the possible extension of Starr Avenue to Fulton.
The Project does not require the extension of Starr Avenue beyond connecting to Adams Street. Any future extension of Starr Avenue is a separate project and not required to analyzed in this EIR.
79-36 The commenter states an opinion that Adams Street should receive bioswales to replenish groundwater.
A discussion of the Project’s stormwater features is discussed on page 2-29 in Chapter 2, Project Description and further evaluated in Section 3.9, Hydrology and Water Quality. The comment does not address the accuracy or adequacy of the Draft EIR. The commenter’s opinion is noted and forwarded to the decision makers for their consideration and no further response is required. 79-37 The commenter states an opinion that the City should designate views of Mt. St.
Helena as a significant view.
The comment does not address the accuracy or adequacy of the Draft EIR. The commenter’s opinion is noted and forwarded to the decision makers for their consideration and no further response is required.
79-38 The comment states an opinion that the Project needs to address the impact of a 100-year flood event.
The Draft EIR evaluates flooding in Section 3.9, Hydrology and Water Quality.
Please see Master Response 3 for additional information on flood risks. 79-39 The commenter asks what buildings foundations will be required and whether prospective homebuyers would be notified that their homes are built on fill and if the homes would be affected by a 100-year flood.
As explained on page 2-31 in Chapter 2, Project Description, “[t]o level the site and to ensure a stable base for new development, the existing fill/soils on the site would be removed, recompacted and returned to the site along with additional fill.” Please see Master Response 3 regarding flooding concerns and Response to Comment 32- 1 regarding the geology of the site.
Agenda Item #5.8.
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79-40 The commenter asks if homeowners would be required to buy flood insurance and how this would impact the financing available to purchase the homes.
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 3 regarding flood concerns and Response to Comment 32-2 regarding flood insurance. 79-41 The comment asserts that the 2019 General Plan designates the site for agriculture rather than medium density residential and that this information should be included in the report rather than in an appendix.
The St. Helena General Plan Update 2040 designates the site for medium-density residential as shown in Figure 2.1 (https://www.cityofsthelena.org/sites/default/ files/fileattachments/planning_resources/page/3505/final_plan_compiled.pdf). This information is also included in the Draft EIR Project Description (Chapter 2) and the Land Use section (section 3.1) of the Draft EIR. The commenter may be referring to Figure 1.3 of the General Plan Update, which shows existing land uses rather than those proposed under the General Plan Update. The comment is noted and forwarded to the decision makers for their consideration and no further response is required. 79-42 The comment opines that there should be a park with trees and a walking path to the Napa River. The commenter also questions why the HOA would service City streetlights and if the HOA needs to pay for full street maintenance and utilities.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. At this time, Project approval only requires approval of the Tentative Subdivision Map. It is anticipated the Project’s HOA would oversee public landscaping and other community owned facilities. 79-43 The comment states an opinion that the Project should contribute to the arts and that funds should be allocated to this purpose.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 79-44 The commenter states that they expect the City, including council members and commission members to express their opinions on the Project.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
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79-45 The commenter states that they are disappointed in the lack of outreach and ability for the public to provide comments on the Project.
Please see Response to Comment 15-4. The comment does not address the accuracy or adequacy of the Draft EIR. The commenter’s opinion is noted and forwarded to the decision makers for their consideration and no further response is required.
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Response to Letter 80
Sandra McCorkle
November 30, 2021
80-1 The comment states an opinion that it is challenging to determine whether the EIR adequately identifies significant environmental effects and goes on to state that the EIR should examine all phases of the project including planning, construction, and operation.
As stated in Chapter 2, Project Description on page 2-32, the Project is only requesting approval of the Tentative Subdivision Map at this time. Subsequent approvals would involve review of discreet components of the Project. The Draft EIR evaluates the direct and indirect impacts associated with construction and operation of the Project with housing and the associated change in the underlying existing conditions present on the site. If it is determined there would be a change in the severity of a Project impact associated with any of the subsequent Project approvals sought by the applicant, additional CEQA review may be required. The public will have the opportunity to review and comment on these subsequent applications. The commenter’s opinion is noted and forwarded to the decision makers for their consideration and no further response is required.
80-2 The comment states an opinion that there is uncertainty regarding the Project description and tentative map because the number and distribution of housing units is different in separate tentative map applications.
As stated in Chapter 2, Project Description, an application was filed with the City for a Tentative Subdivision Map to subdivide the property for residential development.
The application was accepted as complete by the City on March 28, 2011. The Draft EIR incorporates changes to the tentative map requested by the City since the original submission. The Project applicant is proposing to subdivide the site into 51 lots (sized for single-family residences), a 3.4-acre parcel, and two lettered lots (for the existing well and undeveloped land). Homes on 11 of the 51 lots would be developed with an ADU as part of their initial construction. The Project applicant also intends to ultimately develop the 3.4-acre parcel with 25 attached multifamily residential units.
80-3 The comment states that the Notice of Completion indicates there would be 87 units as part of the Project and compares this to the information in the Draft EIR.
Please see Response to Comment 80-2. The Project applicant is proposing 51 single-family residences, 25 attached multifamily residential units, and 11 ADUs, which would total 87 units.
Agenda Item #5.8.
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80-4 The comment asks whether it is reasonable to continue to rely on the 2010 application for the Tentative Subdivision Map and the 2011 Completion Letter from the City and whether the original application is still valid.
As explained starting on page 3.0-2 in the Draft EIR as well as on page 2-12, since the Proposed Project application was submitted in September 2010 and deemed complete by the City in 2011, this EIR uses the 1993 General Plan as the applicable general plan for the purposes of evaluating the Proposed Project. Nonetheless, this EIR also evaluates consistency with the General Plan Update 2040 for informational purposes.
80-5 The comment asks whether the Project should be evaluated under the current General Plan update since the details of the tentative map have been revised to meet new conditions.
Please see Response to Comment 80-4.
80-6 The comment asks what rules allow the tentative map application to remain valid since 2011, and to be revised during its review.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The Project is being processed in accordance with all applicable City and state laws. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 80-7 The comment expresses the commenter’s uncertainty about whether or not the Project is consistent with the City’s Inclusionary Housing Ordinance.
The comment does not address the adequacy of the Draft EIR, but instead refers to the Project’s consistency with the City’s Inclusionary Housing Ordinance. However, as noted in the Draft EIR Chapter 2, Project Description, review and approval of an Affordable Housing Agreement by the City Council is a subsequent discretionary approval and not part of the Tentative Subdivision Map being considered by the City at this time. A determination of consistency will be made at the time that subsequent application is submitted and reviewed.
80-8 The comment states an opinion there is insufficient information to determine if the affordable housing units are comparable in quality to the market rate units.
See Response to Comment 80-7. Review and approval of an Affordable Housing Agreement by the City Council is a subsequent discretionary approval and not part of the Tentative Subdivision Map being considered by the City at this time. Consistency with the requirements of the Inclusionary Housing Ordinance will be determined at the time an application is filed.
Agenda Item #5.8.
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80-9 The comment expresses the commenter’s concern about potential changes to the Project and Tentative Subdivision map if the Proposed Project does not meet the Inclusionary Housing requirements.
The proposed Tentative Subdivision Map could be developed consistent with the Inclusionary Housing Ordinance. Compliance with the City’s Inclusionary Housing Ordinance would be evaluated as a subsequent approval, as explained on page 2-32 of the Draft EIR.
80-10 The comment requests more information specific to the requirements of the Inclusionary Housing Ordinance and whether the Project would require an increase in units. Specifically, the commenter asks if there would be increased density with the potential to create greater environmental impacts. The comment questions the adequacy of the Draft EIR in light of these potential changes.
The current application is requesting approval of the Project’s Tentative Subdivision map, as described in Chapter 2, Project Description. Compliance with the City’s Inclusionary Housing Ordinance would be evaluated as a subsequent approval, explained on page 2-32. As noted on page 2-13, the Project applicant has not requested consideration of a density bonus as part of the Proposed Project application.
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Response to Letter 81
Kathleen McCreedy
November 2, 2021
81-1 The comment states opposition to the Project and provides the commenter’s history as a resident 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.
81-2 The commenter generally states their concerns related to traffic congestion, water supply, sewer capacity, and emergency evacuation.
The comment does not raise specific concerns related to these topics or any specific areas where the Draft EIR analysis is inadequate. However, please see Master Responses 1, 2 and related to emergency evacuation, water supply, and wastewater conveyance and Response to Comment 36-2 that addresses general traffic congestion concerns.
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 future improvements to the City’s sewer system. Please also see Master Response 4. 81-3 The comment asserts that the Project site serves as a wildlife corridor and urges the City to explore ways to conserve the site and generate tax revenue for the City.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate. Please see Responses to Comments 14-2 through 14-6, 55-3, 121-28 and 121-32 for more information on impacts to wildlife and habitat.
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Response to Letter 82
Joe McGrath
November 4, 2021
82-1 The commenter states an opinion that CEQA regulations have not improved California’s natural environment.
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.
82-2 The commenter states that they have not read the Draft EIR thoroughly and that CEQA reports are too lengthy to be reviewed by most citizens.
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.
82-3 The comment states an opinion that the determination of a less-than-significant impact regarding use of the existing agricultural well upstream from the City is unprofessional and should instead be considered a potentially significant impact.
Please see Response to Comment 57-5 and Master Response 2. 82-4 The comment states an opinion that toilet retrofits would likely not be effective to meet water neutrality goals and suggests that the developer should invest in infrastructure to use recycled water. The comment also suggests that the Project incorporate real-time water meter reading and monitoring.
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. See also Master Response 2. 82-5 The comment states an opinion that landscaping requiring irrigation should not be allowed and that new plants should be appropriate to California.
The commenter’s opinion is noted and forwarded to the decision makers for their consideration. As stated in Chapter 2, Project Description, all public landscaping and irrigation would be required to meet the Model Water Efficient Landscape Ordinance requirements in Title 23, Chapter 27 of the California Code of Regulations. The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required.
82-6 The comment opines that pools, or pools without covers, should not be allowed.
Agenda Item #5.8.
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The Proposed Project does not include any pools but it does not preclude future homeowners from installing a pool. 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. 82-7 The comment asks whether the impact of runoff close to the Napa River and upstream of the Vineyard Valley Mobile Home Park and Pope Street bridge has been assessed and that the Project site should fully accommodate stormwater drainage far from the Napa River.
Please see Master Response 4 and Responses to Comments 35-4 through 35-6. 82-8 The comment states an opinion that the land uses in the City are causing workers to commute from other areas thereby increasing traffic congestion in the City.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 82-9 The comment states an opinion that the Proposed Project would result in more commuting traffic congestion and more parking supply issues in the City.
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 Responses to Comments 10-2 and 36-2 that address general traffic concerns.
82-10 The commenter suggests income restrictions for 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.
82-11 The comment asserts that the Project would take away a recreational area and therefore the impact should be considered potentially significant.
The Project site is privately-owned and is therefore not a public recreation area.
Additionally, as discussed in Section 3.12, Public Services and Recreation, the Proposed Project applicant would pay required park fees to be used by the City to purchase land to construct new parks or upgrade existing recreation facilities. 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 Agenda Item #5.8.
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EIR; therefore, no further response is required. Please see Chapter 3, Changes to the Draft for a trails map that shows trails adjacent to the Project site. 82-12 The comment states an opinion that the Project’s VMT analysis approach is incorrect and that the VMT would not be from the residents of the Project but rather employees that serve various needs of the residents.
The VMT analysis for the Project has been conducted per guidance provided by the Governor’s Office of Planning and Research in its Technical Advisory for Evaluating Transportation Impacts in CEQA. The metric for evaluation of VMT for residential projects is VMT per capita or resident and for most non-residential or office projects is VMT per employee. The Project proposes only residential use, therefore, the VMT of the Project would be assessed by estimating the vehicle miles traveled by Project residents for various purposes, such as work, shopping, education, recreation etc. The traffic generated by the Project has been evaluated in the traffic study prepared by Dudek. 82-13 The comment states an opinion the Proposed Project should not be built without an additional connection to Silverado Trail.
The Project does not include the extension of Adams Street 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. 82-14 The comment states an opinion that the Project should incorporate fire-wise design and defensible space.
The Project’s residences would be built in compliance with the California Building Code and California Fire Code requirements for fire protection in place at the time.
Public landscape areas and yards would be regularly irrigated and maintained during the dry summer and fall months to reduce fuel for wildfires. Additionally, please see Master Response 1 regarding emergency evacuation.
82-15 The comment suggests that the Project be Net-Zero energy.
The Project would meet the most current Title 24 standards which require the design of building shells and building components to conserve energy. These standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods. The 2019 Building Energy Efficiency Standards went into effect starting January 1, 2020. The 2019 standards aim to reduce energy use in new homes by more than 50% and require installation of solar photovoltaic systems for single-family homes. Development would be subject to whatever version of the state’s Building Efficiently Standards are in effect at the time of construction.
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Response to Letter 83
John Milliken
November 2, 2021
83-1 The comment refers to an article written by a professor at U.C. Davis and recommends City staff and the Planning Commission review the article.
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.
83-2 The comment states an opinion the Draft EIR does not address potential impacts and does not meet the standards set forth in CEQA for the preparation of EIRs.
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, the Draft EIR was prepared in compliance with California Public Resources Code [PRC], Section 21000 et seq., the CEQA Guidelines (14 CCR 15000 et seq.), and the City’s procedures for implementing CEQA.
83-3 The comment refers to requests to extend the comment period.
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 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 www.CityofStHelena.org.
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Response to Letter 84
John Milliken
November 30, 2021
84-1 The comment states an opinion that the Draft EIR does not indicate how the Project violates or is inconsistent with the City’s Zoning Ordinance and asserts that there are numerous violations of the City’s Zoning Ordinance and identifies non-compliance with the City’s Inclusionary Housing Ordinance because correspondence from the City to the Project applicant regarding compliance concerns were not addressed.
The commentor is correct that the City’s Inclusionary Housing Ordinance would require the Project provide a minimum level of affordability. The Project applicant’s proposal to meet this requirement is part of a subsequent discretionary approval (Affordable Housing Agreement) which must be approved before development can occur, as noted on page 2-32 of the Draft EIR. Staff will review the applicant’s proposal before making a recommendation to the City Council on the Affordable Housing Agreement; until that application is submitted, and the agreement approved by City Council, no development can occur on the site. Please also see page 2-18 of the Draft EIR which lists all the subsequent discretionary action approvals needed before development may occur and explains a final Affordable Housing agreement approved by the City Council would be required prior to recordation of a final subdivision map.
The letter to the applicant (dated April 13, 2021) which is noted by the commenter was responding to the applicant’s suggestion that alternatives were available to address inconsistencies between the proposed tentative map as it existed at the time and the standards of the St. Helena Zoning Code. The map has since been revised, as shown in the Draft EIR and based on staff’s review and consultation with the City Attorney, conforms with the requirements of the City’s Zoning Code and the Subdivision Map Act. 84-2 The comment asserts that the Tentative Subdivision Map is to be denied if it is not consistent with the City’s General Plan and any other relevant planning documents.
The commenter is correct. 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 is inadequate; therefore, no further response is required. Please see also Response to Comment 114-8.
84-3 The comment states an opinion that the Project is required to include an Affordable Housing Agreement and therefore it is not possible to prepare an EIR absent this agreement and notes the Project currently does not include an Affordable Housing Agreement which would make the Project eligible for a state mandated density bonus.
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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 also Response to Comment 84-1 that addresses the Affordable Housing Agreement.
84-4 The comment refers to the need for the EIR to evaluate any increase in units attributed to a density bonus, including how the accessory dwelling units (ADUs) would be defined.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see also Response to Comment 84-1 that addresses the Affordable Housing Agreement. As discussed in Response to Comment 84-4, a future density bonus request, including changes to development standards, would be made as part of the Use Permit approval process for the attached housing units, which would be subject to CEQA review. 84-5 The comment emphasizes that, in the commenter’s opinion, because an Affordable Housing Agreement is not considered part of the Project, the Project violates the City’s Municipal Code and would result in further changes to the number, types and distribution of units to comply with the City’s affordable housing requirements. The comment requests that the City require the applicant to provide an Affordable Housing Agreement that is analyzed in this EIR.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Responses to Comments 84-3 and 84-4 that address the Affordable Housing Agreement requirement. 84-6 The comment refers to a conservation easement and implies that the extension of Adams Street and the intersection of Adams Street and Starr Avenue would be within this easement. The comment goes on to state that a City-owned parcel currently used to enable access to the walking path/trail and the separate levee maintenance road would be paved over by the extension of Starr Avenue.
The comment does not address the accuracy or adequacy of the Draft EIR; therefore, no further response is required. The City has confirmed that the easement noted by the commenter does not include any part of the Project site and would not be affected by the Project. The Proposed Project improvements would not remove the existing levee trail and would not prohibit access to the trail. 84-7 The comment refers to the City’s Flood Protection Project and asserts that an issue exists associated with misuse of funds.
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 additional information on the Napa River levee.
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84-8 The comment refers to comments submitted by another resident on the 2040 General Plan Update project specific to the extension of Adams Street and asserts that the City did not include the extension of Adams Street as part of the Flood Control Project, which was not discussed in the Draft EIR. The comment goes on to state an opinion that there is a lack of City maintenance of the levee and that the levee was never built to accommodate a road.
Comments specific to the 2040 General Plan Update are not relevant to addressing the accuracy or adequacy of the Hunter Subdivision Project; therefore, no response is required. Please see Master Response 3 that addresses concerns associated with the levee including maintenance.
84-9 The comment refers to the conservation easement and the change in character for people accessing the trail with residences proposed adjacent to a portion of the trail.
The change in visual character for people accessing the trail is addressed in detail in Section 3.1, Aesthetics/Visual Resources. As explained on page 3.1-27, the public trail that borders the north/northwest boundary of the site also provides public views of the site. 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. The City has not identified this area for protection of public views.
