3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-24
December 2018, requiring that lead agencies use VMT for analyzing transportation impacts.
CEQA Section 15064.3 of the Guidelines, states compliance will be required beginning July 1, 2020 and that “generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts” and define VMT as “the amount and distance of automobile travel attributable to a project.” It should be noted that “automobile” refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for example, where models or data provide combined auto and heavy truck VMT). Other relevant considerations may include the effects of a project on transit and non-motorized traveled.
As mentioned above, the City has not adopted methodologies for performing VMT analysis per SB 743. Therefore, the following VMT assessment has been prepared consistent with OPR’s December 2018 Technical Advisory (2018), the NVTA regional travel demand model (SolanoNapa Activity Based Model – SNABM), and discussions with City staff.
The following outlines the primary methods used to conduct the VMT analysis:
1. Determine whether the project can be screened out from further VMT analysis and presumed to have a less-than-significant impact by comparing the project features to screening criteria presented in the OPR Technical Advisory.
2. If the project is not screened out, determine the VMT per capita (for residential projects) using the VMT Screening Maps from the SNABM travel demand and forecasting model available at https://arcg.is/1nea4W.
3. Compare the project results to the applicable or most appropriate threshold as directed by the City. For the Proposed Project, the VMT/capita is compared to the Citywide average to determine if the Proposed Project would have a potentially significant impact.
Screening for Land Use Projects
To provide guidance on how to conduct a VMT analysis, OPR released Updates to Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory). The Technical Advisory suggests that agencies may screen out VMT impacts using project size, maps, transit availability, and provision of affordable housing. While OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider thresholds of significance... recommended by other public agencies, provided the decision to adopt those thresholds is supported by substantial evidence” (CEQA Guidelines, Section 15064.7, subd. (c)). • Screening Threshold for Small Projects (110 daily trips or less): Absent substantial evidence indicating that a project would generate a potentially significant level of VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-25
projects that generate or attract fewer than 110 trips per day2 generally may be assumed to cause a less-than significant transportation impact. Based on Proposed Project’s trip generation shown in Table 3.14-1, more than 110 trips per day would be generated; therefore, it would not screen out using the small project criteria. • Map Based Screening for Residential and Office Projects: Residential and office projects that locate in areas with low VMT, and that incorporate similar features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Per the Technical Advisory, maps created with VMT data, from a travel survey or a travel demand model, can illustrate areas that are currently below threshold VMT. Because new development in such locations would likely result in a similar level of VMT, such maps can be used to screen out residential and office projects from needing to prepare a detailed VMT analysis. The Proposed Project’s VMT per capita would exceed the Citywide average VMT per capita, and therefore the Proposed Project would have a potentially significant impact.
• Presumption of Less-than-Significant Impact Near Transit Stations: The Project site is not located within ½ mile of an existing major transit stop or an existing stop along a high-quality transit corridor. Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop3 or an existing stop along a high quality transit corridor4 would have a less-than-significant impact on VMT.
This presumption would not apply, however, if project-specific or location-specific information indicates that the project would still generate significant levels of VMT. For example, the presumption might not be appropriate if the project:
o Has a Floor Area Ratio (FAR) of less than 0.75;
2 CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to allow for maximum planned development and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd. (e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint (i.e., general office building, single tenant office building, office park, and business park) generate or attract an additional 110-124 trips per 10,000 square feet. Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a significant impact. 3 Pub. Resources Code, § 21064.3 (“‘Major transit stop’ means a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.”).
4 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”).
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-26
o Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking); o Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization); or o Replaces affordable residential units with a smaller number of moderate- or highincome residential units.
From review of pre-COVID frequency of transit services provided by Vine Transit Route 10, Vine Route 29 and St. Helena Shuttle near the Project site, the Proposed Project is not located near a major transit stop or high-quality transit corridor. Therefore, the presumption of less-thansignificant VMT impact near a transit station would not apply. • Presumption of Less-than-Significant Impact for Affordable Residential Development:
The Technical Advisory notes that adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT.5,6In areas where the existing jobs housing match is closer to optimal, low income housing nevertheless generates less VMT than market- rate housing.7,8 Therefore, a project consisting of a high percentage of affordable housing may be a basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a presumption of lessthan-significant impact for a 100% affordable residential development (or the residential component of a mixed-use development) in infill locations. Furthermore, a project which includes any affordable residential units may factor the effect of the affordability on VMT into the assessment of VMT generated by those units. The Proposed Project includes 25 multifamily units designated to meet affordable housing requirements which would account for 28.73% affordable housing; however, this would not meet the Technical Advisory’s recommended screening criteria of 100% affordable housing. Therefore, presumption of a less-than-significant VMT impact for affordable residential development is not applicable.
5 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobs housing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and housing by linking the affordability of locally available housing with local wage levels are likely to be associated with reduced commuting distances”).
6 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing shortages, available at https://regionalchange.ucdavis.edu/sites/g/files/dgvnsk986/files/inlinefiles/Urban%20Geography%20benner%20karner.pdf. 7 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 8 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at http://www.aqmd.gov/docs/default-source/ceqa/handbook/capcoa-quantifying-greenhouse-gasmitigation-measures.pdf.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-27
Therefore, the exceptions listed above are not applicable to the Proposed Project.
As outlined above, the Proposed Project does not meet the screening criteria identified in the Technical Advisory. Therefore, an assessment of the Proposed Project’s VMT impact under base year conditions has been provided using available significance thresholds and guidance from OPR and the Technical Advisory.
Methodology for VMT Estimation
For residential projects, such as the Proposed Project, the Technical Advisory indicates that “tour- and trip-based approaches offer the best methods for assessing VMT from residential/office projects and for comparing those assessment to VMT thresholds.” Tour-based assessments are recommended, when available, as they typically capture a more comprehensive representation of travel behavior; however, when tour-based tools or data are not available, the Technical Advisory indicates that “…trip-based assessment of VMT can serve as a reasonable proxy.”
The recent update to the NSABM model is an activity-based model (i.e., tour-based) that provides VMT estimates for traffic analysis zones (TAZ) as well as the VMT average for cities within the Napa County. Therefore, the average VMT/capita at the TAZ level within which the Proposed Project is located was used for comparing the VMT thresholds for the City. The VMT maps available for Napa County from NSABM were used to determine the VMT/capita in the TAZ in which the Proposed Project is located.9
Project Trip Generation
Trip generation estimates for the Proposed Project were calculated based upon trip rates provided in the Institute of Transportation Engineers’ Trip Generation, 10th Edition (ITE 2017).
Average trip generation rates represent weighted averages from studies conducted throughout the United States and Canada since 1980 that surveyed the identified use.10 For example, “single-family detached housing,” which has the highest trip generation rate per dwelling unit of all residential uses, specifically identifies all detached homes on individual lots, with a typical site being a suburban subdivision.
Trip rates for accessory dwelling units (ADUs) are not widely available, and if they are, the rates are unreliable due to the limited (low) number of studies provided. Therefore, in order to 9 The VMT map is available on following link:
https://www.arcgis.com/home/webmap/viewer.html?webmap=765f96cb16d34c8486eaf995012e14ec &extent=-122.554,37.9494,-121.5659,38.6993
10 Single-Family and multifamily land uses are based on surveys and weighted averages. Rates are not based on a specified number of bedrooms or vehicles per household.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-28
conservatively estimate traffic generated from those uses, the ITE multifamily housing rate was used for the ADU rate. Since the ITE multifamily housing rate was used for the proposed ADUs, the ITE single family detached housing rate was used for the proposed multifamily units which assumes that these units may generate more traffic than the proposed ADUs. This would provide for conservative daily and peak hour trip generation estimates of the Proposed Project.
The calculation of Proposed Project trip generation estimates for weekdays and Saturday are shown in Tables 3.14-1 and 3.14-2, respectively.
As shown in Table 3.14-1, during a weekday the Proposed Project would generate 798 daily trips, 62 AM peak hour trips (16 inbound and 46 outbound), and 82 PM peak hour trips (52 inbound and 30 outbound).
Table 3.14-1
Weekday Proposed Project Trip Generation
Trip Generation Rates1
Land Use
Daily Trip
Rate Unit
AM Peak Hour PM Peak Hour
% In % Out Total % In % Out Total
Single-Family Detached
Housing (ITE Code 210)
9.44 DU 0.19 0.56 0.74 0.62 0.37 0.99
Multifamily Housing (LowRise) (ITE Code 220)
7.32 DU 0.11 0.35 0.46 0.35 0.21 0.56
Trip Generation
Land Use
Total No.
of Units Unit Daily
AM Peak Hour PM Peak Hour
In Out Total In Out Total
Single-Family Detached
Housing
51 DU 481 10 28 38 32 19 51
Accessory Dwelling Units 11 DU 81 1 4 5 4 2 6
Multifamily Housing2 25 DU 236 5 14 19 16 9 25
Total Trip Generation 798 16 46 62 52 30 82
Notes:
1 Trip rates from the Institute of Transportation Engineers, Trip Generation, 10th Edition, 2017. 2 Reflects use of a single-family home to provide a conservative estimate.
Source: ITE 2017; Dudek 2020.
As shown in Table 3.14-2, during a Saturday the Proposed Project would generate 815 daily trips, and 80 peak hour trips (40 inbound and 40 outbound).
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-29
Table 3.14-2
Saturday Proposed Project Trip Generation
Trip Generation Rates1
Land Use
Saturday
Trip Rate Unit
Peak Hour
% In % Out Total
Single-Family Detached Housing
(ITE Code 210)
9.54 DU 0.47 0.47 0.93
Multifamily Housing (Low-Rise)
(ITE Code 220)
8.14 DU 0.35 0.35 0.70
Trip Generation
Land Use
Total No.
of Units Unit Daily
Peak Hour
In Out Total
Single-Family Detached Housing 51 DU 487 24 24 48
Accessory Dwelling Units 11 DU 90 4 4 8
Multifamily Housing2 25 DU 239 12 12 24
Total Trip Generation 815 40 40 80
Notes:
1 Trip rates from the Institute of Transportation Engineers, Trip Generation, 10th Edition, 2017. 2 Reflects use of a single-family home to provide a conservative estimate.
Source: ITE 2017; Dudek 2020.
Proposed Project Trip Distribution and Assignment
Proposed Project trips were distributed to the study area intersections using the existing travel patterns and logical commute routes for Proposed-Project-related traffic. Project trips were assigned to the study area intersections by applying the Proposed Project trip generation estimates to the trip distribution percentages at each study area intersection. Single-family units and ADUs were distributed and assigned together, as shown on Figure 3.14-5, while multifamily housing was distributed and assigned separately, as shown on Figure 3.14-6. The total Proposed Project trip assignment is shown in Figure 3.14-7. The Proposed Project’s trip distribution and assignment for Saturday includes all uses combined and is shown on Figure 3.14-8.
Planned Pedestrian and Bicycle Facility Improvements
The pedestrian infrastructure within the study area would remain largely unaffected by the Proposed Project. As Starr Avenue is extended northward and Adams Street extended eastward, additional sidewalks connecting the Proposed Project to the surrounding area would provide pedestrian access to the surrounding residential community. Additionally, the NVTA has plans for the Vine Trail, a network of bicycle and pedestrian paths that will eventually connect all Napa County communities, with construction in the City anticipated to begin as early as 2021.
The Vine Trail, as tentatively proposed, would proceed through sections of the Project site by way of Adams Street and Starr Avenue.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-30
Transit System
The NVTA has published a report, Vision 2040 Moving Napa Forward Transportation Plan, which outlines policies to improve system safety of all users, serve the transportation needs of all users regardless of age, income or ability, and to improve overall reliability of the transit system. As the shift from one-car trips to multi-modal and active transportation uses increases, the plan would require collaboration with the City and other jurisdictions to modify service as needed to serve the community. The plan would also promote the Vine Trail as an active transportation use, and along with the 2019 General Plan’s “Complete Streets” approach, improve overall connectivity, ease of access, and safety for all members of the community.
The Wine Train is not expected to increase frequency or add stops within the city, and additional commuter or freight train traffic is not expected to occur by 2040.
Thresholds of Significance
Consistent with Appendix G of the CEQA Guidelines, a significant impact would occur if development of the Proposed Project would do any of the following:
• Conflict with an applicable plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. • Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b). • Substantially increase hazards due to a geometric design feature (e.g., sharp curves, or dangerous intersections) or incompatible uses (e.g., farm equipment). • Result in inadequate emergency access.
VMT CEQA Analysis
The updated State CEQA Guidelines do not establish a significance threshold for evaluating VMT impacts; however, OPR’s Technical Advisory recommends a threshold of significance for residential, office and other land uses. While the recommended threshold for per capita or per employee for residential or office projects, respectively, is 15% below that of existing development, lead agencies can use more location-specific information to develop their own specific threshold for other project/land use types.
Agenda Item #6.2.
1 5
3 2
6 8
12 11
LIBRARY
MADRONA AVENUE
FULTON LANE
RAILROAD AVENUE
SR-29
SILVERADO TRAIL
HOWELL
PASEO GRAND
MOUNTAIN ROAD
COLLEGE
DRIVE
AVENUE
LANE
ADAMS STREET
HUNT AVENUE
STARR AVENUE
POPE STREET
4 MITCHELL
DRIVE
MAIN STREET
PRATT AVENUE
7 13
SPRING
MTN. ROAD
9 10
Project Trip Distribution & Assignment - Single-Family & Accessory Dwelling Units Hunter Subdivision - St. Helena
FIGURE
6 Mar 11, 2021 - 2:54pm mpopovic P:\300.Environmental\10839 Hunter Subdivision\DUDEK WORK PRODUCTS\DOCUMENTS\Traffic\Graphics\Autocad Files\Base_HunterSubdivision_04.15.19.dwg Layout: fig6-SfAcsTrip
NOT TO SCALE
Source: Google Maps, 05/2017
Main Street
Fulton Ln – Madrona Ave
(0) 1
(0) 1
(1) 0
1 (1)
(1) 1
(2) 1
(1) 2
(0)
1 1
(0) 1
(0) 1
(1) 1
(1) 1
(2) 1
(1) 2
Main Street 2 Adams StreetMain Street
Hunt Avenue
1 (0)
(3) 9
(8) 5
(1)
1 3 Main Street
Pope St – Mitchell Dr
10 (3)
(4) 12
(11) 7
(9)
6 4 Railroad Avenue
Fulton Lane
(1) 3
(3) 2
5 Railroad Avenue
Adams Street
(1) 4 (4) 2
(3) 2
(1) 3
6 Library Lane 8 Adams StreetRailroad Avenue 7 Hunt Avenue Paseo Grand Dr – College Ave 11 Pope Street
(3) 9 (8) 5 (2) 7 (6) 4 (6) 4
(1) 0
(0) 1
(2) 7
Starr Avenue 9 Hunt Avenue
(3) 11
(5)
(16)
10 (10) 7
18 Silverado Trail
Pope Street
(2) 1
(5) 3
(2) 5
(1) 2
Silverado Trail
Howell Mountain Road
1 (2)
(1)
2 12
13 Starr Avenue
Pope Street
(3) 10 (2) 8
(7) 5(9) 6
10 Legend
Site
X Study Intersection
X
(X)
Weekday PM Peak Hour Traffic Volumes
Weekday AM Peak Hour Traffic Volumes
XX% Percentage Distribution
5%
2%
15%
60%
10%
5%
3%
Project Trip Distribution & Assignment - Single Family & Accessory Dwelling Units Hunter Subdivision Project
FIGURE 3.14-5
Path: Z:\Projects\j1083901\MAPDOC\EIR\Transportation
SOURCE: Google Maps 2017 Page 1501 of 4069
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-32
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
1 5
3 2
6 8
12 11
LIBRARY
MADRONA AVENUE
FULTON LANE
RAILROAD AVENUE
SR-29
SILVERADO TRAIL
HOWELL
PASEO GRAND
MOUNTAIN ROAD
COLLEGE
DRIVE
AVENUE
LANE
ADAMS STREET
HUNT AVENUE
STARR AVENUE
POPE STREET
4 MITCHELL
DRIVE
MAIN STREET
PRATT AVENUE
7 13
SPRING
MTN. ROAD
9 10
Main Street
Fulton Ln – Madrona Ave
(0) 1
(0) 1
(1) 1
1 (1)
(1) 1
(2) 1
(1) 2
(0)
1 1
(0) 1 (1) 0
(2) 1
(1) 2
Main Street 2 Adams StreetMain Street
Hunt Avenue
(1) 2
(1) 1
3 Main Street
Pope St – Mitchell Dr
2 (1)
(1) 2
(2) 1
(2)
1 4 Railroad Avenue
Fulton Lane
(1) 3
(3) 2
5 Railroad Avenue
Adams Street
(1) 3 (3) 2
(3) 2
(1) 3
6 Library Lane 8 Adams Street
Railroad Avenue 7 Hunt Avenue
Paseo Grand Dr – College Ave 11 Pope Street
(1) 2 (2) 1 (2) 6 (5) 3 (4) 3
(1) 0
(0) 1
(2) 5
Starr Avenue 9 Hunt Avenue
(1) 3
(2)
(6)
4 (2) 1
7 Silverado Trail
Pope Street
(2) 1
(2) 1
(1) 2
(1) 2
Silverado Trail
Howell Mountain Road
1 (1)
(1) 0
(0) 1
(1)
2 12
13 Starr Avenue
Pope Street
(1) 2 (2) 6
(5) 3(2) 1
10 Legend
Site
X Study Intersection
X
(X)
Weekday PM Peak Hour Traffic Volumes
Weekday AM Peak Hour Traffic Volumes
XX% Percentage Distribution
15%
10%
5%
25%
20%
15%
5%
5%
SOURCE: Google Maps,05/2017
Path: P:300.Environmental\10839 Hunter Subdivision\DUDEK WORK PRODUCTS\DOCUMENTS\Traffic\Graphics\Autocad Files\Base_HunterSubdivision_04.15.19_EIR.dwg Layout: fig1-site location and study area FIGURE 3.14-6
Project Trip Distribution & Assignment - Multi-Family Housing Hunter Subdivision Project
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-34
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
1 5
3 2
6 8
12 11
LIBRARY
MADRONA AVENUE
FULTON LANE
RAILROAD AVENUE
SR-29
SILVERADO TRAIL
HOWELL
PASEO GRAND
MOUNTAIN ROAD
COLLEGE
DRIVE
AVENUE
LANE
ADAMS STREET
HUNT AVENUE
STARR AVENUE
POPE STREET
4 MITCHELL
DRIVE
MAIN STREET
PRATT AVENUE
7 13
SPRING
MTN. ROAD
9 10
Project Trip Assignment - Total (All Uses)
Hunter Subdivision - St. Helena
FIGURE
8 Mar 11, 2021 - 2:51pm mpopovic P:\300.Environmental\10839 Hunter Subdivision\DUDEK WORK PRODUCTS\DOCUMENTS\Traffic\Graphics\Autocad Files\Base_HunterSubdivision_04.15.19.dwg Layout: fig8-ProjTripAs
NOT TO SCALE
Source: Google Maps, 05/2017
Main Street
Fulton Ln – Madrona Ave
(0) 2
(0) 2
(2) 1
2 (2)
(2) 2
(4) 2
(2) 4
(0)
2 1
(0) 2
(0) 1
(1) 1
(2) 1
(4) 2
(2) 4
Main Street 2 Adams StreetMain Street
Hunt Avenue
1 (0)
(4) 11
(9) 6
(1)
1 3 Main Street
Pope St – Mitchell Dr
12 (4)
(5) 14
(13) 8
(11)
7 4 Railroad Avenue
Fulton Lane
(2) 6
(6) 4
5 Railroad Avenue
Adams Street
(2) 7 (7) 4
(6) 4
(2) 6
6 Library Lane 8 Adams StreetRailroad Avenue 7 Hunt Avenue Paseo Grand Dr – College Ave 11 Pope Street
(4) 11 (10) 6 (4) 13 (11) 7 (10) 7
(2) 0
(0) 2
(4) 12
Starr Avenue 9 Hunt Avenue
(4) 14
(7)
(22)
14 (12) 8
25 Silverado Trail
Pope Street
(4) 2
(7) 4
(3) 7
(2) 4
Silverado Trail
Howell Mountain Road
2 (3)
(1) 0
(0) 1
(2)
4 12
13 Starr Avenue
Pope Street
(4) 12 (4) 14
(11) 7 (12) 8
10 Legend
Site
X Study Intersection
X
(X)
Weekday PM Peak Hour Traffic Volumes
Weekday AM Peak Hour Traffic Volumes
Project Trip Distribution & Assignment - Total (All Uses) Hunter Subdivision Project
FIGURE 3.14-7
Path: Z:\Projects\j1083901\MAPDOC\EIR\Transportation
SOURCE: Google Maps 2017 Page 1505 of 4069
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-36
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
1 5
3 2
6 8
12 11
LIBRARY
MADRONA AVENUE
FULTON LANE
RAILROAD AVENUE
SR-29
SILVERADO TRAIL
HOWELL
PASEO GRAND
MOUNTAIN ROAD
COLLEGE
DRIVE
AVENUE
LANE
ADAMS STREET
HUNT AVENUE
STARR AVENUE
POPE STREET
4 MITCHELL
DRIVE
MAIN STREET
PRATT AVENUE
7 13
SPRING
MTN. ROAD
9 10
Project Trip Distribution & Assignment - Saturday (All Uses) Hunter Subdivision - St. Helena
FIGURE
9 Mar 11, 2021 - 3:01pm mpopovic P:\300.Environmental\10839 Hunter Subdivision\DUDEK WORK PRODUCTS\DOCUMENTS\Traffic\Graphics\Autocad Files\Base_HunterSubdivision_04.15.19.dwg Layout: fig9-SaturdayTrip
NOT TO SCALE
Source: Google Maps, 05/2017
Main Street
Fulton Ln – Madrona Ave
4 2
2 5
4 7
7 5
1 2
1 1
1 2
6 6
1 Main Street 2 Adams StreetMain Street
Hunt Avenue
1 5
5 1
1 1
3 Main Street
Pope St – Mitchell Dr
5 7
7 5
4 Railroad Avenue
Fulton Lane
11 11
5 Railroad Avenue
Adams Street
9 1
9 10
10 1
6 Library Lane 8 Adams StreetRailroad Avenue 7 Hunt Avenue Paseo Grand Dr – College Ave 11 Pope Street
6 6
1 1
19 19 8 8
Starr Avenue 9 Hunt Avenue
8 13
8 13
Silverado Trail
Pope Street
2 6
6 2
Silverado Trail
Howell Mountain Road
2 2
12 13
Starr Avenue
Pope Street
5 8
5 8
10 Legend
Site
X Study Intersection
X Saturday Peak Hour Traffic Volumes
XX% Percentage Distribution
15%
5%
30%
30%
15%
5%
Project Trip Distribution & Assignment - Saturday (All Uses) Hunter Subdivision Project
FIGURE 3.14-8
Path: Z:\Projects\j1083901\MAPDOC\EIR\Transportation
SOURCE: Google Maps 2017 Page 1507 of 4069
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-38
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-39
Since the City has not yet adopted VMT significance thresholds, the following significance threshold for residential projects provided in the OPR’s Technical Advisory has been used for the Proposed Project:
• Residential: Exceed a level of 15% below existing VMT per capita, which may indicate a significant transportation impact. Existing VMT per capita may be measured as regional VMT per capita or as city VMT per capita. 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 adopted SCS for that city and should be consistent with the SCS. The VMT analysis for the Proposed Project uses the Citywide VMT per capita as the significance threshold.
Impacts and Mitigation Measures
3.14-1: Would the Proposed Project conflict with an applicable plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? This impact would be less than significant.
As shown in the overview of applicable plans and policies under Section 3.14.3, the Proposed Project would be consistent with applicable plans, city ordinances or policies addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.
As noted in the TIS (Appendix K), the Proposed Project would exceed the City’s General Plan consistency criteria for evaluating LOS. However, as indicated above, under the current CEQA Guidelines, LOS, or vehicle delay, is no longer considered an environmental impact under CEQA, and VMT has been adopted as the most appropriate measure of transportation impacts.
Improvement measures to address potential inconsistencies with General Plan policies are provided in the Proposed Project’s TIS.
In addition, the TIS also addresses Policy CR1.1 and Action CR1.C included in the City’s 2019 General Plan, and acts as the “Special Study” required to evaluate the new pedestrian and bicycle networks on the extension of Starr Avenue, north to Adams Street; and, the extension of Adams Street, east to Starr Avenue. A summary of the analysis of the Starr Avenue and Adams Street extensions are summarized below.
Transit, Pedestrian, and Bicycle
The NVTA manages Vine Transit, which provides transit service in the greater Napa County region and serves the Project site. The St. Helena Shuttle, Vine Route 10, and Vine Route 29 all provide differing levels of frequency and connectivity to transit riders. Access to these transit stops are a few blocks from the Project site and sidewalks are available to ensure safe pedestrian access. No transit stops would be included within the Project site.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-40
In developed areas to the south/southeast sidewalks are present. As part of the Proposed Project, Adams Street and Starr Avenue would be extended to provide vehicle, bicycle and pedestrian access to the site, consistent with the 1993 General Plan Policy 5.8.1 and Policy CR1.1 from the City’s 2019 General Plan. Sidewalks would be provided along both sides of the street allowing safe pedestrian access to the site from adjacent areas. Sidewalks are also available connecting the Project site to downtown St. Helena.
