TO: Airport Land Use Commission
FROM: Dana Morrison, Airport Land Use Commission (ALUC) Executive Officer
REPORT BY: Wendy Atkins, ALUC Staff Liaison
SUBJECT: City of Napa Renewable Resources Project 2.0
RECOMMENDATION
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CITY OF NAPA ANNEXATION / PRE-ZONING OF BIOMASS GASIFICATION FACILITY - AIRPORT LAND USE CONSISTENCY DETERMINATION (P25-00305). The Project is located south of 820 Levitin Way, Napa (APN: 057-090-087) and 600 Tower Road, Napa (APN 057-110-025). The properties are located on the southwest corner of the intersection of Tower Road and Devlin Road and to the north of the terminus of Tower Road, in Napa County, Airport Compatibility Zones B1 and B2.
Staff Recommendation: Approve the Special Conditions Exception request and find the project consistent with the Airport Land Use Compatibility Plan (ALUCP) subject to the recommended Conditions of Approval.
Staff Contact: Wendy Atkins; wendy.atkins@countyofnapa.org
Applicant: City of Napa (Chris Jones); (707) 257-9460; chrisjones@cityofnapa.org
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EXECUTIVE SUMMARY
The Project seeking ALUC review proposes the annexation of a 2.87-acre parcel (APN 057-090-087), and the construction of a new Biomass Conversion Facility (BCF). The Project would increase permitted throughput at the existing Napa Recycling and Compost Facility to an average of 1,000 tons per day (1,500 tons peak) to meet new state regulatory demands. In addition, the Project proposes to use a portion of the parcel to the north located at 600 Tower Road (APN 057-110-025) for inert (concrete, dirt, and gravel) materials processing and storage. These proposed expansions beyond the existing Diversion Facilities are subject to ALUCP review as these uses were not entitled, established or existing prior to the adoption of the 2024 ALUCP.
ENVIRONMENTAL IMPACT
ENVIRONMENTAL DETERMINATION: The Airport Land Use Commission’s (ALUC) Consistency Determination does not meet the definition of a "project" as defined by 14 California Code of Regulations 15378 (State CEQA Guidelines) and, therefore, CEQA is not applicable. The ALUC is only making a finding of consistency with regards to airport compatibility regulations and is not responsible for approving or undertaking the project. The City of Napa is the Lead Agency responsible for carrying out the project and the City of Napa has prepared a Draft Environmental Impact Report (January 2026, State Clearinghouse #2023110393). The City of Napa will determine if any additional required CEQA findings need to be made before taking final action on the proposed City of Napa Renewable Resources Project 2.0.
BACKGROUND AND DISCUSSION
Owner: City of Napa, Attention: Chris Jones, P.O. Box 660, Napa, CA 94559
Discussion: On February 20, 1991, the Napa County Conservation, Development and Planning Commission approved Use Permit Application No. U-90-29. On March 20, 1991, the ALUC approved the Napa County Conservation, Development and Planning Commission Use Permit Consistency Determination for Use Permit No. U-90-29. The project consisted of the establishment of a recyclable materials transfer center to include sorting, packing, and preparation for transport of various recyclable materials including outdoor composting of organic waste, and relocation of existing administration facilities and truck storage/maintenance of normal collection operations.
On August 15, 2012, the ALUC approved the City of Napa Annexation/Pre-Zoning of a Materials Diversion Facility (P12-00224-ALUC). The action consisted of the annexation and prezoning of six contiguous properties as PQ-P:AC (Quasi-Public, Public : Airport Compatibility Overlay) District.
The current Napa Renewable Resources Project 1.0 (NRRP 1.0) located at the Napa Materials Diversion Facility (NMDF) was approved in 2013 (Notice of Determination was filed in 2014) and through subsequent addenda. As a result of NRRP 1.0, a Conditional Use Permit (CUP) was issued by the City of Napa Planning Commission per Resolution PC-2013-15 (approved on November 7, 2013). This is the current CUP for the six core parcels owned by the City that make up the existing NMDF. Prior to the 2013 approval, a Mitigated Negative Declaration (MND) was prepared pursuant to the provisions of CEQA. The 2013 MND for NRRP 1.0 analyzed covered composting, a 20,000 tons per year (tpy) Anaerobic Digestion Facility (ADF), a 1.0- megawatt (MW) biomass gasification facility (BGF), installation of improved stormwater treatment facilities, and solar panels on the roof of the NMDF building and shop building. The 2013 MND also allowed food waste and co-collected food waste to be received at the facility, increased the permitted maximum storage of organics onsite at any one time from 60,000 cubic yards (cy) to 90,000 cy, and changed facility hours to 24-hour operations to operate the blowers for covered composting and operating and the future ADF.
