TO: Napa County Planning Commission
FROM: Brian D. Bordona, Director of Planning, Building and Environmental Services
REPORT BY: Sean Kennings, Contract Planner
SUBJECT: E & P Technology Way - Buildings A & B
RECOMMENDATION
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E&P TECHNOLOGY WAY - BUILDINGS A & B / DENNIS PAULLEY / USE PERMIT APPLICATIONS #P22-00307 and #P22-00308
CEQA Status: Consideration and possible adoption of a Mitigated Negative Declaration. According to the proposed Mitigated Negative Declaration, the proposed project would not have any potentially significant environmental impacts after implementation of mitigation measures. Mitigation measures are proposed for the following areas: Biological Resources, Cultural Resources, and Transportation. The project site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. (State Clearinghouse Number #2024100855) 2024100855)
Request: Approval of two separate Use Permit applications to allow the construction of two separate projects and buildings: Building A - a 450,000 gallon per year wine production and storage facility within a proposed 143,312 sf building (P22-00307-UP) and Building B - speculative warehouse/office uses within a proposed 66,915 sf building (P22-00308-UP).
The Building A project proposes winery uses that will include grape crushing, bulk wine processing and storage, stainless steel tank and barrel storage, bottling, and office space. In addition, approximately 13,000 sf of covered outdoor work area will be located on the north side of the building. The proposal also includes 129 parking spaces and eight (8) spaces for semi-trailers. Access will be provided by three (3) new driveways; one (1) on Technology and two (2) on Morris Court. Tours, tastings, and marketing events are not proposed with this application and will not occur as part of this permit. The applicant is also requesting a variation to the development regulations of the Specific Plan to reduce the required 40-foot average building setback along the south property line to approximately 31-feet.
The Building B project proposes to allow warehouse and office uses within the proposed 66,915 sf building. The proposal also includes 82 parking spaces. Access will be provided via two (2) new access driveways off Technology Way on the far west and east sides of the project site. The warehouse uses are consistent with allowable warehouse uses as outlined in Napa County Code Industrial Park zoning district (18.40.020) and the Napa Valley Business Park Specific Plan (NVBPSP.)
The City of American Canyon will provide both projects with water service . Napa Sanitation District (NSD) will provide sewer. Both buildings will be sprinklered for fire protection.
There are three parcels comprising the two project sites: Building A is proposed on a 13.2-acre parcel on the north side of Technology Way and Morris Court (APN 057-250-030) and Building B is proposed on a 6.87-acre project site on the north side of Technology Way, opposite Gateway Road West (APN’s 057-250-031& -032), which will be merged as required by a condition of approval. Both sites are located in the NVBPSP area within the IP:AC (Industrial Park: Airport Compatibility) Zoning District.
Staff Recommendation: Adopt the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program and approve the Use Permit with the proposed conditions of approval.
Staff Contact: Sean Kennings, Contract Planner, (415) 533-2111, or sean@lakassociates.com
Applicant Contact: Mike Kelley, 5150 Fair Oaks Blvd, Suite 101-219, Carmichael, CA 94608, (916) 956-0524
CONTINUED FROM THE NOVEMBER 20, 2024, PLANNING COMMISSION MEETING.
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EXECUTIVE SUMMARY
Proposed Actions:
That the Planning Commission:
1. Adopt the Revised Mitigated Negative Declaration and Revised Mitigation Monitoring and Reporting Program for the E&P Technology Way Buildings A & B projects based on Findings 1-6 of Attachment A;
2. Approve Use Permit P22-00307, including a variation to development standards, based on Findings 7-14 of Attachment A and subject to the revised conditions of approval (Attachment B); and
3. Approve Use Permit P22-00308 based on Findings 15-19 of Attachment A and subject to the revised conditions of approval (Attachment C).
Discussion:
This item was originally scheduled for hearing before the Commission on November 20, 2024. On November 19, 2024, a lengthy comment letter was submitted on behalf of the Napa-Solano Residents for Responsible Development, represented by Tara C. Renifo of Adams, Broadwell, Joseph & Cardozo. The letter raised concerns about the adequacy of the proposed environmental document. Comment letters were also received from the California Department of Fish and Wildlife, dated November 15, 2024, and Water Audit California, dated November 19, 2026. After considering public comment, the item was continued to a date uncertain to allow the applicant and staff time to address questions and concerns raised in the comment letters.
