MEMORANDUM
To: Town Council Date: April 1, 2025
Brad Raulston, Town Manager
From: Aaron Hecock, Planning & Building Director
Subject: Napa County Regional Climate Action and Adaptation Plan (RCAAP) _____________________________________________________________________________________ Background
At the February 28, 2025 meeting of the Regional Climate Action Committee (CAC), the CAC received a presentation and memo (attached for review) from Ascent Environmental discussing RCAAP CEQA options and associated costs of each.
County staff requested that the CAC review, discuss, and take the memo back to their respective jurisdictions for discussion with staff, counsel, and agency leadership with a plan to bring the item back in March for further discussion and possible action.
The March 28, 2025 CAC meeting was cancelled due to a lack of quorum. The next CAC meeting is scheduled to take place on April 25, 2025, where this item will likely be up for further discussion and possible action.
Options
Based on the attached memo from Ascent Environmental, three options appear most appropriate to consider; they are as follows:
1. Recommend preparation of an Initial Study and Mitigated Negative Declaration (IS/MND) for the RCAAP. The advantage of this option is that there are fewer regulatory obligations related to public participation and analyses, which shortens the time necessary for document preparation and associated costs. The primary disadvantage is this approach's legal defensibility. If litigated, the IS/MND would be subject to the fair argument standard, which dictates that if substantial evidence exists to support a fair argument that a proposed project may have a significant environmental impact, then an EIR must be prepared (this would lead to additional time and expense). Ascent estimates preparation of an IS/MND would cost approximately $90,000 and would take 6 to 9 months to complete (Yountville’s share would be approximately $6,750 for a total of $21,607 including the CAC budget for FY 25/26).
2. Agree with the County’s recommended approach of preparing a Program-level Environmental Impact Report (PEIR) for the RCAAP. The benefit of a PEIR is that it provides a complete and thorough analysis of potential impacts, is highly defensible and can be used to streamline future environmental reviews under CEQA. The disadvantage of preparing a PEIR is that it will take longer and cost significantly more than an IS/MND. Ascent estimates preparation of a PEIR would take approximately 1 year with an estimated cost of $400,000. County Counsel support to review documents involved with preparation of the PEIR is estimated to be an additional $66,800. Yountville’s share of the total $466,800 would be approximately $35,010, for a total of $49,867 including the CAC budget for FY25/26.
3. Recommend against preparing a CEQA document for the RCAAP. Failing to prepare and adopt a CEQA document would leave the RCAAP open to legal challenges and the plan would not meet the minimum criteria specified in the CEQA Guidelines to provide streamlining options for future projects. The proposed FY 25/26 budget for the CAC without environmental review for the RCAAP is $198,098 (Yountville’s share would be $14,857).
Additional Considerations
In addition to the costs described above, continued participation in the RCAAP will require significant staff time, not only to attend CAC meetings, but also to participate in the planned formation of a regional inter-jurisdictional staff level working group. The working group will require additional meetings, time to review technical documents, and opportunities to provide input and feedback. Additionally, time will be required to develop and execute an implementation framework that prioritizes the measures outlined in the RCAAP.
It should be noted that the Town adopted a Climate Action Plan (CAP) in the fall of 2016 (the CAP can be viewed here: Climate-Action-Plan). This plan includes policies and action items aimed at reducing the Town’s Greenhouse Gas Emissions and minimizing our impacts on climate change. Therefore, the Town already has an adopted policy framework to achieve climate action goals that accomplish many of the same objectives of the RCAAP. However, Ascent states that the success of the RCAAP and providing future CEQA streamlining opportunities depends on the continued efforts and participation of all member jurisdictions and that failure to adopt and implement the GHG and adaptation measures included in the RCAAP by any jurisdiction could jeopardize the success of the RCAAP for the whole region.
Attachments
February 20, 2025 CEQA Approach Memo from Ascent Environmental