The six core parcels owned by the City that make up the existing NMDF were annexed into the City of Napa through approval by the Local Agency Formation Commission (LAFCO) of Napa County on March 4, 2014. These six parcels have since been legally merged into a single parcel and are awaiting a new APN number from Napa County.
In 2014, the First Technical Addendum (July 2, 2014) to the 2013 MND was approved, which increased the peak design capacity of the approved ADF from 20,000 to 25,000 tpy, clarified the feedstocks for composting, and institutionalized the historical product depackaging operations.
In 2016, a Second Technical Addendum (May 24, 2016) to the 2013 MND Addendum addressed an increased peak daily tonnage, a shift from the initial 500 tpd to 760 tpd. Furthermore, this addendum responded to specific inquiries from the Bay Area Air Quality Management District (BAAQMD), providing additional analysis for the electric sort line and organics processing equipment replacing diesel-powered machinery.
The current proposed Project under review for compatibility is an expansion of the existing NMDF located at 820 Levitin Way (APNs 057-110-049, 057-110-052, 057-110-065, 057-110-066, 057-110-067, 057-110-068). The existing facility is a legally established land use which receives and processes all solid waste, compostable, and recyclable materials generated within the City of Napa that are collected by Napa Recycling and Waste Services and has been located at the site for approximately 35 years and receives up to 760 tons per day as allowed under their existing Solid Waste Facility Permit 28-AA-0030.
In 2023, the City of Napa purchased the 2.87-acre parcel immediately south of the existing Diversion Facility (APN: 057-090-087-000) where the new BCF is proposed. In order to deter birds from the existing NMDF site and the proposed BCF, Napa Recycling and Waste Services will install a long-range acoustic deterrent (LRAD). The LRAD system may reduce the number of birds onsite, the opportunity for bird strikes on airplanes, and the potential for aircraft crashes. The LRAD is a mobile speaker that broadcasts loud noise and/or bird calls to deter birds from the site. In addition, the Project proposes to use a portion of the parcel to north 600 Tower Road (APN 057-110-025) for inert (concrete dirt, and gravel) materials processing and storage. The Project would increase permitted throughput to an average of 1,000 tons per day (1,500 tons peak) to meet new state regulatory demands. These proposed expansions beyond the existing Diversion Facilities are subject to ALUCP review as these uses were not entitled, established or existing prior to the adoption of the 2024 ALUCP.
While the Project provides greater flexibility in developing and implementing processes and operations that ultimately divert organics from the landfill, decreases GHG emissions, increases the recovery of materials and energy from waste, and allows the facility to operate more efficiently and economically, the Project is incompatible with the ALUCP.
The applicant has requested a Special Condition Exception of the Napa Countywide Airport Land Use Compatibility Plan (ALUCP). Section 3.2.4 of the ALUCP states as follows:
Special Conditions Exception: The policies and criteria set forth in this ALUCP are intended to be applicable to all locations within an Airport Influence Area. However, there may be specific situations where a normally incompatible use can be considered compatible because of terrain, specific location, or other extraordinary factors or circumstances related to the site. After due consideration of all the factors involved in such situations and consultation with Airport management, the ALUC may find a normally incompatible use to be acceptable.
Under the Special Condition Exception, the ALUC may consider the Project’s following benefits:
1. Reduces greenhouse gases and produces carbon-negative byproducts.
2. Limits number of employees (up to three employees at a given time), which makes it less likely that an employee is inside the building and allows for faster egress from the building in the event of a potential aircraft crash.
3. Incorporates special building measures to reduce risks to building occupants in the event of an aircraft crash.
4. Avoids increased bird attraction to the area by using non-attractive woody feedstock. An LRAD system will be installed, which may reduce the number of birds onsite.
5. Complies with national standards, as the Federal Aviation Administration issued a Determination Letter, which concluded that the proposed structure does not exceed obstruction standards and does not present a hazard to air navigation and no risk to national security.
Details Related to Incompatibility.