This item is now back before the Commission after the applicants and their consultants processed and responded to public comments as discussed in more detail below. The previous staff report and video of the November 20, 2024, meeting can be found at the following link: https://napa.granicus.com/player/clip/5543?view_id=3&redirect=true
The project consists of a request to construct two buildings totaling 210,227 sf for a new wine production and warehouse facility with an annual production capacity of 450,000 gallons and a separate warehouse and office building. The wine production facility includes areas for wine production, storage, and office uses. No tours, tastings or marketing activities are proposed. The site plan shows parking consistent with Code requirements. Wineries within the NVBPSP are not subject to the Winery Definition Ordinance, including but not limited to the 75% grape source requirements, accessory to production ratio, and minimum lot size. The project is compatible in design and operation with other projects located in the NVBPSP area and staff supports the use permits, subject to the recommended conditions of approval.
The floor area ratio (FAR) after full build out of Building A will be 24.9%, below the allowable 35%. All vehicles will enter from a new access driveway off Technology Way that runs along the eastern property line. Trucks will stop at the entry scale as needed and then continue to the loading zone for off load or pick up. Trucks will be able to circulate around the building in a one-way loop, exiting at a second driveway on Morris Court. The entrance driveway will be wide enough to accommodate two-way traffic. The applicant is requesting a variation to the development regulations of the Specific Plan to reduce the required 40-foot average building setback along the south property line to approximately 31-feet. The proposed building exceeds the minimum 25-foot building and landscape setback along Technology Way.
The winery building will provide for tank fermentation and storage for bulk wine in stainless steel tanks in a refrigerated building. The facility will be run by 16 full-time and 7 part-time employees during non-harvest season. Seasonal help will increase during harvest to approximately 35 total employees. The building will be used during harvest for crushing up to 450,000 gallons of wine and tank fermentation of bulk wine and juice. Wine storage (tank and barrel) and bottling will take place on a year-round basis. Water demand and wastewater design will include demand for crush, bulk fermentation, storage and bottling uses. No retail sales or access for the general public is proposed. Individual clients will visit the site on occasion to hold meetings with members of the wine trade, such as their distributors, restaurants, wine shop owners and similar types of wine buyers. The only signage will be to identify the building as a winery facility.
The FAR of Building B after full build out will be 22.4%, below the allowable 35%. All vehicles will enter from a new access driveway on Technology Way that runs along the eastern property line. Trucks will then offload or pick up at the rear of the building. Trucks will be able to circulate around the building in a one-way loop, exiting at a second driveway on Technology Way on the west side the building. The entrance driveway will be wide enough to accommodate two-way traffic. The building will be utilized for warehousing. The facility will be run by up to approximately 30 employees. No user has been identified for either building.
ENVIRONMENTAL IMPACT
ENVIRONMENTAL DETERMINATION: Consideration and possible adoption of a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program. According to the proposed Mitigated Negative Declaration, the proposed project would have potentially significant environmental impacts on Biological Resources, Cultural Resources, and Transportation unless mitigation measures are adopted. In accordance with Section 15073 of the California Environmental Quality Act (CEQA) Guidelines, Napa County submitted the initial proposed IS/MND to the State Clearinghouse (SCH #2024100855) for a 30-day review period beginning on October 18, 2024, and running through November 19, 2024. In addition, Napa County circulated a Notice of Intent to adopt the initial proposed IS/MND to interested agencies and individuals. The project is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.
Pursuant to Section15072, the public review period or the notice of intent to adopt the Mitigated Negative Declaration ran from October 18, 2024, to November 19, 2024. Pursuant to Section15073.5 - ‘Recirculation of a Negative Declaration [or Mitigated Negative Declaration] Prior to Adoption’, the following provisions apply:
(a) A lead agency is required to recirculate a negative declaration when the document must be substantially revised after public notice of its availability has previously been given pursuant to Section 15072, but prior to its adoption. Notice of recirculation shall comply with Sections 15072 and 15073.
(b) A "substantial revision" of the negative declaration shall mean: (1) A new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or (2) The lead agency determines that the proposed mitigation measures or project revisions will not reduce potential effects to less than significance and new measures or revisions must be required.