Please see Response to Comment 84-6 for information regarding the conservation easement and a trails map included in Chapter 3, Changes to the Draft EIR that shows trails adjacent to the Project site. 84-10 The comment asserts that the Draft EIR evaluated the Project’s increase in vehicle miles traveled (VMT) but did not address other traffic impacts and also did not address public safety concerns associated with evacuation in the event of an emergency.
The Draft EIR evaluates impacts associated with an increase in VMT. The comment does not specify what traffic impacts were not addressed; therefore, no response is required. Please see Master Response 1 that addresses concerns regarding evacuation in the event of an emergency.
84-11 The comment states an opinion that the Draft EIR does not address pass through traffic by those drivers seeking to avoid congestion on Main Street.
Please see Response to Comment 84-10. These types of transportation operational issues are not required to be evaluated in an EIR.
84-12 The comment discusses what the commenter projects will be an increase in traffic for neighboring areas to navigate with the new intersection of Hunt Avenue and Starr Avenue and the increase in traffic on Starr Avenue.
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Please see Response to Comment 84-10.
84-13 The comment addresses existing parking concerns that the commenter feels exist on Starr Avenue, asserts that these existing parking issues will be exacerbated with the Project, and states the multi-family component can request a parking concession that will reduce the amount of parking to be provided.
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.
As noted in Response to Comment 84-4, the Project applicant is not requesting a density bonus as part of the Project.
84-14 The commenter asserts that evacuation routes for Vineyard Valley and surrounding areas could be impacted by the Project resulting in a public safety failure.
Please see Master Response 1 that addresses concerns regarding emergency evacuation.
84-15 The comment asserts that the City has not been maintaining the levee and the levee was never designed or intended to be used for a road, which could contribute to failure of the levee and goes on to claim this contributes to a compromised levee/floodwall.
Please see Response to Comment 73-5. Please see also Master Response 3 that addresses concerns associated with the levee.
84-16 The comment states an opinion that rodent damage has compromised the integrity of the levee and questions the City’s maintenance records relative to rodent issues.
The manner in which inspection and maintenance responsibilities for the existing levee are assigned are not environmental effects related to the Proposed Project.
Furthermore, under CEQA, the effects of the environment upon the project are not “impacts.” Rather, CEQA requires the lead agency to consider the ways in which the project effects the environment. Please see Master Response 3 that addresses the maintenance, design and stability of the levee.
84-17 The comment claims that the City would be liable in the event of a levee failure resulting in a loss of City funds to provide services to City residents.
Legal liability for a potential future event is not within the scope of CEQA review. The comment does not identify specific issues regarding the adequacy or accuracy of the Draft EIR; therefore, no further response is required. Please see Response to Comment 73-5.
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An attachment to this letter can be found in Appoendix B.
COMMENT LETTER 85
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Response to Letter 85
Michael Mills
November 29, 2021
85-1 The comment states an opinion the Draft EIR does not accurately or fairly evaluate the Project’s potential significant environmental effects, specifically regarding the topics of geology, soils, hydrology, and water quality.
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. However, potential Project impacts to geology and soils are addressed in Section 3.6, Geology and Soils; and potential impacts to hydrology and water quality are addressed in Section 3.9, Hydrology and Water Quality.
85-2 The comment agrees with the Draft EIR’s VMT analysis conclusion of a significant and unavoidable impact. The comment goes on to suggest using vehicle ownership data for city residents to estimate the Project’s VMT rather than values from the travel demand model.
The comment does not identify specific issues regarding the adequacy or accuracy of the Draft EIR; therefore, no further response is required. Please see Response to Comment 98-3 regarding VMT.
85-3 The comment disagrees with the consultant’s (W-Trans) opinion provided in the peer review of the Project’s VMT analysis that the significant and unavoidable impact determination by the City is conservative.
This is a closing comment that does not raise a significant issue regarding the adequacy or accuracy of the Draft EIR; therefore, no further response is required. 85-4 The comment states an opinion that parking in the area is insufficient and that neighborhood homeowners have trouble finding 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.
85-5 The comment states an opinion that maps provided in the Draft EIR are deficient and lack information necessary to understand the Project, but notes specific problems with Figure 2-4 only.
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provided on a tentative map. Information necessary to evaluate the proposed Tentative Subdivision map in the Draft EIR is adequate to evaluate potential Project impacts.
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Response to Letter 86
Doris Mosler
October 30, 2021
86-1 The commenter opposes the Project, claiming that the City is too small to support the Project and expresses general concerns related to noise, traffic, and bird habitat.
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 87
Janell Myhre
November 30, 2021
87-1 The comment states opposition to the Project, supports the claims listed in the letter from Vineyard Valley residents (Comment Letter 111), and wishes to be added to that letter.
The comment also states the commenter’s experience working in emergency management.
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.
87-2 The comment references Comment Letter 111 and asserts that the Project would negatively impact the Vineyard Valley community due to lack of infrastructure.
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 4 that addresses wastewater infrastructure concerns.
87-3 The comment states an opinion the Project would eliminate evacuation routes for Vineyard Valley residents which would be dangerous in the event of an emergency.
Please see Master Response 1 that addresses concerns associated with emergency evacuation.
87-4 The comment requests that City staff explore other options to develop affordable housing.
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 88
Timothy Nieman
88-1 The comment states an opinion that the conclusions in the peer-reviewed well capacity and sustainability analysis include “... appallingly bad science and also bad logic …" and should be revised to state the what the commenter asserts are uncertainties in the study about local geology and hydrology.
The conclusion of the independent analysis prepared by a California licensed and certified Engineering Geologist is that use of the on-site well and pumping from the deeper volcanic aquifer would have less of an effect on the Napa River than withdrawals from the shallow alluvial aquifer. The language on page 3.9-43 of the Draft EIR has been revised to follow the language of the report more closely. Please see Chapter 3, Changes to the Draft EIR for the revised language.
The findings of the independent analysis as well as the proposed volume of pumping support a the EIR’s finding of a less-than-significant impact. 88-2 The comment states an opinion that the finding of less than significant related to the effects of using the onsite well for irrigation use is unsupported.
As stated above in Response to Comment 88-1, the conclusion related to the effects of the proposed onsite well use is based on the professional opinion of a California licensed and certified Engineering Geologist, the known details of the well screening exhibited in Appendix L of the Draft EIR, the relative volume of pumping proposed for the Project’s irrigation purposes, and the direct observations of the well capacity test that was performed onsite. The Well Capacity report (DEIR Appendix L) also includes the recorded stratigraphy that was part of the well completion report that was completed at the time of well construction (Attachment C of Appendix L) that does offer data on the underlying geologic units at the site. 88-3 The comment states an opinion that approval of the well (to provide water for landscape irrigation) is not acceptable until more hydrogeologic data is obtained and the County’s Groundwater Sustainability Agency issues its findings and the potential impact be changed to significant and unavoidable.
Please see Response to Comment 88-2.
88-4 The commenter takes issue with levee safety and the description in the Draft EIR of an overtopping event as something that would be slow and gradual.
To avoid confusion, the sentence that refers to the flooding as slow and gradual has been removed from the document, as shown in Chapter 3, Changes to the Draft EIR.
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See also Master Response 3 for more information related to the levee and flood protection.
88-5 The comment includes a quote from the Association of State Floodplain Managers which states that levees should not be used to protect undeveloped land so that development can occur.
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 regarding the levee.
88-6 The comment references the levee maintenance procedure described in the Draft EIR.
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 regarding the levee.
88-7 The comment requests documentation showing that levee bank inspection and related maintenance have been conducted as least once every three months.
Please see Responses to Comments 75-1, 73-5 and Master Response 3. 88-8 The comment requests documentation regarding the identification and management of animal burrows at the levee.
Please see Responses to Comments 75-1 and 73-5 and Master Response 3. 88-9 The comment concerns a statement made about the location of the epicenter of the 1906 earthquake.
To clarify, the text has been edited on page 3.6-12 of the Draft EIR to correct the description of the 1906 earthquake and is included in Chapter 3, Changes to the Draft EIR.
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COMMENT LETTER 89
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Response to Letter 89
Indrajit Obeysekere
November 22, 2021
89-1 The comment provides an introduction and clarifies that the letter is submitted as a resident of Vineyard Valley Mobile Home Park and not on behalf of other residents or as legal counsel for Vineyard Valley.
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. 89-2 The comment states the Vineyard Valley community is opposed to the Project and the Draft EIR is inadequate because it does not address impacts to the Vineyard Valley senior citizen residents, which are sensitive to impacts from pollutants, noise, glare and traffic and goes on to note the residents are dependent on the open space that will be eliminated by 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 EIR analysis is inadequate, but it should be noted that the Draft EIR includes detailed analyses of all of the topical areas noted in this comment. 89-3 The comment refers to the existing trail that is located parallel to the City’s levee maintenance road and asserts the Project will diminish enjoyment of the trail due to development of the Project site and notes that the Draft EIR includes an analysis of aesthetic impacts.
The commenter’s opinion that the Project would affect enjoyment of the trail is noted and forwarded to the decision makers for their consideration. The aesthetic impacts of the Project are addressed in Section 3.1 of the Draft EIR. The comment does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required.
89-4 The comment states an opinion that development of the Project site resulting in the loss of open space will impact property values and requests that the City Council to consider this as they review the Project.
CEQA does not require an evaluation of the potential financial impacts of a project.
The commenter’s opinion that the Project would affect neighboring property values 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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89-5 The comment claims that the Project would reduce the length of the “community” trail near the site by approximately 40%, and eliminate the prescriptive easement (of the trail) for the benefit of the public over private land and alleges that the Draft EIR diminishes the significance of this community asset.
The Draft EIR acknowledges the existence of the public trail, as noted on pages 2-2 and 2-23 in Chapter 2, Project Description. The EIR notes that the maintenance road adjacent to the northern boundary of the Project site is not a part of the Proposed Project, nor is it a City trail. There is an existing City trail located on the northside of the maintenance road, as shown on a trails map provided in Chapter 3, Changes to the Draft EIR. A small portion of the maintenance road, which is merged with the trail in this location 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. 89-6 The commenter states they are not opposed to development of the Project but are concerned that the Vineyard Valley community was not consulted and indicate the addition of mitigation would have improved 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. 89-7 The comment states an opinion that the Draft EIR is piecemealing the Project because the “whole of the action” does not evaluate additional discretionary approvals effectively eliminating areas of potential controversy and impacts thereby denying the public an opportunity to review and comment.
As noted in Chapter 2, Project Description, the Project applicant submitted an application for a Tentative Subdivision Map that was deemed complete by the City in March 2011. The applicant will subsequently need to obtain approval of an Affordable Housing Agreement, Design Review, or a Use Permit to construct the attached multifamily housing at this time. The public will have the opportunity to review and comment on these subsequent actions. The City is not piecemealing the Project to reduce or eliminate Project impacts and the Draft EIR properly evaluated impacts of the Project.
89-8 The comment states an opinion that Project approvals are being piecemealed and therefore the Draft EIR should be resubmitted and recirculated.
Please see Response to Comment 89-7.
89-9 The comment states an opinion that the applicant plans to piecemeal the Project by deferring the multifamily housing to a further date since it would require a conditional use permit.
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Please see Response to Comment 89-7.
89-10 The comment states an opinion that referring to the trail as a “gravel maintenance road” is dismissive and fails to convey the importance of the trail to the community.
Please see Responses to Comments 70-6 and 89-3.
89-11 The comment states an opinion that the Project would eliminate a substantial portion of the trail by extending Adams Street to Starr Avenue and adding parking to both sides of the extended street.
Please see Responses to Comments 89-3 and 70-6.
89-12 The comment states an opinion that the Project objectives are the applicant’s objectives rather than those of the City as lead agency.
The Project objectives are endorsed by the City as lead agency. No further response is required; the comment is noted and forwarded to the decision makers for their consideration.
89-13 The comment suggests that instead of eliminating the trail by extending Adams Street to Starr Avenue, Starr Avenue can be extended and widened to a cul-de-sac ending at the community trail.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 89-14 The comment states an opinion that an alternative to preserve a portion of the existing vineyards is to incorporate the vineyards as a front yard for Lots 30 to 40.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 89-15 The comment states an objection to the extension of Adams Street at the cost of the community trail.
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. Please see Response to Comment 89- 5 regarding the trail.
89-16 The comment states an opinion that the City should require the developer to enter into a development agreement to vest the 6-year phasing of the multifamily portion of the Project and to enhance and preserve the community trail in the manner stated in the comment.
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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.
89-17 The comment states an opinion that the Draft EIR is flawed because it disregards foreseeable market demand.
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.
89-18 The comment states an opinion that the traffic analysis should be evaluated in phases and construction should be delayed or accelerated based on the phased analysis.
Section 3.14 of the Draft EIR contains the transportation analysis. The transportation analysis does not include a phased approach to buildout of the Project, and the horizon year analyzed was 2040. As stated in the Draft EIR and Appendix K, the Proposed Project would be expected to be completed and occupied by the year 2040. 89-19 The comment states an opinion that the Draft EIR does not adequately describe the aesthetic impact of the Project to users of the community trail.
Please see Responses to Comments 89-2 and 89-3.
89-20 The comment states an opinion that the Draft EIR fails to apply its own analytical standards and the Project would have an obvious significant unavoidable impact to users of the community trail.
Please see Responses to Comments 89-3 and 70-6.
89-21 The comment states an opinion that the community trail fits the definition of a scenic vista.
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.
89-22 The comment states an opinion that the Project alternatives were designed to be easily discarded in favor of the Proposed Project.
Chapter 5 of the Draft EIR evaluates Project alternatives. Section 15126.6(a) of the CEQA Guidelines states there is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason. This rule is described in Section 15126.6(f) of the CEQA Guidelines and requires an EIR to set forth only those alternatives necessary to foster informed decision-making. As defined in Section 15126.6(f), the rule of reason limits alternatives analyzed to those that would avoid or substantially lessen one or more of the significant effects of a project. Of Agenda Item #5.8.
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those alternatives, an EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives that was selected for analysis includes those that would result in reduced impacts when compared to those of the Project.
The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
89-23 The comment states an opinion that the Park/Open Space Preserve alternative is not aggressive or visionary and the developer should have incorporated the wetland into the Project.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 89-24 The comment states an opinion that the best alternative would be a smaller project that eliminates lots 40 through 50, creates a vineyard buffer, and does not include the extension of Adams Street.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. Please see Response to Comment 89-22.
89-25 The comment states that the Draft EIR identifies significant and unavoidable impacts to the community trail and states an opinion that the vineyard would be considered a natural feature.
The analysis in Section 3.1, Aesthetics determines impacts to scenic vistas and the potential for the Project to conflict with zoning and other regulations that govern scenic quality or substantially degrade the existing visual character or quality of public views of the site and its surroundings to be less than significant. The Draft EIR does not identify any significant and unavoidable impacts to scenic vistas, changes in visual character or public views.The commenter does not state where in the Draft EIR it is stated that impacts to the adjacent trail are significant and unavoidable. 89-26 The comment states an opinion that the Draft EIR exceeds the threshold for significance for damage to scenic resources and requests the City reject the Project in favor of a project with reduced density and preservation of the community trail.
The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
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Response to Letter 90
Gabriel and Tishna Pastrama
November 30, 2021
90-1 The commenters state that they are concerned about the Project’s impact on fire risks, drought conditions, electrical outages, road conditions, parking, sewer capacity, and emergency access.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. Further. the adequacy of parking supply is not an environmental impact under CEQA. The commenter’s concern is noted for the decision makers and no further response is required. Therefore, the commenter’s concern is noted for the decision makers.
The Project’s impact on water supply is discussed in Master Response 2; the Project’s impact on emergency access is discussed in Master Response 1; and the Project’s impact on sewer capacity is discussed in Master Response 4. Please also see Response to Comment 51-4 related to fire protection. 90-2 The comment expresses concern regarding the Project’s impact on parking and pedestrian safety.
See Response to Comment 90-1.
Regarding pedestrian safety, Section 3.14 of the Draft EIR addresses this concern. This section analyzes the Project’s transportation impacts related to consistency with plans or policies addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities, hazardous design, and emergency access. The Draft EIR concludes that the Project would have less-than-significant impacts to pedestrian safety. 90-3 The comment repeats a concern related to the City’s parking.
Please see Response to Comment 90-1.
90-4 The comment raises a concern regarding the Project’s impact on emergency evacuation.
Please see Master Response 1, which discusses emergency access and evacuation. 90-5 The comment states an opinion that affordable housing should not be located on one side of the City and, because of this feels that the Project is discriminatory.
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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. 90-6 The commenter is concerned with the Project’s impact on the City’s electrical grid and current condition of the City’s grid.
No specific concerns with the existing electrical infrastructure were identified. The comment does not identify any specific areas where the Draft EIR analysis, finding that the Project’s energy impacts are less than significant, 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 91
Joann Patton
October 31, 2021
91-1 The comment states opposition to the Project. In particular, the comment mentions the Project’s water supply and potential levee failure as issues.
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 92
Kathleen Paulus
October 30, 2021
92-1 The comment states that the Project would be located in the Napa River floodplain, which experiences periodic flooding.
Please see Master Response 3.
92-2 The comment states that building on floodplains has serious consequences because of increased runoff.
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.
92-3 The comment states that building on a floodplain would destroy natural habitat for many species.
Potential impacts to wildlife species are discussed in Section 3.4 of the Draft EIR.
The comment is noted and forwarded to the decision makers for their consideration. 92-4 The comment states an opinion that construction on a floodplain would make it dangerous for wildlife habitat downriver as oils and dirt would pollute the river.
Potential water quality and runoff impacts are discussed in Section 3.9 of the Draft EIR. 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 also Response to Comment 92-3.
92-5 The comment states an opinion that developers want to build in floodplains because they tend to be flat and tend to be close to other amenities.
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 93
Leslie R. Perry, Law Offices of Perry, Johnson, Anderson, Miller & Moskowitz
November 1, 2021
93-1 The comment is an introduction to responses prepared by W-Trans and DKS on the Draft EIRs transportation analysis.
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.