Class II bicycle lanes are available along the entirety of Starr Avenue and Silverado Trail and the majority of Pope Street from Railroad Avenue to Paseo Grand Drive-College Avenue. Class III bicycle routes are provided along Hunt Avenue and portions of Pope Street, east of Railroad Avenue and west of Paseo Grand Drive-College Avenue, towards the approach to the Pope Street Bridge. The extension of Starr Avenue and Adams Street would provide Class III bicycle access to the site and on roadways throughout the site.
The Project site would facilitate accessibility to downtown St. Helena by way of existing sidewalks that would provide access to several neighborhood services such as Main Street, retail and grocery stores, and the City’s Public Library. As shown on the Bicycle Network of the City’s 2019 General Plan, Napa Valley Vine Trail is proposed along Adams Street from Railroad Avenue to Starr Avenue and continues along Starr Avenue to Pope Street. The proposed Napa Valley Vine Trail would include Class I, Class II and Class III bicycle network segments.
The Proposed Project supports the NVTA’s and Vine Transit’s initiatives to foster local accessibility and adequate transit facilities for City residents. The Proposed Project would provide adequate sidewalks and bicycle amenities and would not conflict with any plans or policies supporting either the development of these facilities or the use of these facilities. The Proposed Project does conflict with any plans or policies that address transit, pedestrian and bicyclist facilities; therefore, impacts are less than significant.
Mitigation Measures
None required.
3.14-2: Would the Proposed Project conflict or be inconsistent with CEQA Guidelines Section 15064.3(b)? This impact would be potentially significant.
CEQA Guidelines Section 15064.3(b), focuses on newly adopted VMT criteria for determining the significance of transportation impacts.
As mentioned above, the Proposed Project is requesting approval of a Tentative Subdivision Map to subdivide the Project site into 51 single-family lots with 11 of the 51 lots developed with an ADU and a 3.4-acre lot designated for 25 multifamily units. As directed by the City, the average VMT/capita at the TAZ level was used for comparing the Proposed Project’s VMT Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-41
relative to the Citywide VMT. The VMT maps available for Napa County from NSABM were used to determine the VMT/capita in the TAZ in which the Proposed Project is located.
Figure 3.14-9, VMT Screening Map, illustrates the VMT/capita estimate that was used in screening the Proposed Project. As shown in Figure 3.14-9, the Proposed Project is located is SNABM Zone 199. The VMT per capita of this zone is 11.37 per capita. The Proposed Project’s VMT (Project TAZ VMT of 11.37) was compared with the City’s 2015 baseline VMT per capita from the NSABM model (11.34 VMT per capita). As mentioned above, the City is using OPR’s criteria indicating that a residential project that exceeds a level of 15% below existing VMT per capita would have a potentially significant transportation impact. As shown in the Table 3.14-3, the TAZ within which the Proposed Project is located has an existing VMT per capita of 11.37 which is above the Citywide VMT per capita of 11.34, as well as above the Citywide VMT per capita of 9.64. Therefore, the Proposed Project would exceed OPR’s significance threshold of 15% less than the existing VMT resulting in a potentially significant impact.
Table 3.14-3
Proposed Project VMT Summary
Boundary/Threshold VMT per capita
SNABM Zone 199 (Proposed Project TAZ)1 11.37
St. Helena (City)1 11.34
15% below Citywide Threshold2 9.64
Proposed Project TAZ VMT Above Threshold (greater than Citywide Threshold of 9.64) Yes Proposed Project VMT % Above Threshold3 15.2%
Notes:
1 VMT per capita value is from the VMT Tool for NSABM for 2015 Baseline conditions. 2 15% below Citywide VMT threshold of 11.34 = 9.64.
3 Increase calculated as 11.37-9.64 ÷ 11.37 = 0.152 or 15.2%.
Source: Dudek 2021.
Mitigation Measures
To mitigate the Proposed Project’s impact related to VMT, the following Transportation Demand Management (TDM) strategies and Proposed Project design features were evaluated to determine feasibility for the Proposed Project. Based on the assessment of the potential TDM strategies it was determined implementation of these strategies would reduce the Proposed Project’s VMT nominally (by approximately 2.0%). Therefore, as shown in Table 3.14-3, because the Proposed Project’s VMT would be 15.2% higher than the Citywide VMT per capita under existing conditions a reduction of 2.0% would not reduce VMT to below the Citywide threshold of 9.64. Because there are no feasible mitigation measures available to substantially reduce or lessen the impact of the Proposed Project to less than significant, the impact is a significant and unavoidable impact.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-42
Land Use Strategies
These land use strategies include land use diversity and supporting design features that encourage residents to walk, bike and/or use transit facilities and thereby reduce the total VMT.
The Project site would facilitate accessibility to downtown St. Helena (i.e., approximately 0.7 miles from the Project site) by way of existing and new sidewalks that would provide access to downtown St. Helena including several neighborhood services along Main Street, such as retail and grocery stores, and to the St. Helena Public Library (located 0.1 miles from the Project site).
Due to the Proposed Project location, future residents could walk and bicycle to and from the town center. However, because the Proposed Project does not propose a mix of uses (i.e., retail or commercial) most of the Proposed Project’s VMT would be to external (off-site) destinations and there would be no internal trip capture. Therefore, because the Proposed Project does not include a mix of uses a VMT reduction cannot be applied for any land use strategy.
Neighborhood /Site Design
• Pedestrian Network/ Bicyclist Trail Network
As mentioned under Section 3.14.2 Environmental Setting, pedestrian facilities are located near the Project site and Adams Street and Starr Avenue would be extended as part of the Proposed Project to provide vehicle, bicycle, and pedestrian access to the site. Sidewalks would be provided along both sides of Starr Avenue and Adams Street allowing safe pedestrian access to the site. The Project site would facilitate accessibility to downtown St. Helena by way of existing and proposed sidewalks that would provide access to several neighborhood services such as Main Street, retail and grocery stores, and the City’s Public Library. 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). CAPCOA estimates that for urban and suburban projects, providing a pedestrian network within the Project site that also connects to off-site pedestrian networks would reduce VMT by 2.0%. (CAPCOA SDT-1)
Agenda Item #6.2.
FIGURE X
Hunter Subdivision Project
SOURCE: SNABM 2020
VMT Screening Map for Project Location n NOT TO SCALE
PROJECT
VMT Screening Map
Hunter Subdivision Project
FIGURE 3.14-9
Path: Z:\Projects\j1083901\MAPDOC\EIR\Transportation
SOURCE: SNABM 2020 Page 1513 of 4069
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-44
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-45
Class II bicycle lanes are also available along the entirety of Starr Avenue and Silverado Trail and the majority of Pope Street from Railroad Avenue to Paseo Grand Drive-College Avenue.
Class III bicycle routes are provided along Hunt Avenue and portions of Pope Street, east of Railroad Avenue and west of Paseo Grand Drive-College Avenue, towards the approach to the Pope Street Bridge. Along the Proposed Project access, Starr Avenue connects the site to the larger City bicycle network via Pope Street or Hunt Avenue. The City’s Bicycle Plan was adopted in 2012 as part of the larger Napa County Transportation and Planning Agency’s Bicycle Master Plan. The Napa Countywide Bicycle Plan was released in September 2019, however, has not yet been adopted by the City. This plan includes improvements such as Class III bicycle routes along Main Street, Railroad Avenue and Hunt Avenue and Class II bicycle path along Adams Street and Starr Avenue.
As shown on the Bicycle Network in the City’s 2019 General Plan, Napa Valley Vine Trail is proposed along Adams Street from Railroad Avenue to Starr Avenue and continues along Starr Avenue to Pope Street. The proposed Napa Valley Vine Trail would include Class I, Class II and Class III bicycle network segments.
With the assumption that appropriate supportive features would be provided, a 2.0% VMT reduction per CAPCOA SDT-1 can be expected and applied to the Proposed Project as a result of connections to the existing and proposed pedestrian and bicyclist facilities.
Because the pedestrian and bicycling features contemplated in this strategy are (1) already part of the Project, (2) are already in existence or planned to be constructed by the City, or (3) are beyond the ability of the Proposed Project to implement, no mitigation to require these features is proposed.
Commute Trip Reduction and Travel Services
• TDM Strategy Marketing for Residents
“New resident” information packets could be distributed to all new residents to ensure that they are aware of all alternative transportation mode options available near the Proposed Project.
The City could also post this information on the City’s website so that this information is always accessible. Per CAPCOA standard TRT-7: Commute Trip Reduction Marketing, a VMT reduction percentage can be estimated for this measure, however based on the Proposed Project’s size, it is likely to be less than 0.5%.
Because this measure would have a negligible effect on VMT, it is not proposed as a mitigation measure.
• Bike-Share/Car-Share and Neighborhood Electric Vehicle Program Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-46
Bike-share, car-share, car-pooling and neighborhood electric vehicle (NEV) programs reduce the need to have a car or second car. CAPCOA associates a VMT reduction with NEV participation and ownership, along with a travel network that accommodates NEV use, including features such as charging facilities, striping, signage, and educational tools (CAPCOA SDT-3).
The VMT reductions are based on market penetration levels (i.e., percent of households with access to a NEV) and an average reduction in total VMT per NEV household of 12.7%. Since the number of NEV’s per household cannot be estimated at this time and the city does not have an EV ride share program, no VMT reduction was assumed from this strategy.
Because no VMT reduction is projected to result from this strategy, it is not proposed as a mitigation measure.
• Transit System Improvement Strategies
Network Expansion/Service Frequency/Speed Increase
This strategy would include coordination with the local transit operator (NVTA) to extend transit service to the Project site as well as increase service frequency. Increase in frequency by reducing transit headways, especially of the local shuttle service (St. Helena Shuttle), could potentially reduce the Proposed Project’s VMT. According to the CAPCOA Report, transit network expansion and increasing transit service frequency results in VMT reductions ranging from 0.1-8.2% and 0.02-2.5%, respectively. Per the City’s 2019 General Plan, only 1% of city residents commute by transit. Therefore, transit usage in the city is currently very low and cannot be assumed to provide a significant VMT reduction. Furthermore, the likelihood of an expansion of the transit network or increase in service frequency is not known at this time, therefore no VMT reduction was assumed from this strategy.
Because no VMT reduction is projected to result from this strategy, it is not proposed as a mitigation measure.
3.14-3: Would the Proposed Project increase hazards due to a geometric design feature or incompatible use? This impact would be less than significant.
Due to concerns raised in response to the NOP, the analysis below addresses potential safety hazards associated with Proposed Project access and design, including an overview of accident data. Potential hazards associated with construction activities is also provided.
Proposed Project Access and Circulation
As mentioned previously, the Proposed Project would extend Starr Avenue northward into the Project site, and intersect with Adams Street, which the Proposed Project would also extend eastward from its current terminus. As Starr Avenue is extended northward, it would narrow Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-47
from an approximately 75-foot right-of-way (ROW) to a 60-foot ROW with 4-foot-side sidewalks and a 6-foot-wide planter strip on both sides of the street, consistent with City’s street standards. This extension, along with Adams Street, would be designed to accommodate emergency service vehicles and maintain accessibility for pedestrians and bicyclists according to City street design standards.
Additional, internal public residential streets within the Project site would be created to accommodate neighborhood circulation and provide on-street parking on both sides of the Starr Avenue and Adams Street extensions (where permitted). These roadways would be designed to be consistent with all applicable City street design criteria and conform to the City’s Municipal Code (Section 16.32.060) to ensure that emergency service vehicles can adequately access and circulate within the Project site.
Based on a review of the proposed Tentative Subdivision Map, and field observations of existing on-street conditions around the site on Adams Street and Starr Avenue, there are no visual obstructions that would impede vehicles, bicyclists, and pedestrians from having safe access to and from the Project site.
As Adams Street is extended eastward and Starr Avenue is extended northward to link with Adams Street, the overall roadway geometrics would change. The intersection of Starr Avenue/Hunter Avenue would become a 4-way intersection, and vehicles would be able to access the Project site and unnamed internal roadways (Road A, Road B) within the Project site. The internal roadways would be used by Proposed Project residents, however the potential for Starr Avenue and Adams Street to be used as an alternative to Main Street/ SR 29 could also increase. Motorists could bypass the downtown area by traveling eastbound along Pope Street, northbound along Starr Avenue, westbound along Adams Street, northbound along Railroad Avenue, and finally eastbound along Fulton Lane to connect back to Main Street (the reverse applies for traffic travelling to the south of the region). Currently, motorists travel northbound along Starr Avenue and then westbound along Hunt Avenue before reaching Railroad Avenue. The expected increase in vehicles using these maneuvers would be higher along Adams Street and Starr Avenue, but lower along Hunt Avenue. However, the reopening of the Pratt Avenue connection between Main Street and Silverado Trail, as well as the future extension and connections identified in the 2019 General Plan would eliminate the need for such maneuvers other than under extreme circumstances.
Collision Analysis
A qualitative collision analysis was performed to disclose the collision history in the traffic study area. No incidences were reported near the Project site nor on roads the provide access to the Project site. Five years of collision data, from 2014 to 2018, was obtained from the California Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-48
Highway Patrol’s (CHP) Statewide Integrated Traffic Records System (SWITRS). It is important to note that it may take up to six months for a collision to appear within the database, therefore data for 2018 may be incomplete.11
The SWITRS database is a public system that processes and collects data from CHP and other police agencies. The database was queried to select for all collisions occurring within the jurisdiction of the St. Helena Police Department (SHPD) and then narrowed down to the study area intersections that contained collisions resulting in pedestrian or bicyclist injury, as well as collisions occurring at intersections. Most “rear-end” type of collisions were not considered in this analysis since these types of collisions are considered to be by fault of the driver and not because of the intersection or roadway layout, or lack of signalization, as shown in Table 3.14-4.
The SWITRS files are included in Appendix K.
Table 3.14-4
Collision Summary (2014-2018)
Nearest Study
Intersection
# of Total
Collisions
Total # of
Injured1
Total # of
Pedestrians
Injured
Total # of
Bicyclists
Injured Primary Cause
1. Main Street/Fulton Lane
– Madrona Avenue
9 4 1 0 Ran light; improper turn
2. Main Street/Adams
Street
4 3 3 0 Left turn/pedestrian crossing
conflict
3. Main Street/Hunt Avenue 2 0 0 0 Left turn/pedestrian crossing conflict; improper turn
4. Main Street/Pope Street
– Mitchell Drive
5 2 1 0 Unsafe speed
11. Paseo Grand Drive –
College Avenue/Pope
Street
1 0 0 0 Improper turn
12. Silverado Trail/Pope
Street
15 12 0 0 Left turn and right-of-way
conflicts
13. Silverado Trail/Howell
Mountain Road
4 3 0 0 Improper turn
Notes: SWITRS Database Query conducted March 27, 2019.
1 Consists of all injured parties (motorists, pedestrians, and bicyclists).
Source: SWITRS 2019.
As shown in Table 3.14-4, the total number of people injured within the 40 reported collisions is 24 people, 5 of which were pedestrians, and no bicyclists. The intersection of Silverado Trail/Pope Street had the highest number of total collisions recorded. These collisions may be 11 Data from 2019 and 2020 was not available because the website was undergoing maintenance.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-49
attributed to the narrowing of Pope Street at both approaches to the narrow Pope Street Bridge, creating slower moving traffic heading towards a higher speed roadway (Silverado Trail).
The Proposed Project would not increase hazards due to a geometric design feature or incompatible use that would contribute to an increase in collisions or create visual obstructions that would impede vehicles, bicyclists, and pedestrians from having safe access to and from the Project site. The impact is less than significant.
Construction
Construction activities presented in this section are based on construction assumptions included in Section 3.3, Air Quality. Construction traffic impacts would be temporary until buildout of the Proposed Project is completed. The build out scenario evaluated in the air quality analysis conservatively assumes buildout in 6 years.
Proposed Project construction activities have the potential to cause temporary traffic impacts on motorists. Traffic impacts from construction would be expected to occur as a result of the following conditions:
• Temporary increases in truck traffic associated with delivery of construction materials. • Temporary increases in automobile traffic associated with construction workers traveling to and from the Project site.
• Temporary reductions in existing street capacity or on-street parking from temporary lane closures necessary for the construction of roadway improvements, utility relocation or extension, and drainage facilities.
• Temporary blockage of existing vehicle or pedestrian access to other parcels fronting streets.
For the purposes of this EIR, Proposed Project construction is expected to take 6 years, from site clearing and grading of the site to the end of building construction. Construction activity would occur on weekdays and may occasionally occur on Saturday. All heavy trucks would be required to comply with chapter 10.36 of the City’s Municipal Code that establishes SR 29/Main Street as the primary truck route for heavy construction vehicles (exceeding a maximum gross limit of ten thousand (10,000) pounds). It is anticipated trucks would access the site using SR 29 connecting to Pope Street and Starr Avenue. All construction activities would be limited to Monday through Saturday from 8:00 AM to 5:00 PM, consistent with chapter 8.24 of the City’s Municipal Code that allows construction activities to occur within these days and times.
Of the five construction phases (site preparation, grading, paving, building construction, and architectural coating), the building construction phase would generate the most traffic, related to Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-50
the number of construction workers destined to/from the site. For the 6-year buildout, building construction would generally last for seven months with one phase lasting 11 months.
It is estimated that the maximum number of construction personnel per day during the most intense phase (building construction) would be 20 workers. Assuming worst-case, noncarpooling among the workers, there would be a maximum of 40 construction worker trips per day (20 inbound and 20 outbound). The building construction phase would also require delivery of construction materials. It is estimated that an average of five delivery truck trips per weekday would occur, resulting in 10 daily truck trips (5 inbound and 5 outbound).
In general, the hours of construction typically require workers to be on-site before the weekday morning commuter peak period and allow them to leave before the afternoon commuter peak period (outside of the peak morning and evening commute times). Saturday construction activity would occur outside of the typical weekend midday peak period. Therefore, the large majority of construction-related trips would occur outside of the typical weekday commuter per periods and weekend midday peak period.
Parking for construction workers would be provided on-site. Therefore, construction workers and vehicles would not reduce the availability of parking spaces on streets surrounding the Project site. Also, no bus stops would be relocated and no bus lines would be rerouted due to Proposed Project construction.
Construction of the Proposed Project would be largely contained within the Project site and would generally not affect adjacent street access. In addition, any delays from additional construction traffic and/or construction activities at locations other than the streets adjacent to the Project site are not expected to be substantial. Certain construction activities such as roadway improvements and utility relocation or extension could require temporary lane closures, which would in turn temporarily reduce existing street capacity, but such impacts would be short-term in duration and would done through building and/or grading permits with the City.
Based on the temporary nature of traffic generated by construction workers and delivery trucks; the off-peak travel times of the construction workers; and, the requirement to obtain construction permits through the City along with preparation of a temporary traffic control plan for construction activities, to be approved by the City’s traffic engineer (Municipal Code Section
12.12.050), construction traffic is not expected to create hazards for roadway travelers, pedestrians, bicyclists, or transit riders. The impacts of construction activity on the overall transportation system are anticipated to be temporary in nature and would cause minimal interruption to the regular operation of, the facilities surrounding the Project site. Impacts on traffic associated with construction (e.g., an intermittent reduction in street and intersection operating capacity) are typically considered short-term adverse impacts, but not significant.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-51
Therefore, Proposed Project construction impacts on the transportation system would be less than significant.
Mitigation Measures
None required.
3.14-4: Would the Proposed Project result in inadequate emergency access? This impact would be less than significant.
The St. Helena Fire Department has reviewed the proposed Tentative Subdivision Map and has not identified any issues with inadequate emergency access.
Specifically, the Proposed Project includes two primary access points, Star Avenue and Adams Street as well as a separate emergency vehicle access. In the event of an emergency there would be three avenues that would enable vehicles to enter/exit the Project site. As described in Section 3.12, Public Services, the Proposed Project would be consistent with the 1993 General Plan Policy 8.5.7 and 2019 General Plan Policy PS4.6, which requires all streets and roads be designed with adequate width, turning radius, and grade to facilitate access by City firefighting apparatus, and to provide alternative emergency ingress and egress.
Once the Tentative Subdivision Map is approved, the Proposed Project’s Final Subdivision Map would be subject to additional review by the St. Helena Fire Department to confirm proper access for fire and emergency response is provided and required fire suppression features are included.
Because adequate emergency access is provided the impact is considered less than significant.
Note: Wildfire risk and evacuation regulations are discussed in Section 3.8, Hazards and Hazardous Materials, and state the Proposed Project would not conflict with the Napa County Emergency operations Plan and adequate site access is available in the event of a wildfire.
Mitigation Measures
None required.
3.14.5 Cumulative Impacts
OPR’s Technical Advisory provides guidance to practitioners regarding VMT analysis under cumulative conditions. Specifically, for projects analyzed using a VMT efficiency metric, the following statement is made: “A project that falls below an efficiency-based threshold that is aligned with the long-term environmental goals and relevant plans would have no cumulative Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-52
impacts distinct from the project impact. Accordingly, a finding of less-than-significant project impact would imply a less than significant cumulative impact, and vice versa”.
Impacts related to inadequate emergency access and conflicts with transit, bicycle or pedestrian transportation would be identical to the impacts described in the Proposed Project impacts section; and all impacts would be less than significant.
Cumulative impacts are evaluated within the Cumulative plus Proposed Project framework which is based on the Buildout (2040) condition.
3.14-5:Under Cumulative conditions, would the Proposed Project conflict or be inconsistent with CEQA Guidelines section 15064.3(b)? This impact is considered potentially significant.
Based on the guidance provided by OPR and the VMT analysis above, since the Proposed Project would have a per capita VMT impact under the existing/base year, it would also have a potentially significant cumulative impact to VMT.
Mitigation Measures
Mitigation measures evaluated under Impact 3.14-3 would also apply under cumulative conditions; however, even with the inclusion of feasible TDM the Proposed Project’s cumulative impact cannot be avoided or reduced to a less-than-significant level. No other feasible mitigation measures are available. Therefore, the Proposed Project’s cumulative impact would be significant and unavoidable.
3.14.6 References
California Department of Transportation, 2002. Guide for the Preparation of Traffic Impact Studies. http://www.dot.ca.gov/hq/tpp/offices/ocp/igr_ceqa_files/tisguide.pdf.
Caltrans (California Department of Transportation). 2020. Transportation Impact Study Guide.
Vehicles Miles Traveled-Focused Draft. February 2020.
Napa County Transportation & Planning Agency, 2012. NCTPA Countywide Bicycle Plan. https://www.nvta.ca.gov/sites/default/files/NCTPA%20Countywide%20Bicycle%20Plan_0.pdf.
Metropolitan Transportation Commission, 2017. Plan Bay Area 2040 Regional Transportation Plan and Sustainable Communities Strategy for the San Francisco Bay Area 2017-2040. http://2040.planbayarea.org/reports.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-53
Chris Benner & Alex Karner (2016): Low-wage jobs-housing fit: identifying locations of affordable housing shortages, Urban Geography, DOI:
10.1080/02723638.2015.1112565.
City of St. Helena, 2019. General Plan update 2040. http://www.cityofsthelena.org/ planning/page/2040-general-plan-update.
City of St. Helena, 2019. St. Helena Municipal Code. https://www.codepublishing.com/CA/ StHelena.
California Highway Patrol’s (CHP) Statewide Integrated Traffic Records System (SWITRS).
Dyhett & Bhatia, 2018. Draft Environmental Impact Report for the St. Helena General Plan Update Chapter 3.13 Transportation and Traffic. http://www.cityofsthelena.org/ planning/page/2040-general-plan-update.
ITE (Institute of Transportation Engineers). 2017. Trip Generation Manual. 10th ed. Washington, DC: Institute of Transportation Engineers.
Transportation Research Board. 2016. Highway Capacity Manual. 6th ed. Washington, DC:
Transportation Research Board.
NCTPA, 2015. Vision 2040 Moving Napa Forward. https://www.nvta.ca.gov/sites/ default/files/Vision_2040_Countywide_Plan.pdf.
Napa County, 2008. Napa County General Plan Circulation. https://www.countyofnapa.org/ DocumentCenter/View/3332/Circulation-Element-PDF.
Napa Valley Transportation Authority (NVTA), 2016. Napa Countywide Pedestrian Plan. https://www.nvta.ca.gov/countywide-pedestrian-master-plan.
Napa Valley Transportation Authority (NVTA), 2019. Napa Countywide Bicycle Plan. https://www.nvta.ca.gov/napa-countywide-bicycle-plan.
OPR (California Governor’s Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Accessed May 2020. http://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf.
Agenda Item #6.2.
3.14 – TRANSPORTATION AND CIRCULATION
Hunter Subdivision Project EIR 10839
September 2021 3.14-54
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-1
3.15 ENERGY
This section evaluates the potential impacts that the proposed Hunter Subdivision Project (Proposed Project) may have on energy resources. This section presents the environmental and regulatory energy resource setting along with an analysis and discussion of energy resource impacts resulting from implementation of the Proposed Project.
No comments were received that raised concerns regarding energy resources in response to the Notice of Preparation. A copy of the Notice of Preparation and comments received is included in Appendix A.
Information contained in this section is based on Proposed Project plans and the California Emissions Estimator Model (CalEEMod) (used to estimate Proposed Project energy consumption). The analysis and findings are based on the emissions modeling, which can be found in Appendix C. Other sources consulted are listed in Section 3.15.6, References.
3.15.1 Environmental Setting
The environmental setting for the Proposed Project related to electricity, natural gas, and petroleum, including associated service providers, supply sources, and estimated consumption, is discussed as follows. In summary, in 2017 (the latest calendar year for which data is uniformly available for all three types of energy sources), California’s estimated annual energy use included the following:
• Approximately 257,268 gigawatt hours of electricity (EIA 2019a) • Approximately 2,110,829 million cubic feet (EIA 2019b) • Approximately 16 billion gallons of gasoline (CEC 2018a) Electricity
Electricity usage in California varies substantially by the types of uses in a building, types of construction materials used in a building, and the efficiency of all electricity-consuming devices within a building. Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s electricity use per capita has remained stable for more than 30 years, and the national average has steadily increased (CEC 2015a).