(c) Recirculation is not required under the following circumstances: (1) Mitigation measures are replaced with equal or more effective measures pursuant to Section 15074.1, (2) New project revisions are added in response to written or verbal comments on the projects effects identified in the proposed negative declaration which are not new avoidable significant effects, (3) Measures or conditions of project approval are added after circulation of the negative declaration which are not required by CEQA, which do not create new significant environmental effects and are not necessary to mitigate an avoidable significant effect and (4) New information is added to the negative declaration which merely clarifies, amplifies, or makes insignificant modifications to the negative declaration.
(d) If during the negative declaration process there is substantial evidence in light of the whole record, before the lead agency that the project, as revised, may have a significant effect on the environment which cannot be mitigated or avoided, the lead agency shall prepare a draft EIR and certify final EIR prior to approving the project. It shall circulate the draft EIR for consultation and review pursuant to sections 15086 and 15087, and advice reviewers in writing that a proposed negative declaration had previously been circulated for the project.
Analysis: There were no new avoidable significant effects identified and no new mitigation measures or project revisions added to the mitigated negative declaration in order to reduce the effect to less than significant. No mitigation measures are being replaced with equal or more effective measures pursuant to Section 15074.1. The Biological and Cultural Resources sections of the initial study found that approval of the project, as mitigated would not result in an adverse significant impact on the environment. Subsequent Greenhouse Gas (GHG) Emissions modeling concluded that the increase in GHG emissions from the revised modeling is still below threshold and does not warrant revisions to the project or environmental document. Stormwater control measures required by current County regulation will be required as a condition of approval, avoiding any potential adverse hydrological impacts. Review of the applicant's responses has concluded that the environmental analysis and impacts identified in Mitigated Negative Declaration (MND) remain substantively unchanged and supports the finding that the applicant's responses and additional information do not raise any new issues and do not exceed the level of impacts identified in the previously prepared Mitigated Negative Declaration. See the Background Section for a summary of the applicants’ and staff responses to the comment letters. This proposal does not require a substantial revision of the Mitigated Negative Declaration.
BACKGROUND AND DISCUSSION
Owner: Dennis Paulley
Applicant/Representative: Mike Kelley, 5150 Fair Oaks Blvd, Suite 101-219, Carmichael, CA 94608, (916) 956-0524
Zoning: IP:AC (Industrial Park: Airport Compatibility Combination)
General Plan Designation: Industrial (I)
Use Permit Filed: August 30, 2022; Resubmittals: February 2, 2023, January 30, 2024, February 21, 2024; Application Complete: March 28, 2024
Parcel Size: 20.07 acres (13.2 acres, Building A & 6.87 acres, Building B)
Proposed Building Size: Building A: 143,312 sf building, with 13,000 sf of outdoor covered work areas and Building B: 66,915 sf building.
Proposed Production Capacity: 450,000 gallons per year (Building A)
Number of Employees: The winery facility is expected to employ up to 35 full and/or part-time employees. The office/warehouse building is expected to employ up to 30 employees.
Winery Visitation: None proposed
Winery Marketing Program: None proposed
Hours of Operation: Seven days a week from 6:00 AM to 6:00 PM.
Proposed Parking: On-site parking for: Building A - 129 vehicles (68 parking spaces for tank and barrel storage, 47 spaces for production and bottling, and 14 spaces for the office) and eight (8) spaces for semi-trailers; Building B - 82 vehicles (38 for the warehouse and 44 for the office).
Airport Compatibility: The project was originally reviewed for consistency with the 1999 Airport Land Use Compatibility Plan (ALUCP) since the project was evaluated prior to adoption of the Napa Countywide Airport Land Use Compatibility Plan on December 4, 2024.
The project has since been evaluated for consistency with the 2024 Plan. The majority of the project site, including the proposed development areas, is located within Zone D1 which is the Inner Traffic Pattern Zone. Aircraft are typically 1,000 to 1,500 feet above the runway but can be as low as 600 feet above the airport elevation when circling to land using the Runway 1L approach procedure. Wineries, warehousing, distribution, office and light industrial uses are normally compatible within this zone. There should also be a maximum sitewide average intensity of 200 people per acre, and a maximum single-acre intensity of 800 people per acre. All aspects of the development have been designed to comply with these limitations.
