TO: Napa County Climate Action Committee
FROM: Brian D. Bordona, Director of Planning, Building & Environmental Services
REPORT BY: Jesse Gutiérrez, Principal Planner, Sustainability
SUBJECT: RCAAP CEQA review and Next Steps
RECOMMENDATION
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DISCUSSION AND POSSIBLE ACTION: RCAAP CEQA Review and Next Steps
STAFF REQUEST: Receive a presentation on the planned approach by the All Jurisdictions Working Group regarding the Administrative Draft and direct staff and Ascent to commence the CEQA (California Environmental Quality Act) review process immediately.
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ENVIRONMENTAL IMPACT
ENVIRONMENTAL DETERMINATION: The proposed action is not a project as defined by 14 California
Code of Regulations 15378 (State CEQA Guidelines) and therefore CEQA is not applicable.
BACKGROUND AND DISCUSSION
At the April 25, 2025 CAC meeting, Staff provided an overview of the internal review process of the Administrative Draft RCAAP (Administrative Draft) that would be initiated on the part of the All Jurisdictions Working Group (AJWG) [Napa County - File #: 25-683 <https://napa.legistar.com/LegislationDetail.aspx?ID=7318464&GUID=A08FC092-E1E6-4647-B0BF-0A783DEAEDB1&FullText=1>]. Staff reiterated the Administrative Draft will summarize the findings reported in the various technical memoranda and the Greenhouse Gas (GHG) Emissions reduction measures and the climate adaptation measures developed from them over the past several months, and that all memos and measures have been previously presented to the CAC members and vetted by the project team and staff from jurisdiction agencies. In addition, the Administrative Draft will include chapters on GHG Emissions, Climate Change Vulnerability, GHG Measures, Adaptation Measures, Plan Implementation & Monitoring, an Executive Summary, and Appendices. Ultimately, the purpose and intent of the internal review of the Administrative Draft was for staff to review and refine the document internally, at the administrative/staff level, before becoming a “public” draft.
During the review of the Administrative Draft by the AJWG and following related discussions, which included talks amongst city managers and jurisdiction representatives, a strong preference was voiced to allow for additional time for each city manager and executive staff to work more closely with their respective Boards and Councils to seek input on the RCAAP.
At the June 13 meeting hosted by city managers and County Assistant CEO, the AJWG and jurisdictional representatives agreed on the following:
1. To move forward with an Initial Study (IS) of the RCAAP.
2. Each municipality and their respective CAC members will be responsible for setting up and managing internal conversations during the month of July in order to better understand how the RCAAP will impact their jurisdictions.
3. Each municipality will provide opportunities in the month of August for the public and elected officials to comment on the public draft RCAAP (once released in August).
4. Each municipality will return to the CAC in September to present any feedback or proposed refinements of the RCAAP.
This measured approach is grounded in the desire for each jurisdiction’s boards/councils to further their understanding of the action items contained in the draft RCAAP relative to the distinct goals and priorities of each jurisdiction. This would also provide the opportunity for staff from each jurisdiction, with support from Ascent, CAC staff and the Napa County Resource Conservation District (NCRCD) as it relates to public outreach, while individual jurisdiction staff inform their respective boards/councils regarding the level of involvement and understanding of the RCAAP process to date.
Most jurisdictions within the AJWG indicated they would be working with their respective leadership and members of the community over the summer and concluding the efforts in September 2025. If, following those efforts, refinements to the RCAAP are necessary, they would be considered by staff and Ascent.
This approach would also serve to identify potential refinements to the project description earlier in the process that could influence the level and detail related to required CEQA. Along those lines, the AJWG agreed that it would be prudent to begin the CEQA process with the preparation of an Initial Study to determine if the project (i.e. Draft RCAAP) would have a significant effect on the environment. The Initial Study would provide decision makers with the basis for deciding whether to prepare an Environmental Impact Report (EIR), Negative Declaration (ND), or Mitigated Negative Declaration (MND).
What is an Initial Study?
An Initial Study (IS) can provide a robust and cost-efficient environmental analysis of the RCAAP. While an IS can provide a window into the level of CEQA review that will be required, the IS does not fully satisfy the CEQA requirements that would allow for a mechanism for member agencies to streamline the analysis and mitigation of GHG emissions for future discretionary projects that are subject to CEQA. The IS represents a first step in identifying the potential impacts of implementing the RCAAP and the recommended CEQA pathway.
Some policies, measures, and actions required in the RCAAP to achieve quantifiable reductions in GHG emissions may result in potentially significant effects on the environment that will require mitigation. “Where there is potential for environmental impacts that can be mitigated to a less-than-significant level, a Mitigated Negative Declaration (MND) can be prepared, with the IS used to provide substantial evidence to support the conclusion. If there is substantial evidence that any aspect of the project, either individually or cumulatively, may cause a significant effect on the environment, regardless of whether the overall effect of the project is adverse or beneficial, an EIR would be required (CEQA Guidelines 15063 [b][1]).” - Ascent CEQA Memo February 2025. The IS can also help “screen out” certain topics from detailed consideration in an EIR, if required. If it is determined that the RCAAP does not have a significant effect on the environment, a Negative Declaration (ND) can be prepared.