Two electricity service providers provide service to the City of St. Helena (City) and Napa County.
The City joined the Marin Clean Energy (MCE), a community choice aggregation program.
According to MCE’s 2019 Integrated Resource Plan, approximately 89% of City residents purchase electricity through MCE (MCE 2019). MCE’s 2019 peak demand forecast is approximately 1,048 million kilowatts and annual consumption is expected to be approximately 5,275 million kilowattAgenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-2
hours (kWh) (MCE 2019). The remaining 11% of customers within the City receive electricity from Pacific Gas & Electric Company (PG&E). PG&E provides electric services to 5.4 million customers, including 106,681 circuit miles of electric distribution lines and 18,466 circuit miles of interconnected transmission lines over a 70,000-square-mile service area that includes Northern California and central California (PG&E 2016). As presented in Table 3.15-1, according to PG&E, customers consumed 82,224 million kWh of electricity in 2017 (CEC 2018a).
Table 3.15-1
Pacific Gas & Electric Company 2017 Electricity Consumption Sector Total Electricity (in millions of kWh)
Agricultural and Water Pump 5,049.66
Commercial Buildings 30,446.89
Commercial Other 4,309.58
Industry 10,409.92
Mining and Construction 1,747.35
Residential 29,920.19
Streetlight 340.73
Total Consumption 82,224.32
Note: kWh = kilowatt-hour
Source: CEC 2018a.
PG&E receives electric power from a variety of sources. According to California Public Utilities Commission’s (CPUC) 2018 Renewable Portfolio Standard (RPS) Annual Report to the Legislature, 33% of PG&E’s power came from eligible renewable energy sources in 2017, including biomass/waste, geothermal, small hydroelectric, solar, and wind sources (CPUC 2018). In addition, MCE provides three options to customers including MCE Light Green service, in which 60% of the power mix would be generated by eligible renewable sources and the MCE Deep Green or the MCE Local Sol services, in which 100% of the power mix would come from renewable sources (CEC 2019).
Based on recent energy supply and demand projections in California, statewide annual peak electricity demand is projected to grow an average of 890 megawatts per year for the next decade, or 1.4% annually, and consumption per capita is expected to remain relatively constant at 7,200–7,800 kWh per person (CEC 2015a).
In Napa County, PG&E reported an annual electrical consumption of approximately 1,064 million kWh in 2017, with 685 million kWh for non-residential use and 380 million kWh for residential use (CEC 2018b).
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-3
Natural Gas
The CPUC regulates natural gas utility service for approximately 10.8 million customers who receive natural gas from PG&E, Southern California Gas, San Diego Gas & Electric, Southwest Gas, and several smaller natural gas utilities. PG&E provides natural gas service to most of Northern California, including the City. As provided in Table 3.15-2, PG&E customers consumed approximately 4,715 million therms of natural gas, in 2017 (CEC 2018c).
Table 3.15-2
Pacific Gas & Electric Company 2017 Natural Gas Consumption Sector Total Natural Gas (in millions of therms)
Agricultural and Water Pump 36.40
Commercial Buildings 864.81
Commercial Other 67.96
Industry 1,701.34
Mining and Construction 170.82
Residential 1,873.36
Total Consumption 4,714.69
Source: CEC 2018c.
Natural gas is used for cooking, space heating, generating electricity, and as an alternative transportation fuel. The majority of California’s natural gas customers are residential and small commercial customers (core customers). These customers accounted for approximately 30% of the natural gas delivered by California utilities in 2017. Large consumers, such as electric generators and industrial customers (noncore customers), accounted for approximately 70% of the natural gas delivered by California utilities in 2017 (EIA 2018b).
CPUC regulates California natural gas rates and natural gas services, including in-state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in California comes from out-of-state natural gas basins. California gas utilities may soon also begin receiving biogas into their pipeline systems (CPUC 2017).
In 2012, California customers received 35% of their natural gas supply from basins located in the Southwest, 16% from Canada, 40% from the Rocky Mountains, and 9% from basins located within California (CPUC 2017). Natural gas from out-of-state production basins is delivered into California through the interstate natural gas pipeline system. The major interstate pipelines that deliver out-of-state natural gas to California are the Gas Transmission Northwest Pipeline, Kern River Pipeline, Transwestern Pipeline, El Paso Pipeline, Ruby Pipeline, Southern Trails Pipeline, and Mojave Pipeline. The North Baja–Baja Norte Pipeline takes gas off the El Paso Pipeline at the California/Arizona border and delivers it through California into Mexico. The Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-4
Federal Energy Regulatory Commission regulates the transportation of natural gas on interstate pipelines, and CPUC often participates in Federal Energy Regulatory Commission regulatory proceedings to represent the interests of California natural gas consumers (CPUC 2017).
Most of the natural gas transported through interstate pipelines, as well as some Californiaproduced natural gas, is delivered through the PG&E and Southern California Gas intrastate natural gas transmission pipeline systems (commonly referred to as California’s “backbone” natural gas pipeline system). Natural gas on the backbone pipeline system is then delivered into local transmission and distribution pipeline systems or to natural gas storage fields. Some large noncore customers take natural gas directly off the high-pressure backbone pipeline system, and some core customers and other noncore customers take natural gas off the utilities’ distribution pipeline systems. CPUC has regulatory jurisdiction over 150,000 miles of utility‐ owned natural gas pipelines, which transported 82% of the natural gas delivered to California’s gas consumers in 2012 (CPUC 2017).
PG&E and Southern California Gas own and operate several natural gas storage fields located in Northern and Southern California. These storage fields and four independently owned storage utilities—Lodi Gas Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage—help meet peak-season natural gas demands and allow California natural gas customers to secure natural gas supplies more efficiently (CPUC 2017).
California’s regulated utilities do not own any natural gas production facilities. All natural gas sold by these utilities must be purchased from suppliers and/or marketers. The price of natural gas sold by suppliers and marketers was deregulated by the Federal Energy Regulatory Commission in the mid-1980s and is determined by market forces. However, CPUC decides whether California’s utilities have taken reasonable steps to minimize the cost of natural gas purchased on behalf of its core customers (CPUC 2017).
In 2017 (the most recent year for which data is available), PG&E had delivered 39 millions of therms to Napa County, with the majority going to residential uses (21 millions of therms) (CEC 2018d).
Demand for natural gas can vary depending on factors such as weather, price of electricity, the health of the economy, environmental regulations, energy efficiency programs, and the availability of alternative renewable energy sources. As previously indicated, natural gas is available from a variety of in-state and out-of-state sources and is provided throughout the state in response to market supply and demand. Complementing available natural gas resources, biogas may soon be available through existing delivery systems, thereby increasing the availability and reliability of resources.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-5
Petroleum
There are more than 34 million registered vehicles in California, and those vehicles consume an estimated 16 billion gallons of fuel each year (CEC 2020; DMV 2019). Petroleum currently accounts for approximately 92% of California’s transportation energy consumption (CEC 2020).
However, technological advances, market trends, consumer behavior, and government policies could result in significant changes in fuel consumption by type and in total. At the federal and state levels, various policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation‐source air pollutants and greenhouse gas (GHG) emissions, and reduce vehicle miles traveled (VMT).
Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.
Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined in recent years, and availability of other alternative fuels/energy sources has increased. The quantity, availability, and reliability of transportation energy resources have increased in recent years, and this trend may likely continue and accelerate (CEC 2017).
Increasingly available and diversified transportation energy resources act to promote continuing reliable and affordable means to support vehicular transportation within the state.
3.15.2 Regulatory Setting
Federal, state, and local agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation, the U.S.
Department of Energy, and the U.S. Environmental Protection Agency are three federal agencies with substantial influence over energy policies and programs. On the state level, CPUC and California Energy Commission (CEC) are two agencies with authority over different aspects of energy. Relevant federal, state, and local energy-related regulations are summarized as follows.
Federal Regulations
Federal Energy Policy and Conservation Act
In 1975, Congress enacted the Federal Energy Policy and Conservation Act, which established the first fuel economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-6
Intermodal Surface Transportation Efficiency Act of 1991 The Intermodal Surface Transportation Efficiency Act (ISTEA) of 1991 promoted the development of intermodal transportation systems to maximize mobility and address national and local interests in air quality and energy. ISTEA contained factors for metropolitan planning organizations to address in developing transportation plans and programs, including some energy‐related factors. To meet the new ISTEA requirements, metropolitan planning organizations adopted policies defining the social, economic, energy, and environmental values guiding transportation decisions.
Transportation Equity Act for the 21st Century
The Transportation Equity Act for the 21st Century was signed into law in 1998 and builds on the initiatives established in the ISTEA legislation (discussed above). The act authorizes highway, highway safety, transit, and other efficient surface transportation programs. The act continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of transportation decisions. The act also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of intelligent transportation systems to help improve operations and management of transportation systems and vehicle safety.
Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 was signed into law. In addition to setting more stringent Corporate Average Fuel Economy standards for motor vehicles, the Energy Independence and Security Act includes the following other provisions related to energy efficiency:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325) • Building Energy Efficiency (Sections 411–441)
This federal legislation (the RFS) requires ever-increasing levels of renewable fuels to replace petroleum (EPA 2013, 2015). The U.S. Environmental Protection Agency is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many other stakeholders.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-7
The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the Energy Independence and Security Act, the RFS program was expanded in several key ways that lay the foundation for achieving significant reductions in GHG emissions from the use of renewable fuels, reducing imported petroleum, and encouraging the development and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
• Expands the RFS program to include diesel, in addition to gasoline • Increases the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022 • Establishes new categories of renewable fuel, and sets separate volume requirements for each one
• Requires the U.S. Environmental Protection Agency to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces
Additional provisions of the Energy Independence and Security Act address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green” jobs.
State Regulations
The following discussion focuses primarily on those policies, regulations, and laws that directly pertain to energy-related resources. Also refer to Section 3.7, Greenhouse Gas Emissions, which addresses various policies, regulations, and laws targeted to the reduction of GHG emissions that are expected to achieve co-benefits in the form of reduced demand for energyrelated resources and enhanced efficiencies in the consumption of energy-related resources.
Warren–Alquist Act
The California Legislature passed the Warren–Alquist Act in 1974. The Warren–Alquist Act was created by the CEC. The legislation also incorporated the following three key provisions designed to address the demand side of the energy equation:
• It directed the CEC to formulate and adopt the nation’s first energy conservation standards for both buildings constructed and appliances sold in California.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-8
• The act removed the responsibility of electricity demand forecasting from the utilities, which had a financial interest in high demand projections, and transferred it to a more impartial CEC.
• The CEC was directed to embark on an ambitious research and development program, with a particular focus on fostering what were characterized as non-conventional energy sources.
State of California Energy Action Plan
The CEC and CPUC approved the first State of California Energy Action Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided. The plan also identified policies, strategies, and actions that are cost effective and environmentally sound for California’s consumers and taxpayers. In 2005, a second Energy Action Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the prior 2 years.
At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new energy action plan. This determination was based, in part, on a finding that the state’s energy policies have been significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed as follows). Rather than produce a new energy action plan, the CEC and CPUC prepared an “update” that examines the state’s ongoing actions in the context of global climate change.
Senate Bill 1078 (2002)
Senate Bill (SB) 1078 established the California RPS Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill also required the CEC to certify eligible renewable energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above-market costs of renewable energy.
Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018) SB 107 accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 requires all California utilities to generate 33% of their electricity from eligible renewable energy resources by 2020. Specifically, SB X1-2 sets a three-stage compliance period: by December Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-9
31, 2013, 20% had to come from renewables; by December 31, 2016, 25% had to come from renewables; and by December 31, 2020, 33% will come from renewables.
SB 350 requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.
SB 100 increased the standards set forth in SB 350 establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024; 52% by December 31, 2027; and 60% by December 31, 2030, be secured from qualifying renewable energy sources.
SB 100 states that it is the policy of the state that eligible renewable energy resources and zerocarbon resources supply 100% of the retail sales of electricity to California. This bill requires that the achievement of 100% zero-carbon electricity resources do not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
Consequently, utility energy generation from non-renewable resources is expected to be reduced based on implementation of the 60% RPS in 2030.
Assembly Bill 1007 (2005)
AB 1007 required the CEC to prepare a statewide plan to increase the use of alternative fuels in California (State Alternative Fuels Plan). The CEC prepared the plan in partnership with the California Air Resources Board (CARB) and in consultation with the other state, federal, and local agencies. The plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in-state production of biofuels without causing a significant degradation of public health and environmental quality.
Assembly Bill 32 (2006) and Senate Bill 32 (2016)
In 2006, the Legislature enacted AB 32, the California Global Warming Solutions Act of 2006.
AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32, CARB prepares scoping plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focus on increasing energy efficiencies and the use of renewable resources and reducing the consumption of petroleum-based fuels (e.g., gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-10
Additional information on AB 32 and SB 32 is provided in Section 3.7 of this Environmental Impact Report.
California Building Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Part 6 establishes energy efficiency standards for residential and non-residential buildings constructed in California to reduce energy demand and consumption. Part 6 is updated periodically to incorporate and consider new energy efficiency technologies and methodologies.
The 2019 Title 24 standards are the currently applicable building energy efficiency standards and became effective on January 1, 2020. The 2019 Title 24 Building Energy Efficiency Standards would further reduce energy used and associated GHG emissions compared to prior standards. In general, single-family residences built to the 2019 standards are anticipated to use approximately 7% less energy due to energy efficiency measures than those built to the 2016 standards; once rooftop solar electricity generation is factored in, single-family residences built under the 2019 standards would use approximately 53% less energy than those under the 2016 standards (CEC 2018e). Nonresidential buildings built to the 2019 standards are anticipated to use an estimated 30% less energy than those built to the 2016 standards (CEC 2018e).
State Vehicle Standards
In a response to the transportation sector accounting for more than half of California’s carbon dioxide (CO2) emissions, AB 1493 was enacted in 2002. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles whose primary use is noncommercial personal transportation in the state. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. The 2009–2012 standards resulted in a reduction in approximately 22% GHG emissions compared to emissions from the 2002 fleet, and the 2013–2016 standards resulted in a reduction of approximately 30%.
In 2012, CARB approved a new emissions-control program for model years 2017 through 2025.
The program combines the control of smog, soot, and global warming gases and requirements for greater numbers of zero-emission vehicles into a single package of standards called Advanced Clean Cars. By 2025, when the rules would be fully implemented, new automobiles would emit 34% fewer global warming gases and 75% fewer smog-forming emissions (CARB 2011).
Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum-based fuels.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-11
Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning, regional transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates. As codified in California Government Code, Section 65080, SB 375 requires metropolitan planning organizations to include a sustainable communities strategy in its regional transportation plan. The main focus of the sustainable communities strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions, but the strategy is also a part of a bigger effort to address other development issues within the general vicinity, including transit and VMT, which influence the consumption of petroleum-based fuels.
Regional Regulations
Association of Bay Area Governments
In July 2017, the Association of Bay Area Governments, the designated metropolitan planning organization for the San Francisco Bay Area region adopted the Plan Bay Area 2040 (ABAG 2017). The Plan Bay Area is a long-range plan for transportation projects within the planning area and focuses on cost-effective operational improvements to preserve the existing and expanded regional transportation system through 2040. The 2017 update to the Plan Bay Area focused on refinement of and addressing implementation challenges to the previous (2010) plan. The Plan Bay Area includes seven goals and 13 performance targets covering three broad areas: the environment, equity, and the economy. The performance targets are evaluated in several areas defined as key concerns, including climate protection, adequate housing, healthy and safe communities, open space and agricultural preservation, equitable access, economic vitality, and transportation system effectiveness.
Local Regulations
City of St. Helena 1993 General Plan
The City of St. Helena 1993 General Plan does not include any relevant policies related to energy conservation.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-12
City of St. Helena 2019 General Plan1(“General Plan Update 2040”) The City of St. Helena 2019 General Plan includes policies related to energy conservation.
Although the analysis is based on the 1993 General Plan, the following policies are included for informational purposes:
Policy CC2.1: Encourage measures to reduce energy demand through conservation and efficiency.
Policy CC2.2: Support local efforts to improve the energy supply by switching from fossil fuels to renewables.
3.15.3 Impacts
Methods of Analysis
Energy calculations from construction and operation of the Proposed Project were calculated using CalEEMod Version 2016.3.2. Details relevant to the modeling assumptions are described below.
Construction
Heavy-duty construction equipment of various types would be used during construction. A spreadsheet-based model consisting of data values presented in Appendix D of CalEEMod’s User Guide and specific information provide by PG&E was used to estimate construction equipment usage; results are included in Appendix C of this Environmental Impact Report. Fuel use associated with truck deliveries and worker vehicle trips are also included in this analysis.
Based on that analysis, diesel-fueled construction equipment would operate for an estimated 23,666 hours, as summarized in Table 3.15-3, Hours of Operation for Construction Equipment.
Table 3.15-3
Hours of Operation for Construction Equipment
Phase Hours of Equipment Use
Site Preparation (2023) 560
Grading (2023) 1,280
Paving (2023) 960
Building Construction (2023-2028) 65,440
Architectural Coating (2023-2028) 672
Total 68,912
Source: See Appendix C for details.
1 Also known as the “St Helena General Plan Update 2040,” the 2019 General Plan is referred to in this EIR by its adoption date.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-13
Fuel consumption from construction equipment was estimated by converting the total CO2 emissions from each construction phase to gallons using conversion factors for CO2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor for diesel is 10.21 kilograms per metric ton CO2 per gallon (The Climate Registry 2020).
Operations
Operational energy calculations were estimated for buildout of the Proposed Project. The first full year of operation was assumed to be 2029, which is based on the completion of all construction activities.
As represented in CalEEMod, energy sources include emissions associated with building electricity and natural gas usage (non-hearth). The estimation of operational energy estimates (electricity and natural gas) were based on CalEEMod land use defaults and number of dwellings units. CalEEMod uses Residential Appliance Saturation Survey (RASS) datasets to obtain the energy intensities of different end use categories for different building types in different climate zones (CEC 2010).
Petroleum fuel consumption associated with motor vehicles traveling to and from the Project site is a function of VMT as a result of Proposed Project operation. As shown in Appendix C, the annual VMT attributable to the Proposed Project is expected to be approximately 1,605,342 VMT per year. Similar to construction worker and vendor trips, fuel consumption was estimated by converting the total CO2 emissions from each land use type to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. The default fleet mix in CalEEMod for Napa County assumes that approximately 92.9% of vehicles are from light-duty to medium-duty vehicles and motorcycles were assumed to run on gasoline and the remaining 7.1% of vehicles represent medium-heavy duty to heavy-duty vehicles (delivery vehicles) and buses/recreational vehicles, which were assumed to run on diesel. Because CalEEMod calculates emissions from the transportation sector based on trip generation, the fleet mix assumes a disproportionately high number of medium-duty and heavy-duty trucks and bus trips. For example, of the 900 vehicle trips generated by the Proposed Project per day, the CalEEMod default would assume that approximately 64 trips per day are medium- and heavy-duty truck and bus trips, which is unrealistic for a residential project. Notably, CalEEMod calculates such a high number because the default fleet mix in is based on VMT and not vehicle trips and trucks travel approximately three to four times longer per trip than passenger vehicles.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-14
Thresholds of Significance
Consistent with Appendix G of the California Environmental Quality Act Guidelines, a significant impact would occur if development of the Proposed Project would do any of the following:
• Result in the wasteful, inefficient or unnecessary consumption of energy resources during project construction or operation.
• Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Impacts and Mitigation Measures
3.15-1:Would the Proposed Project result in wasteful, inefficient or unnecessary consumption of energy resources during Project construction or operation? This impact would be less than significant.
Construction Energy Use
Electricity
The majority of the energy used during construction would be from petroleum. The amount of electricity used during construction would be minimal; typical demand would stem from the use of electrically powered hand tools and construction trailer(s) by managerial staff during the hours of construction activities. The electricity used for construction activities would be temporary and minimal; therefore, impacts would be less than significant.
Natural Gas
The need for natural gas is not anticipated during construction activities. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed under the following subsection, Petroleum. Any minor amounts of natural gas that may be consumed as a result of Proposed Project construction would be temporary and negligible and would not have an adverse effect; therefore, impacts would be less than significant.
Petroleum
Petroleum would be consumed throughout construction of the Proposed Project’s infrastructure as well as residences. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction, and VMT associated with the transportation of construction materials and construction worker commutes would also result in petroleum consumption. Heavy-duty construction equipment associated with construction activities involved in grading and trenching for utilities would rely on diesel fuel. It is assumed construction workers would travel to and from the Project site in gasoline-powered vehicles.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-15
The estimated diesel fuel use from construction equipment is shown in Table 3.15-4, Construction Equipment Diesel Demand.
Table 3.15-4
Construction Equipment Diesel Demand
Phase
Pieces of
Equipment
Equipment
CO2 (MT)a
kg
CO2/Gallon Gallons
Site Preparation (2023) 7 16.73 10.21 1,638.13
Grading (2023) 8 26.06 10.21 2,552.46
Paving (2023) 6 20.03 10.21 1,961.49
Building Construction (2023-2028) 53 1,118.13 10.21 109,512.98 Architectural Coating (2023-2028) 6 12.54 10.21 1,400.40 Total 117,065.46
Notes: CO2 = carbon dioxide; kg = kilogram; MT = metric ton.
Sources: See Appendix C for details; The Climate Registry 2020.
Fuel consumption from worker and vendor trips was estimated by converting the total CO2 emissions from the construction phase to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. Worker vehicles are assumed to be gasoline fueled, and vendor/hauling vehicles are assumed to be diesel fueled.
Calculations for total worker, vendor, and hauler fuel consumption are provided in Table 3.15-5, Construction Worker Vehicle Gasoline Demand, and Table 3.15-6, Construction Vendor Truck Diesel Demand.
Table 3.15-5
Construction Worker Vehicle Gasoline Demand
Phase Trips
Vehicle CO2
(MT)a
kg
CO2/Gallonb Gallons
Site Preparation (2023) 180 0.55 8.78 62.57
Grading (2023) 400 1.22 8.78 139.04
Paving (2023) 300 0.92 8.78 104.28
Building Construction (2023-2028) 53,900 149.43 8.78 17,019.87 Architectural Coating (2023-2028) 1,232 3.38 8.78 385.34 Total 17,711.12
Notes: CO2 = carbon dioxide; kg = kilogram; MT = metric ton.
Sources: See Appendix C for details, The Climate Registry 2020.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-16
Table 3.15-6
Construction Vendor Truck Diesel Demand
Phase Trips
Vehicle CO2
(MT)a
kg
CO2/Gallonb Gallons
Site Preparation (2023) 0 0.00 10.21 0.00
Grading (2023) 40 0.50 10.21 48.60
Paving (2023) 0 0.00 10.21 0.00
Building Construction (2023-2028) 10,780 131.97 10.21 12,925.25 Architectural Coating (2023-2028) 0 0.00 10.21 0.00
Total 12,973.85
Notes: CO2 = carbon dioxide; kg = kilogram; MT = metric ton; kV = kilovolt Sources: See Appendix C for details, The Climate Registry 2020.
As shown in Tables 3.15-3 through 3.15-6, construction activities are estimated to consume approximately 147,750 gallons of petroleum during the construction phase. By comparison, approximately 89 billion gallons of petroleum would be consumed in California over the course of the Proposed Project’s construction phase based on the California daily petroleum consumption estimate of approximately 78.6 million gallons per day (EIA 2019c). Thus, the total expected petroleum use from the Proposed Project’s construction represents approximately
0.31% of California’s consumption of petroleum over the construction duration. Notably, the Proposed Project would be subject to CARB’s In-Use Off-Road Diesel Vehicle Regulation that applies to certain off-road diesel engines, vehicles, or equipment greater than 25 horsepower.
The regulation: (1) imposes limits on idling, requires a written idling policy, and requires a disclosure when selling vehicles; (2) requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System) and labeled; (3) restricts the adding of older vehicles into fleets starting on January 1, 2014; and (4) requires fleets to reduce their emissions by retiring, replacing, or repowering older engines, or installing Verified Diesel Emission Control Strategies (i.e., exhaust retrofits). The fleet must either show that its fleet average index was less than or equal to the calculated fleet average target rate, or that the fleet has met the Best Achievable Control Technology requirements. Therefore, because the Proposed Project would not be unusual as compared to overall local and regional demand for energy resources and would not involve characteristics that require equipment that would be less energy-efficient than at comparable construction sites in the region or state, Proposed Project construction would not result in wasteful, inefficient, or unnecessary consumption of petroleum and impacts would be less than significant.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-17
Operational Energy Use
Electricity
At full build-out, the Proposed Project’s operational phase would require electricity for operating the residences. CalEEMod default values for electricity consumption for each land use were applied (CAPCOA 2017). The electricity use for residential buildings is calculated in CalEEMod using energy intensity value (electricity use per square foot per year) assumptions, which were based on the RASS (CEC 2010).
The 2019 Title 24 standards were approved and adopted by the CEC in December 2018. The 2019 standards became effective on January 1, 2020. It was assumed that the Proposed Project would comply with the 2019 standards for the purposes of this evaluation; however, if the Proposed Project is approved whatever adopted standards are in place at the time would take precedence. Per the CEC Impact Analysis for the 2019 Update to the California Energy Efficiency Standards for Residential and Non-Residential Buildings, the first-year savings for newly constructed residential buildings, are 596 gigawatt hours of electricity, 50.4 megawatt of demand, and 0.4.42 million therms of gas, representing reductions from the 2016 Title 24 standard of 4%, 15%, and 5%, respectively.