93-2 The comment provides a general introduction to the VMT analysis and asserts that the VMT analysis included in the Draft EIR is conservative and does not meet the intent of current City and state polices.
Please see Response to Comment 93-8.
93-3 The comment reiterates the intent of SB 743 and quotes guidance from OPR’s Technical Advisory regarding assessment of VMT impacts and the ability of the lead agency to adopt their own thresholds of significance.
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.
93-4 The comment reiterates OPR’s recommended guidance for measuring VMT, screening criteria, and significance threshold to evaluate VMT impacts.
The commenter is confirming the approach used to evaluate the Project’s VMT analysis. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 93-5 The comment reiterates OPR’s recommended guidance and screening criteria to determine VMT significance.
The commenter is confirming the approach used to evaluate the Project’s VMT analysis. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 93-6 The comment reiterates OPR’s approach to establish VMT thresholds.
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The commenter is confirming the approach used to evaluate the Project’s VMT analysis. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 93-7 The comment provides results of the Napa-Solana Travel Demand Model VMT for the City and the Project’s traffic analysis zones (TAZ).
The commenter is confirming the approach used to evaluate the Project’s VMT analysis. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 93-8 The comment states that using the citywide average compared to the countywide average as the baseline for VMT would require mitigation measures which are not achievable for residential projects in the City.
The OPR guidance under the frequently asked questions for SB 743 Implementation section, in response to consideration of geographic boundary for VMT impacts (https://opr.ca.gov/ceqa/sb-743/faq.html#VMT-TA-regional) states that:
As used in the VMT Technical Advisory, “regional” refers to the full geography within the jurisdictional borders of a metropolitan planning organization (MPO) or a regional transportation planning agency (RTPA). Comparing a project’s VMT per capita or VMT per employee to that of the entire region (i.e., MPO or RTPA) or entire city allows a lead agency to better align with the state’s climate commitments.
Comparison to only a portion of the region or city could result in a less environmentally protective significance threshold, potentially disconnecting significance determinations from those commitments. For example, comparing a project to only the unincorporated areas of a county, or just a select portion of a county, may exclude lower VMT areas. However, thresholds that vary by location, but where each threshold is more environmentally protective than a region- or citybased threshold, would still be aligned with state climate commitments.
Additionally, it is stated in the OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018):
Proposed development referencing a threshold based on city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the number of units specified in the SCS for that city, and should be consistent with the SCS.
As mentioned in the OPR guidance, a more environmentally protective approach would be considered aligned with state climate goals. Therefore, using the citywide average (11.34 VMT per capita) as the baseline provides the city a threshold that is more conservative than the countywide average (17.30 VMT per capita). This would result in significant VMT impacts and require projects to implement mitigation measures to reduce VMT. However, it is possible that some projects may need to adopt overriding considerations if feasible mitigation measures are not available or Agenda Item #5.8.
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adequate. Future residential projects would be consistent with the City’s goal of providing more housing units including affordable housing. Additionally, the residential units provided by the Project are consistent with City’s General Plan, General Plan Housing Element requirements and the Plan Bay Area 2040 Regional Transportation Plan and Sustainable Communities Strategy. 93-9 The comment states that affordable housing has been identified as a strategy that can be presumed to reduce a project’s VMT.
The Draft EIR notes inclusion of affordable workforce housing as part of the Project but does not estimate any associated VMT reduction. Based on OPR guidance, projects that propose 100% affordable housing can be presumed to have a lessthan-significant VMT impact. Guidance for VMT reduction strategies is available in the document Quantifying Greenhouse Gas Mitigation Measures, August 2010 from the California Air Pollution Control Officers Association (CAPCOA) which has been recently updated in the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, August 2021. Per the CAPCOA 2010 handbook, a maximum of 1.2% VMT reduction is achievable by including affordable housing in a project. Per the updated 2021 handbook, integrating affordable and below market housing units is considered a supporting or non-quantified greenhouse gas and VMT reduction measure.
Therefore, it is inferred that the VMT reduction due to integration of affordable housing in the Project would not reduce the Project’s VMT impact to less than significant and hence is not included in the Draft EIR VMT analysis, which presents a more conservative approach.
93-10 The comment states that adopting the citywide average as the baseline for determining VMT impacts would result in all future residential projects in the City (that generate more than 110 trips per day) to result in a significant VMT impact requiring preparation of an EIR and adoption of overriding considerations. This would increase the cost to project applicants and increase the difficulty in addressing the City’s need for housing.
As noted in Response to Comment 93-8, using the citywide average as the baseline provides the City a threshold that is more conservative and would require projects to implement mitigation measures to reduce VMT. However, it is possible that some projects may result in a significant and unavoidable VMT impact and need to adopt overriding considerations.
93-11 The comment explains that the commute pattern, housing affordability, and jobs/housing ratio in the City supports and meets the intent of SB 743 and achieves VMT reduction if more housing is provided in the City.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.
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93-12 The comment supports using the countywide VMT as baseline for comparing the Project’s VMT per capita and concluding less than significant impact.
Please refer to response 93-8.
93-13 The comment restates that the City should consider adopting an appropriate VMT baseline for determining VMT impacts which allows the City to achieve its housing goals.
Please see Response to Comment 93-8.
93-14 The comment states that DKS analyzed consistency with City zoning and land use designations, current planning initiatives, non-market-based housing ratio and California Density Bonus Law criteria, and the Project’s VMT.
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.
93-15 The comment is restating information from the Project description.
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.
93-16 The comment states that the Project is consistent with all relevant density restrictions and zoning code policies.
The commenter is correct. The Project is consistent with the City’s land use designation and zoning for the site. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 93-17 The comment states that the Napa Countywide Bicycle Plan, St. Helena Pedestrian Plan, and General Plan Circulation and Climate Change sections were reviewed for policies and planning initiatives relevant to the Project.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.
93-18 The comment states the intent of SB 743 and guidance from the OPR’s Technical Advisory on VMT screening and notes that the Project does not meet any of the screening criteria.
The commenter is correct. The Project was reviewed to determine if it would meet any of the screening criteria established by OPR and based on this review the Project does not meet any of the screening criteria.
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93-19 The comment elaborates on the affordable housing VMT screening criteria and provides an example from the City of Goleta which allows any housing development that provides 20% non-market rate housing units, to screen out from doing a VMT analysis. The comment suggests that the City should consider such screening criteria to presume less than significant VMT impacts.
As described in Response to Comment 93-9, available methods for estimating VMT reduction by integrating affordable and below market housing units suggest that the VMT reduction achieved by doing so is either low (less than 2%) or non-quantifiable.
The City has chosen to use the methodology which provides the most conservative or environmentally protective criteria and threshold to assess VMT impacts. 93-20 The comment describes the intent of SB 743 and its relationship with the state’s climate change goals and lists other legislative mandates and mandates that target greenhouse gas emission reduction. The comment compares the citywide VMT and countywide VMT and suggests that regional average should be used for establishing the baseline VMT.
Please see Response to Comment 93-8 for an explanation regarding use of the citywide VMT baseline.
93-21 The comment compares the TAZ structure representing the City with a larger city such as Santa Maria and states an opinion that, in order to establish a citywide baseline threshold, there should be a larger sample of TAZs and variation in land uses.
The commenter is providing their opinion, which is not supported by the OPR guidance and recommendations, regarding the size or land uses of a city. As stated in Response to Comment 93-8, the OPR guidance has allowed the lead agency to determine whether a citywide or regional VMT should be used as the baseline and the lead agency can also choose a more environmentally protective threshold, which the City has done.
93-22 The commenter states they are not aware of any other city that has used a citywide baseline average for residential uses and that most cities within the Napa County have not formally adopted VMT threshold or screening criteria.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 93-23 The comment provides a closing statement and restates that OPRs Technical Advisory is an implementation guidance to establish VMT thresholds and suggests the OPR recommended VMT screening criteria be used for the Project’s VMT analysis and reiterates using the regional baseline versus the citywide VMT.
Please see Responses to Comments 93-8, 93-9 and 93-10.
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93-24 The comment confirms that the Project does not exceed the population or number of units specified in the Plan Bay Area 2040 Regional Transportation Plan and Sustainable Communities Strategy.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 93-25 The comment restates that using the citywide VMT baseline does not align with the intent of SB 743.
Please see Responses to Comments 93-8 and 93-10.
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COMMENT LETTER 94
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Response to Letter 94
Leslie R. Perry, Law Offices of Perry, Johnson, Anderson, Miller & Moskowitz
November 8, 2021
94-1 The letter objects to an extension of the CEQA comment period and claims the City has delayed processing the Project.
Based on numerous requests from local residents to extend the Draft EIR comment period the City granted an extension of an additional 22 days. The City has not intentionally delayed processing the Project or completion of the CEQA process.
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Response to Letter 95
Vivian Pirchner
November 18, 2021
95-1 The commenter requests to be added to a list of those opposed to the Project.
The commenter has been added to a list of interested public members; however, this list does not distinguish those who support or oppose the Project. 95-2 The comment states a concern regarding the Project’s impact on 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.
95-3 The comment raises a concern that the Project would negatively impact emergency evacuation within the area.
Please see Master Response 1 that addresses concerns associated with emergency evacuation.
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COMMENT LETTER 96
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Response to Letter 96
Chuck Pniower
November 16, 2021
96-1 The commenter is concerned regarding the Project’s impact on the City’s sewer infrastructure and fire department.
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. 96-2 The comment acknowledges the need for housing and requests the City to find a balance in supporting developers and the community.
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 97
Patrick and Laura Pohlen
97-1 The comment refers to the City’s infrastructure and states an opinion that improvements are needed before the City can approve new development. The comment mentions general concerns related to the following topics: water, sewer, storm drainage, utilities, police, fire, and schools and states an opinion that City’s infrastructure cannot handle the increased Project demand.
Impacts regarding public utilities and public services are addressed in Sections 3.12 and
3.13 of the Draft EIR. Please see Master Responses 1, 2 and 4 regarding the ability of the City’s police and fire departments to serve the Project, and water and wastewater infrastructure. See also Response to Comment 14-4 related to public services. 97-2 The comment raises concerns related to the Project’s impact on traffic congestion and 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. Please see Responses to Comments 10-2 and 36-2 that address general traffic concerns.
97-3 The comment states an opinion about the advantages of maintaining open space and opines that the loss of the site’s open space will negatively impact residents.
The Project site is privately owned and is therefore not a public open space. 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.
97-4 The comment provides an aerial image of the project site and asks the City to reject the Project.
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 98
Charlotte Powell
October 31, 2021
98-1 The comment states opposition to the Project due to potential impacts to wildlife and open space.
Please see Section 3.4 of the Draft EIR and Responses to Comments 14-2 through 14-6, 55-3, 121-28 and 121-32 for more information on impacts to wildlife and habitat.
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Response to Letter 99
Lisa Redmon
October 28, 2021
99-1 The comment provides the commenter’s personal history as a resident 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. 99-2 The comment raises concerns about flooding and water supply and states that previous projects were rejected due these considerations.
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 Responses 2 and 3 related to the Project’s water supply and potential flood-related impacts. 99-3 The comment raises a concern about emergency evacuation in the event of a fire.
Please see Master Response 1 addressing concerns regarding emergency evacuation. 99-4 The comment raises a concern regarding the Project’s 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.
99-5 The comment states an opinion that low-income housing should be spread out throughout the City, rather than concentrated in one 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.
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Response to Letter 100
Greg Reynolds
November 5, 2021
100-1 The comment serves as an introduction to the commenter and notes numerous concerns 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.
100-2 The comment states three areas of concern: emergency evacuation, water/sewer discharge, and traffic.
Please see Master Response 1 for information on emergency evacuation concerns and Master Response 4 for information specific to wastewater. The comment does not indicate any specific concerns regarding traffic or where the Draft EIR analysis is inadequate; therefore, no further response can be provided. 100-3 The comment introduces the Vineyard Valley Mobile Home Park and asserts that the mobile home community has spent an increasing amount of time focused on fire suppression, readiness, and safety.
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.
100-4 The comment states the Project was not part of the City’s Flood Protection project.
Please see Master Response 3 that addresses the Flood Protection Project in relation to this Project.
100-5 The comment expresses a concern about emergency evacuation for Vineyard Valley residents and harm to the levee from Project construction.
Please see Master Response 1 for additional information on emergency evacuation concerns and Master Response 3 for information on the Napa River levee (or the City’s Flood Protection Project).
100-6 The comment states the commenter’s concern about water conservation.
Please see Master Response 2 for more information on water supply. 100-7 The comment states an opinion that connecting the Project to the Vineyard Valley wastewater discharge sewer would overwhelm the sewer system.
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Please see Master Response 4 which addresses this concern in detail. 100-8 The comment states an opinion that, because the Project’s VMT is estimated to exceed the City wide VMT per capita and would result in a significant and unavoidable impact, the Project should be denied.
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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COMMENT LETTER 101
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Response to Letter 101
Ringenberg
November 2, 2021
101-1 The comment is opposed to the Project and states an opinion that it would provide no positive contribution to the community.
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.
101-2 The comment states an opinion that there are many environmental concerns that would arise from 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.
101-3 The comment states an opinion that two-story homes would eliminate views of scenic vistas for Valley Vineyard residents and any pedestrians who use the open space area and the Project seems to be an upscale development.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision -makers for their consideration. 101-4 The comment states an opinion that long-term construction of the Project would impact aesthetics.
Short-term visual construction-related impacts are not evaluated because the impacts are temporary and would not result in any long-term, permanent impacts.
Please see Responses to Comments 7-6 and 84-9 that address potential aesthetic impacts.
101-5 The comment states an opinion that Project construction would cause traffic impacts and damage roads.
The Project’s impact on transportation and circulation is addressed in Section 3.14, Transportation and Circulation. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required.
101-6 The comment asks what impact the Project would have on the current riparian reserve.
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Impacts to riparian habitat are discussed in Section 3.4 of the Draft EIR. Please see also Response to Comment 14-2 that addresses impacts to riparian resources. 101-7 The commenter states an opinion, related to air quality, that there is an extensive amount of construction vehicles and heavy-duty construction equipment resulting in approximately 100-200 vehicles for residency, averaging a maximum of two per household.
It is unclear if the commenter is stating construction of the Project would generate 100-200 vehicles relative to the number of proposed residents. However, as discussed in Section 3.3, Air Quality, the construction equipment mix used for estimating the construction emissions of the Proposed Project is shown in Table 3.3- 5 of the Draft EIR. Notably, because detailed specific information regarding the construction equipment fleet is unknown at the time of analysis, the analysis is based on the default construction equipment fleet provided by California Emissions Estimator Model (CalEEMod) which is based on land use information such as the number of dwelling units to be developed. Furthermore, construction tabs within CalEEMod contain default information that was obtained from a survey of other construction sites conducted by the South Coast Air Quality Management District.
The construction survey data is grouped by construction phase and lot acreage. The default construction equipment list and phase length data were determined to be the most appropriate for the size and types surveyed. Regarding vehicle trips generated by operations, trip generation of the Project was based on the Traffic Impact Study.
Overall, construction and operations of the Project would not exceed the air district’s significance thresholds, as presented in Tables 3.3-8 and 3.3-9 in the Draft EIR, and impacts would be less than significant.
101-8 The comment includes an excerpt which states that human activity has changed the natural environment to a point where the viability of many ecosystems is now under threat.
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.
101-9 The comment asks whether an archaeologic study has been performed at the Project site and asserts that a tribal burial ground was identified at adjacent land.
The analysis conducted for the Draft EIR included a very thorough evaluation of the potential for subsurface cultural resources, as well as human remains to be present.
As noted on page 3.5-23, “a Cultural Resources Inventory and Extended Phase I and Phase II Report was prepared for the Proposed Project in March 2020 (Appendix E).
The inventory included a review of the CHRIS records search provided by the NWIC, NAHC sacred lands file search, Native American coordination, historic research, an intensive pedestrian survey, XPI investigations, Phase II excavation, and ground penetrating radar. The study also reviewed historical aerials and topographic maps. The Agenda Item #5.8.
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CHRIS records search included a review of their collection of mapped prehistoric, historical and built-environment resources, Department of Parks and Recreation (DPR) Site Records, technical reports, archival resources, and ethnographic references.
Additional consulted sources included the NRHP, California Inventory of Historical Resources/CRHR and listed Office of Historic Preservation Archaeological Determinations of Eligibility, California Points of Historical Interest, California Historical Landmarks, and Caltrans Bridge Survey information.”
Please see also Response to Comment 55-4.
101-10 The comment asserts, without providing evidence, that the levee has not been maintained since 2010 and that there is significant rodent activity in the levee. The comment also brings up a concern about liquification of alluvial soils.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. Please see Master Response 3 regarding the levee.
Liquefaction impacts are discussed in Section 3.6 of the Draft EIR. Mitigation measure GEO-1 requires prior to the issuance of any site-specific grading or building permits, the Project applicant shall have a design-level geotechnical report prepared and submitted to the City for review and approval in accordance with adopted City standards. The proposed structural building designs are also required to adhere to the currently adopted version of the California Building Code, which includes standards for seismic safety related to soil stability. 101-11 The commenter states an opinion that, due to the increase in vehicular traffic, the global warming effects from additional roadways, home emissions, reflection, and reduction of absorbing land surface should be considered. In addition, the comment appears to address two separate issues: changes in GHG emissions from Project activities, and what is often referred to as the “urban heat island effect” resulting from land use changes. Both issues are addressed below.
GHG emissions related to Project construction and operation, including vehicular emissions, is discussed under Impact 3.7-1 on page 3.7-30 of the Draft EIR. The Project would result in estimated GHG emissions of 815 MT CO2e per year, which would be a cumulatively less-than-significant GHG impact. The GHG analysis also increases the potential for CO2 emissions due to the loss of agriculture land (loss of carbon sequestration). The proposed landscape plan includes planting approximately 185 trees, including scarlet maple (Acer Rubrum), Chinese pistache (Pistacia Chinensis) and tulip tree (Liriodendron Tulipifera). Furthermore, an approximately one-acre portion of the existing vineyard within the project site would remain. The California Emissions Estimator Model (CalEEMod) includes carbon content values, which are based on Intergovernmental Panel on Climate Change (IPCC) reports, to estimate the loss of sequestered carbon (release of CO2). For cropland, which would be the closest land use associated with the existing vineyards, removal of cropland Agenda Item #5.8.