Ascent can prepare an Administrative Draft Initial Study with mitigation measures if potentially significant impacts are identified. Staff from all 6 jurisdictions would have a chance to review and comment on the draft IS.
The following are estimated costs and timelines associated with the IS pathways:
A. $130,000 for an Initial Study and Negative Declaration or Mitigated Negative Declaration (IS/MN or IS/MND). This option would take 6-9 months to complete. The IS pathway presents mitigation for all impacts determined to be potentially significant in support of an MND. The IS/MND would include a description of the RCAAP, identification of baseline environmental setting conditions, and identification of environmental effects. The analysis would include a checklist for each resource that mirrors the sample environmental checklist with brief discussions to substantiate the conclusions reached for each threshold.
B. $250,000-$350,000 for an Initial Study and Focused Program-level EIR (PEIR). This option would be time-intensive because it would result in the preparation of two reports and would take 12-18 months to complete. The IS pathway would be used to inform the scope of the PEIR, such that the PEIR would evaluate in detail only the impacts on resources that are determined to be potentially significant and require mitigation in the IS. The PEIR would describe the components of the RCAAP and the baseline environmental setting conditions and would identify the environmental effects of those topics that need to be fully analyzed (based on the findings of the IS). Potentially significant impacts and corresponding mitigation measures would be identified.
An environmental review document is required in the development of a CEQA-compliant GHG emissions reduction and climate adaptation plan. The RCAAP is a project under CEQA and a project is defined as “the whole of an action.” For the RCAAP, the whole of an action is the implementation of the RCAAP program, which consists of 46 proposed GHG reduction measures and 40 proposed climate adaptation measures. Important to note, this does not mean that every jurisdiction is expected to implement every single measure found in the plan. Rather, there are measures that apply to all jurisdictions, such as “developing and adopting a Zero-Carbon Buildings Reach Code for New Construction,” and there are measures that are more heavily weighted to a specified jurisdiction. For example, the Unincorporated County would be largely responsible for implementing the measures and accompanying actions to “Reforest burned areas with oak trees.”
Next Steps
With this item, staff request that CAC members work with their city/town management, municipal leadership, and municipal departmental staff to identify refinements if necessary to the RCAAP. Staff also requests CAC members work with their city/town management, municipal leadership, and municipal department staff to take the RCAAP Public Draft, once available in August, to their constituents and to their respective councils for feedback.
The project consultant team, Ascent Environmental, will be available upon request, to provide support during one council/board presentation per jurisdiction. CAC members and their municipal leadership can choose to have Ascent attend one of their meetings now or during the adoption phase (expected spring 2026). In order to remain within budget and scope there is only an opportunity for one meeting with Ascent per jurisdiction. Any additional support required from jurisdictions will be considered a separate cost for that particular jurisdiction.
The City Managers, Board CEO, and the project’s AJWG agreed in their meeting on June 13th that this is the best step forward in the development of the RCAAP to ensure that each of the jurisdictions understand the full scope of the commitments and resources this plan will require for implementation.
The Public Draft of the RCAAP is expected to be ready for public review in early August 2025. It is the responsibility of the CAC members, city management, and municipal departmental staff to share the Public Draft of the RCAAP (once released in August 2025) with the entire council/board of each jurisdiction and with constituents, in the manner they each see fit.
The County on behalf of the CAC has scheduled 2 public meetings to present the RCAAP to the public:
Wednesday, August 20 - Yountville Community Center, Heritage Room 6:00pm-8:00pm
Thursday, August 21 - American Canyon Public Library, Community Room 5:30pm-7:30pm
To provide time for the coordination between CAC members, city management, and agency staff the CAC will not meet in July and August. CAC members will return for the September 26 CAC meeting, at which time jurisdiction representatives (or CAC members) will be expected to present each municipality’s feedback or refinements to the RCAAP, if necessary. This is not an RCAAP adoption process.
Based on the CAC’s positive vote today, project staff will immediately direct Ascent to begin preparing a scope of work, budget, and timeline for the Initial Study of the RCAAP.
Moving the RCAAP forward successfully will require continued commitment, effort, and participation from all CAC member jurisdictions, including city/town management and departmental leadership and staff. The advantages of a regional approach to climate action and adaptation include the ability to share resources, coordinate grant and funding opportunities, leverage local and regional expertise, and work together to implement GHG emissions reduction measures and climate adaptation actions that strengthen communities and produce a compounded reduction in climate impacts on the region.