Operational electricity use for the Proposed Project is presented in Table 3.15-7, Estimated Electrical Demand.
Table 3.15-7
Estimated Electrical Demand – Proposed Project Operation Land Use Type1 Estimated Electrical Demand (kWh per year) Accessory Dwelling Units 47,675.90
Single-Family Housing 411,955.00
Multifamily Units 126,011.00
Total 585,641.90
Notes:
1 Land use type was taken from the CalEEMod modeling and represents the closest land use to what is in the Proposed Project. kWh = kilowatt-hour
Source: See Appendix C for details.
As shown in Table 3.15-7, the Proposed Project is estimated to have a total electrical demand of approximately 585,642 kWh per year. By comparison, in 2017, PG&E supplied 82,224 million kWh of electricity to customers while MCE projects approximately 5,275 million kWh of electricity to be consumed (CEC 2018a; MCE 2019). Therefore, the Proposed Project would not result in a wasteful use of energy. Impacts related to operational electricity use would be less than significant.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-18
Natural Gas
Natural gas would be directly consumed throughout operation of the Proposed Project, primarily through building heating and fireplace (only natural gas fireplaces are assumed) options for homes. As described above and consistent with electricity use, the Proposed Project’s natural gas use was estimated using CalEEMod.
Table 3.15-8, Estimated Natural Gas Demand, shows the estimated natural gas use (therms per year) for Proposed Project operation.
Table 3.15-8
Estimated Natural Gas Demand – Project Operation
Land Use Type1 Estimated Natural Gas Demand (therms per year) Accessory Dwelling Units 1,052.14
Single-Family Housing 13,633.90
Multi-Family Units 4,486.15
Total 19,172.19
Note:
1 Land use type was taken from the CalEEMod modeling and represents the closest land use to what is in the Proposed Project.
Source: See Appendix C for details.
As presented in Table 3.15-8, the Proposed Project is estimated to use approximately 19,172 therms of natural gas per year. By comparison, in 2017, PG&E supplied 4,715 million therms of natural gas to customers (CEC 2018c). Therefore, natural gas consumption impacts would be less than significant.
Petroleum
The majority of fuel consumption resulting from the Proposed Project’s operational phase would be attributable to the use of resident, visitor, and delivery motor vehicles traveling to and from the Project site, as well as fuels used for alternative modes of transportation that may be used by residents, visitors, and deliveries.
Calculations for annual mobile-source fuel consumption are provided in Table 3.15-9, Mobile Source Fuel Consumption – Operation.
Table 3.15-9
Mobile Source Fuel Consumption – Proposed Project Operation Fuel Vehicle MT CO2 kg CO2/Gallon Gallons
Gasoline 510.16 8.78 58,104.81
Diesel 39.04 10.21 3,823.75
Total 61,928.56
Notes: CO2 = carbon dioxide; kg = kilogram; MT = metric ton.
Sources: See Appendix C for details (mobile source CO2); The Climate Registry 2020 (kg/CO2/gallon).
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-19
As shown in Table 3.15-8, mobile sources from Proposed Project operation would result in approximately 58,105 gallons of gasoline per year and 3,824 gallons of diesel consumed per year. By comparison, California as a whole consumed approximately 16 billion gallons of petroleum in 2017 (CEC 2018a).
Over the lifetime of the Proposed Project, the fuel efficiency of the vehicles being used by residents and visitors is expected to increase. As such, the amount of petroleum consumed as a result of vehicular trips to and from the Project site during operation would decrease over time.
There are numerous regulations in place that require and encourage increased fuel efficiency.
For example, CARB has adopted an approach to passenger vehicles by combining the control of smog-causing pollutants and GHG emissions into a single, coordinated package of standards. The approach also includes efforts to support and accelerate the numbers of plug-in hybrids and zero-emissions vehicles in California (CARB 2013). Additionally, in response to SB 375, CARB adopted the goal of reducing per-capita GHG emissions from 2005 levels by 10% by 2020, and 19% by 2035 for light-duty passenger vehicles in the planning area for the Association of Bay Area Governments. As such, Proposed Project operation is expected to use decreasing amounts of petroleum over time due to advances in fuel economy.
In summary, although the Proposed Project would increase petroleum use during operation, the use would be a small fraction of the statewide use and due to efficiency increases, diminish over time.
Given these considerations, petroleum consumption associated with the Proposed Project operation would not be considered inefficient or wasteful and impacts would be less than significant.
Mitigation Measures
None required.
3.15-2: Would the Proposed Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? This impact would be less than significant.
The Proposed Project is required to meet Title 24 and California Green Building Standards Code (CALGreen) standards to reduce energy demand and increase energy efficiency.
According to the CEC, single-family homes built under the 2019 standards would use approximately 7% less energy than those built under the 2016 standards. The 2019 standards would also require the installation of rooftop solar for all new homes under three stories in height. With the inclusion of solar, homes would use approximately 53% less energy compared with the 2016 standards (CEC 2018e). In addition, the 2019 standards would include improvements to residential building’s thermal envelope through high performance attics, walls and windows which will reduce energy consumption. Therefore, the Proposed Project would provide opportunities for improved energy efficiency that would support state and local plans for increasing renewable energy efficiency. For the reasons stated, the Proposed Project would not Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-20
conflict with or obstruct a state or local plan for renewable energy or energy efficient, and impacts would be less than significant.
Mitigation Measures
None required
3.15.4 Cumulative Impacts
The cumulative context for energy resources is development that would be allowed under the City’s 1993 General Plan. Potential cumulative impacts on energy would result if the Proposed Project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of energy. This could result from development that would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation.
3.15-3: Would the Proposed Project contribute to an increase in wasteful, inefficient or unnecessary consumption of energy resources during Project construction or operation? The Project’s contribution would not be considerable.
Past, present, and future projects within the areas serviced by the energy service providers could cumulatively increase the use of energy resources. Projects that include development of large buildings or other structures that could have the potential to consume energy in an inefficient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use. Other development projects within the region would result in incremental increases in long-term energy consumption similar to the Proposed Project through the introduction of new population to the region. Each of these projects, however, would be required to comply with local and state regulations for reducing energy consumption and increasing energy efficiency during operation. Nonetheless, the overall increase in demand for energy resources is a potentially significant cumulative impact.
Similar to the Proposed Project, cumulative projects would be subject to CALGreen or stricter local regulations which provides energy efficiency standards for commercial and residential buildings. CALGreen would implement increasingly stringent energy efficiency standards that would require the Proposed Project and the cumulative projects to minimize the wasteful and inefficient use of energy. In addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy. Future development would also be required to meet even more stringent requirements, including the objectives set forth in the AB 32 Scoping Plan (CARB 2017), which would seek to make all Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-21
newly constructed residential homes zero net energy consumers by 2020, and all new commercial buildings Zero-Net-Energy consumers by 2030. Furthermore, various federal and state regulations, including the Low Carbon Fuel Standard, Pavley Clean Car Standards, and Low Emission Vehicle Program, would serve to reduce the transportation fuel demand of cumulative projects.
In summary, with adherence to the increasingly stringent building and vehicle efficiency standards the Proposed Project would reduce energy consumption and would not contribute to a cumulative impact to the wasteful or inefficient use of energy. As such, the Proposed Project would not result in a cumulatively considerable contribution to a potentially significant cumulative impact and the Proposed Project’s contribution is less than considerable resulting in a less-than-significant cumulative impacts.
Mitigation Measures
None required
3.15.5 References
ABAG (Association of Bay Area Governments). 2017. Plan Bay Area 2040. Accessed January 2018. http://2040.planbayarea.org/cdn/farfuture/u_7TKELkH2s3AAiOhCyh 9Q9QlWEZIdYcJzi2QDCZuIs/1510696833/sites/default/files/2017-11/ Final_Plan_Bay_Area_2040.pdf.
CARB (California Air Resources Board). 2011. Facts About the Advanced Clean Cars Program.
Revised November 9, 2011. Accessed April 2018. https://www.arb.ca.gov /msprog/zevprog/factsheets/advanced_clean_cars_eng.pdf.
CARB. 2013. “Clean Car Standards – Pavley, Assembly Bill 1493.” Last reviewed May 6, 2013.
Accessed December 2017. http://arb.ca.gov/cc/ccms/ccms.htm.
CARB. 2017. The 2017 Climate Change Scoping Plan Update: The Proposed Strategy for Achieving California’s 2030 Greenhouse Gas Target. January 20, 2017. Accessed December 2017. https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf.
CEC (California Energy Commission). 2010. 2009 Residential Appliance Saturation Study.
CEC-200-2010-004-ES. Accessed December 2018. https://www.energy.ca.gov/ appliances/rass/previous_rass.html.
CEC. 2018a. “Diesel Fuel Data, Facts, and Statistics.” Accessed March 2019. http://www.energy.ca.gov/almanac/transportation_data/diesel.html.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-22
CEC. 2018b. Electricity Consumption by County. Accessed January 2019. http://ecdms.energy.ca.gov/elecbycounty.aspx.
CEC. 2018c. Natural Gas Consumption by Entity. Accessed January 2019. http://ecdms.energy.ca.gov/gasbyutil.aspx.
CEC. 2018d. Gas Consumption by County. Accessed January 2019. http://ecdms.energy.ca.gov/gasbycounty.aspx.
CEC. 2018e. 2019 Building Energy Efficiency Standards – Frequently Asked Questions. March 2018. Accessed May 2019. https://www.energy.ca.gov/title24/2019standards/ documents/2018_Title_24_2019_Building_Standards_FAQ.pdf.
CEC. 2019. Marin Clean Energy – 2017 Power Content Label. Accessed April 2019. https://www.energy.ca.gov/pcl/labels/2017_labels/MCE_2017_PCL.pdf.
CEC. 2020. “California Energy Almanac.” Accessed January 2020. http://www.energy.ca.gov/ almanac/.
City of St. Helena. 1993. City of St. Helena 1993 General Plan. September 18, 1993.
City of St. Helena. 2018. St. Helena General Plan Update 2040, Draft Environmental Impact Report. SCH# 2010042001. October 23, 2018.
City of St. Helena. 2019. City of St. Helena General Plan Update 2040. June 2019.
CPUC (California Public Utilities Commission). 2013. “California’s Zero Net Energy Policies and Initiatives.” September 18, 2013. http://www.cpuc.ca.gov/WorkArea/ DownloadAsset.aspx?id=10718.
CPUC. 2017. “Natural Gas and California.” January 2017. Accessed April 2018. http://www.cpuc.ca.gov/natural_gas/.
CPUC. 2018. 2018 RPS Annual Report to the Legislature. November 2018. Accessed January 2019. http://www.cpuc.ca.gov/uploadedFiles/CPUC_Public_Website/Content/ Utilities_and_Industries/Energy_-_Electricity_and_Natural_ Gas/Renewables%20Portfolio%20Standard%20Annual%20Report%202018.pdf.
DMV (California Department of Motor Vehicles). 2019. Statistics for Publication, January through December 2018. March 2019. https://www.dmv.ca.gov/portal/wcm/ connect/5aa16cd3-39a5-402f-9453-0d353706cc9a/official.pdf?MOD=AJPERES& amp;CONVERT_TO=url&CACHEID=5aa16cd3-39a5-402f-9453-0d353706cc9a.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-23
EIA (U.S. Energy Information Administration). 2019a. “California Electricity Profile 2016.” EIA, Electricity. Released January 8, 2019. Accessed April 2019. https://www.eia.gov/ electricity/state/california/index.php.
EIA. 2019b. “Natural Gas Consumption By End Use (California, 2017).” EIA, Natural Gas.
Released April 30, 2019.
EIA. 2019c. “California State Profile and Energy Estimates – Table F16: Total Petroleum Consumption Estimates, 2017.” Accessed January 2020. https://www.eia.gov/state /seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_use_pa.html&sid=US&sid=CA.
EPA (U.S. Environmental Protection Agency). 2013. “Renewable Fuel Standard (RFS).” Last updated December 10, 2013. Accessed April 2018. http://www.epa.gov/otaq/ fuels/renewablefuels/.
EPA. 2015. “Overview for Renewable Fuel Standard.” Last updated September 28, 2015.
Accessed April 2018. https://www.epa.gov/renewable-fuel-standard-program/ program-overview-renewable-fuel-standard-program.
MCE (Marin Clean Energy). 2019. 2019 Integrated Resource Plan.
PG&E (Pacific Gas & Electric Company). 2016. Company Profile. Accessed January 2019. https://www.pge.com/en_US/about-pge/company-information/profile/profile.page.
The Climate Registry. 2020. Default Emission Factors. April 2020. Accessed September 2020. https://www.theclimateregistry.org/wp-content/uploads/2020/04/The-Climate-Registry2020-Default-Emission-Factor-Document.pdf.
Agenda Item #6.2.
3.15 – ENERGY
Hunter Subdivision Project EIR 10839
September 2021 3.15-24
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
Hunter Subdivision Project EIR 10839
September 2021 4-1
CHAPTER 4
CEQA CONSIDERATIONS
4.0 INTRODUCTION
Section 15126 of the California Environmental Quality Act (CEQA) Guidelines requires that all aspects of a project must be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. As part of this analysis, the Environmental Impact Report (EIR) must also identify (1) significant environmental effects of the project, (2) significant environmental effects that cannot be avoided if the project is implemented, (3) significant irreversible environmental changes that would result from implementation of the project, (4) growth-inducing impacts of the project, and (5) alternatives to the project (evaluated in Chapter 5, Project Alternatives).
As noted throughout this EIR, the proposed Hunter Subdivision Project (Proposed Project) is requesting approval of a Tentative Subdivision Map. At this time the applicant is not requesting approval of entitlements that would enable development to proceed if the Proposed Project is approved. Subsequent discretionary actions and approvals would be required by the City of St.
Helena (City) in order for development to be permitted.
4.1 SIGNIFICANT ENVIRONMENTAL EFFECTS
Chapter ES, Executive Summary, and Sections 3.1 through 3.15 of this Draft EIR provide a comprehensive identification of the Proposed Project’s potentially significant environmental effects, including the level of significance both before and after mitigation.
4.2 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS
Section 15126.2(b) of the CEQA Guidelines requires that an EIR describe any significant impacts that cannot be avoided, even with the implementation of feasible mitigation measures.
The environmental effects of the Proposed Project on various aspects of the environment are discussed in detail in the technical sections contained in Chapter 3, Environmental Analysis, of this Draft EIR. There are two significant and unavoidable transportation impacts that cannot be avoided if the Proposed Project is approved as described in Section 3.14, Transportation and Circulation. The remainder of Proposed Project impacts can be mitigated to a less-thansignificant level through the adoption of recommended mitigation measures or compliance with existing requirements or laws.
Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-2
4.3 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL IMPACTS
Section 15126.2 (d) of the CEQA Guidelines requires a discussion of any significant irreversible environmental change that would be caused by a project. Generally, a project would result in significant irreversible changes if:
• The primary and secondary impacts would generally commit future generations to similar uses (such as highway improvement that provides access to a previously inaccessible area); • The project would involve a large commitment of nonrenewable resources (CEQA Guidelines Section 15126.2(d));
• The primary and secondary impacts would generally commit future generations to similar uses;
• The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project; • The project would involve a large commitment of nonrenewable resources; or • The proposed consumption of resources is not justified (e.g., the project involves the wasteful use of energy).
Implementation of the Proposed Project would result in the long-term commitment of resources of the Project site to urban land use. Future development of the Project site would likely result in or contribute to the following irreversible environmental changes:
• Conversion of undeveloped land currently partially used as a vineyard. Approximately
16.9 acres of undeveloped land would be converted to urban uses, thus precluding other alternate land uses in the future.
• Irreversible consumption of energy and natural resources associated with the future use of the site.
Development of the Proposed Project would result in the commitment of the Project site to urban development, thereby precluding other uses for the lifespan of the Proposed Project.
Restoration of the site to pre-developed conditions would not be feasible given the degree of disturbance, the urbanization of the area, and the level of capital investment.
Resources that would be permanently and continually consumed by Proposed Project implementation include water, electricity, natural gas, and fossil fuels. Wood products, asphalt, and concrete would be used in construction along with gas and diesel fuel. With respect to operational activities, compliance with all applicable state and local building codes, as well as mitigation measures, planning policies, and standard conservation features, would ensure that resources are conserved to the maximum extent possible. The Proposed Project would Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-3
incorporate a number of sustainable practices that reduce the consumption of energy and water.
Nonetheless, construction activities related to the Proposed Project would result in the irretrievable commitment of nonrenewable energy resources, primarily in the form of fossil fuels, natural gas, and gasoline and diesel for automobiles and construction equipment.
The CEQA Guidelines also require a discussion of the potential for irreversible environmental damage caused by environmental accidents associated with the Proposed Project. While the Proposed Project would result in the use, transport, storage, and disposal of minor amounts of hazardous materials during Proposed Project construction and operation, as described in Section
3.8, Hazards and Hazardous Materials, all such activities would comply with applicable local, state and federal laws related to the use, storage and transport of hazardous materials, which significantly reduces the likelihood and severity of accidents that could result in irreversible environmental damage. The Proposed Project itself does not include any uniquely hazardous uses that would require any special handling or storage. Further, the Proposed Project does not contain any industrial uses that would use or store acutely hazardous materials.
Implementation of the Proposed Project would result in the long-term commitment of resources to urban development. The most notable significant irreversible impacts include the use of nonrenewable and/or slowly renewable natural and energy resources, such as lumber and other forest products and water resources during construction activities. Operations associated with future uses would also consume natural gas and electricity. These irreversible impacts, which are unavoidable consequences of urban growth, are described in detail in the appropriate sections of this Draft EIR (see Chapter 3).
4.4 GROWTH-INDUCING IMPACTS
As required by Section 15126.2(e) of the CEQA Guidelines, an EIR must discuss ways in which a project could foster economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding environment. Also, the EIR must discuss the characteristics of the project that could encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. Growth can be induced in a number of ways, such as through the elimination of obstacles to growth, the stimulation of economic activity within the region, or the establishment of policies or other precedents that directly or indirectly encourage additional growth. Under CEQA, this growth is not to be considered necessarily detrimental, beneficial, or of significant consequence. Induced growth would be considered a significant impact if it can be demonstrated that the potential growth, directly or indirectly, significantly affects the environment.
In general, a project could foster spatial, economic, or population growth in a geographic area if the project removes an impediment to growth (e.g., the establishment of an essential public Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-4
service, the provision of new access to an area, or a change in zoning or General Plan amendment approval), or economic expansion or growth occurs in an area in response to the project (e.g., changes in revenue base, employment expansion). These circumstances are further described below.
• Elimination of Obstacles to Growth: This refers to the extent to which a proposed project removes infrastructure limitations or provides infrastructure capacity (e.g., constructing new roads or extending public utilities), or removes regulatory constraints that could result in growth unforeseen at the time of project approval. • Economic Effects: This refers to the extent to which a proposed project could cause increased activity in the local or regional economy. Economic effects can include such effects as the “multiplier effect.” A “multiplier” is an economic term used to describe interrelationships among various sectors of the economy. The multiplier effect provides a quantitative description of the direct employment effect of a project, as well as indirect and induced employment growth. The multiplier effect acknowledges that the on-site employment and population growth of each project is not the complete picture of growth caused by the project.
Elimination of Obstacles to Growth
The elimination of either physical or regulatory obstacles to growth is considered to be a growthinducing effect, though not necessarily a significant one. A physical obstacle to growth typically involves the lack of public service infrastructure. The extension of public service infrastructure, including roadways, water mains, and sewer lines into areas that are not currently provided with these services would be expected to support new development. Similarly, the elimination or change to a regulatory obstacle, including existing growth and development policies, could result in new growth. Because the Project site is located within the City’s Urban Limit Line and existing services are stubbed to the site, elimination of obstacles to growth is not a factor for this Proposed Project.
Removal of Infrastructure Limitations or Provision of Capacity The elimination of physical obstacles to growth is considered a growth-inducing effect, although not necessarily a significant one.
The physical constraints to growth in the vicinity of the Project site include existing residential development to the south, southwest, west and southeast, which would preclude development immediately to the south, southwest, and southeast of the site, and existing office uses to the west, which would preclude inducing growth to the west of the site. Utility infrastructure is also stubbed to the site so no off-site connections would be required. The connection to existing City Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-5
infrastructure to serve the Project site would not induce growth in this area. Due to the location of the Project site within the City’s Urban Limit Line and access to utilities, the Proposed Project would not eliminate any constraints that are currently obstacles to growth in this portion of the City that would hasten development of this area.
The City’s Residential Growth Management System is no longer enforceable due to the passage of SB 330 (see Gov't Code sec. 66300) otherwise known as the Housing Crisis Act of 2019. This act prevents cities from establishing or implementing any provision that imposes a limit on the number of housing units that can be approved or constructed annually or for some other period. Therefore, the City can no longer limit residential growth to approximately two percent per year (no more than nine building permits for market rate housing could be issued each year), while providing for both market rate and affordable housing units (Municipal Code Chapter 17.152).
Economic Effects
Implementation of the Proposed Project would affect the local economy through the construction of new residences that would require construction workers during the short-term and would encourage people to either relocate or move to the City to take advantage of proximity to local shops, restaurants, and other amenities in nearby downtown.
Additional local employment can be generated through the multiplier effect, as discussed previously in this chapter. The multiplier effect tends to be greater in regions with larger, diverse economies due to a decrease in the requirement to import goods and services from outside the region.
Two different types of additional employment are tracked through the multiplier effect. Indirect employment includes those additional jobs that are generated through the expenditure patterns of direct employment associated with the Proposed Project. Indirect jobs tend to be in relatively close proximity to the places of employment and residence.
The multiplier effect also calculates induced employment. Induced employment follows the economic effect beyond the expenditures of the residents within a project area to include jobs created by the stream of goods and services necessary to support residences within the Project site. When a manufacturer buys or sells products, the employment associated with those inputs or outputs are considered induced employment.
For example, when an employee of the Proposed Project goes out to lunch, the person who serves the employee lunch holds a job that is indirectly related to the Proposed Project. When the server then goes out and spends money in the economy, the jobs generated by this third-tier effect are considered induced employment.
Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-6
The multiplier effect also considers the secondary effect of employee expenditures. Thus, it includes the economic effect of the dollars spent by those employees and residents who support the employees of the Proposed Project.
Increased future employment generated by employee spending ultimately results in physical development of space to accommodate those employees. It is the characteristics of this physical space and its specific location that will determine the type and magnitude of environmental impacts of this additional economic activity. Although the economic effect can be predicted, the actual environmental implications of this type of economic growth are too speculative to predict or evaluate, since they can be spread throughout the City, Napa County, and beyond.
Impacts of Induced Growth
The growth induced directly and indirectly by the Proposed Project could contribute to the environmental impacts, discussed in Chapter 3, in the City and the County, as well as the greater regional area. Any such environmental effects, however, are too diffuse and speculative to predict or describe with any particularity.
Indirect and induced population growth in the City would further contribute to the loss of open space because it would encourage the conversion of undeveloped land to urban uses for additional housing and infrastructure. However, it is assumed this new growth would occur within areas of the City designated and zoned for development or planned for potential future urban development. The City has designated areas for future development in order to protect areas of active agriculture, also within the incorporated City but outside of the Urban Limit Line.
Again, however, the particular open space that might get converted cannot be predicted with any certainty, all such conversions to urban land use would occur within areas planned for growth designated in the City’s General Plan. Development of the property to the north of the Project site is outside of the City’s Urban Limit Line and would require a general plan amendment and compliance with CEQA to evaluate potential impacts.
In summary, although the Proposed Project can be said to induce growth, the consequences of such growth-inducement are too speculative to meaningfully predict and, furthermore, due to the designation of the Project site for future residential development in the City’s 1993 General Plan and 2019 General Plan1, implementation of the Proposed Project would not be considered growth inducing. Growth-inducing effects are therefore considered less than significant. 1 Also known as the “St Helena General Plan Update 2040,” the 2019 is referred to in this EIR by the year of its adoption.
Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-7
4.5 ENERGY USAGE
Measures intended to reduce unnecessary or inefficient use of resources or energy consumption are incorporated into the Title 24 and CALGreen standards, which the Proposed Project would be required to comply with. Implementation of the Proposed Project would result in the commitment of limited, renewable resources such as lumber and water. In addition, development allowed under both the 1993 General Plan and the 2019 General Plan would irretrievably commit nonrenewable resources for the construction and maintenance of buildings, infrastructure, and roadways. These non-renewable resources include mined materials such as sand, gravel, steel, copper, and other metals. The City recognized that buildout of the General Plan also represents a long-term commitment to the consumption of fossil fuels, natural gas, diesel and gasoline. Increased energy demands would be used for construction, lighting, heating, and cooling of residences, and transportation of people within, to, and from the Project site. The Proposed Project’s energy requirements are analyzed in Section 3.15 of this Draft EIR.
The analysis determined that the Proposed Project’s use of energy resources, including electricity, natural gas, and petroleum, would not be wasteful, inefficient or unnecessary during Proposed Project construction or operation. Please see Section 3.15, Energy, for more information on energy demands of the Proposed Project.