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would result in a rate of 6.2 MT CO2/acre. Regarding carbon sequestration from the planting of a variety of tree species, the Project would result in a sequestration rate of 0.0354 MT CO2/tree/year assuming growth over 20 years. Therefore, the Project would result in an overall gain in sequestered carbon, reducing the Project’s overall GHG emissions presented in Table 3.7-6 of the Draft EIR.
Regarding the potential for increased temperatures due to additional roadways and structures, this effect is typically associated with high density urban development, rather than the more suburban densities typical of the project area. Furthermore, these effects are localized, rather than contributors to global warming. Heat islands are most commonly addressed through the planting of street trees. As discussed above, the Project would plant approximately 185 trees. There is no evidence that the Project would contribute to an adverse environmental impact due to any heat island effect.
101-12 The comment states an opinion that the current open space area provides a buffer to wildfires and that the Project would create a bigger potential for fire and flood threat to existing Vineyard Valley homes.
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 regarding flooding concerns.
101-13 The comment states an opinion that the Project would reduce the ability for natural water saturation and flow, contributing to a higher potential for flooding and runoff of natural soils.
Please see Response to Comments 35-4 through 35-6.
101-14 The comment states an opinion that the Project violates Municipal Code 1741, since affordable housing would be, in the commenter’s opinion, segregated from other residences and appears to be significantly different from market-rate units.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. In addition, the commenter appears to be referencing an incorrect section of th City’s Municipal Code bcasue there is no section “1741”. It is assumed the commenter is referring to chapter 17.146 of the Municipal Code that addresses affordable housing. Please see Response to Comment 45-2.
101-15 The comment states an opinion that the Project would cause traffic and construction noise, and vibration which would shift soils and impact natural water flow.
The Project’s impact on transportation and circulation is addressed in Section 3.14.
Noise and vibration impacts are discussed in Section 3.11 and hydrology impacts are Agenda Item #5.8.
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discussed in Section 3.9. 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. 101-16 The comment states an opinion that the Project would strain police, fire, and emergency services, as well as schools.
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.
101-17 The comment states an opinion that the intended purpose of the land was to remain open space for public enjoyment and safety from floods and fire.
The Project site is not publicly owned and is therefore not a public open space. In addition, the Project site has been designated and zoned for residential development dating back to the 1975 General Plan. 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. 101-18 The comment states an opinion that City water and sewer services have limitations and that the City is currently in a severe drought situation.
Please see Master Response 2 regarding water supply and Master Response 4 regarding sewer capacity.
101-19 The comment asserts that the cost of the Project would be absorbed by current residents.
The CEQA Guidelines do not require the fiscal or economic costs of a project to be evaluated, unless they could indirectly result in result in significant physical changes in the environment. 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. 101-20 The comment states an opinion that the Project would result in traffic congestion and damage to streets.
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. 101-21 The comment suggests that the Project would result in a reduction in the number of visitors to the City.
Agenda Item #5.8.
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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.
101-22 The comment states an opinion that there would be transportation and circulation impacts.
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 EIR or analysis is inadequate; therefore, no further response is required. 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.
101-23 The comment states an opinion that the City has had many energy-related emergencies and asks if the City has is a plan for infrastructure updates to support current needs as well as the Proposed 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.
101-24 The comment states an opinion that the Project is in direct violation to the Army Corps of Engineers Policy and Procedures document.
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.
101-25 The comment states an opinion that the Project is not in the best interest of the community.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. 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 102
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Response to Letter 102
Jim Ritchie
November 1, 2021
102-1 The comment expresses the commenter’s concern regarding the Project’s impact on the City’s water supply and suggests regulating the Project’s water usage.
Please see Master Response 2 that addresses the City’s ability to supply water to the Project and the Project’s compliance with City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the City’s Municipal Code. 102-2 The comment expresses the commenter’s concern related to the Project’s impact on local traffic. Specifically, potential traffic impacts to Pope Street.
Please see Response to Comment 57-11.
102-3 The comment addresses the Project’s impact on 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.
102-4 The comment states opposition to the Project because it would, in the commenter’s opinion, decrease the quality of life for St. Helena residents.
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 103
Vivian Robison
November 4, 2021
103-1 The comment serves as an introduction to the commenter and their opposition 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.
103-2 The comment states an opinion that construction behind the levee would result in levee failure by taking away permeable soils.
Please see Master Response 3.
103-3 The comment states an opinion that the Project would eliminate an open space fire break, encroach on agricultural land, negatively impact views, destroy wildlife habitat, and remove the existing walking 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.
103-4 The comment states an opinion that the higher elevation of the Project would result in runoff waters flooding the Vineyard Valley Mobile Home Park and threaten health and safety.
Please see Responses to Comments 35-4 through 35-6.
103-5 The comment states an opinion that excess energy and water consumption from the Project would burden the power grid and water supply.
Potential impacts regarding energy, public utilities, and water are discussed in Sections 3.15, Section 3.13, and Section 3.9, respectively. The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. Please see Master Response 2 regarding water supply. 103-6 The comment states an opinion that construction of the Project would disturb neighbors with noise, vibration, light pollution, and air pollution.
Agenda Item #5.8.
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The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. However, please see Response to Comment 38-1 that addresses these concerns.
103-7 The comment states an opinion that traffic congestion and overall vehicular safety within the neighborhood would worsen as a result of the Proposed Project and that an additional connection to Silverado Trail would be needed.
Overall safety and vehicular collisions within the City were analyzed within Section
3.14 of the Draft EIR and Project impacts were concluded to be less than significant.
Please see Response to Comment 57-11 for additional information regarding the extension of Adams Street to Silverado Trail.
103-8 The comment expresses an opinion that emergency services would have difficulty in navigating within the City as a result of the Proposed Project and that emergency evacuation along Adams Street and Pope Street would be reduced.
For additional information regarding emergency vehicle access and evacuation, please see Master Response 1.
103-9 The comment states an opinion that the Project is an “oversized market rate housing development” that should be rejected.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
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COMMENT LETTER 104
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Response to Letter 104
Linda Rose
October 4, 2021
104-1 The comment states opposition to the Project and raises concerns regarding the availability of water to serve the Project, traffic generation, and size of the development.
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 EIR or analysis is inadequate; therefore, no further response is required.
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Response to Letter 105
A. Venezia Rouas
October 30, 2021
105-1 The comment states opposition to the Project regarding the Project’s water usage and references water restrictions for City residents.
The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
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Response to Letter 106
Laurence Schlatter
November 14, 2021
106-1 The comment expresses opposition to the Project and explains the commenter’s history as a resident of the City. The comment also raises a general concern, stating an opinion that the City is under a water shortage.
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. Also, please see Master Response 2, which addresses the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code.
106-2 The comment expresses a concern related to the Project’s impact on traffic and pedestrian safety.
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 further response is required. 106-3 The comment states an opinion that the Project would remove a popular walking trail.
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 and on page 2-23 in Chapter 2, Project Description. 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.
106-4 The comment raises a general concern related to emergency evacuation.
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, in response to the commenter’s concern related to emergency access and evacuation, please see Master Response 1. 106-5 The comment expresses general opposition to the Project and claims that many residents are also opposed 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 107
John Schoof
October 30, 2021
107-1 The comment states that the Project should be deferred until more water supply is available that can support existing and future potable water demand of the City.
Please see Master Response 2.
107-2 The comment states an opinion that the existing vineyards should be preserved.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. 107-3 The comment proposes alternative locations for infill housing development.
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.
107-4 The commenter claims that Starr Avenue is being used as a bypass route to downtown and that child safety is reduced because vehicles ignore stop signs at the intersection of Hunt Avenue and Starr Avenue.
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.
107-5 The comment claims that parking in the neighborhood is full and that the extension of Starr Avenue and Adams Street would make parking more difficult.
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.
107-6 The comment states an opinion that the Proposed Project be revised to eliminate the extension of Starr Avenue. The commenter also asserts that parking is an issue in the area.
The Project does not preclude the future expansion of Adams Street connecting to Silverado Trail. 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.
Please refer to Response to Comment 107-5 for concerns regarding parking.
Agenda Item #5.8.
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107-7 The commenter states an opinion that, in order to mitigate the use of natural gas and promote the movement to all-electric homes, the Project should be outfitted with solar panels and electric storage batteries.
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.
107-8 The comment states an opinion that additional power from solar panels could be used to finance the development of additional parking for the Hunt’s Grove apartments as well as water and sewer improvements.
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.
107-9 The comment states an opinion that additional households from the Project would impact water conservation efforts and would contribute to the higher cost of living in 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.
107-10 The comment states an opinion that groundwater should not be used for residential irrigation.
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.
107-11 The comment summarizes the concerns discussed in the comment letter.
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.
Agenda Item #5.8.
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COMMENT LETTER 108
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Response to Letter 108
Cathy Small
November 3, 2021
108-1 The comment expresses opposition to the Project due to concerns noted in the letter (and addressed below).
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.
108-2 The comment asserts, without indicating the source of information, that the Project site is the location of where Native American’s “lived and were buried” and this needs to be respected.
Please see Response to Comment 55-4, which provides more detail specific to the presence of any tribal cultural resources or human remains. 108-3 The commenter states their concerns regarding availability of water to serve the City residents and asks where the City will get water to serve the Project.
Please see Master Response 2 that addresses concerns regarding water. 108-4 The comment raises a concern that the City’s police and fire services will be impacted by the Project resulting in the need to hire more staff and slower response times.
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 services and do not anticipate a decline in response times to the site. 108-5 The comment states an opinion the City’s parks will experience more usage and will require more City staff to maintain the parks due to the increase in demand.
The Project would accommodate an increase in the City’s population but as discussed on page 3.12-17 of the Draft EIR, the City requires the Project applicant to pay park and recreational impact fees to cover the cost of land acquisition and park improvements and property tax revenue would help fund additional City park staff, if Agenda Item #5.8.
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required. The Draft EIR concluded that payment of the required park and recreation impact fees would ensure the Project would not adversely impact City park facilities. 108-6 The comment addresses the ability of the school district to provide for additional students.
Based on the St. Helena Unified School District (SHUSD) student generation demand rates, the Project would add a total of 28 K-12 students to the SHUSD, as discussed in the Draft EIR starting on page 3.12-11. Based on 2019 enrollment numbers there is adequate capacity to accommodate the increase in students and existing schools are estimated to have more than sufficient capacity for projected enrollment through 2025. Under SB 50, payment of required school impact fees is complete and full mitigation for any potential impacts related to the need for school facilities.
108-7 The comment asserts that more children will be on local roadways and asks how the children will be kept safe.
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.
108-8 The commenter is concerned about traffic congestion along Starr Avenue and Adams Street. The comment asserts that traffic congestion is already high in the neighborhood and that the Pope Street Bridge is not wide enough to accommodate trucks.
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. 108-9 The comment asserts, without citing a source, that there are speeding issues along Pope Street and that drivers do not pay attention to stop signs and crosswalks. The comment also states an opinion that overall safety for pedestrian and motorists would be worsened with the proposed project.
Transportation impacts are analyzed in Section 3.14 of the Draft EIR. This Section analyzed Project transportation impacts related to consistency with plans or policies addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities, hazardous design, and emergency access. The Draft EIR concludes that the Project would have less-than-significant impacts to these matters. 108-10 The comment raises numerous concerns on the part of the commenter regarding the levee including status of certification by FEMA and the Army Corps of Engineers, levee maintenance, storm water flows from the site into the adjacent Vineyard Valley development, and status of the floodplain.
Agenda Item #5.8.
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The levee provides a 200-year level of flood protection, rather than the “100-year flood plain” referenced in the comments. The manner in which inspection and maintenance responsibilities for the existing levee are assigned are not environmental effects related to the Proposed Project. Furthermore, under CEQA, the effects of the environment upon the project are not “impacts.” Rather, CEQA requires the lead agency to consider the ways in which the project effects the environment. The potential hydrological effects of the Project, including the potential to impede or redirect flood flows, are considered in Section 3.9 of the Draft EIR. See also Master Response 3 for further details regarding the levee, required certification, and maintenance responsibilities.
108-11 The comment expresses a general belief that open space provides habitat to plants and animals and requests that wildlife habitat be left alone.
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. 108-12 The comment is referencing the emergency evacuation route used by Vineyard Valley residents along the existing levee maintenance road and questions if this road would be accessible if the Project is approved.
Please see Master Response 1 that provides more details specific to the maintenance road for emergency evacuation for both Vineyard Valley residents and Project residents.
108-13 The comment requests the Project not be approved because it is “too big for our little town.”
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 109
Patricia Stephens
November 2, 2021
109-1 The comment provides the commenter’s personal history as a resident of the City.
The commenter is concerned about the City’s current traffic and water supply and states an opinion that the Project would negatively impact the City’s police and fire departments.
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. The Draft EIR concludes that City’s police and fire departments have adequate staff to accommodate the increase in demand for services and do not anticipate a decline in response times to the site.
Please see Master Response 2 that addresses water supply.
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 travelled (VMT), and potential impacts to transit, bicycle, and pedestrians. 109-2 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.
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Response to Letter 110
Carolyn Troyan
November 6, 2021
110-1 The comment states opposition to the Project regarding concerns related to the Project’s potential impact to the adjacent walking trail and City’s water supply.
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 111
Valley Vineyard Mobile Home Park
November 29, 2021
111-1 The comment states an opinion that the Vineyard Valley Mobile Home Park community would be directly and significantly impacted by the Project. The comment introduces the concerns discussed in the comment letter.
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.
111-2 The comment states an opinion that because the Project’s VMT is estimated to be
15.2% higher than the Citywide VMT per capita it would be a significant and unavoidable impact which cannot be mitigated, and the EIR should not be approved.
Please refer to Response to Comment 93-8 for clarification on VMT baseline and significance threshold used for the Project’s VMT comparison. The commenter’s opinion the EIR should not be certified is noted and forwarded to the decision makers for their consideration.
111-3 The comment restates information included in the Draft EIR regarding the sewer system and wastewater flows.
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. See also Master Response 4. 111-4 The comment states that the sewer pipe connecting to the Vineyard Valley manhole is part of a wastewater siphon system and asserts, citing an EPA newsletter article, that siphon systems are known to result in water and waste backups.
Please see Master Response 4.
111-5 The comment states an opinion that additional wastewater flows from the Project would result in health and safety issues for Vineyard Valley residents. The comment states an opinion that the Draft EIR does not address the issue of sewage backup at Vineyard Valley.
Please see Master Response 4.
111-6 The comment states an opinion that wastewater estimates in the Water Neutral Report (Appendix J) may be 50% to 100% lower than reality.
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Please see Master Response 4.
111-7 The comment states an opinion that the assumption of 35 gallons per occupant per day of residential wastewater discharge does not match historical City water usage described in the 2016 Water and Wastewater Study, which ranges from 65 to 80 gallons per occupant per day.
Please see Master Response 2.
111-8 The comment asserts that 35 gallons per occupant per day is not a reasonable assumption.
Please see Master Response 2.
111-9 The comment states an opinion that the Draft EIR does not address the public health and safety issue of increased wastewater flows resulting in sewage backup at Vineyard Valley.
Please see Master Response 4.
111-10 The comment states an opinion that the Draft EIR is wrong about its water use estimates.
Please see Master Response 2.
111-11 The comment asserts that sewage spills at Vineyard Valley have been documented to occur with lower wastewater flows than the estimates presented in the Draft EIR.
Please see Master Response 4.
111-12 The comment states an opinion that the Proposed Project would have a negative effect on emergency evacuation in the City, especially along Adams Street.
For concerns regarding emergency evacuation, please see Master Response 1. 111-13 The comment asserts that the issue of emergency evacuation in the event of a hazardous waste spill event is not covered in the Draft EIR.
Please see Master Response 1 regarding emergency evacuation. 111-14 The comment claims that emergency access was not analyzed in the Draft EIR and expresses an opinion that emergency access would be greatly diminished due to the Proposed Project.
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 Agenda Item #5.8.
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Response 1, that provides more details specific for emergency evacuation for both City residents and the Proposed Project.
111-15 The comment states an opinion that the Project would impair the Vineyard Valley evacuation plan and that this issue has not been adequately addressed in the Draft EIR.
Please see Master Response 1.
111-16 The comment states an opinion that the Draft EIR fails to adequately address CEQA requirements related to hazards and hazardous materials, transportation, and wildfire.
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. The Draft EIR evaluates the potential for the Project to expose future residents to potential hazards in Section 3.8, Hazards and Hazardous Conditions. The analysis concludes impacts would be less than significant with the exception for the potential for residual pesticides to be present in the soils. Compliance with required mitigation would ensure the impact would be reduced to less than significant. Please see Responses to Comments 10-2, 36-1 and 36-2 regarding transportation and 39-5 and 82-14 regrading wildfire. 111-17 The comment states an opinion that the Project would harm Vineyard Valley residents in an emergency evacuation event.
Please see Master Response 1. The commenter’s opinion is noted and forwarded the decision makers.
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Response to Letter 112
Vineyard Valley Residents
November 17, 2021
The City received a second letter from the Vineyard Valley residents that is a duplicate of Letter 111. Please see Responses to Letter 111.
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Response to Letter 113
Maria Villegas
October 29, 2021
113-1 The comment asks for clarification on why the Project site has not been re-evaluated as a very high fire hazard zone if part of the site was burned in the Glass Fire.
On page E-3 of the Draft EIR 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. Neither the City or applicant are involved in the designation of fire hazard zones. Please see Response to Comment 76-9 regarding the Glass Fire.
113-2 The commenter asks whether climate change is considered when determining state responsibility areas.
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 Response to Comment 113-1. 113-3 The comment states an opinion that the neighborhood does not have adequate evacuation routes and that the Proposed Project would need to mitigate for additional evacuation routes in case of wildfire.