A small portion of the riparian corridor along Sheehy creek, at the northwest corner of the Building A project site, is located within Zone B1 which is the Inner Approach/Departure Zone. Aircraft would be overflying at low altitudes on final approach and straight-out departures, typically 200 to 400 feet above the runway elevation. No structures are proposed within this area.
Adjacent Zoning / Land Use:
The property is bordered on the west by Morris Court and commercial warehouse buildings; to the south by Technology Way and commercial warehouse buildings; to the east by 240 Gateway Road East, a multi-tenant office building and commercial office buildings further east, to the northeast by the Napa Valley Transportation Authority facility, and to the north by Sheehy Creek and property owned by the Napa Sanitation District (NSD) and used as spray fields for treated wastewater. The properties comprising the project site have access and frontage on Technology Way and Morris Court. There is a conservation easement that runs along the north and northeast boundary of the project site which includes a meandering path along the south side of Sheehy creek. There are also public utility easements along the north and east property lines of APN 057-250-030 (Building A.)
North: PL:AC - Adjoining the project site to the north, on the north side of Sheehy Creek, is an undeveloped/agriculture property (NSD spray fields) on a 263.45-acre site.
South: IP:AC - Across Technology Way from the project site to the south are several parcels with offices and warehouses.
West: IP:AC - Adjoining the project site to the east is an 11.06-acre undeveloped parcel within the NVBPSP boundary. West of the undeveloped parcel are an existing warehouse and office buildings on a 16.07-acre parcel.
East: IP:AC - Immediately east is a 2.83-acre site with a small office building. To the northeast across Sheehy Creek is a 5.9-acre property with several office and warehouse buildings.
Parcel History/Setting:
The project sites are irregular shaped rectangular lots that are long and narrow and relatively flat, except for the banks of Sheehy Creek, an intermittent creek that traverses the northern property boundaries of the sites from east to west, with gentle slopes ranging from 0-5 percent. Grade elevations on the site range from approximately 20 to 37 feet above mean sea level, sloping east to west. The Technology Way roadway and Morris Court were constructed in 2007 and will provide direct access to the sites via new curb cuts with additional access from Morris Court for Building A. Sheehy Creek is located mostly on the norther boundary of the proposed development area. The majority of the site is dominated by disked, ruderal grasses, with vegetation and bushes and riparian areas along the creek.
Code Compliance History:
There are no open or pending code violations for the subject site.
Wineries in Vicinity:
Attachment L provides of list of wineries/production facilities operating, approved to operate, or pursuing approvals to operate within the NVBPSP Area.
Discussion Points:
1. Building Design, Layout & Materials - Both buildings include site-cast tilt-up concrete wall panels with a multi-color textured coating system and multiple score lines/reveals, storefront glazing systems, painted steel channel canopies, truck loading docks, grade level roll-up doors, and metal man-doors. Color choices include white, green, and grey painted stucco panels. The winery building also includes a covered outdoor work area for the crush pad in front of the loading docks. The overall design is equivalent to other similar more recent industrial projects approved and/or constructed within the NVBPSP boundaries and meets the minimum design requirements for the NVBPSP industrial park area.
2. Access - Access to the buildings is proposed via new curb cuts off Technology Way and Morris Court. As mentioned above (Parcel History/Setting) Technology Way and Morris Court were constructed in the mid-2000s as part of the NVBP development. On-site drive aisles are designed to County standards and wrap around both buildings providing Fire Department and emergency vehicle access to all areas of the buildings. The project has been reviewed by the County Fire Department and Engineering Services Division and found acceptable as conditioned.
3. Parking - The NVBPSP requires one parking space per 1,000 sf for the first 20,000 sf of floor area and one parking space per 2,000 sf of floor area thereafter for storage/warehousing use. The Specific Plan also requires one parking space per 250 sf of floor area for office areas and one space per 500 sf of floor area for manufacturing areas. Based on the preliminary floor plan of the proposed buildings, which includes approximately 116,112 sf of tank/barrel storage area, 23,700 sf of production/bottling area, and 3,500 sf of office area, 129 parking spaces are required. For the warehouse building, approximately 55,915 sf is dedicated to warehouse area, and 11,000 sf is allocated for office area, 82 parking spaces are required. The site plan includes 129 parking spaces for Building A consistent with Code requirements and more than adequate to accommodate the expected 35 full and part time employees. Building B includes 82 spaces, 38 for the warehouse, and 44 for the office uses consistent with Code requirements. 25 spaces out of the 82 total for Building B would be designated as compact spaces.