4.6 CUMULATIVE IMPACTS
CEQA requires that an EIR contain an assessment of the cumulative impacts that could be associated with the Proposed Project. This assessment involves examining Proposed-Projectrelated effects on the environment in the context of similar effects that have been caused by past or existing projects, and the anticipated effects of future projects. As indicated in the CEQA Guidelines, the discussion of cumulative impacts need not provide the same level of detail as Proposed-Project-related impacts. The discussion should be guided by “standards of practicality and reasonableness” (CEQA Guidelines, Section 15130(b)). Although project-related impacts can be individually minor, the cumulative effects of these impacts, in combination with the impacts of other projects, could be significant under CEQA and must be addressed (14 CCR Section 15130(a)). Where a lead agency concludes that the cumulative effects of a project, taken together with the impacts of other closely related past, present, and reasonably foreseeable probable future projects are significant, the lead agency then must determine whether the project’s incremental contribution to such significant cumulative impact is “cumulatively considerable” (and thus significant in and of itself).
Cumulative Context
To ensure an adequate discussion of cumulative impacts is included in an EIR, CEQA allows the lead agency to use either a list of past, present, and probable future projects (including Agenda Item #6.2.
4 – CEQA CONSIDERATIONS
Hunter Subdivision Project EIR 10839
September 2021 4-8
those projects outside of the control of the lead agency), or projections included in an adopted local, regional, or statewide plan like a general plan (CEQA Guidelines, Section 15130(b)(1)).
The general cumulative impact context for evaluating cumulative impacts for the majority of the technical issue areas evaluated in Chapter 3 of this Draft EIR considers buildout of the City’s 1993 General Plan because this General Plan was in effect when the Proposed Project application was deemed complete in September 2011, or evaluates the potential loss of resources on a much broader, regional scale. The cumulative impact analyses in this Draft EIR thus do not rely on any list of specific pending, or reasonably foreseeable development proposals in the general vicinity of the Project site or within the City. The City updated the General Plan in 2019. However, 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 2019 General Plan for informational purposes and the cumulative analysis will note any changes, if relevant between buildout assumptions under the 1993 General Plan as compared to the 2019 General Plan.
It is important to note that the basis of the cumulative analysis varies by technical area. For example, traffic and traffic-related air emissions and noise analyses assume development that is planned and/or anticipated in the City, as well as the surrounding unincorporated area, because each contributes to traffic on local and regional roadways that is quantifiable. Operational air quality impacts are evaluated against conditions in the City and surrounding areas within the San Francisco Bay Area Air Basin. The technical sections in Chapter 3 evaluate the Proposed Project’s cumulative impacts at the end of the impact analysis. The cumulative analysis in each of the technical sections evaluates the Proposed Project’s contribution to the cumulative scenario to determine if the Proposed Project’s contribution to an existing significant cumulative impact would be considerable resulting in an impact. A description of the cumulative context for each issue area evaluated is included in the cumulative impacts at the end of each technical section of Chapter 3.
Agenda Item #6.2.
Hunter Subdivision Project EIR 10839
September 2021 5-1
CHAPTER 5
PROJECT ALTERNATIVES
5.0 INTRODUCTION
The purpose of the alternatives evaluation in an Environmental Impact Report (EIR), as stated in Section 15126.6(c) of the California Environmental Quality Act (CEQA) Guidelines, is to ensure that “[t]he range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects” identified under the proposed project.
Pursuant to CEQA Guidelines, Section 15126.6, alternatives to the proposed Hunter Subdivision Project (Proposed Project) are presented in this Draft EIR to provide the public, public agencies and decision makers with a range of possible alternatives to the Proposed Project to consider. The CEQA Guidelines state that an EIR shall describe a reasonable range of alternatives that would avoid or substantially lessen any significant effects of the project but need not consider every conceivable alternative. The CEQA Guidelines further state that “the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly” (CEQA Guidelines, Section 15126.6(b)). Therefore, an EIR must describe a range of reasonable alternatives to the proposed project (or to its location) that could feasibly attain most of the basic objectives of the project. The feasibility of an alternative may be determined based on a variety of factors, including, but not limited to, site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and site accessibility and control (CEQA Guidelines, Section 15126.6(f)(1)).
Alternatives in an EIR must be potentially feasible (CEQA Guidelines, Section 15126.6(a)). Agency decision makers ultimately decide what is “actually feasible.” (California Native Plant Society v. City of Santa Cruz (2009) 177 Cal. App. 4th 957, 981 (CNPS).) Under CEQA, “feasible” is defined as capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors (CEQA Guidelines, Section 15364). The concept of “feasibility” also encompasses the question of whether a particular alternative or mitigation measure promotes the underlying goals and objectives of a project. (Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, 1506-1509; CNPS, supra, 177 Cal. App. 4th at p. 1001; In re Bay-Delta Programmatic Environmental Impact Report Coordinated Proceedings (2008) 43 Cal.4th 1143, 1165, 1166.) Moreover, “‘feasibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, legal, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417.)
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-2
An EIR need not evaluate the environmental effects of alternatives in the same level of detail as the proposed project, but must include enough information to allow meaningful evaluation, analysis, and comparison with the proposed project. The alternatives discussion is intended to focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives as listed in Chapter 2, Project Description, and in this chapter of this Draft EIR.
The lead agency’s decision-making body, in this case the St. Helena City Council, has the discretion to select a Proposed Project alternative in lieu of the Proposed Project. If this were to occur, the City Council would need to ensure that the level of detail included in the alternatives analysis is adequate and that there would not be any new or significant impacts as a result of selecting the alternative. The required Findings of Fact and Mitigation Monitoring Plan (MMP) would need to be prepared that identifies the alternative as the project selected for approval. It is anticipated that if one of the Proposed Project alternatives is selected, the mitigation measures identified for the Proposed Project would not change and would still be required and, depending on the alternative selected, may require additional mitigation measures where impacts are more severe than the Proposed Project.
This chapter identifies the Proposed Project objectives, describes the Proposed Project alternatives, and evaluates the comparative effects of the alternatives relative to the Proposed Project. As required under Section 15126.6(e) of the CEQA Guidelines, the environmentally superior alternative is identified and included at the end of this chapter.
Significant and Unavoidable Impacts
The Proposed Project would result in the following significant and unavoidable transportation impacts. There is no feasible mitigation available to reduce these impacts to less than significant. • The Proposed Project would generate an increase in project-specific vehicle miles traveled (VMT) that would exceed the Office of Planning and Research’s (OPRs) threshold of 15% below that of existing development.
• Under cumulative conditions the Proposed Project would generate an increase in VMT that would exceed the threshold.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-3
Project Objectives
Pursuant to CEQA Guidelines, Section 15124(b), a clear statement of project objectives is required. The Proposed Project includes the following project objectives:
• Subdivide the site consistent with the City’s General Plan and Zoning for the site to accommodate residential development.
• Provide opportunities to develop a variety of housing types, including multi-family, singlefamily, and accessory dwelling units, affordable to a range of incomes including, very low, low and moderate-income households.
• Provide opportunities to contribute to the provision of workforce and affordable housing consistent with the City’s adopted Housing Element and the Regional Housing Needs Assessment (RHNA) approved by the Association of Bay Area Governments (ABAG). • Minimize traffic-related environmental impacts, such as noise, air quality and greenhouse gases by lowering commute patterns for St. Helena workers by providing more local housing opportunities.
• Support alternative transportation by providing a pedestrian and bicycle linkages through St.
Helena, eventually connecting the regional Vine Trail from Calistoga to the Vallejo Ferry. • Exceed the City’s green building ordinance (Municipal Code Chapter 15.53) and incorporate sustainable design features including water conservation measures, drought resistant landscaping with low flow watering systems, south and west side tree placement to reduce reliance on air conditioning units, and pre-wiring for photovoltaic systems. • Implement the General Plan Circulation Element by completing the planned extension of Starr Avenue and the partial planned extension of Adams Street from where Adams Street terminates to connect to the Project site.
• Minimize City water use by continuing the use of an existing on-site water well for irrigation of Project landscaped areas.
Alternatives Considered but Dismissed from Further Consideration As noted previously, the purpose of an alternatives analysis is to develop alternatives to the Proposed Project that substantially lessen at least one of the significant environmental effects identified as a result of the Project, while still meeting most, if not all, of the basic Proposed Project objectives. Proposed Project alternatives that would lessen the severity of some of the impacts identified under the Proposed Project are addressed later in this chapter.
One of the requirements for an alternatives analysis that is set forth in the CEQA Guidelines is identification of alternatives that were considered by the lead agency but rejected as infeasible Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-4
during the scoping process. As stated in Section 15126.6(c) of the CEQA Guidelines, the EIR should briefly explain the reasons underlying this determination. Among the factors that may be used to eliminate alternatives from detailed consideration in the EIR are:
(i) Failure to meet most of the basic project objectives, (ii) Infeasibility, or
(iii) Inability to avoid significant environmental impacts (CEQA Guidelines Section 15126.6(c))
Section 15126.6(f)(1) of the CEQA Guidelines states that, “among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the applicant can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent).” However, as stated in this subsection, no single factor establishes a fixed limit on the scope of reasonable alternatives.
An alternate site or off-site alternative was determined to be infeasible for the Proposed Project because the Project applicant owns the Project site and it would not be feasible to acquire, control or otherwise have access to a new property within the City large enough to accommodate the Proposed Project. Therefore, an off-site or alternate Proposed Project location was dismissed from further evaluation.
A reduced density alternative was considered but dismissed because it does not avoid or reduce any potentially significant impacts and would not avoid any health and safety concerns required for the City to make findings under Section 15041 of the CEQA Guidelines and Government Code Section 65589.5(j).
Lastly, a mixed-use alternative that includes commercial uses in addition to residential was also considered and dismissed because it would not be consistent with the underlying land use designation and zoning and would require a General Plan Amendment and rezone. Therefore, this alternative was considered but ultimately dismissed from further review.
5.1 ALTERNATIVES CONSIDERED IN THIS EIR
This section provides a description of the alternatives to the Proposed Project analyzed in this Draft EIR and evaluates how specific impacts differ in severity from those associated with the Proposed Project. For purposes of this analysis, the potentially significant impacts identified under the alternatives analysis are assumed to be fully mitigated through compliance with mitigation measures identified in the Executive Summary chapter in Table ES-1 and in Sections Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-5
3.1 through 3.15 included in Chapter 3, which contains the environmental analysis of the Proposed Project.
The Proposed Project alternatives identified herein address the significant construction-related and operational impacts (before mitigation) identified for the Proposed Project including aesthetics/visual resources, biological resources, cultural resources, geology and soils, noise and vibration, and traffic and circulation. Thus, the alternatives developed for the Proposed Project contemplate a change in land uses to address these impacts. In many instances, the impacts are virtually identical to the Proposed Project and are described as such.
This Draft EIR has incorporated a reasonable range of Proposed Project alternatives that, collectively, attain a majority of the Proposed Project objectives in a reasonable manner while reducing the severity of the significant impacts (before mitigation) identified under the Proposed Project.
CEQA Guidelines Section 15126.6(e) requires that an EIR include an alternative that describes what would reasonably be expected to occur on the property in the foreseeable future if the Proposed Project were not approved, based on current plans and consistent with available infrastructure and community services (i.e., “No Project” alternative). For projects other than a land use plan (for example, a development project on an identifiable property), the “No Project” alternative is considered to be a circumstance under which the project does not proceed. (CEQA Guidelines Section 15126.6(e)(3)(A-B)). “If disapproval of the project under consideration would result in predictable actions by others, such as the proposal of some other project, this ‘no project’ consequence should be discussed. … [W]here failure to proceed with the project will not result in preservation of existing environmental conditions, the analysis should identify the practical result of the project’s non-approval and not create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment.” Because the Proposed Project is on land that is designated and zoned for housing, it would be artificial to assume that the Project site’s existing physical environment would be preserved by rejection of the Proposed Project. Therefore, this EIR includes two “No Project” alternative analyses: (1) the scenario where the Project does not proceed and the Project site remains in its existing undeveloped condition is evaluated as the “No Project/No Development Alternative,” and (2) the potential scenario where the Project site is used and developed in accordance with the City’s existing land use plans (2019 General Plan) is evaluated as the “No Project/General Plan Alternative.”
The alternatives to the Proposed Project analyzed in this Draft EIR are as follows:
• Alternative 1: No Project/No Development
• Alternative 2: No Project/General Plan
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-6
• Alternative 3: Park/Open Space Preserve
• Alternative 4: Increased Density/Affordable Housing
Alternative 1: No Project/No Development Alternative
Description
The No Project/No Development Alternative considers the effects of forgoing the Project entirely and leaving the Project site in its current undeveloped condition. Under the No Project/No Development Alternative, the Proposed Project would not be approved or constructed. Under this alternative, the Project site would retain its current land use designation and zoning consistent with both the 1993 General Plan and the City’s current 2019 General Plan. The No Project/No Development Alternative allows decision-makers to compare the impacts of the Proposed Project to retaining the existing condition of the site. The No Project/No Development Alternative describes the environmental conditions that exist at the time that the environmental analysis commenced (CEQA Guidelines, Section 15126.6 (e)(2)).
This alternative would not meet the City's General Plan policies or Project objectives, or state policies of promoting development of new housing, including affordable housing. For policy reasons, and because the No Project/No Development Alternative would fail to meet any of the basic objectives of the Project or of the City's General Plan, this alternative could be rejected in favor of the Proposed Project.
Comparative Analysis of Environmental Effects
The No Project/No Development Alternative would produce no changes on the Project site, because the site would remain in its current undeveloped condition, effectively eliminating the Project impacts discussed in this Draft EIR.
There would be no change to visual conditions at the site, so no mitigation would be required related to spillover light. There would be no air emissions associated with Project construction and operation and there would be no increase of any emissions, including ozone, PM2.5, or PM10, which are designated nonattainment in the San Francisco Bay Area Air Basin (SFBAAB), that could substantially contribute to a potential violation of applicable air quality standards or to nonattainment conditions. There would be no increase in greenhouse gases (GHG), energy, or demand for public service or utilities. There would be no land disturbance so there would be no impacts to biological, cultural, or geological resources, or any impacts related to hazardous materials, so no mitigation would be required. Additionally, there would be no changes in ambient noise levels associated with Project construction and operation.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-7
Lastly, there would be no increase in the number of vehicles accessing the site and on area roadways and intersections. Thus, there would be no impact associated with the Project’s increase in VMT.
Ability to Meet Proposed Project Objectives
The No Project/No Development Alternative would not achieve any of the Project objectives because development would not occur.
Alternative 2: No Project/General Plan Alternative
Description
Under this alternative, it is assumed the Project would be developed consistent with the underlying MDR land use designation and MR zoning which allows development of the Project site with residential uses up to a maximum density of 12 dwelling units/acre (du/ac) under the 1993 General Plan MDR designation which was revised to 16 du/ac under the 2019 General Plan consistent with the MR zoning, which permits a maximum density of 16 du/ac. For the purposes of this alternative a density of 9 du/ac was assumed for a total of 152 single-family residential units. Based on the number of units this alternative would result in a population of 372 residents, an increase of 159 residents as compared to the Project. It is assumed Starr Avenue and Adams Street would both be extended to connect to the Project site and the street and lot layout would be very similar to the Project with the exception of the 3.4-acre portion of the site currently designated for multifamily units (Lot 52). This portion of the Project site would be configured to accommodate single-family residences.
Comparative Analysis of Environmental Effects
Due to the denser development and increased number of residential units, it is anticipated that impacts associated with air quality, greenhouse gases, energy, public utilities, population and housing, and noise would be increased. It is anticipated the same mitigation measures for impacts to nesting birds and bats (biological) and the potential to unearth any previously unknown historic, archeological, or paleontological resource (cultural, geology and soils), potential soil contamination from agricultural chemical residues (hazards), and noise from construction equipment would be still be required. The potential impacts are compared below.
Impacts Identified as Being the Same or Similar to the Proposed Project Under this alternative, impacts to the loss of agricultural land would remain less than significant, the same as the Proposed Project because the entire site would be developed. There would be Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-8
an increase in lights, the same as the Proposed Project, so mitigation would be required to address spillover light (AES-1).
Biological impacts related to special-status species, riparian habitat, sensitive natural communities, migratory wildlife corridors, wildlife nursery sites, tree preservation policies, and any other conservation plans would remain the same as the Proposed Project. This alternative would still require implementation of Mitigation Measures BIO-1 through BIO-3 to minimize impacts to bats and nesting birds and erosion impacts. This alternative would also still require development over the existing seasonal wetlands in order to accommodate single-family development. Thus, impacts to the seasonal wetlands would total 0.7 acres, the same as the Proposed Project.
Cultural and geological impacts would be similar to the Proposed Project. Ground disturbance would be performed in the same development area and mitigation would still be required to ensure that any historical, archaeological, and paleontological impacts are less than significant (Mitigation Measures CUL-1 and GEO-2). A design-level geotechnical report would also be required, per Mitigation Measure GEO-1 to ensure the homes are constructed consistent with any site-specific grading or foundation recommendations.
Because this alternative would still involve disturbance of site soils, soils testing for agricultural chemicals of concern would still be required as a condition of approval for construction and grading permits. Mitigation would still be required (Mitigation Measure HAZ-1) to ensure potential impacts would be less than significant.
It is assumed Starr Avenue and Adams Street would both be extended to connect to the Project site and the street and lot layout would be very similar to the Proposed Project with the exception of the 3.4-acre portion of the site currently designated for multifamily units. Internal roadways would be similar and still be designed consistent with all applicable City street design criteria and impacts would remain less than significant.
Impacts Identified as Being Less Severe than the Proposed Project No impacts were identified as being less severe than the Proposed Project.
Impacts Identified as Being More Severe than the Proposed Project The No Project/General Plan Alternative would include 152 single-family residential units and no multifamily units. This alternative would result in a population of 372 residents, an increase of 159 residents as compared to the Proposed Project. While air quality impacts would be slightly more severe, they would still be less than significant and would not require any mitigation. This would be the same for greenhouse gas emissions impacts and energy impacts.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-9
Noise from construction equipment would be greater from the Proposed Project due to the increased amount of development and the nature of construction of single-family residences.
Construction equipment would still need to be equipped with suitable exhaust and intake silencers, and stationary construction equipment would need to be located away from adjacent residential property boundaries as is practical, in accordance with Mitigation Measure NOI-1.
This would ensure that noise impacts related to construction would still be less than significant.
Noise impacts from operation as well as vehicle trips would also be slightly greater but would not be substantial enough to constitute significant impacts.
The increase in 159 residents would also increase the demand for water supply, wastewater conveyance and treatment, schools, and solid waste disposal. However, the increase in severity would not be great enough to constitute significant impacts. These impacts are described in further detail below.
For the Proposed Project, the water demand for single-family residences assumes eight persons per home, based on the City’s demand factor of four bedrooms and two persons per bedroom for the market rate homes and two bedrooms for the affordable housing units, based on the Preliminary Water Calculations prepared for the Proposed Project (see Appendix J). The projected residential water demand for this alternative is shown in Table 5-1 below. With the City’s demand factor assumption of eight occupants per single-family residence, the water demand calculation assumes this alternative would result in a total anticipated water demand of approximately 47.6 acre-feet (AF) per year. Water demand is expected to increase, but the same as the Proposed Project any development is required to offset its increase in water in compliance with the City’s Water Neutral Ordinance. The same as the Proposed Project, all units would be designed to include efficient and lower-water-using fixtures and appliances and irrigation systems consistent with Green Building Standards Code (CAL Green Code) that requires the installation of water-efficient indoor infrastructure to conserve water. The landscape irrigation demand under this alternative would comply with the City’s Model Water Efficient Landscape Ordinance (MWELO) as well. In addition, irrigation of public landscaping would be offset through planting of drought tolerant plants, water conservation measures, and use of the on-site well, the same as the Proposed Project.
Table 5-1
Alternative 2: No Project/General Plan Alternative Residential Water Demand Fixture
Flow Rate
gal/min or
gal/flush
Flow Duration
(min., flush,
load, etc)
Daily Uses
per
Occupant
Number of
Occupants1
Gallons per
Day
Acre-feet Per
Year
Showerheads 2 8 1 1,216 19,456 21.79
Sink Faucets 1.5 0.25 3 1,216 1,368 1.53
Kitchen Faucet 1.5 4 1 1,216 7,296 8.17
Toilet 1.3 1 3 1,216 4,742.4 5.31
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-10
Table 5-1
Alternative 2: No Project/General Plan Alternative Residential Water Demand Fixture
Flow Rate
gal/min or
gal/flush
Flow Duration
(min., flush,
load, etc)
Daily Uses
per
Occupant
Number of
Occupants1
Gallons per
Day
Acre-feet Per
Year
Clothes Washer 19.7 1 0.37 1,216 8,863.424 9.93
Dish Washer 6.3 1 0.1 1,216 766.08 0.86
Total Water Demand 42,491.9 47.59
Note:
1 For the purposes of determining the Proposed Project’s water demand, the City’s demand factor is based on the number of bedrooms and persons per bedroom, which differs from the City’s persons per household (PPH) to determine the number of residents a residential project would generate, which is 2.45 PPH.
Source: Appendix J.
The water demand of 47.6 AF per year would also translate to 47.6 AF per year of wastewater demand, also expected to be higher than the Proposed Project but would not require mitigation.
This alternative is also expected to result in a slight increase in solid waste generation (see Table 5-2). The solid waste generation rates used for the Proposed Project are based on the U.S. Environmental Protection Agency (EPA) estimate of 0.0033 tons/day/dwelling unit for multifamily residential homes. This would result in a solid waste generation estimate of 0.234 tons per day, 0.277 tons greater than the Proposed Project’s estimate. However, the amount of solid waste generated during operation would still be much less than the unused daily capacity of the Clover Flat landfill (425 tons per day), and therefore would not exceed the capacity of the landfill. The impact would remain less than significant and would not require mitigation.
Table 5-2
Alternative 2: No Project/No Action Alternative Projected Solid Waste Generation Land Use
Generation Rate
(tons/day/unit)
Waste Disposed
(tons per day)
152 Single-family Residential Units 0.0033 0.502
Total 0.502
Source: CalRecycle 2018.
Table 5-3 considers the increase in school-age children attending primary, elementary, middle and high schools. Student generation rates were derived from the SHUSD Facility Master Plan, which outlines expected growth in demand for school facilities associated with projected development and plans how to fund and respond to such growth. This alternative is expected to generate approximately 35 students in total, an increase of 7 students compared to the Proposed Project. This increase would not exceed the current capacity of schools within the SHUSD, and development under this alternative would still be required to pay the necessary school impact fees.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-11
Table 5-3
Alternative 2: No Project/No Action Alternative Student Generation Grades
Student Generation Rate
(per total number of units) Students Generated
K-2 0.058 8.816
3-5 0.080 12.16
6-8 0.088 13.38
9-12 0.088 15.84
Total 57
Source: SHUSD 2010.
Because of the increased number of residential units, the Project’s VMT would be greater than the Proposed Project and the impact would remain significant and unavoidable.
Ability to Meet Proposed Project Objectives
The No Project/General Plan Alternative would develop the site consistent with the underlying land use designation and zoning assuming ag a density of 9 du/ac and would complete the planned extensions of Adams Street and Starr Avenue. However, this alternative would not achieve the Proposed Project objective of developing a variety of housing types, including multifamily housing and ADUs. Housing would be less affordable to a range of incomes since development would be limited to single-family homes. This alternative would not minimize traffic-related environmental impacts due to the increase in units and residents. Overall, this alternative would not meet most of the Proposed Project objectives.
Alternative 3: Park/Open Space Preserve Alternative
Description
The Park Preserve/Open Space Alternative includes an approximately 1-acre park/open space that would preserve a majority of the on-site wetlands to help lessen impacts to seasonal wetlands (Impact 3.4-2), as shown on Figure 5-1, Park Preserve Alternative. To accommodate the park three lots would need to be removed (Lots 44, 45, 46) and vegetated swales to capture runoff would be located adjacent to developed areas. It is anticipated the park would be landscaped with native plants and may include a small tot lot or be left as passive open space.
The remaining approximately 16-acres would be developed with approximately the same number of residential units as the Proposed Project and would maintain a density of 5.1 du/ac.
The single-family lots would be slightly smaller than the Proposed Project and there could be an increase in the number of multifamily units. Site access and internal roads would essentially be the same as the Proposed Project. The same number of residents, 213, is conservatively assumed under this alternative, the same as the Proposed Project.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-12
Comparative Analysis of Environmental Effects
Disturbance to the Project site to accommodate development would be slightly less as compared to the Proposed Project. Even though this alternative would result in a slightly smaller development footprint, it is anticipated construction-related impacts associated with potential impacts to biological, cultural, geological resources, hazardous materials, and noise would essentially remain the same as the Proposed Project, less-than-significant with mitigation. It is anticipated the same mitigation measures for impacts to nesting birds (biological) and the potential to unearth any previously unknown historic, archeological, or paleontological resource (cultural, geology and soils), and potential soil contamination from agricultural chemical residues (hazards) would be still be required. While there would still be impacts to two seasonal wetlands (0.006 of an acre), this alternative would minimize impacts to the 0.065 acre of seasonal wetlands at the site. The potential impacts are compared below.
Impacts Identified as Being the Same or Similar to the Proposed Project The change in visual quality would be the same as the Proposed Project and the impact would remain less than significant. There would be an increase in lights, the same as the Proposed Project, so mitigation would be required to address spillover light (AES-1). Under this alternative, impacts to the loss of agricultural land would also remain less than significant.