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 related to emergency evacuation for both Vineyard Valley residents and the Proposed Project. 113-4 The comment states that the Silverado Trail is currently (October 2022) closed, and asserts that traffic congestion in the City has worsened. The comment asks for additional traffic mitigations.
Please see Response 50-4.
113-5 The comment asks how water shortages would be mitigated in a severe drought.
Please refer to Master Response 2.
113-6 The comment asks why St. Helena is the only city in Napa County penalized for overuse of water and whether the Project would also be subject to current penalty fees.
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Please refer to Master Response 2.
113-7 The comment asks if the well to be used for the Project is currently functioning and when it was last inspected or tested.
Please refer to Master Response 2 and Response to Comment 57-5. 113-8 The comment asks how the City’s water usage would be impacted in the event the well is non-functioning. The comment also asks how it was determined who owns the well and how it would be maintained.
Please refer to Master Response 2 and Response to Comment 57-5. 113-9 The comment asks why new development should be considered when residents of the City are already not pleased with excessive water penalty fees.
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.
113-10 The comment notes that the area contains sensitive archeological resources along with human remains and asks why the site is no longer eligible for the California Register of Historic Resources and the National Register of Historic Places.
The Draft EIR addresses the history of the area, including the Project site for the potential for cultural resources (including human remains) to be present on the Project site. To evaluate the potential for the Project site to contain sensitive archeological resources and human remains a Cultural Resources Inventory and Extended Phase I and Phase II Report (confidential Appendix E) was prepared for the Proposed Project. Research conducted included a California Historical Resources Information System (CHRIS) records search, which was conducted at the Northwest Information Center (NWIC) for the Project site and surrounding 0.5-mile radius. This search included their collection of mapped prehistoric, historical and built-environment resources, Department of Parks and Recreation (DPR) Site Records, technical reports, archival resources, and ethnographic references.
Additional consulted sources included the National Register of Historic Places (NRHP), California Inventory of Historical Resources/California Register of Historical Resources (CRHR) and listed Office of Historic Preservation Archaeological Determinations of Eligibility, California Points of Historical Interest, California Historical Landmarks, and Caltrans Bridge Survey information. The records search concluded that 59 previous cultural resources technical investigations have been conducted within a one half-mile of the Project site. Of these, seven have included a portion of the Project site resulting in approximately 90% of the Project site included in previous investigations.
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Archaeological investigations conducted the Flood Protection Project overlapped the western and northern portions of the present Project site. As a result of the survey work conducted for the Flood Protection Project eight archaeological resources were identified (all in the general vicinity of the present Project site). Of the eight resources five lacked sufficient data potential and integrity to meet the criteria for NRHP eligibility. It was determined that three sites were eligible for listing in the NRHP. Only one archaeological resource (CA-NAP-406) which intersects the Project site has been determined to be eligible for CRHR and NRHP listing. The Phase I and Phase II archaeological excavations conducted on the Project site in addition to a ground penetrating radar investigation concluded there are no intact deposits or features associated with CA-NAP-406 that appear to extend into or within the Project site.
The Cultural Inventory and Extended Phase I and Phase II Report conducted for the Proposed Project noted three archeological sites were previously identified within the Project site (CA-NAP-406, CA-NAP-843, and CA-NAP-1008), two of which (CA-NAP843 and CA-NAP-1008) were determined not to be NRHP/CRHR eligible. The Cultural Inventory Report determined that impacts to CA-NAP-843 and CA-NAP1008 would not represent a significant effect.
The Flood Protection Project resulted in a substantial level of previous archaeological investigation work along the western and northern portions of the Project site. A total of 163 human burials were recovered from one site as part of the Flood Protection Project, the largest number of burials recovered from a single site in Napa Valley to date. However, based on the Phase I and Phase II investigations conducted on the Project site along with ground penetrating radar no human remains were documented within the archaeological resources that intersect the Project site.
The Draft EIR concluded that there are no resources that would qualify the entire Project site to be eligible for listing on either the National Register of Historic Places (NRHP) or the California Inventory of Historical Resources/California Register of Historical Resources (CRHR). Detailed information and analysis supporting this conclusion is provided in Section 3.5 of the Draft EIR. 113-11 The comment references resources identified within the Project site and requests this be clarified.
Please see Response to Comment 113-10 that addresses this comment. 113-12 The comment asks if specific artifacts, trade beads, projectile points, and charmstones, bone tools and groundstone have been returned to the Wappo Tribe, and who has current possession of the artifacts.
There is no mention of beads being discovered at the Project site; 3 projectile point fragments were identified as part of cultural evaluation conducted in 1993 for a different project in proximity to the Project site (DEIR p. 3.5-7). There is no reference to charmstone, bone tools or groundstone being found on the Project site. It is not Agenda Item #5.8.
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known if the other artifacts identified at the other project were returned to the Wappo Tribe or where these artifacts currently are located.
113-13 The comment references AB 52 and is asking why the Mishwah-Wappo Tribal chairman was not contacted.
A letter was sent to Vincent Salsedo with the Mishewal-Wappo Tribe of Alexander Valley on April 23, 2018. The Mishewal-Wappo Tribe did not respond to the City’s letter requesting consultation on this Project.
113-14 The commenter requests information on where the 163 human remains are located.
As noted in Response to Comment 113-10, the human remains were discovered as part of the City’s Flood Protection Project. The location of any recorded cultural resource is confidential so the location of where the human remains were discovered is not available for public review.
113-15 The comment states that California Health and Safety Code Section 7050.5 includes specific procedures to follow to address any human remains that may be discovered and is asking to clarify if this procedure was followed.
It is not clear if the comment is asking about the Proposed Project or the City’s Flood Protection Project. Since the Project is under review at this time it is assumed the comment is referencing the Proposed Project. Compliance with this state law is required during any ground disturbing activities and has been identified as Mitigation Measure CUL-2.
113-16 The comment expresses an opinion that the Draft EIR addressed human remains and historical artifacts in a “deplorable manner” and requests the applicant demonstrate decency and respect.
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 114
Maria Villegas
November 29, 2021
114-1 The comment asks if the application was submitted to the City in 2010 why does the 1993 General Plan take precedence.
As explained in the Draft EIR on pages ES-1, 2-12 and 3.0-2 through 3.0-3, because the tentative map application was submitted in September 2010 and deemed complete by the City in 2011, this EIR uses the 1993 General Plan as the applicable general plan for the purposes of evaluating the Proposed Project, since 1993 General Plan was the adopted general plan in effect in 2011. The City did not adopt an updated general plan until 2019. Therefore, as required by the Subdivision Map Act, the consistency of the proposed subdivision with the general plan must be evaluated under the 1993 General Plan. However, regarding policies that are adopted to avoid or reduce an environmental effect, the Draft EIR also considers the current General Plan (adopted 2019).
114-2 The comment wants to know what the approval date was for the application and how long an application is valid.
The application was deemed complete by the City in 2011. The City has determined that the application is still valid, and the applicant continues to seek approval of the Project. 114-3 The comment is asking if an extension has been requested to prevent a lapse in permits; the basis for the extension; time frame for filing an extension and what work has been completed since the extension.
The application does not require an extension, as described below under Response to Comment 114-4. The tentative map has not been approved, no City permits or other agency permits have been issued for the Project, and no work has been done on the Project.
114-4 It appears the commenter believes an extension is required for the application and if not then the Project would be subject to compliance with the current (2019) City General Plan.
Please see Responses to Comments 114-1 and 114-2 which explains why the application is not subject to an extension and why the Project is required to be evaluated under the 1993 General Plan. In addition, the Project also reviewed consistency with the City’s General Plan Update 2040 that was adopted in 2019. 114-5 The comment notes the City issued a completeness letter for the application in 2011. The commenter appears to be asking why the City has not yet taken action on the Project.
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As noted on page 2-11 of the Draft EIR, the City prepared an EIR to evaluate the Proposed Project in 2012 and in 2013 the Proposed Project came before the City’s Planning Commission for review. The Planning Commission did not take action on the Proposed Project at that time and the item was continued. Additional information was subsequently submitted by the Project applicant, which resulted in the need to revise and update the Draft EIR. The original EIR consultant was not able to revise the EIR so the City retained a new EIR consultant in 2017 to prepare a new EIR to evaluate the Project.
114-6 The comment is requesting to know why the Project is not required to be evaluated under the City’s current General Plan since the 1993 General Plan was developed to oversee 1993 through 2010.
Please see Response to Comment 114-1.
114-7 The comment appears to be questioning the accuracy of information contained in the 1993 General Plan pertaining to the City’s water supply, electrical grid, and climate change. It appears the commenter believes data from the 1993 was used to address potential impacts to these services.
Please see Response to Comment 9-4 that addresses these concerns as well as Master Response 2 that addresses water supply.
114-8 The comment is referencing the Findings of Fact and Statement of Overriding Considerations prepared for the City’s 2040 General Plan, which was adopted in May 2019 and states the Draft EIR in inconsistent with the 2019 General Plan.
The St. Helena General Plan Update 2040, adopted in 2019, is the City’s current general plan. Any development application made today would be considered under the 2040 Plan. However, as stated in Response to Comment 114-1, the Project application was deemed complete in 2011. The Subdivision Map Act requires that the proposed subdivision be evaluated under the general plan that is in effect at the time the application is deemed complete. Therefore, the consistency analysis for the proposed subdivision is on the general plan adopted in 1993. The Draft EIR therefore considers consistency with the 1993 General Plan, but also considers policies of the 2040 Plan that relate to the avoidance or reduction of an environmental effect. 114-9 The comment is referencing the City’s mandatory water conservation requirements and requests clarification on limits for hand washing and flushing of toilets and the impact this would have on the City’s existing development.
The comment appears to be general in nature and it is not clear what the commenter is requesting be clarified. The comment is not addressing the accuracy or adequacy of the Draft EIR; therefore, no further response is required. Please see Master Response 2, Agenda Item #5.8.
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which provides additional information on water and the City’s Water Neutral Policy and Chapter 13.12, Water Use and Efficiency of the Municipal Code. 114-10 The comment references emergency evacuation and how the Project proposes to address traffic and emergency access.
Please see Master Response 1 that addresses emergency access and evacuation concerns.
114-11 The comment asserts that the Project would eliminate the existing walking path and the on-site vineyards and wants to know how this will be mitigated and how removal of the vineyards preserves open space.
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 and on page 2-23 in Chapter 2, Project Description. The existing trail parallel to the maintenance road would remain and would not be altered by the Proposed Project.
The Project would not impact the existing walking path and no mitigation is required.
The existing vineyards on the Project site would be removed with the exception of the one-acre portion located in the “panhandle” portion of the site. The vineyards are not officially protected, so no mitigation is required.
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Response to Letter 115
Maria Villegas
115-1 The comment references construction-related air emissions and how the Project is proposing to address these concerns.
Section 3.3, Air Quality, of the Draft EIR, provides a detailed analysis of construction-related emissions and measures to reduce impacts. 115-2 The commenter asks why development is proposed on a site that, as noted in the Draft EIR, presents a risk of settlement.
The potential for settlement to be a concern for the Project is evaluated under Impact 3.6-2 on page 3.6-24. Because there is the potential the recompacted native and non-native soils could be unstable mitigation measure GEO-1 is required which ensures that a design-level geotechnical report be prepared and expands upon the typical steps completed as part of standard building and grading permit approvals in order to ensure weak/compressible soils are mitigated and the potential impact would be less than significant. 115-3 The comment is asking if the Project would be able to withstand a 6.0 magnitude earthquake and questions if the mitigation is adequate to address the potential for liquefaction.
The Draft EIR describes liquefaction starting on page 3.6-14 and notes the Project site is mapped as having a moderate liquefaction susceptibility; however, due to fairly shallow depth to groundwater the risk for liquefaction to occur is potentially significant. Mitigation measure GEO-1 requires a designlevel geotechnical report be prepared to identify specific site preparation methods, grading practices, foundation designs, and other recommendations appropriate for minimizing damage from weak soils, expansive soils, differential settlement, and seismic hazards, including liquefaction. 115-4 The comment asks how the soil hazards onsite would be mitigated “given ‘no seismic hazard zones have yet to be delineated for the City including the Project site.’”
As stated in the Draft EIR on page 3.6-14, the California Geological Survey has not mapped the Project site area as part of the Seismic Hazards Zonation Program. Implementation of mitigation measure GEO-1 would ensure that the required final design-level geotechnical report be consistent with Special Publication 117A which specifies how to mitigate seismic hazards through site preparation methods (e.g., removal of liquefiable soils, use of engineered fill, and soil treatment methods) and/or foundation design (e.g., deep foundation Agenda Item #5.8.
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systems). Adherence to Special Publication 117A and building code requirements have proven sufficient to reduce potential impacts to less-thansignificant levels. 115-5 The comment references the significant traffic impact to an increase in vehicle miles traveled (VMT) and asks if the Draft EIR is complete since no mitigation is available to address this impact.
The CEQA Guidelines recognize that a project may result in significant impacts that cannot be mitigated to a less-than-significant level. The City can approve a project that has a significant and unavoidable impact providing the benefits of the project outweigh the adverse environmental effects.
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Response to Letter 116
Lori Vrabel
October 11, 2021
116-1 The comment expresses opposition to the Project. The comment also raises two general concerns related to the City’s water supply and sewage capacity.
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, please see Master Response 2, which addresses the City’s Water Neutral Policy and Master Response 4 that addresses wastewater capacity.
116-2 The comment expresses concern related to the Project’s impact on local traffic and emergency evacuation.
Please see Master Response 1 that addresses concerns associated with emergency evacuation. 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 travelled (VMT), and potential impacts to transit, bicycle, and pedestrians.
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Response to Letter 117
Ree Whitford
November 6, 2021
117-1 The comment states opposition to the Project and makes reference to the drought.
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, please see Master Response 2, which addresses the Project’s impact on the City’s water supply. 117-2 The commenter is opposed to the Project and to more development within 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.
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Response to Letter 118
Mark Willey
October 30, 2021
118-1 The comment serves as an introduction to the concerns that follow.
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.
118-2 The comment states an opinion that having an affordable housing complex located next to retirement communities would increase the likelihood of crimes being committed.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. CEQA does not require an analysis of social issues such as criminal activity. The comment is noted and forwarded to the decision makers for their consideration.
118-3 The comment states an opinion that emergency evacuation would be made more difficult due to the Project’s location and number of residents and raises concerns regarding emergency vehicle access.
Please also Master Response 1 for more details related to emergency evacuation for residents.
118-4 The comment states an opinion that the Project may result in children and pets disturbing the habitat restoration area near the Project site.
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.
118-5 The comment states an opinion that the loss of the walking trail would impact views and the enjoyment of residents and visitors to the site.
Please see Response to Comment 114-11.
118-6 The comment states an opinion the Proposed Project would increase traffic congestion on Pope Street and along the roadways leading to the project site.
Please see Response to Comment 108-8.
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118-7 The comment states an opinion that the Project would result in a decrease in visitors and revenue at local wineries.
The comment does not identify any specific areas where the Draft EIR or analysis is inadequate; therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. Please see Response to Comment 2-4 regarding economic concerns.
118-8 The comment states an opinion that water restrictions hurt residents’ lifestyles and resale values.
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.
118-9 The comment states an opinion that toilet retrofits would not mitigate water impacts from the Project.
Please see Master Response 2.
118-10 The comment asks who would be responsible for repairs to toilet retrofits and if it is guaranteed that contractors would be available to do the work. The comment also states there would be an added impact to the City’s infrastructure.
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 4 regarding the City’s wastewater infrastructure.
118-11 The comment states opposition to the Project in light of the concerns presented in the comment letter.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter's opinion is noted and forwarded to the decision makers for their consideration.
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Response to Letter 119
Connie Wilson
October 30, 2021
119-1 The commenter states opposition to the Project and references the City’s sewer infrastructure, water supply, and historical 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. However, please see Master Response 2 which addresses the Project’s impact on the City’s water supply and Master Response 4 which addresses concerns regarding the City’s sewer system.
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Response to Letter 120
Terry Wood
November 2, 2021
120-1 The commenter asks where water to supply the Project would come from.
Water to support the Project would come from a variety of sources, as discussed in Section 3.13, Utilities and Service Systems. Please see Master Response 2 that provides further details on water supply and the City’s Water Neutral Policy and Municipal Code.
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Response to Letter 121
Angela Zivkovic
121-1 The comment states an opinion the Draft EIR is inadequate and does not address environmental impacts due to climate change.
The comment does not identify any specific areas where the EIR or analysis is inadequate. However, please see Master Response 2 and Responses to Comments 3-1, 9-4 and 14-9 that address concerns associated with climate change. 121-2 The comment states an opinion that the Draft EIR used outdated and irrelevant data, including the 100-year flood plain approach no longer used by FEMA, based on assumptions that the climate would remain unchanged.
Please see Master Response 3 and Response to Comment 31-1. 121-3 The comment states an opinion that climate change will exacerbate natural disasters including fire, floods, and droughts.
The comment does not address the adequacy of the Draft EIR, but instead expresses the commentor’s opinion about the project. The comment is noted and forwarded to the decision makers for their consideration. 121-4 The comment suggests that the flood analysis in the Draft EIR is inadequate and claims that the Project site is in a high-risk flood zone.
As detailed in the Draft EIR on page 3.9-7 in Section 3.9, Hydrology and Water Quality, the Project site is not located within a FEMA designated Special Flood Hazard Area as a result of construction of the levee. The newly constructed Napa River levee is designed to provide 200-year flood protection with additional flood protection provided by the additional freeboard. The Draft EIR includes a thorough description and analysis of the flood protection measures that the levee provides starting on page 3.9-7 through 3.9-13 as well as pages 3.9-44 and 3.9-45. See also Master Response 3 for further information on the levee. 121-5 The comment states an opinion that public safety and transportation during emergencies and natural disasters is not adequately addressed in the Draft EIR.
Please see Master Response 1.
121-6 The comment states an opinion that the threat to future water supply is not adequately addressed in the Draft EIR.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-664
Please see Master Response 2.