4. Building Setbacks/Landscaping - The NVBPSP requires a building setback with a 40-foot average, and a minimum of 25-feet, from Technology Way and Morris Court. The 25-feet adjoining the two streets is required to be landscaped. The NVBPSP also requires 10-foot building and landscaping setbacks from the side and rear property lines when the property lines do not adjoin a street. No variation to the IP development standards is requested for Building B. However, Building A, the nearest to Technology Way, is setback a minimum of 31-feet and includes the minimum 25-feet of landscaping. In addition to road and property line setbacks, the project also requires adhering to the required conservation easement setback from Sheehy Creek, discussed below. The applicant is requesting a variation to the development regulations of the Specific Plan to reduce the required 40-foot average building setback along the south property line to approximately 31-feet. The project meets the 40-foot average along the Morris Court side (west) of the property, but requirements for truck and vehicle circulation access to the rear of the winery building precludes the project from meeting the 40-foot average along the Technology Way frontage. The reduced setback would provide an appropriate buffer for development and preserve the conservation easement to the creek. Based on site constraints specific to the Sheehy Creek conservation easement, staff believes the findings can be met in support of the requested variation to the development regulations (see Attachment A).
5. Sheehy Creek - Sheehy Creek traverses the site from east to west and is located on the northern boundary of the proposed development area. The current configuration of Sheehy Creek, a jurisdictional watercourse, was re-routed to its present location between July 2003 and July 2004 based on aerial imagery, as part of overall development of the rest of the industrial park to the south. There are no jurisdictional culverts on-site required to reach the project area, and no crossings over Sheehy Creek are included as part of the proposed project. No riparian habitat would be removed or affected by the project. A 35-foot-wide Conservation Easement along Sheehy Creek was recorded in 2006 and extends approximately one mile along both banks of the Sheehy Creek riparian corridor. The northerly property line for the Building B site is coterminous with the centerline of the creek and includes the 35-foot side Conservation easement on the south side of the creek. However, the northerly property line of the project site for Building A includes the creek as well as the Conservation easement along both sides of the creek reducing the developable area of the site. The area encumbered by the Conservation easement counts as meeting the required landscaping along the rear property line pursuant to NCC Section 18.40.170(A)(5). Although no development is proposed within the Conservation easement, the project biologist is recommending that silt fencing be installed along the entire length of the Conservation Easement boundary in order to avoid any impacts to this watercourse. This recommendation is memorialized in the IS/MND as a mitigation measure and as a condition of approval attached.
6. Zoning and Winery Definition Ordinance (WDO) - The site of the proposed wine production facility zoned IP:AC (General Industrial: Airport Compatibility) District. The intent of the IP District is to provide areas exclusively for modern, non-nuisance light industrial and office uses which are compatible with each other and with adjoining non-industrial areas where applicable. Wine production facilities are conditionally permitted uses in the IP District. Because the proposed project would not operate within the County’s AW (Agricultural Watershed) or AP (Agricultural Preserve) districts, the project is not subject to the roadway setback, grape sourcing, and other requirements of County Code Sections 18.104.200 through 18.104.250 (WDO).
7. Public Utilities - Water services will be provided by the City of American Canyon and will be required to meet the City's Zero Water Footprint (ZWF) Policy, which may include contributing to the City's water conservation fund. Sewer services will be provided by Napa Sanitation District (NSD). Both agencies have indicated that there is capacity to serve the proposed project and have issued new will-serve letters.
8. Greenhouse Gas Reduction Strategies - The County requires project applicants to consider methods to reduce Green House (GHG) emissions consistent with the Napa County General Plan Policy CON-65(e), which requires GHG review of discretionary projects. The applicant has completed the Department’s Best Management Practices Checklist for Development Projects, which is attached to this report as Attachment E. The applicant intends to implement the following GHG reduction methods for both buildings: generation of on-site renewable energy; habitat restoration/new vegetation; electric forklifts, build to CALGREEN Tier 1 standards; solar hot water heating; exceed Title 24 energy efficiency standards; energy conserving lighting; energy star/cool roofing; bicycle incentives; connection to recycled water; water efficient fixtures; low-impact development (LID); water efficient landscape; electric vehicle charging station installation; design to maximize daylighting of interior spaces; and, limited grading. A condition of approval is included to require implementation of the checked Voluntary Best Management Practices Measures submitted with the project application.