Biological impacts related to special-status species, riparian habitat, sensitive natural communities, migratory wildlife corridors, wildlife nursery sites, tree preservation policies, and any other conservation plans would remain the same as the Proposed Project. This alternative would still require implementation of Mitigation Measures BIO-1 through BIO-3 to minimize impacts to bats and nesting birds and erosion impacts. Impacts related to jurisdictional wetlands are described further below, under “Impacts Identified as Being Less Severe than the Proposed Project.” Cultural and geological impacts would be similar to the Proposed Project. The extent of grounddisturbance would be similar, albeit slightly less, and mitigation would still be required to ensure that any historical, archaeological, and paleontological impacts are less than significant (Mitigation Measures CUL-1 and GEO-2). A design-level geotechnical report would also be required, per Mitigation Measure GEO-1 to ensure the homes are constructed consistent with any site-specific grading or foundation recommendations.
Because this alternative would still involve disturbance of site soils, soils testing for agricultural chemicals of concern would still be required as a condition of approval for construction and grading permits. Mitigation would still be required (Mitigation Measure HAZ-1) to ensure potential impacts would be less than significant.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-13
Noise from construction equipment would likely be similar to the Proposed Project. Construction equipment would still need to be equipped with suitable exhaust and intake silencers, and stationary construction equipment would need to be located away from adjacent residential property boundaries as is practical, in accordance with Mitigation Measure NOI-1. This would ensure that noise impacts would still be less than significant.
Under this alternative, impacts associated with air and GHG emissions due to construction and operation and increase in demand for public services, utilities and energy would remain less than significant, the same as the Proposed Project.
The potable water and landscape irrigation demand under this alternative would be very similar to the Proposed Project and would comply with the City’s MWELO and Water Neutrality Ordinance and would be required to off-set the increase in water demand. Water and wastewater impacts would be less than significant, the same as the Proposed Project.
Because the same number of units would be developed the impact to VMT would remain the same as the Proposed Project, significant and unavoidable. Internal roadways would remain the same and still be designed consistent with all applicable City street design criteria and impacts would remain less than significant.
Impacts Identified as Being Less Severe than the Proposed Project The Project site currently supports four seasonal wetlands for 0.07 acre and two agricultural ditches, as shown on Figure 3.4-2 in Section 3.4, Biological Resources. These features are anticipated to meet the criteria for jurisdictional waters of the United States.
With implementation of this alternative, the impact to seasonal wetlands would be less severe than the Proposed Project. The Park Preserve/Open Space Alternative includes an approximately 1-acre park that would preserve two of the larger wetland features to help reduce Impact 3.4-2. The area of impacted wetlands would be reduced to .006 acres rather than 0.07 acres from the Proposed Project. In order to ensure viability of the wetlands, vegetated swales would be located between the park and any developed uses. The swales would capture runoff from adjacent developed areas in order to maintain the water quality of the wetlands.
Impacts Identified as Being More Severe than the Proposed Project No impacts were identified as being more severe than the Proposed Project.
Relationship to Proposed Project Objectives
The Park Preserve/Open Space Alternative would still manage to achieve all stated Proposed Project objectives. The main changes from this alternative would be a small decrease in the residential footprint and the avoidance of seasonal wetlands at the Project site. This alternative Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-14
would still subdivide the site consistent with the underlying land use designation and zoning, complete the planned extensions of Adams Street and Starr Avenue, provide a variety of housing types, including affordable housing, and provide more local housing opportunities.
Alternative 4: Increased Density/Affordable Housing Alternative Description
The Increased Density/Affordable Housing Alternative includes the approximately 1-acre park to preserve a majority of the on-site seasonal wetlands with the remaining approximately 16-acres designated for up to 180 affordable housing units, assuming a density of 11.3 dwelling units per acre (du/ac) under the existing Medium Density Residential (MDR) land use designation (current zoning allows for a maximum density of 16.0 du/ac). The units would be attached housing (duplex or triplex) and would be 100% affordable. It is assumed buildings would be no taller than 30-feet, consistent with the underlying MR zoning. Under the technical guidance issued by the Office of Planning and Research, a 100% affordable housing project is exempt from the requirement to calculate VMT. Site access and internal roads would essentially be the same as the Proposed Project. Using the City’s persons per household factor of 2.45 people per unit for medium/higher density residential land uses this alternative would generate 441 residents, an increase of 194 residents as compared to the Proposed Project.
Comparative Analysis of Environmental Effects
The Proposed Project includes a Tentative Subdivision Map to create 51 market-rate singlefamily residences (with ADUs on 11 of these lots) and 25 attached multifamily units. The Increased Density/Affordable Housing Alternative would increase the density from 5.1 du/ac to a density of 11.3 du/ac. All units would be attached housing (duplex or triplex) and would be 100% affordable. Due to the increase in residents, it is anticipated the increase in air pollutants and GHG emissions associated with operation would be slightly higher than the Proposed Project due to the increase in vehicle trips, as well as the demand for water supply, wastewater conveyance and treatment, schools, solid waste disposal, and energy. Construction and footprint-related impacts associated with biological, cultural, and geological resources, hazardous materials, and noise would essentially be the same as the Proposed Project, as these impacts would be less-than-significant with mitigation. It is anticipated the same mitigation measures for impacts to bats, and nesting birds (biological) and the potential to unearth any previously unknown historic, archeological, or paleontological resource (cultural, geology and soils), and potential soil contamination from agricultural chemical residues (hazards) would be still be required. This alternative would minimize impacts to on-site seasonal wetlands with inclusion of the 1-acre park, similar to the Park Preserve/Open Space Alternative. The potential impacts are compared below.
Agenda Item #6.2.
Date: 3/15/2021 - Last saved by: tfriesen - Path: Z:\Projects\j1083901\MAPDOC\PD\Figure5-1_ParkPreserveAlternative.mxd Construction Road
DEL RIO CT
PASEO GRAND
HUNT AVE
STARR AVE
HARVEST LN
S AVE
MONTE VISTA AVE
GROVE CT
SAN JUAN CT
DEL RIO CT
LTON
MEADOWCREEK CIR
MAINTENANCE RD/PUBLIC TRAIL
Park Preserve Alternative
Hunter Subdivision Project
SOURCE: USDA 2016, USGS 2018, Napa County 2015
0 125 250Feet
Project Boundary
Park Preserve Alternative (0.6 acre)
FIGURE 5-1
Detention
Basin
Vineyard Valley
Mobile Home
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-16
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-17
Impacts Identified as Being the Same or Similar to the Proposed Project Under this alternative, impacts to the loss of agricultural land would remain less than significant, the same as the Proposed Project. The change in visual quality would be greater than the Proposed Project but essentially the impact would remain less than significant. The increase in lighting associated with development would also be the same as the Proposed Project and would require mitigation (AES-1).
Biological impacts related to special-status species, riparian habitat, sensitive natural communities, migratory wildlife corridors, wildlife nursery sites, tree preservation policies, and any other conservation plans would remain the same as the Proposed Project. This alternative would still require implementation of Mitigation Measures BIO-1 through BIO-3 to minimize impacts to bats and nesting birds and erosion impacts. Impacts related to jurisdictional wetlands are described further below, under “Impacts Identified as Being Less Severe than the Proposed Project.” Cultural and geological impacts would be similar to the Proposed Project. While the extent of ground disturbance may differ due to construction of more duplex/triplex housing essentially the same area of disturbance would occur and mitigation would still be required to ensure that any historical, archaeological, and paleontological impacts are less than significant (Mitigation Measures CUL-1 and GEO-2). A design-level geotechnical report would also be required, per Mitigation Measure GEO-1 to ensure the homes are constructed consistent with any sitespecific grading or foundation recommendations.
Under this alternative, the Project would still be required to perform soils testing for agricultural chemicals of concern as a condition of approval for construction and grading permits for the Project site. Mitigation would still be required (Mitigation Measure HAZ-1) to ensure potential impacts would be less than significant.
Impacts Identified as Being Less Severe than the Proposed Project The impact to jurisdictional wetlands under this alternative would be less severe than the Proposed Project. This alternative would include an approximately 1-acre park, as described in the Park Preserve/Open Space Alternative that would preserve a majority of the on-site wetlands to help reduce Impact 3.4-2. The area of impacted wetlands would be 0.006 of an acre rather than 0.07 acre under the Proposed Project.
Because affordable housing projects are not required to evaluate VMT, there would be no impact to an increase in VMT eliminating the significant and unavoidable Project impact.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-18
Impacts Identified as Being More Severe than the Proposed Project Under this alternative the density would increase from 5.1 du/ac under the Proposed Project to
11.3.0 du/ac. As discussed above, this alternative would generate 441 residents, an increase of 228 residents as compared to the Proposed Project.
Due to the increase in residents, it is anticipated the increase in air pollutants associated with operation would be slightly higher than the Proposed Project due to the increase in vehicle trips and emissions from the increased number of residents. While air quality impacts would be slightly more severe, they would still be less than significant and would not require any mitigation. This would be the same for greenhouse gas emissions impacts and energy impacts.
While the severity of impacts would slightly increase, they would still remain less than significant and would not require mitigation to address.
Noise from construction equipment would be greater from the Proposed Project due to the nature of construction of single-family residences versus attached duplex/triplex housing.
Construction equipment would still need to be equipped with suitable exhaust and intake silencers, and stationary construction equipment would need to be located away from adjacent residential property boundaries as is practical, in accordance with Mitigation Measure NOI-1.
This would ensure that noise impacts related to construction would still be less than significant.
Noise impacts from operation as well as vehicle trips would also be slightly greater but would not be substantial enough to constitute significant impacts.
The increase in 228 residents would also increase the demand for water supply, wastewater conveyance and treatment, schools, and solid waste disposal. However, the increase in severity would not be great enough to constitute significant impacts. These impacts are described in further detail below.
For the Proposed Project, the water demand for single family residences assumes eight (8) persons per home, based on the City’s demand factor of four bedrooms and two persons per bedroom for the market rate homes and two bedrooms for the affordable housing units, based on the Preliminary Water Calculations prepared for the Project (see Appendix J). The projected residential water demand for this alternative is shown in Table 5-4 below. The water demand calculation for this alternative assumes the 180 attached duplex and triplex units would be equally divided between 2-bedroom, 3-bedroom, and 4-bedroom units. With the City’s demand factor assumption of two occupants per bedroom, the water demand calculation assumes this alternative would result in a total anticipated water demand of approximately 42.3 acre-feet (AF) per year. Water demand is expected to increase, but the same as the Proposed Project any development is required to offset its increase in water in compliance with the City’s Water Neutral Ordinance. The same as the Proposed Project, all units would be designed to include Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-19
efficient and lower-water-using fixtures and appliances and irrigation systems consistent with Green Building Standards Code (CAL Green Code) that requires the installation of waterefficient indoor infrastructure to conserve water. The landscape irrigation demand under this alternative would comply with the City’s Model Water Efficient Landscape Ordinance and possibly may be lower than the Proposed Project’s irrigation demand because there would be no private lawns. In addition, irrigation of public landscaping would be offset through planting of drought tolerant plants, water conservation measures, and use of the on-site well, the same as the Proposed Project.
Table 5-4
Alternative 4: Increased Density/Affordable Housing Alternative Residential Water Demand
Fixture
Flow Rate
gal/min or
gal/flush
Flow Duration
(min., flush,
load, etc)
Daily Uses
per
Occupant
Number of
Occupants1
Gallons per
Day
Acre-feet Per
Year
Showerheads 2 8 1 1,080 17,280 19.37
Sink Faucets 1.5 0.25 3 1,080 1,215 1.36
Kitchen Faucet 1.5 4 1 1,080 6,480 7.26
Toilet 1.3 1 3 1,080 4,212 4.72
Clothes Washer 19.7 1 0.37 1,080 7,872.12 8.82
Dish Washer 6.3 1 0.1 1,080 680.4 0.76
Total Water Demand 37,739.52 42.3
Note:
1 For the purposes of determining the Proposed Project’s water demand, the City’s demand factor is based on the number of bedrooms and persons per bedroom, which differs from the City’s persons per household (PPH) to determine the number of residents a residential project would generate, which is 2.45 PPH.
Source: Appendix J.
The water demand of 42.3 AF per year would also translate to 42.3 AF per year of wastewater demand, also expected to be higher than the Proposed Project but would not require mitigation.
This alternative is also expected to result in a slight increase in solid waste generation. The solid waste generation rates used for the Proposed Project are based on the U.S. Environmental Protection Agency (EPA) estimate of 0.0013 tons/day/dwelling unit for multi-family residential homes. This would result in a solid waste generation estimate of 0.234 tons per day, only 0.001 tons greater than the Proposed Project’s estimate, as shown in Table 5-5. The impact would remain less than significant and would not require mitigation.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-20
Table 5-5
Alternative 4: Increased Density/Affordable Housing Alternative Projected Solid Waste Generation
Land Use
Generation Rate
(tons/day/unit)
Waste Disposed
(tons per day)
180 Multi-family Residential (Duplex/Triplex) Units 0.0013 0.234 Total 0.234
Source: CalRecycle 2018.
Table 5-6 considers the increase in school-age students for primary, elementary, middle and high schools. Student generation rates were derived from the SHUSD Facility Master Plan, which outlines expected growth in demand for school facilities associated with projected development and plans how to fund and respond to such growth. This alternative is expected to generate approximately 57 students in total, an increase of 29 students compared to the Proposed Project. This increase would not exceed the current capacity of schools within the SHUSD, and this alternative would still be required to pay the necessary school impact fees.
Table 5-6
Alternative 4: Increased Density/Affordable Housing Alternative Student Generation Grades
Student Generation Rate
(per total number of units) Students Generated
K-2 0.058 10.44
3-5 0.080 14.4
6-8 0.088 15.84
9-12 0.088 15.84
Total 57
Source: SHUSD 2010.
Relationship to Proposed Project Objectives
The Increased Density/Affordable Housing Alternative would subdivide the site consistent with the underlying land use designation and zoning, would complete the planned extensions of Adams Street and Starr Avenue, and would contribute to the provision of workforce and affordable housing objective. However, this alternative would not achieve the Proposed Project objective of developing a variety of housing types, including single-family and ADUs. The housing would be affordable to a range of incomes including, very low, low and moderate-income households, but would not include any single-family or market rate homes. This alternative generally meets a majority of the Proposed Project objectives but not all of the objectives.
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-21
5.2 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
The No Project/No Development alternative is the environmentally superior alternative. It would avoid all Project-related environmental impacts. CEQA Guidelines Section 15126.6(e)(3)(A) requires that when the No Project alternative is environmentally superior, another alternative be selected as the environmentally superior alternative. The environmentally superior alternative would be the Park Preserve alternative. This alternative would reduce Impact 3.4-2 by developing a passive park surrounding three out of four of the site’s jurisdictional wetlands.
However, this alternative would not avoid all of the significant impacts associated with the Project and all of the identified mitigation would still be required.
Table 5-7 provides an overview of impacts compared to the Proposed Project.
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.1 Aesthetics/Visual Resources
3.1-1: Would the Project have a substantial adverse
effect on a scenic vista? This would be a less-thansignificant impact.
LS NI LS LS LS
3.1-2: Would the Project conflict with applicable
regulations governing scenic quality or substantially
degrade the existing visual character or quality of
public views of the site and its surroundings? This
would be a less-than-significant impact.
LS NI LS LS LS
3.1-3: Would the Proposed Project potentially create
a new source of substantial light or glare which
would adversely affect day or nighttime views in the
area? This would be a potentially significant impact.
LS/M NI LS/M LS/M LS/M
3.1-4: Would the Proposed Project contribute to
cumulative changes in the existing visual character
or conflict with applicable regulations governing
scenic quality? The project’s contribution would not
be considerable.
LS NI LS LS LS
3.1-5: Would the Proposed Project contribute to a
cumulative increase in light and glare? The project’s
contribution would not be considerable with
mitigation.
LS/M NI LS/M LS/M LS/M
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-22
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.2 Agricultural and Forestry Resources
3.2-1: Would the Proposed Project convert Prime
Farmland and Farmland of Statewide Importance,
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use? This is a less-than-significant impact.
LS NI LS LS LS
3.2-2: Would the Proposed Project involve other
changes in the existing environment which, due to
their location or nature, could result in conversion of farmland, to non-agricultural use or conversion of
forest land to non-forest use? This is a less-thansignificant impact.
LS NI LS LS LS
3.2-3: Would the Proposed Project contribute to
cumulative impacts associated with the loss or
conversion of existing agricultural resources? The
project would result in a less than considerable
contribution.
LS NI LS LS LS
3.3 Air Quality
3.3-1: Would implementation of the Proposed
Project conflict with or obstruct implementation of
the applicable air quality plan? This is a less-thansignificant impact.
LS NI LS+ LS LS+
3.3-2: Would implementation of the Proposed
Project result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is nonattainment under an applicable
federal or state ambient air quality standard? This is
a less-than-significant impact.
LS NI LS+ LS LS+
3.3-3: Would implementation of the Proposed
Project expose sensitive receptors to substantial
pollutant concentrations? This is a less-thansignificant impact.
LS NI LS+ LS LS+
3.3-4: Would the Proposed Project contribute to
cumulative air quality emissions within the existing
area? The contribution would not be considerable.
LS NI LS+ LS LS+
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-23
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.4 Biological Resources
3.4-1: Would the Proposed Project have a
substantial adverse effect, either directly or through
habitat modifications, on species identified as a
candidate, sensitive, or special status species in
local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service? This would be a
significant impact.
LS/M NI LS/M LS/M LS/M
3.4-2: Would the Proposed Project have a
substantial adverse effect on federally protected
wetlands as defined by Section 404 of the Clean
Water Act through direct removal, filling,
hydrological interruption, or other means? This
would be a significant impact.
LS/M NI LS/M LS/M- LS/M3.4-3: Would the Proposed Project interfere substantially with the movement of any native
resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife
nursery sites? This would be a potentially significant
impact.
LS/M NI LS/M LS/M LS/M
3.4-4: Would the Proposed Project contribute to
cumulative impacts with respect to biological
resources? The project’s contribution would not be
considerable.
LS NI LS LS LS
3.5 Cultural and Tribal Cultural Resources
3.5-1: Would the Proposed Project cause a
substantial adverse change in the significance of a
historical resource as defined in CEQA Guidelines
Section 15064.5? This would be a significant
impact.
LS/M NI LS/M LS/M LS/M
3.5-2: Would the Proposed Project cause a
substantial adverse change in the significance of an
archaeological resource pursuant to CEQA
Guidelines Section 15064.5? This would be a
potentially significant impact.
LS/M NI LS/M LS/M LS/M
3.5-3: Would the Proposed Project disturb human
remains, including those interred outside of formal
cemeteries? This would be a less-than-significant
impact.
LS NI LS LS LS
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-24
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.5-4: Would the proposed project cause a
substantial adverse change in the significance of a
tribal cultural resource that is listed or eligible for listing in the California Register of Historical
Resources, or in a local register of historical
resources, or a resource determined by the lead
agency to be significant? This impact is considered
potentially significant.
LS/M NI LS/M LS/M LS/M
3.5-5: Would the Proposed Project contribute to
cumulative impacts to cultural resources, including
historical and archeological resources as defined in
CEQA Guidelines Section 15064.5 and human
remains? This impact is considered potentially
significant.
LS/M NI LS/M LS/M LS/M
3.5-6: Would the Proposed Project contribute to
cumulative impacts to tribal cultural resources,
currently listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources, or a resource
determined by the lead agency to be significant?
This impact is considered potentially significant.
LS/M NI LS/M LS/M LS/M
3.6 Geology and Soils
3.6-1: Would implementation of the Proposed
Project directly or indirectly cause potential
substantial adverse effects, including the risk of
loss, injury, or death involving strong seismic
ground shaking and/or liquefaction? This would be a
potentially significant impact.
LS/M NI LS/M LS/M LS/M
3.6-2: Would implementation of the Proposed
Project occur on weak, compressible, and/or
expansive soils that could result in adverse impacts
on habitable structures? This would be a less-thansignificant impact.
LS NI LS LS LS
3.6-3: Would implementation of the Proposed
Project directly or indirectly destroy a unique
paleontological resource or site? This would be a
potentially significant impact.
LS/M NI LS/M LS/M LS/M
3.6-4: Would the Proposed Project contribute to
cumulative impacts related to geologic or seismic
hazards? This would be a less than considerable
contribution.
LS NI LS LS LS
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-25
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.7 Greenhouse Gas Emissions
3.7-1: Would implementation of the Proposed
Project generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment? This would be a lessthan-significant impact.
LS NI LS+ LS LS+
3.7-2: Would implementation of the Proposed
Project conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases? This would be a
less-than-significant impact.
LS NI LS+ LS LS+
3.7-3: Would the Proposed Project contribute to
cumulative GHG emissions within the region? The
Project’s contribution would not be considerable.
LS NI LS+ LS LS+
3.8 Hazards and Hazardous Materials
3.8-1: Would implementation of the Proposed
Project create a significant hazard to the public or
the environment through the routine transport, use,
or disposal of hazardous materials? This would be a
less-than-significant impact.
LS NI LS LS LS
3.8-2: Would implementation of the Proposed
Project create a significant hazard to the public or
the environment through reasonably foreseeable
upset and accident conditions involving the release
of hazardous materials into the environment? This
would be a potentially significant impact.
LS/M NI LS/< LS/M LS/M
3.8-3: Would implementation of the Proposed
Project impair implementation of or physically
interfere with an adopted emergency response plan
or emergency evacuation plan? This would be a
less-than-significant impact.
LS NI LS LS LS
3.8-4: Would implementation of the Proposed
Project expose people or structures, either directly
or indirectly, to a significant risk of loss, injury, or death involving wildland fires? This would be a lessthan-significant impact.
LS NI LS LS LS
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-26
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.8-5: Would implementation of the Proposed
Project contribute to a cumulative increase in the
potential exposure of people to sites where soil
contamination could be present from past or current
uses, or to hazards associated with the use and
transport of hazardous materials? The project’s
contribution would be less than considerable.
LS NI LS LS LS
3.9 Hydrology and Water Quality
3.9-1: Would implementation of the Proposed
Project violate water quality standards or waste
discharge requirements, or otherwise substantially
degrade surface or groundwater quality? This would
be a less-than-significant impact.
LS NI LS LS LS
3.9-2: Would implementation of the Proposed
Project deplete groundwater supplies or interfere
substantially with groundwater recharge such that
the project may impede sustainable groundwater
management of the basin? This would be a lessthan-significant impact.
LS NI LS LS LS
3.9-3: Would implementation of the Proposed
Project substantially alter the existing drainage
pattern of the site or area through the addition of
impervious surfaces resulting in erosion or siltation
on- or off-site; increasing the rate or amount of
surface runoff resulting in flooding on- or off-site;
contributing runoff water which would exceed the
capacity of existing or planned stormwater drainage
systems or provide polluted runoff; or impede or
redirect flood flows? This would be a less-thansignificant impact.
LS NI LS LS LS
3.9-4: Would implementation of the Proposed
Project release pollutants during flooding? This
would be a less-than-significant impact.
LS NI LS LS LS
3.9-5: Would implementation of the Proposed
Project conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan? This would be a
less-than-significant impact.
LS NI LS LS LS
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-27
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.10 Land Use
3.10-1: Would implementation of the Proposed
Project conflict with the City’s 1993 General Plan
policies or other regulations adopted for the purpose
of avoiding or mitigating an environmental effect?
This would be a less-than-significant impact.
LS NI LS LS LS
3.11 Noise and Vibration
3.11-1: Would short-term construction noise levels
cause a substantial temporary increase in ambient
noise levels? This would be a potentially significant
impact.
LS/M NI LS/M+ LS/M LS/M+
3.11-2: Would existing residential areas be exposed
to vibration peak-particle velocities greater than 0.2- inch per second or vibration levels greater than 80
VdB due to project construction? This would be a
less than significant impact.
LS NI LS LS LS
3.11-3: Would on-site operation noise from the
proposed residences result in noise exposure levels
that would impact adjacent residences? The impact
would be less than significant.
LS NI LS+ LS LS+
3.11-4: Would the Proposed Project vehicle trips
result in off-site roadway noise level increases that
could impact noise sensitive land uses located
along such roadways? The impact would be less
than significant.
LS NI LS+ LS LS+
3.11-5: Would the Proposed Project, in addition to
cumulative development in the City, increase traffic
noise that exceeds the City’s noise standards? The
Project’s contribution would not be considerable.
LS NI LS LS LS
3.12 Public Services and Recreation
3.12-1: Would the Proposed Project increase
demand for public services requiring the need to
construct new facilities, or expand existing facilities, the construction of which could cause significant
environmental impacts? This would be a less-thansignificant impact.
LS NI LS+ LS LS+
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-28
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.12-2: Would the Proposed Project increase the
use of existing neighborhood parks or other
recreational services such that a substantial
physical deterioration of the facility would occur, or
require the construction or expansion of facilities
that could have a physical adverse effect on the
environment? This would be a less-than-significant
impact.
LS NI LS+ LS LS+
3.12-3: Would the Proposed Project contribute to a
cumulative increase in demand for public services,
schools, and recreation facilities? The Project’s
contribution would not be considerable.
LS NI LS+ LS LS+
3.13 Utilities
3.13-1: Would the Proposed Project require or result
in the relocation or construction of new or expanded
water, wastewater treatment, or storm water
drainage, electric power, natural gas, or
telecommunications facilities? This is a less-thansignificant impact.
LS NI LS+ LS LS+
3.13-2: Would the Proposed Project have sufficient
water supplies available to serve the project and
reasonably foreseeable future development during
normal, dry, and multiple dry years? This is a lessthan-significant impact.
LS NI LS+ LS LS+
3.13-3: Would the Proposed Project result in a
determination by the wastewater treatment provider
which serves or may serve the project that it has
adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments? This is a less-than-significant impact.