121-7 The comment claims that the levee is not supported by federal funds and that the concept of a 100-year flood is outdated.
Please see Master Response 3 for a response to comments regarding the levee. 121-8 The comment claims that the Draft EIR ignores “the fact that this Project is in a highrisk flood zone” and is City managed and maintained rather than maintained by the US Army Corps of Engineers.
As described in Response to Comment 121-4, the Project site is not located in a Special Flood Hazard Area as a result of construction of the levee. The levee provides a 200-year level of flood protection, rather than the “100-year flood plain” referenced in the comments. The manner in which inspection and maintenance responsibilities for the existing levee are assigned are not environmental effects related to the Proposed Project. Furthermore, under CEQA, the effects of the environment upon the project are not “impacts.” Rather, CEQA requires the lead agency to consider the ways in which the project effects the environment. The potential hydrological effects of the Project, including the potential to impede or redirect flood flows, are considered in Section 3.9 of the Draft EIR. See also Master Response 3 for further details regarding the levee, required certification, and maintenance responsibilities.
121-9 The comment claims the Project site is within a flood zone and the levee does not account for increased risks associated with climate change.
As detailed in the Draft EIR beginning on page 3.9-7, the Project site is not located within a FEMA designated Special Flood Hazard Area as a result of construction of the levee. In addition, the levee provides greater than the often standard 100-year flood protection with a 200-year flood design to account for other factors such as climate change. See also Master Response 3 for further details regarding the levee and Response to Comment 121-1 regarding climate change. 121-10 The comment states that levee failure would result in a financial burden on the City and its residents.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate, and CEQA does not require a discussion of financial impacts. Therefore, no response is required. The comment is noted and forwarded to the decision makers for their consideration. However, please see Master Response 3 regarding the potential for levee failure.
121-11 The comment states that the recent atmospheric river event that flooded parts of the river bank was modest in comparison to impending catastrophic weather events.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-665
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 regarding the Napa River levee.
121-12 The comment states an opinion that wildfire incidents will increase due to climate change.
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 39-5, 76-9 and 82-14 that address wildfire issues.
121-13 The comment states an opinion that the Draft EIR does not account for the increased wildfire risk from climate change and the increase in evacuations.
Please see Master Response 1 and Responses to Comments 121-1 and 121-12 regarding climate change and wildfire concerns.
121-14 The comment states an opinion that increased wildfire incidents would result in more mudslides.
Please see Response to Comment 39-5.
121-15 The comment references the recent wildfires in Napa Valley and Sonoma Valley, and asserts that the wildfire season in California is increasing in length.
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. The Draft EIR addresses if the Project would expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires under Impact 3.8-4 on page 3.8-21 of the Draft EIR.
121-16 The comment asserts that the two evacuation routes out of the City (Highway 29 and Silverado Trail) are inadequately sized.
Please see Master Response 1.
121-17 The comment states an opinion that the Project would endanger existing City residents by adding to the population.
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.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-666
121-18 The comment expresses concern regarding emergency evacuation and claims the Proposed Project would reduce the ability for residents to safely evacuate the area during emergencies and requests additional mitigation measures.
Please also see Master Response 1, that provides more details related to emergency evacuation for both City residents and Project residents. 121-19 The comment states an opinion that emergency evacuation would be made more difficult due to the Proposed Project and that there are equity issues.
Please see Master Response 1.
121-20 The comment asserts that the Pope Street Bridge is not sufficient to facilitate emergency evacuation resulting in a reduction in access in the event of a wildfire evacuation.
Potential Project impacts along Pope Street and the Pope Street Bridge are analyzed in detail within Section 3.14, Transportation and Circulation of the Draft EIR and within Appendix K, Traffic Impact Study Please see Master Response 1. 121-21 The comment references a recent event in which a mudslide resulted in the closure of Silverado Trail.
Please see Response to Comment 39-5.
121-22 The comment states an opinion that, due to drought conditions and predictions for future droughts, the Project’s water demands cannot be supported.
See Master Response 2 for further details regarding the City’s water supplies and demands.
121-23 The comment asserts that climate change is decreasing snowpack and water supply.
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 Response to Comment 121-1.
121-24 The comment asks what the City’s plan is for dealing with severe and sustained drought conditions due to climate change and providing adequate water supply for current and future residents.
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. However, please see Master Response 2 regarding water supply.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-667
121-25 The comment states an opinion that toilet retrofits are inadequate and that water supply will continue to be severely impacted by climate change. The comment states that the Draft EIR does not address these issues.
Please see Response to Comment 2 regarding water supply. 121-26 The comment states an opinion that the Project would irreversibly damage the aesthetics of the City by impacting views of the natural habitat restoration area and hills on either side of the valley.
Please see Responses to Comments 7-6 and 50-7.
121-27 The comment states an opinion that the Project would alter the aesthetics of the City’s east side by increasing traffic and congestion.
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. Please see Response to Comment 121-26. 121-28 The comment states an opinion that the increase in traffic generated by the Project would significantly impact air quality and surrounding areas including current residents as well as existing wildlife.
As discussed 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 operations of the Project be substantially lower than the BAAQMD significance thresholds as presented in Tables 3.3-8 and 3.3-9 (DEIR pp. 3.3-32 and 3.3-33).
Thus, the Project would have a less-than-significant impact on air quality associated with construction and operation of the Project. The Project would not result in a significant degradation of the area’s air quality that could adversely impact City residents and local wildlife.
121-29 The comment states an opinion that the Project would severely impact schools, recreation programs, water supply, sewer capacity, and garbage services.
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 89-2, 97-1 and 108-6 regarding schools; 70-7 and 79-3 regarding parks and Master Responses 2 and 4 that address water supply and wastewater. The Draft EIR addresses the Project’s increase in solid waste in Section 3.13 Public Utilities. See Impact 3.13-4 starting on page 3.13-33.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-668
121-30 The comment states an opinion that increased population from the Project would lower the quality of schools and asks where funds would come from in order to support rapid growth.
Please see Response to Comment 8-6.
121-31 The comment states an opinion that current water and sewage treatment facilities are in need of repair and that substantial infrastructure improvements would be required to accommodate growth. The comment asserts that there is no evaluation of how 500 new residents would be accommodated by the Project.
Please see Master Response 2 regarding water supply and Master Response 4 regarding wastewater. Additionally, the City uses a persons per household factor of
2.45 people per unit for medium/higher density residential land uses. Using this factor, the 87 units in the applicant’s development proposal (including ADUs) would conservatively generate 213 residents, as explained on page 2-23 in Chapter 2, Project Description.
121-32 The comment asserts that that the Project site is used by various waterfowl species and contends that this use includes nesting.
The Draft EIR concluded that some birds may use the grassland for nesting when sufficient cover (i.e., tall vegetation) is present, but that it is unlikely that the approximately 9.7 acres of mowed annual grassland without a nearby open water area such as a pond or marsh represents critical foraging or nesting habitat for waterfowl species. The Draft EIR includes mitigation (BIO-2) to detect and avoid any nesting birds, including waterfowl that may nest within the Project site prior to commencing any construction activities.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-669
COMMENT LETTER 122
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-670
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-671
Response to Letter 122
Daniel Hale
122-1 The commenter is stating an opinion that there is a desire to conclude an impact is less than significant and that many impacts are significant.
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.
122-2 The comment states an opinion that the alternatives evaluated for the Project are not well thought out and that a more dense alternative with more housing diversity would be better for this Project.
Please see Response to Comment 89-2.
122-3 The comment references the amount of impervious surface area and states an opinion that the Project would contribute to a substantial alteration to the existing drainage pattern due to the increase in impervious surfaces.
The Draft EIR evaluates the increase in impervious surface area and changes to the existing drainage pattern under Impact 3.9-3 starting on page 3.9-44 in Section, 3.9, Hydrology and Water Quality. The Draft EIR concludes that Project would increase the amount of stormwater; however, increased runoff would be contained within the City’s detention basin without the need to expand the basin. Therefore, impacts were determined to be less than significant.
122-4 The comment requests data for the current capacity and condition of the City’s water and wastewater infrastructure.
The City has indicated the water and wastewater infrastructure is adequate and have not identified any concerns with the ability to serve the Project, as addressed in the Draft EIR starting on page 3.13-17. Please see also Master Response 4 that addresses the wastewater infrastructure.
122-5 The comment raises a concern regarding adequate water supplies to serve the Project.
Please see Master Response 2 that addresses water supply. 122-6 The comment requests information on the capacity of the City’s existing wastewater system to serve the needs of the Project.
Please see Master Response 4 that addresses wastewater infrastructure. 122-7 The comment states an opinion that the Project would further stress the ability of the City’s infrastructure to serve the additional load generated by the Project.
Please see Response to Comment 122-4 and Master Response 4 that addresses wastewater infrastructure.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-672
122-8 The commenter disagrees with the finding that the City’s water and wastewater infrastructure is adequate to serve and that the existing infrastructure is fragile and has been neglected.
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 122-4 through 122-7.
122-9 The comment states an opinion that the Project ignores the presence of the adjacent trail.
The Draft EIR recognizes the trail specifically in Chapter 2, Project Description and also in Section, 3.12, Public Services and Recreation. Please see also Response to Comment 114-11.This comment does not relate to the adequacy of the Draft EIR (which discusses the trail). The comment is forwarded to decision makers for their consideration. Please see Chapter 3, Changes to the Draft EIR for a figure showing the adjancent trails.
122-10 The comment states an opinion that it is difficult to support the incremental approval of a tentative map followed by other required approvals because the Project is not addressing compliance with the City’s Inclusionary Housing Ordinance.
Please see Responses to Comments 19-1 and 84-3 that explain the approval process. There is no requirement that the Tentative Map have an Affordable Housing Agreement approved at the time of Map approval.
122-11 The commenter disagrees that increasing the amount of impervious surface area would result in a less-than-significant impact.
Please see Response to Comment 122-3.
122-12 The comment states an opinion that consideration of the adjacent trail and impacts to the trail are not addressed.
Please see Responses to Comments 84-9, 89-3, 89-5 and 114-11. 122-13 The comment asks if the Draft EIR accurately addresses the status of the onsite well.
The onsite irrigation well is addressed in detail in the Draft EIR in Section 3.9, Hydrology and Water Quality starting on page 3.9-40. The well is currently not operating as noted on page 3.9-43. The history of the well is unknown but it is assumed it was used at one time for irrigation of the onsite vineyard. Please also see Master Response 2 for more information specific to the onsite well. 122-14 The comment questions whether retrofitting homes to achieve water neutrality is practical.
Please see Master Response 2 that addresses this concern. 122-15 The comment asserts that there are alternate ways to achieve water neutrality and encourages the City to look at other solutions to offsetting an increase in water demand.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-673
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 also Master Response 2.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-674
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4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-741
Responses to Planning Commission Meeting Commenters
November 2, 2021
PC-1 The comment states an opinion that many issues areas dismissed in the Draft EIR that would cause a significant environmental impact.
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.
PC-2 The comment is in support of the No Project Alternative because the Project would irreversibly damage the aesthetics 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.
PC-3 The comment asserts that residents would not be able to walk through the Project area to view the natural habitat restoration area and hills on either side of the valley.
The Project site is not publicly-owned and is therefore not a public open space. 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.
PC-4 The comment states an opinion that the Project would alter the aesthetics of Starr Avenue by increasing traffic congestion.
The aesthetics due to an increase in traffic is not an issue evaluated because traffic is always changing and does not constitute a permanent physical change. The comment is noted and forwarded to the decision makers for their consideration.
PC-5 The commenter states an opinion that the increase in traffic generated by the Project would significantly impact air quality and surrounding areas including existing residents as well as wildlife.
Please see Response to Comment 61-2 regarding air quality concerns and Response to Comment 14-2 regarding wildlife.
PC-6 The comment states an opinion that the Project would impact the wildlife in the protected wildlife habitat zone adjacent to the Project site.
It is not clear from the commenter what habitat zone is adjacent to the Project site.
The City has not identified the presence of any habitat zone. The comment does not Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-742
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.
PC-7 The commenter states an opinion that the increase in vehicular traffic due to the Project would result in a significant impact to air quality.
Please see Response to Comment PC-5 that addresses this concern.
PC-8 The comment states an opinion that the Draft EIR does not adequately evaluate and mitigate water quality and hydrology impacts.
Please see Master Response 2 and the Response to Comments for Letter 32.
PC-9 The comment states an opinion that the idea to use an agricultural well to supply water to Project residents is naïve and inadequately addressed in the Draft EIR.
Please see Master Response 2 and Responses to Comments 88-2 and 88-3.
PC-10 The comment asserts that climate change is limiting water supply and that it is irresponsible to propose that 500 new residents be served by an agricultural well.
As stated in Chapter 2 of the Draft EIR, the Project is estimated to result in the addition of 213 new residents to the City and the City would provide water to serve future residents. The onsite well would only be used to provide water for irrigation.
Please see Master Response 2 regarding water supply.
PC-11 The comment states an opinion that the Project does not consider the limited amount of public open space available in the City.
Public recreational spaces are discussed in Section 3.12 of the Draft EIR.
Additionally, the Project site is not publicly-owned and is therefore not a public open space 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.
PC-12 The comment states an opinion that based on the minimum open space access requirement of 60 square feet for chickens in California, City residents should have a right to at least 1,800 square feet of open space.
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.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-743
PC-13 The comment states an opinion that each resident of the City only has access to about 500 square feet of open space which is less than the equivalent minimum requirement for chickens.
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.
PC-14 The comment asserts that noise and vibration impacts to adjacent residents and the existing low-income housing development on Hunt Avenue have not been adequately addressed.
Noise and vibration impacts are discussed in Section 3.11 of the Draft EIR. See also Response to Comment 38-1. 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.
PC-15 The comment asserts that the Project would increase traffic congestion in the area.
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 travelled (VMT), and potential impacts to transit, bicycle, and pedestrians. See also Responses to Comments 10-2 and 36-2. The comment does not identify any specific areas where the Draft analysis is inadequate; therefore, no further response is required.
PC-16 The comment asserts that the City already has difficulty serving current residents with regard to public services, recreation, and utilities.
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. Impacts to public services, recreation, and public utilities are discussed in Section 3.12 and Section 3.13 of the Draft EIR.
Please see also Response to Comment 97-1 for additional information.
PC-17 The comment states an opinion that the Project would severely impact schools, water supply, sewer capacity, and garbage services.
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 decisionmakers for their consideration. Please see also Response to Comment 121-29.
PC-18 The comment asserts that local public schools would be unable to provide quality education to a growing student body.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-744
Please see Response to Comment 108-6.
PC-19 The comment asserts that current water and sewage treatment facilities are in need of repair and are barely able to meet current needs of residents.
Please see Master Response 2 regarding water supply and Master Response 4 regarding wastewater. The City has not identified any issues with their water infrastructure or wastewater treatment plant to serve the Project.
PC-20 The comment asserts that there are already issues at the sewer lines on Starr Avenue and at Vineyard Valley that would be severely impacted by the Project.
Please see Master Response 4.
PC-21 The comment asserts that there are many concerns about the Project ranging from levee access and maintenance to scenic vistas and privacy concerns.
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 1 and 3 regarding emergency access and the Napa River levee and Responses to Comments 7-6 and 50-7 regarding visual issues. Privacy is not an issue required to be evaluated in an EIR and is not relevant to this Project.
PC-22 The commenter stated an opinion that there are many circumstances regarding the current environment that must not be ignored by City planners and City Council members.
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.
PC-23 The comment asserts that the “Flood Wall project” did not include the Proposed Project and that there is concern that the Project would remove safe evacuation and access through the adjacent Vineyard Valley Mobile Home Park.
Please see Master Response 1 regarding emergency evacuation concerns and Master Response 3 regarding the Napa River levee.
PC-24 The comment states the commenter’s concern that the Project would undermine the levee and overwhelm the Army Corps of Engineers strategy to protect Vineyard Valley residents and their homes.
Please see Master Response 3.
PC-25 The comment asserts that Vineyard Valley residents are concerned about water.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-745
Please see Master Response 2.
PC-26 The comment asserts that Vineyard Valley’s wastewater discharge sewer is documented to have significant issues when it rains.
Please see Master Response 4.
PC-27 The comment states an opinion that, because the Project’s VMT is estimated to be
15.2% higher than the City wide VMT per capita and has a significant and unavoidable impact which cannot be mitigated, that the Project and the EIR should be denied.
Please refer to Responses to Comments 93-8 and 111-2.
PC-28 The commenter asserts that the City Council has an obligation to citizens to protect the environment by denying the Draft EIR.
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.
PC-29 The commenter is concerned that the Project would increase the need for power.
The Project’s energy use and potential impacts to public utilities are described in Section 3.13, Utilities and Section 3.15, Energy. As documented in the Draft EIR adequate facilities and supplies are available to serve the Project and impacts are less than significant. 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.
PC-30 The commenter states an opinion that the Project would result in an increase in power outages due to the City’s struggling power system.
See Response to Comment PC-29.
PC-31 The comment asserts that Adams Street and Starr Avenue are the only evacuation routes for additional residents from the Project site as well as existing residents in the area.
Please see Master Response 1.
PC-32 The comment states an opinion that parking supply is an issue within the neighborhood and that wildfires that create emergency evacuations would be a problem.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-746
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. . For concerns regarding emergency evacuation, please see Master Response 1.
PC-33 The comment claims that a lack of parking would require future residents to panic during emergencies and that the Proposed Project would increase traffic congestion during emergency situations.
Please see Master Response 1.
PC-34 The comment suggests that nature should be respected by not building the Project in an area protected by a levee.
Please see Master Response 3.
PC-35 The comment asserts that it is “common sense” that the Project site is not meant for human habitat.
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. The Project site is located within the City limits and has been designated and zoned for housing since the 1975 General Plan.
PC-36 The comment states that Project would be built over a Native American burial site that contains human remains and artifacts.
Please see Response to Comment 55-4. There is no evidence that the site is a Native American burial site.