9. Public Comments - Following the publishing of the original staff report in October 2024, staff received two lengthy comment letters from the law firm of Adams, Broadwell, Joseph, and Cardozo (Adams Broadwell)(Exhibit N) challenging the public review period due to lack of availability of the supporting documentation and a subsequent letter from Adams Broadwell questioning the conclusions in the IS/MND and a comment letter from Water Audit California (WAC)(Exhibit O). In addition, staff also received a letter from the California Department of Fish and Wildlife (CDFW)(Exhibit M) requesting specific changes to Mitigation Measures for Burrowing Owl, raptors, and other nesting birds. The applicant’s consultant, First Carbon Solutions (FCS), has prepared a comprehensive review and response document addressing all the comments and questions submitted to the County by Adams Broadwell and CDFW (Exhibit Q). The FCS memorandum also contains an Errata section where clarifying information and revisions to the IS/MND are provided for incorporation into the Final IS/MND. The revisions prepared by FCS represent minor technical changes, updates and clarification. None of the information provided in this memorandum or the Errata section includes information requiring recirculation of the IS/MND. As a result, and where appropriate, staff has supplemented the Biological Resources mitigation included in the IS/MND to better reflect comments from CDFW. A clarification to the impact discussion for Greenhouse Gases was also included. As a result, the IS/MND does not need to be recirculated for review, and the document can be adopted as modified in Attachment D. In addition, staff prepared a memo addressing the letter from WAC (Exhibit R). Previous comments not mentioned herein are included in Exhibit P.
Decision Making Options:
As noted in the Executive Summary Section above, Staff is recommending approval of the project with conditions of approval as described in Option 1 below. Decision making options including the following:
Option 1 - Approve Applicant’s Proposal with Project Specific Conditions of Approval
This option would result in approval of the proposed 450,000 gallon per year wine production facility and the adjacent warehouse building. Staff recommends this option as the request is consistent with the Zoning Ordinance, Specific Plan, applicable General Plan policies, and other County regulations. Furthermore, this option has been analyzed for its environmental impacts, which were found to be less than significant as mitigated.
Action Required - Follow the proposed action listed in the Executive Summary.
Option 2 - Reduced Project Alternative
Discussion - Although development in the business park area generally does not lend itself to reduced project alternatives such as floor area reductions, and/or restrictions on the number of employees, hours of operation or business operations, this option would reduce the scope of the project via reduced production.
Action Required - Follow proposed action listed in Executive Summary and amend scope and project specific conditions of approval to place limits on development. If major revisions of the conditions of approval are required, item will need to be continued to a future date.
Option 3 - Deny Proposed Use Permit Modification
Discussion - In the event the Commission determines that the project does not, or cannot meet the required findings for grant of a use permit or consistency with the General Plan, Commissioners should articulate what aspect(s) of the project is in conflict with required findings or General Plan, and either deny the request or continue the item to allow the applicant an opportunity to redesign the project.
Action Required - Commission should articulate the aspect(s) of the project in conflict with required findings or General Plan and either take action to deny the project or, if needed, remand the matter to staff for preparation of required findings to return to the Commission on specified date.
Option 4 - Continuance Option
Discussion - The Commission may continue an item to a future hearing date at its own discretion.
Supporting Documents
A. Revised Recommended Findings
B. Revised Recommended Conditions of Approval and Final Agency Approval Memos - Building A (P22-00307-UP)
C. Revised Recommended Conditions of Approval and Final Agency Approval Memos - Building B (P22-00308-UP)
D. Revised Initial Study/Mitigated Negative Declaration & MMRP
E. Use Permit Application Packets
F. Biological Resources Assessment
G. Transportation Impact Study
H. Water Supply Reports
I. Geotechnical Investigation
J. Stormwater Control Plans
K. Graphics
L. NVBPSP Wineries
M. California Department of Fish and Wildlife letter dated November 15, 2024
N. Adams, Broadwell, Joseph & Cardoza letter dated November 15, 2024
O. Water Audit California letter dated November 19, 2024
P. Other Public Comments
Q. First Carbon Solution Response to comment Memo dated November 10, 2025
R. Staff Memo dated November 20, 2025