LS NI LS+ LS LS+
3.13-4: Would the Proposed Project generate solid
waste in excess of State or local standards, or in
excess of the capacity of local infrastructure, or
otherwise impair the attainment of solid waste
reduction goals? This is a less-than-significant
impact.
LS NI LS+ LS LS+
3.13-5: Would the proposed project comply with
federal, state, and local statutes and regulations
related to solid waste? This is a less-than-significant impact.
LS NI LS+ LS LS+
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-29
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.13-6: Would the Proposed Project contribute to an
increase in demand for water supply, wastewater
treatment, stormwater or solid waste? The Project’s
contribution would not be considerable.
LS NI LS+ LS LS+
3.14 Transportation and Traffic
3.14-1: Would the Proposed Project conflict with an
applicable plan, ordinance or policy addressing the
circulation system, including transit, roadway,
bicycle and pedestrian facilities? This would be a
less-than-significant impact.
LS NI LS LS LS
3.14-2: Would the Proposed Project conflict or be
inconsistent with CEQA Guidelines section
15064.3(b)? This is a significant impact.
SU NI SU SU NI
3.14-3: Would the Proposed Project increase
hazards due to a geometric design feature or
incompatible use? This is a less-than-significant
impact.
LS NI LS LS LS
3.14-4: Would the Proposed Project result in
inadequate emergency access. This is a less-thansignificant impact.
LS NI LS LS LS
3.14-5: Under Cumulative conditions, would the
Proposed Project conflict or be inconsistent with
CEQA Guidelines section 15064.3(b)? This is
considered a significant impact.
SU NI NI NI NI
3.14-6: Under Cumulative conditions, would the
Proposed Project increase hazards due to a
geometric design feature or incompatible use? This
is considered a less than significant impact.
LS NI SU SU SU
3.15 Energy
3.15-1: Would implementation of the Proposed
Project result in wasteful, inefficient or unnecessary
consumption of energy resources during
construction or operation? This would be a lessthan-significant impact.
LS NI LS+ LS LS+
3.15-2: Would implementation of the Proposed
Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? This
would be a less-than-significant impact.
LS NI LS+ LS LS+
Agenda Item #6.2.
5 - PROJECT ALTERNATIVES
Hunter Subdivision Project EIR 10839
September 2021 5-30
Table 5-7
Comparison of Project Alternatives
Impact
Proposed ProjectAlternative 1: No Project/No DevelopmentAlternative 2: No project/general PlanAlternative 3: Park PreserveAlternative 4: Increased Density/Affordable Housing
3.15-3: Would the Proposed Project contribute to an
increase in wasteful, inefficient or unnecessary
consumption of energy resources during
construction or operation? The Project’s contribution
would not be considerable.
LS NI LS+ LS LS+
Notes:
LS = Impacts less than significant
NI = No impact
LS/M = Impacts less than significant after mitigation
PS = Potentially significant (mitigation not determined) SU= Significant and Unavoidable
“+” indicates the impact is more severe than the Project impact “-“ indicates that the impact is less severe than the Project impact Agenda Item #6.2.
Hunter Subdivision Project 10839
September 2021 6-1
CHAPTER 6
REPORT PREPARERS
City of St. Helena
City of St. Helena Planning & Community Improvement Department 1572 Railroad Avenue
St. Helena, California 94574
Maya DeRosa, AICP
Planning and Building Director
Dudek
1102 R Street
Sacramento, California 95811
Christine Kronenberg, AICP, Project Manager
Angelica Chiu, Environmental Planner
Matthew Morales, Air Quality Specialist
Ian McIntire, Air Quality Specialist
Laura Burris, Botanist
Keith Babcock, Principal Biologist
Craig Seltenrich, Senior Aquatic Biologist
Adam Giacinto, Archeologist
Dylan Duvergé, PG, Hydrogeologist
Jonathan Leech, AICP, INCE, Acoustician
Transportation Subconsultant - W-Trans
Steve Weinberger, Principal
Agenda Item #6.2.
6 – REPORT PREPARERS
Hunter Subdivision Project 10839
September 2021 6-2
INTENTIONALLY LEFT BLANK
Agenda Item #6.2.
1 NOTICE OF PREPARATION
FOR THE HUNTER SUBDIVISION PROJECT
ENVIRONMENTAL IMPACT REPORT
COMMENT PERIOD: March 6, 2018 through April 9, 2018.
All persons and public agencies are invited to submit written comments as to the scope and content of the EIR.
This Notice of Preparation (NOP) initiates the environmental review process in accordance with the California Environmental Quality Act (14 California Code of Regulations [CCR] Section 15082) for a land development project in the City of St. Helena (City). The City will be the Lead Agency and will commission the preparation of an Environmental Impact Report (EIR) for the Hunter Subdivision project (proposed project). The purpose of an NOP is to provide sufficient information about the proposed project and its potential environmental impacts to allow agencies and interested parties the opportunity to provide a meaningful response related to the scope and contents of the EIR, including mitigation measures that should be considered and alternatives that should be addressed (State CEQA Guidelines 14 CCR Section 15082[b]).The project description, location, and probable environmental effects of the proposed project are briefly described below.
Providing Comments
The City is soliciting comments from responsible and trustee public agencies, private organizations, and individuals regarding the scope and content of the EIR for 30 days. Because of time limits mandated by State law, comments should be provided no later than 5:00 PM on April 9, 2018. Please send all comments to:
Noah Housh, Planning and Community Improvement Director City of St. Helena, Planning & Community Improvement Department 1480 Main Street
St. Helena, CA 94574
Email: [email protected]
Agencies that will need to use the EIR when considering permits or other approvals for the proposed project should provide the name of a contact person, phone number, and email address in their comment. Each responsible and trustee agency must also provide the City with specific detail about the scope and content of the environmental information related to the responsible or trustee agency’s area of statutory responsibility that must be included in the EIR. (CEQA Guidelines, § 15082, subd. (b).)
Agenda Item #6.3.
2 Comments provided by email should include “Hunter Subdivision Project NOP Scoping Comment” in the subject line, and the name and physical address of the commenter in the body of the email.
Public Scoping Meeting
A public scoping meeting will be held by the City to inform interested parties about the proposed project, and to provide agencies and the public with an opportunity to provide comments on the scope and content of the EIR. Following a brief presentation of the project description and an overview of the CEQA process the floor will be opened to citizens, agency representatives and other individuals to provide comments directly to staff and the consultant team regarding the scope of the EIR. Additionally comment cards will be available to provide written comments to staff and consultants and will be accepted both at the meeting and afterward at City Hall.
The meeting time and location are as follows:
March 12, 2018
6:00 p.m. to 7:30 p.m.
City of St. Helena Fire Department
1480 Main Street
St. Helena, CA 94574
The meeting space is accessible to persons with disabilities. Individuals needing special assistive devices will be accommodated to the City’s best ability. For more information, please contact Noah Housh (at the contact information above) at least 48 hours before the meeting.
Project Location
The project site is located in the northeast portion of the City, at the eastern terminus of Adams Street, north of Starr Avenue and west of the Napa River (Assessor’s Parcel 009-030-057), see Figure 1, Project Location.
Project History
The environmental review process for the proposed project started in June 2011 when a NOP was prepared and circulated. The Draft EIR was released for public review in May 2012 and the City’s Planning Commission held hearings in July and August 2012 to take comments on the adequacy of the EIR. A Final EIR was prepared in September 2013, but due to new project information and a request from the applicant representative, the City opted to continue the item.
From 2013-2016 the Draft EIR was updated to include some new information however the revised draft was never completed and therefore the revised Draft EIR was not released for public review or comment. Due to the age of the overall document and analysis, staff recommended that the project be reanalyzed through a new EIR process, and this NOP is intended to inform the public a new EIR analysis has been initiated.
Agenda Item #6.3.
3 Separately, the City completed the construction of the Flood Protection Project in 2011, which consisted of river channel improvements, a levee, and floodwall construction along the Napa River adjacent to the project site. On November 5, 2012, the Federal Emergency Management Agency (FEMA) accepted the Flood Protection Project and revised the Flood Insurance Rate Map (FIRM), such that the project site is no longer located within a 100-year flood zone.
Project Description
The proposed project includes a request to approve a Tentative Map to subdivide the existing
16.9-acre parcel into 51 single-family lots, one 3.4-acre parcel, and a 0.06-acre remainder parcel.
The 51 single-family lots would typically range in size from 7,000 to 8,000 square feet, with some larger corner and cul-de-sac lots. The single-family lots could be developed with single-family market-rate housing and may include, under City and state housing law, the construction of an Accessory Dwelling Unit (ADU).1 In order to meet the minimum density requirements for the site, at least 87 dwelling units must be built as a part of the project. Information from the applicant identifies 51 single family homes, and at least 11 ADUs are proposed to be built on the singlefamily lots, with the remaining 25 required units proposed to be constructed on the 3.4 acre parcel, as a multifamily development likely in the form of duplex units. This combination of single-family homes, ADUs and multifamily homes is proposed to meet the 87 total units required to be constructed in by projects’ Medium Density Residential (MDR) General Plan and Medium Density Residential (MR) zoning designations.
Properties designated as MDR by the General Plan typically are used for residential purposes, for example, single-family attached and detached homes, secondary residential units, and similar and compatible uses. This designation permits densities of 5.1 to 16.0 dwelling units per acre (du/acre). The project proposes the minimum allowable density of 5.1 du/acre, although the maximum density allowed on the site 16.0 du/ac, allowing up to 270 dwelling units based on the
16.9 acre parcel size. The City is in the process of updating its General Plan, however the project will be evaluated under the City’s adopted 1993 General Plan, based on the timing of the application.
The project site is zoned MR. The MR district is consistent with the M DR General Plan land use designation. This district provides for single-family detached homes, ADUs, supportive and transitional housing, and other similar uses found consistent with the General Plan and MR district, as permitted land uses. Conditional land uses include single-family housing where the minimum density would otherwise require two units or more and new attached duplex and/or triplex units.
The project design also includes onsite water, sewer and storm drain infrastructure to tie into the City’s existing system and the extension of Adams Street and Starr Avenue to connect to the City’s roadway system, in keeping with the City’s 1993 General Plan Circulation Element. 1 Accessory Dwelling Units are also known as granny flats, in-law units, or secondary units.
Agenda Item #6.3.
4 Anticipated project approvals required to construct all units proposed in the project include:
Tentative Map, Final Subdivision Map, Conditional Use Permit, Design Review, and Allocations under the City’s Growth Management System.
To date, the applicant has filed a Tentative Map application requesting that the City subdivide the existing 16.9 acre parcel into 52 individual residential lot including 51 single-family residential lots and one 3.4 acre parcel for 25 multifamily homes. The applicant has indicated an intent to create affordable units on the 3.4-acre parcel and provide an Affordability Agreement.
Potential Environmental Effects
The EIR will describe the reasonably foreseeable and potentially significant adverse effects of the proposed project (both direct and indirect). The EIR will also evaluate the cumulative impacts of the project when considered in conjunction with other related past, present, and reasonably foreseeable future projects. The City anticipates that the proposed project could result in potentially significant environmental impacts in the following topic areas, which will be further evaluated in the EIR:
Aesthetics
Air Quality
Agricultural Resources
Biological Resources
Cultural/Paleontological/Tribal Resources
Greenhouse Gas Emissions
Geology, Soils and Seismicity
Hazards and Public Safety
Hydrology and Water Quality
Land Use/Demographics
Noise and Vibration
Public Utilities/Energy
Public Services/Recreation
Transportation
Agenda Item #6.3.
29 Project Location
Hunter Subdivision Project
SOURCE: USDA NAIP Imagery (2016); Napa County GIS (2015) Date: 2/13/2018 - Last saved by: rstrobridge - Path: Z:\Projects\j1083901\MAPDOC\PD\Figure1_ProjectOverview.mxd 0 0.5 0.25 Miles
St. Helena City
Boundary
Project Site
FIGURE 1
Vallejo Benicia
Fairfield
Fairfield
Dixon
Vacaville
Hercules
Napa
Yountville
St.
Helena
Calistoga
Clearlake
San
Rafael
Novato
Winters Davis
Petaluma
Sonoma
Rohnert
Park
Sebastopol
Windsor
Healdsburg
Woodland
Cloverdale
Santa Rosa
Santa Rosa
Suisun
City
Colusa County
Lake County
Napa County
Sonoma County
Yolo County
Marin County Solano
County
101
116
221
281
128
16 53
121
175
12 113
12 128
29 1
680
505
5 80
Project Site
Agenda Item #6.3.
AFFORDABLE/WORK FORCE HOUSING
Site Plan
Hunter Subdivision Project
FIGURE 2 SOURCE: RSA Consulting, Feb., 2017
Z:\Projects\j1083901\MAPDOC\PD
Agenda Item #6.3.
From: Lederer, Steven
To: Noah Housh
Cc: Lederer, Steven; Dillon, Diane; Morrison, David; Stangland, Steve; Chapin, Craig; McDowell, John; Arias, Juan; Erica Ahmann Smithies
Subject: RE: Hunter NOP Electronic Notification
Date: Wednesday, March 07, 2018 8:49:27 AM
Attachments: image001.png
Mr. Housh,
Thank you for the opportunity to provide input on the NOP for the Hunter Ranch Development. The County may provide other comments later, but one specific area of concern the County has is traffic and circulation as it relates to impacts on Silverado Trail. In conjunction with Highway 29, Silverado Trail is the primary method vehicles have for traversing the valley from north to south, and the only one that bypasses the large traffic delays caused by St. Helena.
The EIR should study all practical methods for avoiding increasing traffic impacts on Silverado Trail.
It is also necessary to point out that the County’s General Plan contains many policies on maintaining the rural character of the valley, part of which is avoiding the installation of traffic signals wherever possible. Should the EIR find that any changes are needed on Silverado Trail (such as at Pope Street or perhaps creation of a new access), we strongly recommend solutions such as roundabouts or something similar in lieu of traffic signals.
We look forward to continue to participate in this process.
Steve Lederer
Director, Napa County Public Works
From: Housh, Noah
Sent: Tuesday, March 06, 2018 5:18 PM
To: Housh, Noah <[email protected]>
Subject: Hunter NOP Electronic Notification
***Information Only; Please Do Not Reply All***
Greetings,
At the recently held neighborhood meeting for the Hunter Residential Subdivision, you provided your email contact information indicating you would like to be notified of future project activities.
Attached please find the formal Notice of Preparation initiating the Environmental Impact Review (EIR) process for this project.
As was identified at the neighborhood meeting, a scoping meeting for the EIR is scheduled for Monday, March 12, 2018, from 6:00 – 7:30 pm at the St Helena Fire Department (1480 Main Street).
This meeting will provide an opportunity for individuals to speak directly to the California Environmental Quality Act (CEQA) consultants regarding the scope of the EIR analysis.
Agenda Item #6.3.
Alternatively, if you are unable to attend this meeting, please feel free to provide your written comments to me (electronically or hard copy) any time before April 9, 2018, to ensure they are considered in the EIR analysis. My contact information is provided in the notice, and in the signature below
After the initial analysis is completed, a draft EIR will be published for a 45-day public review and comment period, during which the public will have an additional opportunity to comment on the environmental analysis and resulting document. This is tentatively scheduled to occur in late spring or early summer, 2018.
These comments will then be used to finalize the document making modifications or expanding the analysis, as appropriate. Further, a response to each comment will be provided in the Final draft EIR for the project, which will then be taken before the Planning Commission for review and action at a public hearing tentatively proposed to be held in late summer or early fall of 2018.
Please forward this message to anyone you feel may be interested in the Hunter Residential Subdivision EIR process. Thank you for your attention to this matter.
NOAH HOUSH
PLANNING & COMMUNITY IMPROVEMENT DIRECTOR
City of St. Helena | Planning & Community Improvement Department 1480 Main Street | St. Helena, CA 94574
Direct: (707) 968-2659 | [email protected] | http://cityofsthelena.org/planning CONFIDENTIALITY NOTICE: This email message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is privileged, confidential, and/or exempt from disclosure under applicable law. If you are not the intended recipient of the message, please contact the sender immediately and delete this message and any attachments. Thank you.
Agenda Item #6.3.
From: Sandra Lowry
To: Cindy Tzafopoulos
Cc: Noah Housh; Mark Prestwich
Subject: HUNTER EIR
Date: Thursday, April 12, 2018 4:48:17 PM
Gentlemen,
I am writing on behalf of my husband, Cecil Lowry. and myself. Our address is 1175 Starr Avenue and we moved here in July, 1997. We are opposed to yet another development near our home on Starr Avenue.
The EIR should look carefully at traffic and parking. More developments mean more cars and trucks coming and going and where will they park? Already our neighborhood is impacted by overflow trucks and automobiles from the Hunts Grove residents parking up and down Starr and Meadowcreek Circle. We are additionally impacted by speeding vehicles up and down Starr at all times of the day and night, making crossing the street to visit a neighbor a hazard. The crosswalk at Starr and Meadowcreek Circle is basically ignored. Most importantly, all the traffic comes to a dead stop on Pope Street because of the Pope Street bridge. I believe the last EIR decided traffic was an unmitigable issue.
The EIR must look at the Hunter Project in terms of water consumption. Previous EIR study suggested a water neutrality by installing low flush toilets. Is this a joke? More people means more water use in common sense terms.
The proposed development will have many of the homes built behind the levee, in an area at serious risk of liquification, not to mention flooding, a disaster waiting to happen.
Thank you for listening. Sandra Lowry
Agenda Item #6.3.
From: John Milliken
To: Cindy Tzafopoulos
Cc: Noah Housh; Mark Prestwich
Subject: Hunter EIR Scoping Comments
Date: Thursday, April 12, 2018 11:14:19 AM
Attachments: C001 SENT Hunter Comment Ltr.pdf
NPS_Urban-facts_final.pdf
Response to Response.docx
Hunter EIR Scoping Comments 4/12/18
Please find listed below areas that should be included in the scope of the new EIR. In addition, I have attached comments from a CEQA Attorney and my own comments prepared in response to the original DEIR. Also attached is an informational report prepared by the EPA that reviews how to protect water quality from Urban Runoff. These attachments detail many of the shortcomings of the original DEIR and I would like them included for consideration for the scoping of the new EIR.
Design, Implementation and Administration of the Affordable Units It will be very difficult to conduct a thorough EIR that subscribes to CEQA standards until the design, implementation, and administration of the affordable housing components are fully understood.
How and who is going to build them? Will they have to built before the market rate houses? How large will they be and how many occupants will they have. How many bedrooms, bathrooms, and parking spaces will there be? Are they going to be rentals or owner occupied? Will the multi-family units need zoning variances or conditional permits? Will the 10 lots with Granny units be deed restricted or under the control of the owner? What mechanisms are in place to ensure that the 10 granny units are indeed made available as affordable and when will they be built. If the project qualifies for a density bonus by right, should the EIR anticipate this and factor in the potential impact of additional units? All of this should be explained and understood BEFORE the EIR is started so that there are no surprises that could derail this second attempt at completing an EIR for this project. It is one thing to draw boxes on a sub-division map and designate them as affordable for development concessions. It is quite another to adequately explain how this will all work within the parameters of existing regulations and requirements. And, without this information, preparing an informed EIR will be incredibly difficult.
Design and Implementation of a controlled intersection at the Pope Street Bridge and Silverado Trail
Well after the completion of the last DEIR, the applicant claimed they had new information and that they would submit a design and pay for this intersection (along with approval from the County) to mitigate traffic impacts. Will information on how this will be accomplished (or is even practical) be provided BEFORE the start of the new EIR?
Plans for mitigating loss of State Designated Prime Agricultural Land Well after the completion of the last DEIR, the applicant claimed that they had new information for a plan for offsetting the loss of Prime Agricultural Land. Will this information be provided BEFORE the start of the new EIR?
Impacts of Traffic Through Neighborhoods
Agenda Item #6.3.
Beyond traffic count studies, will the new EIR take into account traffic that will utilize the Adams and Starr extensions to circumvent traffic delays on the Silverado Trail and Highway 29. The advent of apps like Waze and Google Maps will re-direct increasing amounts of traffic through neighborhoods.
Residents of Hunts Grove will now have to cross a busy intersection upon exiting their development.
This is a particular concern for the safety of children and pedestrians who now do not face crossing a street in order to walk to/from school or shopping.
Loss of open space and safe access to the Napa River Walk for pedestrians and dog walkers Once Starr is extended to meet Adams, residents and visitors who currently use the undeveloped city owned lot to access the River walk will be faced with sharing their walk with traffic and parked cars to reach the walk. This will be a significant danger to children and dog walkers.
John Milliken
[email protected]
707-963-8134 (Office) 707-486-4266 (Mobile\Text)
1256 Hudson Ave.
St. Helena, CA 94574
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
Agenda Item #6.3.
and snowmelt remains above the
surface, where it runs off rapidly in
unnaturally large amounts.
Storm sewer systems concentrate
runoff into smooth, straight
conduits. This runoff gathers speed
and erosional power as it travels
underground. When this runoff
leaves the storm drains and empties
into a stream, its excessive volume
and power blast out streambanks,
damaging streamside vegetation and
wiping out aquatic habitat. These
increased storm flows carry sediment
loads from construction sites and
other denuded surfaces and eroded
streambanks. They often carry
higher water temperatures from
streets, roof tops, and parking lots,
which are harmful to the health and
reproduction of aquatic life.
from
Did you know that because of impervious surfaces like pavement and rooftops, a typical city block generates more than 5 times more runoff than a woodland area of the same size? The most recent National Water Quality Inventory reports that runoff from urbanized areas is the leading source of water quality impairments to surveyed estuaries and the third-largest source of impairments to surveyed lakes.
I
n urban and suburban areas, much
of the land surface is covered
by buildings and pavement, which
do not allow rain and snowmelt
to soak into the ground. Instead,
most developed areas rely on storm
drains to carry large amounts of
runoff from roofs and paved areas to
nearby waterways. The stormwater
runoff carries pollutants such as oil,
dirt, chemicals, and lawn fertilizers
directly to streams and rivers, where
they seriously harm water quality.
To protect surface water quality and
groundwater resources, development
should be designed and built to
minimize increases in runoff.
How Urbanized Areas
Affect Water Quality
Increased Runoff
The porous and varied terrain of
natural landscapes like forests,
wetlands, and grasslands traps
rainwater and snowmelt and allows
them to filter slowly into the ground.
In contrast, impervious (nonporous)
surfaces like roads, parking lots, and
rooftops prevent rain and snowmelt
from infiltrating, or soaking, into
the ground. Most of the rainfall
The loss of infiltration from
urbanization may also cause profound
groundwater changes. Although
urbanization leads to great increases
in flooding during and immediately
after wet weather, in many instances
it results in lower stream flows
during dry weather. Many native fish
and other aquatic life cannot survive
when these conditions prevail.
Increased Pollutant Loads
Urbanization increases the variety
and amount of pollutants carried
into streams, rivers, and lakes. The
pollutants include:
• Sediment
• Oil, grease, and toxic chemicals
from motor vehicles
• Pesticides and nutrients from
lawns and gardens
• Viruses, bacteria, and nutrients
from pet waste and failing septic
systems
• Road salts
• Heavy metals from roof shingles,
motor vehicles, and other sources
• Thermal pollution from dark
impervious surfaces such as streets
and rooftops
These pollutants can harm fish and
wildlife populations, kill native
vegetation, foul drinking water
supplies, and make recreational areas
unsafe and unpleasant.
Clean Water Is Everybody’s Business
URBAN RUNOFF EPA 841-F-03-003
Relationship between impervious cover and surface runoff. Impervious cover in a watershed results in increased surface runoff. As little as 10 percent impervious cover in a watershed can result in stream degradation.
Protecting Water Quality Agenda Item #6.3.
Managing Urban Runoff
What Homeowners Can Do
To decrease polluted runoff from
paved surfaces, households can develop
alternatives to areas traditionally covered
by impervious surfaces. Porous pavement
materials are available for driveways and
sidewalks, and native vegetation and mulch
can replace high maintenance grass lawns.
Homeowners can use fertilizers sparingly
and sweep driveways, sidewalks, and roads
instead of using a hose. Instead of disposing
of yard waste, they can use the materials to
start a compost pile. And homeowners can
learn to use Integrated Pest Management
(IPM) to reduce dependence on harmful
pesticides.
In addition, households can prevent
polluted runoff by picking up after pets and
using, storing, and disposing of chemicals
properly. Drivers should check their cars
for leaks and recycle their motor oil and
antifreeze when these fluids are changed.
Drivers can also avoid impacts from car
wash runoff (e.g., detergents, grime, etc.) by
using car wash facilities that do not generate
runoff. Households served by septic systems
should have them professionally inspected
For More Information
U.S. Environmental Protection Agency
Nonpoint Source Control Branch (4503T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
www.epa.gov/nps
and pumped every 3 to 5 years. They should
also practice water conservation measures to
extend the life of their septic systems.
Controlling Impacts from New
Development
Developers and city planners should
attempt to control the volume of runoff
from new development by using low
impact development, structural controls,
and pollution prevention strategies. Low
impact development includes measures that
conserve natural areas (particularly sensitive
hydrologic areas like riparian buffers and
infiltrable soils); reduce development
impacts; and reduce site runoff rates by
maximizing surface roughness, infiltration
opportunities, and flow paths.
Controlling Impacts from
Existing Development
Controlling runoff from existing urban
areas is often more costly than controlling
runoff from new developments. Economic
efficiencies are often realized through
approaches that target “hot spots” of
runoff pollution or have multiple benefits,
such as high-efficiency street sweeping
(which addresses aesthetics, road safety,
and water quality). Urban planners and
others responsible for managing urban
and suburban areas can first identify and
implement pollution prevention strategies
and examine source control opportunities.