PC-37 The comment asserts that the Wappo tribal chairman was not listed in the Draft EIR as being notified under AB 52.
Please see Response to Comment 55-4.
PC-38 The comment requests an extension of the Draft EIR comment deadline by an additional 30 to 45 days.
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 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 www.CityofStHelena.org.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-747
PC-39 The comment states the commenter’s concerns regarding a lack of adequacy of the Project’s proposed bicycle and pedestrian facilities.
Please see Response to Comment 1-2.
PC-40 The comment restates the opinion expressed by others that VMT impacts would be significant and unavoidable. The comment also states that the City’s 2019 Bicycle Plan calls for Class I multi-use facilities along Adams Street and Starr Avenue, which would connect to other multimodal uses and to the Napa Valley Vine Trail.
Please see Response to Comment 1-2.
PC-41 The comment claims that the Project would be more walkable and bikeable if additional bicycle facilities were included.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. Please see Response to Comment 1-2.
PC-42 The comment asserts that the Draft EIR uses outdated or faulty plans for transportation assumptions.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no further response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
PC-43 The commenter states that there is confusion as to why the public meeting is about comments on the EIR rather than comments on 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. The purpose of the hearings held to take comments on the Draft EIR is not to discuss the merits of the Project but rather the adequacy of the information provided in the Draft EIR. The Planning Commission hearing to review the Project will be an opportunity to provide input on the merits of the Project.
PC-44 The comment states an opinion that the Project should consider energy efficiency, housing equity, and resource consumption to achieve a net-zero impact on the environment.
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 also Responses to Comments 82-15 and 107-7 regarding state required building code requirements.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-748
PC-45 The comment states an opinion that the affordable housing units should look similar to market-rate units.
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.
PC-46 The comment states an opinion that there should be at least 1 acre of public open space that connects to a walking path to 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.
PC-47 The comment states an opinion that the Project should allow at least 50% of the moderate and lower income units to be owner-occupied rather than offered as rentals.
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.
PC-48 The comment states an opinion that new construction should be fire-resistant with underground utilities.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. The Project is required to comply with the California Building Code Standards and Fire Code as well as the City’s development requirements which oversees undergrounding of any electrical lines.
PC-49 The comment asks whether the City has considered requesting the Project only be served by electric power.
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. However, the City has not adopted an ordinance requiring all new construction be electric and it is not a requirement of the state building code.
PC-50 The comment states an opinion that the Project would affect emergency evacuation in the area and that another connection to Silverado Trail is needed to alleviate traffic congestion on Hunt Avenue and Pope Street.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-749
For concerns regarding emergency evacuation, please see Master Response 1. 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.
PC-51 The comment states an opinion that retrofitting toilets would not make the project water neutral and that there needs to be more investment in infrastructure.
Please see Master Response 2.
PC-52 The comment states the commenter’s opposition to the Project and requests the Draft EIR comment period be extended.
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 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 www.CityofStHelena.org. The commenter’s opposition to the Project is forwarded to the decision makers for their consideration.
PC-53 The comment states an opinion that the intersection of Hunt Avenue and Starr Avenue is unsafe for pedestrians and for people waiting for the bus. The commenter said that cars frequently do not stop fully, and the stop sign is faded.
Transit, pedestrian access, and collisions have been analyzed in detail within Section
3.14, Transportation and Circulation of the Draft EIR and within Appendix K, Traffic Impact Study and no safety impacts were identified. For additional information, please see Response to Comment 74-6.
PC-54 The comment states an opinion that additional traffic would make conditions even more unsafe for children that ride the bus.
Please see Response to Comment 74-6.
PC-55 The comment expresses concern regarding parking in the neighborhood.
The CEQA Guidelines do not require parking be evaluated in an EIR; therefore, the commenter’s concern is noted for the decision makers and no further response is required.
PC-56 The comment states an opinion that existing traffic and parking problems have not been addressed by the City and that the Proposed Project would make matters worse.
Existing traffic conditions, along with the addition of the Proposed Project, and 2040 buildout of the City are analysis scenarios which have been analyzed in detail within Section 3.14, Transportation and Circulation of the Draft EIR and within Appendix K, Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-750
Traffic Impact Study. The comment does not raise does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. Please see Response to Comment PC-55 that addresses parking concerns.
PC-57 The commenter states they would rather have an affordable housing development similar to Hunt’s Grove rather than the potential for new homes to be owned by second homeowners.
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.
PC-58 The comment states an opinion that there is not enough time to review the Draft EIR and requests that the comment period to be extended.
Please see Response to Comment PC-52.
PC-59 The comment states an opinion that it would not be possible to develop the Project without serious degradation of plant and wildlife species in the 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 also Response to Comment 14-2 regarding wildlife concerns.
PC-60 The comment states an opinion that the Project would devastate wildlife and plant habitat at the adjacent conservation easement, agricultural lands, and public property.
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 14-2 and 36-3 regarding impacts to biological resources and the conservation easement noted in the comment,
PC-61 The comment states an opinion that the Project is not compatible with current habitat restoration efforts.
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. It is unclear from the comment what habitat restoration efforts are ongoing within the Project site.
PC-62 The comment asserts that the City is struggling with water supply and expresses an opinion that the priority for new development should be to provide housing for employees that cannot to afford to live in the City.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-751
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 supply.
PC-63 The comment states an opinion that the Project is incompatible with available resources and current environmental efforts.
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.
PC-64 The comment asks whether there has been a survey of people who use the walking trail at the Project site.
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.
PC-65 The comment asserts that weather events which closed roadways in the City would cause more traffic congestion once Starr Avenue is connected to Adams Street.
Potential Project impacts, as well as impacts related to construction of the Project, along Starr Avenue and Adams Street, and the connection of both roadways to one another, are analyzed in detail within Section 3.14, Transportation and Circulation of the Draft EIR and within Appendix K, Traffic Impact Study. The comment describes that roadways in the area, such as Silverado Trail, were closed due to weather events; however, these closures are assumed to be temporary. Since the closure is not expected to be permanent and is not related to the Project, no further response is required.
PC-66 The comment asks for additional analysis of traffic patterns if Silverado Trail is closed and the effect the closure would have on Starr Avenue, especially during weather related closures.
Please see Response to Comment PC-65.
PC-67 The comment asserts that the traffic issues associated with the Proposed Project are greater than that those evaluated in the Draft EIR.
The comment does not raise does not identify specific areas where the Draft EIR is inadequate; therefore, no further response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
PC-68 The comment states an opinion that retrofitting toilets would not make the Project water neutral and that water usage is not addressed in the Draft EIR.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-752
The Project’s increase in water demand was analyzed in the Draft EIR in Section
3.13, Public Utilities starting on page 3.13-24. Please see Master Response 2 for additional details regarding the Project’s water usage and compliance with the City’s water neutral requirements.
PC-69 The comment states an opinion that water supply problems should be addressed in more detail in the Draft EIR.
Please see Response to Comment PC-69 and Master Response 2.
PC-70 The comment states an opinion that the Draft EIR comment period is short and asks whether the City staff has the power to extend the comment period.
The comment was addressed during the public meeting and no further response is required. Please see also Response to Comment PC-52.
PC-71 The comment asserts that certain members of City staff have the power to extend the Draft EIR comment period.
Please see also Responses to Comments PC-52 and PC-71.
PC-72 The comment asks how to submit a request for extension of the Draft EIR comment period and if the appropriate authorities would be notified of the request.
The comment was addressed during the public meeting and no further response is required. Please see also Response to Comment PC-52.
PC-73 The comment states an opinion that water is the biggest issue of the Project.
Please see Master Response 2.
Agenda Item #5.8.
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Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-787
Responses to Planning Commission Meeting Commenters
November 30, 2021
PC-74 The comment states an opinion that the Project attorney’s letter regarding extension of the Draft EIR comment period was threatening.
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.
PC-75 The comment asserts that residents are still struggling through a pandemic and expresses the commenter’s opinion that the extension of the comment period is appreciated.
Please see Response to Comment PC-52.
PC-76 The comment states an opinion that supplying the cost of water fixtures would not equate to the water usage of 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. Please see also Master Response 2.
PC-77 The comment states an opinion that safety and evacuation and circulation are not adequately addressed in the Draft EIR.
Safety, collisions, and overall circulation are all analyzed within Section 3.14, Transportation and Circulation of the Draft EIR and within Appendix K, Traffic Impact Study. For concerns regarding emergency evacuation, please see Master Response 1.
PC-78 The comment states an opinion that the multifamily housing is segregated from the rest of the Project and would create inequity issues in 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.
PC-79 The commenter encouraged City staff to continue outreach to the community through social media and educate residents on how to access the Draft EIR and provide comments.
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.
PC-80 The commenter states that they appreciate the extension of the comment period but that it is still difficult to find the time to review the Draft EIR.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-788
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.
PC-81 The comment states an opinion that allowing attendance of the public meeting through Zoom results in low in-person turnout and fewer public comments.
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. See also Response to Comment 30-6 regarding online public meetings.
PC-82 The commenter states that they would appreciate an opportunity during the spring to comment on the Project in person.
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. The City will post a notice when the Project is scheduled for hearings before the Planning Commission as well as City Council.
PC-83 The comment states their opinion that the estimated persons per household for the purposes of calculating park demand is very different from the estimate used in the utility section. The commenter also asserted that the estimate of 12 elementary students from the Proposed Project seems low.
Please see Response to Comment 70-4.
PC-84 The commenters states their interest in the persons per household and number of elementary students that live along Hunt Street.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required.
PC-85 The comment states an opinion that the City’s parks inventory does not meet park ratio goals and that residents of the City desire and deserve a higher standard.
Park ratio goals are discussed in Section 3.12 of the Draft EIR. Please see also Response to Comment 70-5.
PC-86 The comment states an opinion that the Draft EIR ignores the loss of the recreational value of the maintenance path.
Please see Responses to Comments 70-6 and 89-3.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-789
PC-87 The comment states an opinion that the Project site is visited for recreation and to experience nature and that the Project would diminish a recreational resource.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. Please see Response to Comment 82-11.
PC-88 The comment states an opinion that the Draft EIR does not mention climate change and that it does not make sense to build houses where it can flood.
The Draft EIR addresses climate change in Section 3.7, Greenhouse Gas Emissions.
Additionally, please see Master Response 3 which addresses climate change concerns.
PC-89 The comment asserts that there is less snowpack each year which results in less water availability and that this is not addressed in the Draft EIR.
Please see Master Response 2.
PC-90 The commenter states an opinion the increase in traffic generated by the Project would significantly impact air quality.
Please see Response to Comment PC-5.
PC-91 The commenter states that they play in the grassy areas of the Project site and opines that the Draft EIR does not account for issues important to the community.
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 Response to Comment 82-11.
PC-92 The commenter said that there are an additional 55 people that signed the comment letter representing the concerns of the Vineyard Valley Mobile Home Park.
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.
PC-93 The comment asserted that the residents of Vineyard Valley would like to see the Project evaluated more thoughtfully than what is provided in the Draft EIR.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration.
PC-94 The comment asserts that residents use the Project site as a recreational area and it should be preserved for recreational purposes.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-790
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. The commenter’s opinion is noted and forwarded to the decision makers for their consideration. Please see Response to Comment 82-11.
PC-95 The comment states an opinion that, in addition to loss of a recreational area, the Project would also result in effects on water, sanitation, crime, fire, and floods.
The comment does not identify any specific areas where the Draft EIR analysis is inadequate; therefore, no response is required. Please see Master Responses 1, 2, 3 and 4 that address concerns associated with public safety, water supply, the Napa River levee, and wastewater. See also Responses to Comments 39-5 and 121-15 regarding wildfire.
PC-96 The comment states the commenter’s concern about the adequacy of the Draft EIR due to data relied upon to evaluate water supply and traffic.
Please see Master Response 2 that addresses water supply and Responses to Comments 10-2 and 89-2 regarding traffic.
PC-97 The comment states an opinion that the Draft EIR does not account for changes occurring due to climate change, including less water availability.
Please see Master Responses 2 and 3 and Responses to Comments 14-9 through 14-17.
PC-98 The comment states an opinion that the Project does not consider drought issues and that new development would require more water to accommodate residents.
Please see Master Response 2.
PC-99 The comment states an opinion that climate change raises the likelihood of a catastrophic flood and that FEMA has revised what is considered a flood zone.
Please see Master Response 3.
PC-100 The comment states an opinion that the Draft EIR does not account for climate change and uses outdated flood data.
Please see Master Response 3.
PC-101 The comment states an opinion that it is a possibility that the levee would fail under a catastrophic flood situation.
Please see Master Response 3 regarding the potential for levee failure.
PC-102 The comment states an opinion that the Project would exacerbate problems with emergency evacuation.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-791
Please see Master Response 1 regarding emergency evacuation.
PC-103 The comment states an opinion that fire incidents and emergency evacuation incidents are increasing and that this is not accounted for in the Draft EIR.
Please see Master Response 1 regarding emergency evacuation.
Agenda Item #5.8.
4 – Response to Comments
Hunter Subdivision Project EIR 10839
January 2023 4-792
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Agenda Item #5.8.
29 Regional Location
Hunter Subdivision Project
SOURCE: Napa County 2015, USDA 2016
Date: 4/30/2019 - Last saved by: mwatson - Path: Z:\Projects\j1083901\MAPDOC\PD\Figure2-1_RegionalLocation.mxd 01 600 ,200
Feet
Project Boundary
FIGURE 2-1
American
Canyon
Napa
Yountville
St.
Helena
Calistoga
Napa
County
Lake County
Sonoma County
Yolo County
Marin County
Solano County
101
116
16 121
175
113
12 12
128
1 29
128
80 680
505
5 Project Site
Agenda Item #5.9.
Date: 3/12/2021 - Last saved by: tfriesen - Path: Z:\Projects\j1083901\MAPDOC\PD\Figure2-3_AdjacentLandUses.mxd Saint Helena
Public Library
Vineyard Valley
Mobile Home
Hunt’s Grove
Apartments
Offices
Vineyard
Well
Existing
Construction
Detention
Basin
Maintenance Rd/Public Trail
Hollis Ln
Starr Ave
Harvest Ln
Peppertree Cir
June Ln
Paulson Ct
Railroad Ave
San Juan Ct
Library Ln
Del Campo Ct
Redondo
Ct
Del Rio
Ct
Paseo Grand Dr
Signorelli Cir
LagunaSecaCt
Meadowcreek Cir
Adams St
Chiles Ave
Hunt Ave
Fulton Ln
Silverado Trail North
Pope St
N a p a
R i v e r
Existing On-Site and Adjacent Land Uses
Hunter Subdivision Project
SOURCE: USDA 2016, USGS 2018, Napa County 2015
0 200 400Feet
Project Boundary
St. Helena City Boundary
FIGURE 2-3
Agenda Item #5.9.
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City of St. Helena
Zoning Districts
A-20: Agriculture
PR: Parks and Recreation
WW: Woodlands & Watershed
OS: Open Space
CB: Central Business
SC: Service Commercial
BPO: Buisness & Prof. Office
I: Industrial
PQP: Public & Quasi-Public
W: Winery
HR: High Density Residential
MR: Medium Density Residential
LR: Low Density Residential
LR-1A: Low Density Residential One Acre minimum
PD: Planned Development
HP: Historic Preservation
MHP: Mobile Home Park
PI: Parking Impact Overlay District selection
SP: Hwy 29 Specific Plan
St. Helena City Limits
St. Helena Urban Limit Line Date: 3/29/2018
i
µ 0 0.25 0.5 1 Miles
Mobile Home Park
i
i
City of St. Helena
This Zoning Map is subject to changes
and should not be used for anything
other than reference. For the most up to
date Zoning information please contact
the City of St. Helena Planning Dept.
SPRING STREET
SYLVANER AVENUE
AVENUE HUDSON
VALLEYVIEW STREET
OLIVE AVENUE
BIRCH STREET
ALLYN AVENUE
NORTH CRANE AVENUE
MITCHELL DRIVE
SPRING STREET
REISLING WAY
MADRONA STREET
MADRONA STREET
HILLVIEW PLACE
SCOTT STREET
VINEYARD AVENUE
DORIS CT
DORIS AVE
STOCKTON STREET
PINE STREET
ADAMS STREET
HUDSON AVENUE
ADAMS STREET
TAINTER STREET
SPRING STREET
VOORHEES CIR
SYLVANER AVENUE
CHARDONNAY WAY
COLUMBARD CT
PINOT WAY
CHABLIS CIR
SPRING BROOK CT
STOCKTON STREET
PINE STREET
KEARNEY STREET
PINE STREET
OAK AVENUE
ANDREA AVENUE
SPRING MOUNTAIN ROAD
SPRING MOUNTAIN CT
QUAIL CT
ELMHURST AVENUE
MAIN STREET (STATE HIGHWAY 29)
MAIN STREET
SOUTH CRANE AVENUE
VALLEJO STREET
SULPHUR SPRINGS AVENUE
MAIN STREET
ARROWHEAD DR
SULPHUR SPRINGS AVENUE
EL BONITA AVE
KENNEDY CT
LA QUINTA WAY
ROSE STREET
VINTAGE AVE
McCORMICK STREET
LA FATA STREET
DOWDELL LANE
FOUNTAIN STREET
MILLS LANE
CHARTER OAK AVENUE
MAIN STREET
KIDD RANCH ROAD
McCORKLE AVENUE
ALLISON AVENUE
BROWN STREET
POPE STREET
POPE STREET MARIPOSA LANE
POPE STREET
PAULSON CT
STARR AVENUE
HARVEST LANE
DEL MONTE CT
SAN LUCAS CT
PASEO GRAND DRIVE
LOS ROBLES CT
RODONDO CT
SAN ARDO CT
LA CUESTA CT
SAN JAUN CT
LAGUNA SECA
DEL CAMPO CT
DEL RIO CT
COLLEGE
AVENUE
POPE STREET
SILVERADO TRAIL
SILVERADO TRAIL
SILVERADO TRAIL
MEADOW CREEK CIRCLE
HUNT AVENUE
MONTE VISTA AVE
GROVE CT
CHILES AVENUE
CHILES AVENUE
SIGNORELLI CIR
EDWARDS AVENUE
CHURCH STREET
ADAMS STREET
LIBRARY LN
RAILROAD AVENUE
FULTON LN
FULTON LANE
ALEXANDER CT
OAK AVENUE
KEARNEY STREET
MAIN STREET
GRAYSON AVENUE
VIDOVICH AVENUE
HASTY CT
PRATT AVENUE
PRATT AVENUE
PRATT AVENUE
WALLIS CT
PARK STREET
CRINELLA DRIVE
CRINELLA DRIVE
HENRY CT
CHRISTINE CT
JUNE LANE
SULPHUR SPRINGS CREEK
SULPHUR SPRINGS CREEK
NAPA RIVER
NAPA RIVER
NAPA RIVER
NAPA RIVER
MNT. ROAD
BRITANY LANE
HOWELL MNT. ROAD
BIG ROCK
ROAD
MAIN STREET
DEER PARK ROAD
DEER PARK ROAD
SIVERADO TRAIL
NAPA WINE TRAIN
NAPA WINE TRAIN
NAPA WINE TRAIN
HIGHWAY 29
HIGHWAY 29
KNOLL PLACE
MARDONE KNOLL
KNOLL CIRCLE
KNOLL PLACE
KNOLL CT
SIVERADO TRAIL
VOELKER CT
ed
NAPA RIVER
NAPA WINE TRAIN
City of St. Helena
Zoning Districts
A-20: Agriculture
PR: Parks and Recreation
WW: Woodlands & Watershed
OS: Open Space
CB: Central Business
SC: Service Commercial
BPO: Buisness & Professional Office
I: Industrial
PQP: Public & Quasi-Public
W: Winery
HR: High Density Residential
MR: Medium Density Residential
LR: Low Density Residential
LR-1A: Low Density Residential One Acre Minimum
RR: Rural Residential Overlay
PD: Planned Development
HP: Historic Preservation
MHP: Mobile Home Park
PI: Parking Impact Overlay District
SP: Hwy 29 Specific Plan
St. Helena City Limits
St. Helena Urban Limit Line
i
µ
MEADOWOOD LANE
STATE
STATE
LEWELLING AVE
INGLEWOOD AVE
WHITE LN.