They should seek out priority pollutant
reduction opportunities, then protect
natural areas that help control runoff, and
finally begin ecological restoration and
retrofit activities to clean up degraded water
bodies. Local governments are encouraged
to take lead roles in public education
efforts through public signage, storm drain
marking, pollution prevention outreach
campaigns, and partnerships with citizen
groups and businesses. Citizens can help
prioritize the clean-up strategies, volunteer
to become involved in restoration efforts,
and mark storm drains with approved “don’t
dump” messages.
Turn Your Home into a Stormwater Pollution Solution!
www.epa.gov/nps
This web site links to an EPA homeowner’s guide to healthy habits for clean water that provides tips for better vehicle and garage care, lawn and garden techniques, home improvement, pet care, and more.
National Management Measures to Control Nonpoint Source Pollution from Urban Areas
www.epa.gov/owow/nps/urbanmm
This technical guidance and reference document is useful to local, state, and tribal managers in implementing management programs for polluted runoff. Contains information on the best available, economically achievable means of reducing pollution of surface waters and groundwater from urban areas.
Onsite Wastewater Treatment System Resources
www.epa.gov/owm/onsite
This web site contains the latest brochures and other resources from EPA for managing onsite wastewater treatment systems (OWTS) such as conventional septic systems and alternative decentralized systems. These resources provide basic information to help individual homeowners, as well as detailed, up-to-date technical guidance of interest to local and state health departments.
Low Impact Development Center
www.lowimpactdevelopment.org
This center provides information on protecting the environment and water resources through integrated site design techniques that are intended to replicate preexisting hydrologic site conditions.
Stormwater Manager’s Resource Center (SMRC)
www.stormwatercenter.net
Created and maintained by the Center for Watershed Protection, this resource center is designed specifically for stormwater practitioners, local government officials, and others that need technical assistance on stormwater management issues.
Strategies: Community Responses to Runoff Pollution
www.nrdc.org/water/pollution/storm/stoinx.asp
The Natural Resources Defense Council developed this interactive web document to explore some of the most effective strategies that communities are using around the nation to control urban runoff pollution. The document is also available in print form and as an interactive CD-ROM.
February 2003
Related Publications
Agenda Item #6.3.
Response to Response to Comments: Prepared by John Milliken Inadequate Analysis and Flawed Findings in FEIR Section I: Hydrology and Water Quality The less than significant finding (LTS) in the FEIR concerning water quality and potential harm to the habitat of the endangered species in the adjacent Napa River is completely without merit. The EIR insufficiently identifies and fails to provide a level of analysis of the significant impacts of polluted runoff, increased storm water volumes, and diminished re-charging of the underlying aquifer (affecting summer stream flows) that will be caused by the project. Not only are the significance of these impacts ignored, corresponding mitigations to lessen their effects are not proposed either.
The credibility of the entire EIR process is in question if you agree with the presumption that an 87 unit development, located in a flood plain, with acres and acres of impervious surfaces (roads, driveways, parking lots, walkways, roofs, patios, utility pads, etc.), will not have any significant impact on water quality, groundwater recharging, or the amount of runoff generated by the project. The likelihood of significant impacts to water quality and harm to protected species is even more pronounced if the cumulative effects over many years are considered. Not identifying cumulative impacts to hydrology and water quality is another serious failure in this FEIR.
Instead of identifying significant impacts and proposing mitigations, the FEIR spontaneously claims that, ”it was abundantly clear that potential impacts to aquatic resources that could potentially result from water quality or runoff flow caused by the project would be insignificant and, therefore, not a significant impact to aquatic resources on, adjacent to, or downstream of the project, including to fish, fish habitat, or fish movement.” This claim was made in spite of a 6 page report to the contrary prepared by a fisheries biologist expert, Jeff Hagar, who was commenting on the inadequacies of the DEIR. Instead of heeding Mr. Hagar’s meticulously researched and documented analysis, the FEIR took a pass on his findings and deflected them all away by claiming that the project will have to apply for an EPA NPEDS (National Pollutant Discharge Elimination System) permit and this will mitigate everything. Interestingly, Table III-1, Required Discretionary and Ministerial Permits and Approvals, from the DEIR does not even list a NPEDS permit.
A General NPED Construction Permit’s scope applies only to storm water runoff during a project’s construction phase and is an important protection for water quality. However, there are no impacts identified in the FEIR concerning Hydrology and Water Quality post construction singularly or cumulatively. And if there are no impacts identified, there are certainly no mitigations offered either. As it turns out, this is a common theme of both the DEIR and FEIR. The analysis of the DEIR was preoccupied with the environmental impacts of the construction phase of the project and tended to ignore/neglect the post construction and cumulative impacts of the project, another example of improper CEQA mandated analysis.
So what types of mitigations could have been proposed by a proper analysis? Quite a few, if you had just perused the EPA’s brochure on the impacts of Urban Development Guidelines. Somehow this readily available information was ignored or not even considered in both the DEIR and FEIR. Which leads one to ponder the competence of the firm that was hired to prepare both of these reports.
Nonpoint source (NPS) pollution, unlike pollution from industrial and sewage treatment plants, comes from many diffuse sources. NPS pollution is caused by rainfall or snowmelt moving over and through the Agenda Item #6.3.
ground. As the runoff moves, it picks up and carries away natural and human-made pollutants, finally depositing them into lakes, rivers, wetlands, coastal waters and ground waters.
Urbanization increases the variety and amount of pollutants carried into our nation's waters. In urban and suburban areas, much of the land surface is covered by buildings, pavement and compacted landscapes. These surfaces do not allow rain and snow melt to soak into the ground which greatly increases the volume and velocity of stormwater runoff. In addition to these habitat-destroying impacts, pollutants from urban runoff include:
•Sediment
•Oil, grease and toxic chemicals from motor vehicles
•Pesticides and nutrients from lawns and gardens
•Viruses, bacteria and nutrients from pet waste and failing septic systems •Road salts
•Heavy metals from roof shingles, motor vehicles and other sources •Thermal pollution from impervious surfaces such as streets and rooftops These pollutants can harm fish and wildlife populations, kill native vegetation, foul drinking water, and make recreational areas unsafe and unpleasant
Controlling Impacts from New
Development
Developers and city planners should
attempt to control the volume of runoff
from new development by using low
impact development, structural controls,
and pollution prevention strategies. Low
impact development includes measures that
conserve natural areas (particularly sensitive
hydrologic areas like riparian buffers and
infiltrable soils); reduce development
impacts; and reduce site runoff rates by
maximizing surface roughness, infiltration
opportunities, and flow paths.
As stated in the DEIR, permit approval is not a substitute for thorough and complete environmental review. From the DEIR:
E. DISCRETIONARY ACTIONS
Agenda Item #6.3.
It is anticipated that this EIR will provide environmental review for all discretionary approvals and actions necessary for the proposed project. A number of permits and approvals would be required before the development of the project could proceed. As Lead Agency for the proposed project, the City of St. Helena would be responsible for the majority of approvals required for development. A list of required permits and approvals that may be required by the City and other agencies includes, without limitation, those provided in Table III-1.
The FEIR does NOT provide environmental review for the discretionary approval and actions necessary for a NPEDS permit.
Given that the project site is located on the floodway of a river that has been designated as impaired for endangered fish species, a thorough EIR analysis, that strictly follows CEQA guidelines, is even more of an imperative. It would surely be a mistake to rely on solely NPEDS permitting standards in such an environmentally sensitive area. The project site is so close to the impaired river that options for improving water quality are extremely limited. Quite simply, polluted high sediment runoff from the acres and acres of impervious surfaces will enter the gravity operated storm water basin and then exit directly into the impaired river. Although it is predicted that storm water handling facilities will have the capacity to handle storm water flows from the project, there is no denying that the level of water pollutants and quantity of runoff into the river from the project will be far greater than pre-project levels. The DEIR refers to studies of sediment TMDL being developed with the goal of reducing sediment discharges into sensitive fish spawning areas. However, these studies are ongoing and TMDLs have not yet been established. Until they are, the FEIR should not assume that the issuing of a NPEDS permit will reduce project water quality to less than significant. This is best summed up by the fisheries biologist, Jeff Hagar:
This comment brings up another shortcoming of the FEIR, there are no comments in regard to the DEIR from other government and private stakeholders working to restore endangered fish habitat just south of the project. Should not there have been comments solicited from California Coastal Conservancy, U.S.
Army Corps of Engineers, Napa County Resource Conservation District, California Fish and Game, California Water Quality Control Board, and a group of 23 private property owners with property that borders the Rutherford Reach, the 4.5 mile stretch of the Napa River between St. Helena and Oakville? Were these entities ever contacted and asked to comment on the DEIR and allowed to express concerns about the projects impacts on their environmental restoration efforts just to the south? As the lead agency responsible for producing an EIR that will adequately inform government decision makers as well as the public, the City of St. Helena should instruct the EIR consulting firm to re-evaluate the preparation of the Hunter Development EIR and recirculate a document that meets the standards established by CEQA. The deficiencies of the FEIR concerning Hydrology and Water Quality documented above are just one of the many areas of this FEIR that provide inadequate and incomplete analysis of the project’s impacts on environmental quality.
Agenda Item #6.3.
Agenda Item #6.3.
From: Cindy Tzafopoulos
To: Noah Housh
Subject: FW: Hunter EIR comments
Date: Thursday, April 12, 2018 4:37:06 PM
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1480 Main Street
St. Helena, CA 94574
Direct 707-968-2742 | Fax 707-963-7748
[email protected]
www.cityofsthelena.org
From: [email protected] [mailto:[email protected]]
Sent: Thursday, April 12, 2018 4:36 PM
To: Cindy Tzafopoulos <[email protected]>; Cindy Tzafopoulos <[email protected]>
Cc: [email protected]
Subject: Hunter EIR comments
Hi Cindy – please add these questions to the EIR
Hope all is well. Weird weather, right? From 80 degrees to rain storms and 45 degrees. What season is this?
Cheers,
Ann
Question #1
How will this project affect the St Helena city groundwater wells at the Stonebridge locations? The project plan states it will provide all the landscaping water for 87 houses’ lawns, flowers, bushes, gardens, carwashes, and other watering uses. The number could be 20-40 units higher if the project includes regulated affordable housing. Since the well is located next to the Napa River upstream from the City of St Helena wells that supply our community with water, what mapping will be conducted to determine if the aquifers are connected? If they are connected, then drawing large amounts of water from the same groundwater source needs to be assessed so it does not deplete the City wells supply. Who will conduct the mapping? How many groundwater data points will be included in any mapping exercise? Will it be a sufficient number to adequately determine that the Hunter well is on an aquifer that is separated from the city aquifer? This question must be answered accurately, because the city relies on the groundwater Agenda Item #6.3.
from these 2 wells as a critical source of water in times of drought when Bell Canyon is depleted. (Example – the drought resulting in exposure of large portions of the bottom of the Bell Canyon reservoir.
Question #2:
The project area is in a low lying wet area on the historic floodplain for this part of the Napa River. It has flooded numerous times over the last 20-30 years. Even in non-flood years, large portions have remained wet during the summers, to the point that vine growth and production was hampered due to the wet soils. Presently, this area is covered with standing water during and after rains with water depths often 10-12 inches deep. The project will add millions of gallons (25 acre feet) of landscaping water annually to an area that has never been irrigated.
Will the addition of paved surfaces, construction pads, streets and structures cause compaction of the soils/subsoils in the area? Will this cause subsidence or instability of structures in and around the project area over time? Will subsidence cause new unknown flooding issues? Question #3:
There is an existing subsoil study on the project area that shows what is considered to be the profile of a historic pond, which is typical in areas proximal to meandering rivers. Since the area is a known liquefaction zone in an earthquake prone location, and soils of this type can be unstable, how will this affect the safety of the homes and the structural integrity of the levee in an earthquake or major flood?
Agenda Item #6.3.
From: Tim Nieman
To: Cindy Tzafopoulos; Noah Housh; Mark Prestwich
Subject: Scoping comments on Hunter EIR
Date: Thursday, April 12, 2018 1:37:08 PM
I’d like to submit the following comments for the Scoping of the Hunter EIR Groundwater usage on the site
The estimates of historical groundwater usage on the site need to be redone. The previous EIR made some highly questionable assumptions about historical groundwater usage, leading to an estimate of pre-flood-project groundwater demand on the site of 22 AF. There are two errors in the consultant’s methodology rendering this estimate much too high.
1. The consultant assumed that all of the vineyards on the site were historically irrigated. There is little need to irrigate this wet vineyard and there is no evidence that there has ever been an irrigation system on the site, so the assumption that the well was used to irrigate the entire site is unfounded. There are no remnants of piping or any other irrigation components currently. And, vintners adjacent to the site who have lived here for decades do not recall there ever being such a system. The property is adjacent to the river and is one of the wettest vineyard locations in the valley. There is little need to irrigate there. Adjacent vineyards which are updip and drier are all dry farmed. If the assumption is to be made that irrigation once existed for the entire vineyard, it is incumbent upon the consultants to prove that such a system existed.
2. The consultant assumed vineyard irrigation rates from the Oakville area, a much drier area farther from the Napa River. Even if this area was ever irrigated, Oakville irrigation rates are too high. Again, this is a wet vineyard which would need water only rarely in the driest of years, if at all.
Therefore, historical groundwater pumping on the site was likely localized, sporadic and minimal.
The actual usage would be a small fraction of the 22 AF. What are the new estimates of historical production? What data are used to justify those estimates? Impacts on the Napa River, including fish
The existing groundwater well on the site is only hundreds of feet from the Napa River. If the aquifer being accessed is at all connected to the river, then the well is drawing down from the Napa River, impacting river flows and fish habitat. What is the connection to the Napa River? How much is the impact on river flow from pumping on the site at different rates? A groundwater hydrology study should be undertaken to determine the connection to the river.
Impacts on City Groundwater Supply Wells
The existing groundwater well on the site is updip of City water supply wells and the proposed levels of use could impact City wells. Is it the same aquifer? How would pumping on the site affect groundwater levels in the City wells, at different rates? A groundwater hydrology study should be undertaken to determine if there is a connection to the City’s groundwater supply wells and the potential for drawdown of those wells.
Agenda Item #6.3.
From: Vickie Bradshaw
To: Cindy Tzafopoulos
Cc: Noah Housh; Mark Prestwich
Subject: Hunter EIR Scoping Comments
Date: Thursday, April 12, 2018 9:20:20 AM
CindyBelow are my comments regarding the scope of the Hunter EIR.
1. The EIR for the Hunter Project cannot be done until it is conclusively determined whether or not the Hunter Project qualifies for the 40% affordable housing benefits, including priority in water and sewer connections, use of prior year surplus units from the Growth Management System (GMS), etc. The reason for this is that the environmental impact is completely different if the benefits are applied to the project than if they are not applied. An example is that if the project qualifies under the inclusive housing and affordable housing ordinances, then the entire project can be completed in 2 years, according to the developer. If the project does not qualify, then the Hunter Project could take up to 10 years to complete, assuming very few, if any other houses are built in St. Helena during that timeframe because the project would be limited to the annual 9 units allowed under the GMS. It isn’t hard to see that the environmental impacts are quite different under these two scenarios.
Before the EIR begins, it has to be determined if the Project qualifies for such benefits or not.
This decision cannot run on parallel tracks with the EIR and then come together at the end, as Noah Housh suggested at the neighborhood scoping meeting last month. For the EIR to be accurate, the EIR consultants must know what scenario applies before the EIR begins. And, in cases like this, it does matter to CEQA if the housing is market rate or affordable because the priority benefits derived from hitting a 40% affordable housing rate under City ordinances changes that environmental analysis. In this case, it is not the affordability of the housing that affects the CEQA analysis, but the priority benefits given by the City and/or the state that changes the impact on the environment from building this project.
The prior Hunter Project EIR inappropriately assumed (without confirming) that the Hunter Project would qualify for the priority benefits stemming from the project complying with the inclusive housing and affordable housing ordinances at the 40% rate. That assumption cannot be part of the current EIR process because it likely will make the EIR inaccurate.
If the developer does not want to show to the satisfaction of the City Council that their current proposal completely meets all of the City’s inclusive and affordable housing requirements to qualify for the 40% priority benefits, then the EIR should be done without giving any credit for any of those benefits before the EIR is started. At the very least this would change the environmental analysis from a two-year project to a potential ten-year project with ongoing environmental impacts.
If the EIR assumes the project will qualify for the 40% rate and if it is later determined that the current project cannot meet the inclusive housing and affordable housing ordinance requirements without resubmitting a tentative map, then the City would be in the position of looking at yet another Hunter EIR exercise. It would make more sense to make that determination now.
2. The Hunter Project EIR has to take into consideration the cumulative impacts of the 17-acre Agenda Item #6.3.
Hunter Project, along with the 24-acres of Key Opportunity Sites (sites 1, 2, and 6 on page 134 of the Housing Element Needs Assessment), which begins about 3 blocks from the Hunter Project and extends south across Pope Street. These cumulative sites will significantly impact surrounding streets and the Pope Street bridge. Such cumulative effects will undoubtedly impact the environment and have to be taken into consideration in the Hunter Project EIR.
3. The Hunter Project EIR needs to consider the environmental impacts resulting from a potential levee failure. CA Government Code §65302(g)(2)(A)(vii-viii) requires that St.
Helena include a levee failure map in its General Plan Update to show areas that would be inundated in the event of a levee failure. It will be important to have such an inundation map to show the environmental difference between the situations where the land behind the levee is undeveloped, as it is now, and the situation where the land behind the levee is covered over with asphalt and houses, which is a situation where there would be significantly less permeable land for flood waters to be absorbed. The environmental differences between these two situations would likely be significant.
Of additional environmental interest is that fact that the area closest to the Napa River where the levee is located is considered a high liquefaction susceptibility area (Figure 4.K-2 in the General Plan Update) and liquefaction is a well-known and significant cause of levee failure.
4. The EIR for the Hunter Project has to assume the project can be built out to the maximum density allowed resulting from any density bonuses provided under city ordinances and state law, even assuming the current project does not now show such a density bonus in the “deemed complete” tentative map. The current owner and/or developer could decide after an EIR is approved to sell the property and the new owners could apply for the density bonuses prior to seeking building permits. At that point it would be too late for the EIR to take into consideration the increased housing units, population, cars and other environmental impacts because the EIR would already have been completed and approved.
Thank you for your consideration, Vickie Bradshaw
Victoria Bradshaw
California Strategies, LLC
One Embarcadero, Suite 1060
San Francisco, CA 94111
(415) 705-5276
980 9th Street, Suite 2000
Sacramento, CA 95814
(916) 266-4575
Agenda Item #6.3.
From: Noah Housh
To: "Chuck Vondra"
Cc: [email protected]
Subject: RE: Hunter NOP Electronic Notification
Date: Wednesday, March 07, 2018 10:07:00 AM
Attachments: image001.png
Hi Chuck,
Thank you for taking the time to provide your input on the EIR and project.
City staff and project consultants will ensure that the review process fully vets the proposed project and meets all requirements of the law.
Further, I will be sure to keep you informed of all steps in the review process.
Thanks again,
NOAH HOUSH
PLANNING & COMMUNITY IMPROVEMENT DIRECTOR
City of St. Helena | Planning & Community Improvement Department 1480 Main Street | St. Helena, CA 94574
Direct: (707) 968-2659 | [email protected] | http://cityofsthelena.org/planning From: Chuck Vondra [mailto:[email protected]]
Sent: Tuesday, March 06, 2018 5:35 PM
To: Noah Housh
Cc: [email protected]; CityCouncil
Subject: RE: Hunter NOP Electronic Notification
Hello Noah,
Thanks for hosting the meeting last week. As I mentioned at the meeting, kicking off the EIR seems very premature and a waste of time and money.
1. The applicant is still formulating and the City still reviewing the affordable housing component. How can we comment on something that is incomplete, and has not been reviewed by the city?
2. As was brought up by Planning Commissioner Grace Kistner, our municipal code requires that in order to qualify for density bonuses (without which this project will never get built) the project needs 20% AFU for sale. This will almost certainly require a revised subdivision map, and likely a brand new subdivision application. It seemed to me that the developer has not thought this project out very well as is making it up as he goes along. With this understanding Agenda Item #6.3.
an EIR at this juncture makes no sense.
3. This project is extremely unpopular by a majority of residents and a hasty ill-planned EIR process will most certainly be vigorously challenged. Why not pause and let the developer get his plans together first, it is not fair to ask the community to weigh on a moving target.
Sincerely,
Chuck Vondra – Principal, Sr. Consultant
Bus: 707-963-5418 E-Mail [email protected] Cell: 707-815-6355 1176 Starr Avenue, St. Helena, CA 94574
www.Com-Strat.com
Your independent expert for technology consulting and project management.
The information contained in this email is proprietary and confidential, and may be used only by its intended recipient. If you receive this email in error, you should contact the sender and then delete permanently by pressing <shift><delete>. Thank you for your consideration.
From: Noah Housh [mailto:[email protected]]
Sent: Tuesday, March 6, 2018 5:18 PM
To: Noah Housh <[email protected]>
Subject: Hunter NOP Electronic Notification
***Information Only; Please Do Not Reply All***
Greetings,
At the recently held neighborhood meeting for the Hunter Residential Subdivision, you provided your email contact information indicating you would like to be notified of future project activities.
Attached please find the formal Notice of Preparation initiating the Environmental Impact Review (EIR) process for this project.
As was identified at the neighborhood meeting, a scoping meeting for the EIR is scheduled for Monday, March 12, 2018, from 6:00 – 7:30 pm at the St Helena Fire Department (1480 Main Street).
This meeting will provide an opportunity for individuals to speak directly to the California Environmental Quality Act (CEQA) consultants regarding the scope of the EIR analysis.
Alternatively, if you are unable to attend this meeting, please feel free to provide your written comments to me (electronically or hard copy) any time before April 9, 2018, to ensure they are considered in the EIR analysis. My contact information is provided in the notice, and in the signature below
After the initial analysis is completed, a draft EIR will be published for a 45-day public review and Agenda Item #6.3.
comment period, during which the public will have an additional opportunity to comment on the environmental analysis and resulting document. This is tentatively scheduled to occur in late spring or early summer, 2018.
These comments will then be used to finalize the document making modifications or expanding the analysis, as appropriate. Further, a response to each comment will be provided in the Final draft EIR for the project, which will then be taken before the Planning Commission for review and action at a public hearing tentatively proposed to be held in late summer or early fall of 2018.
Please forward this message to anyone you feel may be interested in the Hunter Residential Subdivision EIR process. Thank you for your attention to this matter.
NOAH HOUSH
PLANNING & COMMUNITY IMPROVEMENT DIRECTOR
City of St. Helena | Planning & Community Improvement Department 1480 Main Street | St. Helena, CA 94574
Direct: (707) 968-2659 | [email protected] | http://cityofsthelena.org/planning Agenda Item #6.3.
From: Cindy Tzafopoulos
To: Noah Housh
Subject: FW:
Date: Thursday, April 12, 2018 4:20:13 PM
Attachments: 541c_93_GP_Policies_9.4.4._&_9.4.5.png
image001.png
image002.png
image004.png
image005.png
image006.png
Thank you,
Cindy Tzafopoulos
City Clerk
City of St. Helena
1480 Main Street
St. Helena, CA 94574
Direct 707-968-2742 | Fax 707-963-7748
[email protected]
www.cityofsthelena.org
From: Wendell Laidley [mailto:[email protected]]
Sent: Thursday, April 12, 2018 4:17 PM
To: Cindy Tzafopoulos <[email protected]> Subject:
Cindy,
The first photos are showing up now. Can you tell me if you receive this with the first 7 photos in it? Just hit reply if you would. Thanks.
Wendell
Dear Cindy,
Please consider these comments regarding the scope of the Hunter EIR.
An earlier EIR dismissed flood risk for the Hunter Property behind the levee as "less than significant" as shown below ...
Agenda Item #6.3.
That citation reports the "potential flooding impact, under CEQA, is less than significant." With due respect to all, I consider the flood risk behind the levee and its potential consequences to be substantial, and ask that the flood risk be thoroughly studied so St. Helena residents and taxpayers do not become liable for damages occurred on that property when the levee alignment violated St.
Helena's own 1993 General Plan, which contained this provision ...
Agenda Item #6.3.
... that "grading and earth filling within the designated 100-year floodway should not be permitted." Unfortunately the Vineyard Valley development was developed directly atop the floodway to the Napa River, as shown on these photographs ...
and from the east side of the River ...
Agenda Item #6.3.
These photos show that the floodwater trapped behind the Vineyard Valley cinder block wall did not overtop the riverbank, but instead drained naturally from the watershed northwest of Vineyard Valley, toward the historic floodway now blocked by Vineyard Valley.
Disruption of that historic natural floodway caused both floods in 1986 and 1995 that caused over $100 Million as documented by City Manager Johansson in his Project Summary report to Assemblywoman Noreen Evans and Senator Pat Wiggins ...
Agenda Item #6.3.
Engineers know as basic safety practice not to obstruct floodplains, as confirmed below in St.
Helena's 1993 General Plan ...
Agenda Item #6.3.
Unfortunately that basic practice was ignored in the levee alignment, which bisects the very floodplain that caused the 1986 and 1995 floods that caused over $100 Million as reported above by former City Manager Bert Johansson.
After the 1986 flood, in his letter of August 14, 1986, to developer McDonnell, then City Engineer Jack Meade warned Mr. McDonnell against reconstructing Vineyard Valley on its floodway blocking site ...
Agenda Item #6.3.