ZINFANDEL LANE
SILVERADO TRAIL
CONN VALLEY Rd.
HOWELL MOUNTAIN Rd.
CHARTER OAK AVENUE
Date: 4/24/2018
Agenda Item #5.9.
Agenda Item #5.9.
Walking Path/Trail
Levee Maintenance
Road
128
29 Hollis Ln
Paseo Grand Dr
S tarr Ave
Allison Ave
June Ln
Paulson Ct
GranadaCt
Del Monte Ct
Fulton
Ln
San Lucas Ct
Peppertree Cir
Madrona Ave
Library Ln
Del Campo Ct
Kidd Ranch Rd
Stockton St
Crinella Dr
Church St
Kearney St
Ma riposa Ln
Del Rio Ct
Redondo
Ct
Brown St
Mitchell Dr
Edwards St
Pratt Ave
Money Way
Pine St
Oak Ave
Charter Oak Ave
Laguna SecaCt
Signorelli Cir
Tainter St
McCorkle Ave
Spring St
Meadowcreek Cir
Adams St
Railroad Ave
Chiles Ave
Hunt A ve
Pope St
29 Main St
Napa River Loop
Hunter Subdivision Project
SOURCE: Napa County 2015, Bing 2022
Date: 6/22/2022 - Last saved by: tfriesen - Path: Z:\Projects\j1083901\MAPDOC\FigureX_NapaRiverLoop.mxd 0 610 305 Feet
Napa River Loop
Hunter Subdivision Project Boundary
St. Helena City Boundary
101
37 12
221
29 1
116
175
121
12 128
128
16 680
780
5 505
80 Lake County
Sonoma County
Yolo County
Marin County
Solano County
Project Site
Agenda Item #5.9.
1 HUNTER SUBDIVISION TRAFFIC ANALYSIS SUMMARY
The following is a summary of the results of the traffic analysis is Appendix K to the Draft EIR. For detailed information, please refer to the traffic analysis.
Existing Conditions
• Under existing conditions (without project traffic), the City’s current level of service (LOS) standards for traffic congestion are exceeded on weekdays at three locations:
o Main Street/Pope Street-Mitchell Drive: LOS F in the morning peak hour, LOS F in the evening peak hour
o Paseo Grand Drive – College Avenue/Pope Street: LOS D in the morning peak hour o Silverado Trail/Pope Street: LOS D in the evening peak hour At ten other locations examined in the study, the City’s LOS standards are not exceeded on weekdays.
• On Saturdays, the City’s current LOS standards are exceeded at one location:
o Main Street/Pope Street – Mitchell Drive: LOS F in the evening peak hour Project Impacts
• The proposed project would add traffic to the local roadway system:
o A total of 798 trips on a typical weekday
o 62 weekday morning peak hour trips
o 82 weekday evening peak hour trips
o 815 total trips on a weekend day (Saturday)
o 80 weekend evening peak hour trips
• The addition of traffic from the proposed project to existing traffic would add trips to the local roadway system, and would affect the intersections already exceeding the City’s desired LOS standards on weekdays:
o Main Street/Pope Street – Mitchell Drive: Continues to operate with unsatisfactory LOS at LOS F during both the AM and PM peak hours. However, the increase in delay is less than 5.0 seconds in the AM peak hour (4.8 seconds), while the increase in delay is greater than 5.0 seconds in the PM peak hour (11.4 seconds). This constitutes a deficiency with the City’s LOS impact criteria for the PM peak hour. o Paseo Grand Drive – College Avenue/Pope Street: Continues to operate with unsatisfactory LOS at LOS D in AM peak hour. This intersection is unsignalized and does not satisfy peak hour signal warrants (traffic signal), and the increase in delay is less than 5.0 seconds (1.1 seconds). Therefore, the project would not exceed the City’s impact criteria and would be consistent with the City’s LOS policies. o Silverado Trail/Pope Street: Continues to operate with unsatisfactory LOS at LOS D in the PM peak hour. This intersection is unsignalized and satisfies the peak hour signal warrant (traffic signal) for the PM peak hour, however the increase in delay is Agenda Item #5.9.
2 less than 5.0 seconds (1.3 seconds). Therefore, the project would not exceed the City’s impact criteria and would be consistent with the City’s LOS policies. • Adding traffic from the proposed project to existing traffic would have the following impact on the existing location where weekend LOS standards are exceeded:
o Main Street/Pope Street – Mitchell Drive: Continues to operate with unsatisfactory LOS at LOS F, however, the increase in delay is less than 5.0 seconds (3.7 seconds).
Therefore, the project would not exceed the City’s impact criteria and would be consistent with the City’s LOS policies.
• Based on the LOS results of the Existing plus Project weekday and Saturday peak hour traffic analysis, and the City’s impact criteria, the proposed project would be inconsistent with the City’s LOS policies, and would require an improvement:
o Main Street/Pope Street – Mitchell Drive: LOS F during the weekday PM peak hour. • Adding project traffic to projected future (2040) traffic on local roadways would affect the intersections which already operate below the City’s LOS standards on weekdays:
o Main Street/Pope Street – Mitchell Drive: LOS F in AM and PM peak hours. The proposed project would contribute traffic to this LOS deficiency. o Paseo Grand Drive – College Avenue/Pope Street: LOS E in AM peak hour. This intersection would remain unsignalized in the Buildout condition, and would not satisfy the peak hour signal warrant in the AM peak hour. Therefore, this would be consistent with the City’s LOS policies.
o Silverado Trail/Pope Street: LOS E in AM peak hour, and LOS F in the PM peak hour.
This intersection would remain unsignalized in the Buildout condition. However, the AM and PM peak hour traffic volumes would satisfy the peak hour signal warrant. The proposed project would contribute traffic to this LOS deficiency. • Under Saturday Buildout (2040) conditions, the project would add to the following intersections where weekend LOS exceeds City standards:
o Main Street/Pope Street – Mitchell Drive: LOS F in the weekday and Saturday peak hours. The proposed project would contribute traffic to this LOS deficiency. o Silverado Trail/Pope Street: LOS F. This intersection would remain unsignalized in the Buildout condition. However, its Saturday peak hour volume would satisfy the peak hour signal warrant. The proposed project would contribute traffic to this LOS deficiency.
• Based on the LOS results of the Buildout (2040) weekday and Saturday peak hour traffic analysis, and the City’s impact criteria, the proposed project would create an LOS deficiency at the following intersections, and would require improvements:
o Main Street/Pope Street – Mitchell Drive: LOS F during the weekday and Saturday peak hours.
o Silverado Trail/Pope Street: LOS E during the weekday AM peak hour, LOS F during the weekday PM peak hour and Saturday peak hours. The weekday and Saturday peak hours volumes satisfy peak hour signal warrants.
Agenda Item #5.9.
3 Recommended Improvements and Conclusion
• The traffic study recommends several improvements to address existing+project and future (2040) traffic impacts:
o Implement the following improvement to the intersection of Main Street/Pope Street – Mitchell Drive:
• Westbound right turn phase to allow for overlapping turns. This will allow for permitted right turns occurring during a red light and also a protected right-turn phase occurring turning a non-conflicting movement, such as the southbound left-turn protected phase. o Implement the following improvement to the intersection of Main Street/Pope Street – Mitchell Drive:
• Construction of one or more of the various roadway connections recommended in the St. Helena General Plan Update EIR (discussed in detail in Section 3.13 – Transportation and Traffic). These connections would improve overall LOS in the Buildout (2040) scenario:
• Connection 2A: College Avenue extension to Mills Lane (may require realignment of Mills Lane to meet Main Street/Grayson Avenue intersection). • Connection 3: Oak Avenue extension from Mitchell Drive to Grayson Avenue. • Connection 2B, Connection 2C, Connection 5B, or a combination of Connections 1, 4 and 5A may provide congestion relief to Main Street/Pope Street-Mitchell Drive, but these improvements have additional considerations related to neighborhood traffic volumes and costs related to crossings of the Napa River. o Implement the following improvement to the intersection of Silverado Trail/Pope Street:
• Installation of a traffic signal at the intersection, as well as, at the adjacent, closelyspaced intersection Silverado Trail/Howell Mountain Road. This intersection is recommended for signalization according to the analysis in the St. Helena General Plan Update EIR. With a traffic signal in-place, this intersection would operate with satisfactory LOS.
• If these improvements are implemented, the intersections would operate at acceptable levels.
Agenda Item #5.9.
JOSHUA S. DEVORE
[email protected]
October 31, 2022
Via Email:
Commissioner John Ponte, Chair, [email protected] Commissioner Autumn Anderson, [email protected] Commissioner Marika Rothfeld, [email protected] Commissioner Rosaura Segura, [email protected] Commissioner Christopher Warner, [email protected] City Manager Anil Comelo, [email protected]
Community Development Director Maya DeRosa, [email protected] RE: Hunter Subdivision Project Environmental Impact Report, File #PL10-040 Dear Chair Ponte, Commissioners, City Manager Comelo, Community Development Director DeRosa:
We represent the Saint Helena Citizens for a Sustainable Future, a diverse group of City residents who are extremely concerned by the City’s actions with respect to the referenced project.
Numerous members of the Citizens group have individually commented on the project in the past. They write now collectively due to what appears to be an imminent failure of the City to recognize and adhere to recent groundwater requirements.
Before the Planning Commission is a request to certify the Final EIR and approve a Tentative Map for the Hunter Subdivision project. There have been extensive comments on the failures of the EIR to consider basic detrimental aspect of the project. The Final EIR responses have failed to provide a good-faith effort at full disclosure by ignoring, distorting, or giving short-shrift to those comments. As a reminder, this project was tabled nearly a decade ago, in part due to a determined need to improve the Pope Street/Silverado Trail intersection as a result of the project. Obviously, the applicant hopes that has simply been forgotten, or that the City will ignore its level of service (LOS) analysis.
Though VMT analysis is indeed the latest requirement, the project is reviewed under the 1993 General Plan. LOS must be considered per General Plan policies 5.4.1 and 5.4.2. And while there is also an analysis of some portions of the current general plan for comparison, some of the most relevant plan 1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.1.
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Agenda Item #5.9.
October 31, 2022
policies are omitted, such as LU2.61 and CR1.42 The traffic study acknowledges the significant impact on traffic at Main and Pope Street, but ignores the worsening traffic at Pope/Silverado.3 That said, we will not restate all the issues with the EIR here, as they have been raised by more than 100 commenters and are too numerous to list. We do note now however one glaring problem in the proposed findings that requires, at the very least, additional analysis of a significant environmental issue facing all of California, sustainable groundwater management.
The project is for the subdivision of a 16.92 acre property. The EIR analyzed its proposed groundwater use of an on-site well of up to 17.16 acre-feet (AF) per year to provide for all on-site irrigation of public and private landscaping, as well as a small remnant of an existing vineyard. (DEIR 3.9-
40.) (The EIR also fancifully suggests that the remainder of the project will be water neutral, despite its demand for nearly 20 AFY beyond that produced by the onsite well. But that fantasy is not even the instant problem.)
The proposed finding regarding the project’s consistency with the Napa Valley Subbasin Groundwater Sustainability Plan (GSP) is contrary to the evidence. Proposed Hydrology and Water Quality finding I. 7. states:
The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. The County works with local jurisdictions, including the City, to sustainably manage the Napa Valley Groundwater Subbasin in compliance with SGMA. In its most recent assessment of conditions, the County, through its technical consultant, determined that the Subbasin is not exhibiting significant impacts with regard to the applicable sustainability indicators defined by SGMA, including lowering of groundwater levels, depletion of groundwater in storage, degradation of groundwater quality, and depletion of interconnected surface waters.
(Staff Report p. 50-51 (emphasis added.))
This is inconsistent with the Napa Valley Subbasin Groundwater Sustainability Plan’s (GSP) recent assessment, published in January 2022:
Groundwater levels reflect the amount [of] groundwater in storage and the movement of groundwater. Monitoring data exhibit generally stable long-term trends, although conditions are largely dependent on seasonal precipitation input.
Several wells located near the Napa Valley Subbasin margin in the northeastern Napa area, southwestern Yountville area, and southeastern St. Helena area show 1 “LU2.6 Allow residential density at the higher end of the permitted range for single family development within Medium and High Density Residential Land Use designations as long as the development character of the single family area is maintained, including lot widths, orientation to street, building heights, onsite parking, traffic, and noise, among other considerations.” (2019 General Plan.) 2 “CR1.4 Develop and use, in addition to intersection level of service standards, performance measures that consider all road users to determine transportation impacts of new development.” (2019 General Plan.) 3 DEIR Appendix K, p. 36 Table 7 (emphasizing worsening delay at Main Street/Pope Street - Mitchell Drive, but ignoring change in AM Peak LOS at Silverado Trail/Pope Street from LOS C to LOS E.) 1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.1.
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Agenda Item #5.9.
October 31, 2022
periods of groundwater decline during times of drought. Continued monitoring of groundwater levels will be important to evaluate future hydrologic and climatic influences.
(Napa Valley Subbasin Groundwater Sustainability Plan Summary, Executive Summary (Jan. 2022) p. 2, available at https://www.countyofnapa.org/DocumentCenter/View/23549/GSP_Executive-SummaryAbstract?bidId=.) Indeed, while the GSP consists of a dozen separate sections, plus an Executive Summary and an Executive Summary Abstract, this critical contradictory information is found on the top of the second page of the Executive Summary Abstract – the simplest and first document of the GSP. (See https:// www.countyofnapa.org/3218/GSP-Sections.) It is indeed one of the most prominent findings of the GSP that wells in southeastern Saint Helena are showing evidence of groundwater decline during this ongoing drought.
Thus, the proposed contrary finding on this critical matter not only is not supported by substantial evidence, it is directly contrary to the most recent information.
As a result of these findings, Napa County has recently substantially revised downward the allocation of groundwater to subbasin, valley-floor properties. Although such properties were previously allocated 1 acre-foot of water per acre, per year, going forward all uses will be limited to 0.3 AF/acre/ year. This includes both existing and proposed wells. Any existing well usage above that level is prohibited to increase above its current net usage. (See Napa County Well Permit Standards FAQ, available at https://www.countyofnapa.org/DocumentCenter/View/25906/Well-Permit-StandardsFAQs---15-July-2022.) New domestic wells outside the subbasin may use 2 AF/year total (not per acre), and new public water supply wells may use their parcel specific recharge.4 But the well proposed to deliver the 17+ AF is not a new well.
Although the project is conditioned to require offsetting its Municipal water demand of 19.8 AF/year, no recognition of the GSP Subbasin limitations of groundwater use is made for the additional
17.16 AF/year to be pumped from the onsite well. The EIR does disclose that the well is currently inoperable meaning that the existing baseline for groundwater use is zero (DEIR 3.9-42 (Staff Report p. 594). As such the new water use proposed would be required to be limited to no greater than 0.3 AF/AC per year to comply with the GSP sustainable groundwater limitations.
However, there is no discussion of this GSP limitation and its potential impacts on rural residences and agriculture let alone any mitigation proposed or required. Instead, DEIR Appendix L, the September 9, 2021 Well Capacity Study Memorandum, referenced the prior 1 AF/AC allotment that has been reduced by 70%. Yet that memorandum emphasizes that “it is recommended that the annual groundwater use conform with County policy.” (DEIR Appx. L, p.1 (emphasis in original.) (No well interference analysis appears to have been conducted either, despite the well being within 1,500 feet of the Stonebridge wells.)
4 WAA Tier 1: Water Use for Napa County, available at
https://www.countyofnapa.org/DocumentCenter/View/25905/Well-Permit-Standards-Applicability-Tables---15- July-2022
1500 FIRST STREET | STE 200 | NAPA, CA 94559 | T: 707.261.7000 DPF-LAW.COM Agenda Item #5.1.
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11 Agenda Item #5.9.