Airport Land Use Consistency Factors:
1. Location - The Biomass Gasification Facility, is proposed to be constructed on a 2.87-acre parcel APN 057-090-087, south of the existing Napa Materials Diversion Facility (NMDF) located at 820 Levitin Way. Access to the parcel is located off of Devlin Road. In addition, the Project proposes to use a portion of the 8.32-acre parcel to the north located at 600 Tower Road, APN, 057-110-025) for inert (concrete, dirt, and gravel) materials processing and storage. Access to the parcel is located off of Trower Road. All aspects of the proposed Project are located within Airport Land Use Compatibility Zones B1 and B2. Airport Land Use Compatibility Zone B1 is characterized by aircraft overflying a low altitudes on final approach and straight-out departures-typically only 200 to 400 feet above the runway elevation. Zone B2 is characterized by aircraft on direction turning on 1L/19R to avoid turning over adjacent runway. Aircraft -especially smaller, piston-powered aircraft-turning base to final on landing approach or initiating turn to en route direction on departure; aircraft altitude typically less than 500 feet above runway, particularly on landing. The proposed Project was reviewed by the Federal Aviation Administration (FAA), who, determined that the Project could be compatible with current and future airport operations and flight patterns. The project was referred to the Napa County Airport Manager for comments. On May 12, 2026, a response was received providing support for the goals of the proposed Napa Renewable Resources Project (NRRP) and its plan to divert landfill disposal of local organic waste, reducing GHG emissions, and producing carbon-negative byproducts. However, the Airport Manager proposed that the potential risk from bird strikes to aircraft should also be a goal of the expansion. As recommended by the Airport Manager, Condition of Approval No. 2.0(a), has been included which states as follows:
“The Napa Renewable Resources Project (NRRP) 2.0 project shall complete a wildlife hazard assessment (WHA) leading to a wildlife hazard management plan (WHMP), to include baseline data, data after the imminent NRRP 1.0 modifications expected to reduce wildlife attractant and assess data after the proposed City of Napa NRRP 2.0 Project is implemented at the recycling facility. The WHMP will be prepared using the same biological expertise as the Napa County Airport WHMP. The airport will update its 2017 plan. The plans will identify relevant species and populations posing a danger to aircraft in the area, characterize the habitat, water, and food sources that are attractants to significant animal and bird populations, and identify recommended approaches based on data to coordinate habitat modification, hazing, and depredation activity. The scope of work for the Airport WHMP will adhere to FAA Advisory Circular 150-5200-33C and 150-5200-38.”
2. Land Use - The parcels are located in Airport Compatibility Zones B1 and B2. In the ALUCP, a ‘Power Plant’ is defined as “primary, peaking, renewable energy, bio-energy" is noted as an incompatible use in the B1 and B2 Compatibility Zones. This type of use is a Risk-Sensitive Land Use and not allowed in portions of an Airport environs regardless of the number of occupants associated with the use. Further, peaking, and renewable energy power plants; electrical substations; and other utilities are considered Critical Community Infrastructure, [ALUCP Chapter 3.4.9.(c)] and pertains to facilities where the damage or destruction of which would cause significant adverse effects to public health and welfare beyond the immediate vicinity of the facility.
The ALUCP defines “Incompatible” to mean that the use should not be permitted under any normal circumstances. Limited exceptions are possible for site-specific special circumstances. The intent of this criterion is to facilitate evacuation of a building if it were to be hit by an aircraft.
Chapter 5 [Exhibit 5-1, Notes (6)] of the ALUCP states that “No proposed use shall be allowed that would create an increased attraction for wildlife and that is inconsistent with FAA rules and regulations including, but not limited to FAA Advisory Circular 150/5200-33C, Hazardous Wildlife Attractants On or Near Airports and Advisory Circular 150/5200-34A, Construction or Establishment of Landfills near Public Airports. Of particular concern are landfills and certain recreational or agricultural uses that attract large flocks of birds which pose bird strike hazards to aircraft in flight. See Policy 3.5.3.” The proposed Project will result in less incompatibility than the existing Napa Materials Diversion Facility because organics are proposed to be processed “in-vessel” with the Anaerobic Digestion Facility, the woody feedstock does not attract birds, and it would not increase the bird attraction to the site. In addition, the Project proposes to install a LRAD wildlife deterrent system.
Furthermore, Condition of Approval No. 2.0(a) has been included to require that the NRRP 2.0 shall complete a wildlife hazard assessment (WHA) leading to a wildlife hazard management plan (WHMP). The plans will identify relevant species and populations posing a danger to aircraft in the area, characterize the habitat, water, and food sources that are attractants to significant animal and bird populations, and identify recommended approaches based on data to coordinate habitat modification, hazing, and depredation activity.
ALUCP Chapter 3.2.4 (Special Conditions Exception) states that there may be specific situations where a normally incompatible use can be considered compatible because of terrain, specific location, or other extraordinary factors or circumstances related to the site. In considering any such exceptions, the ALUC shall take into account the need for special measures to reduce the risks to building occupants in the event that the building is struck by an aircraft. In general, the risks to building occupants can be reduced by making the potential for a crashing aircraft to intrude into the building less likely, enhancing the building’s fire control measures, and/or enabling faster egress from the building in the event of an aircraft crash. Potential special measures for the Project could include using concrete walls, limiting the number and size of windows, upgrading the strength of the building roof, avoiding skylights, enhancing the fire sprinkler system (e.g., dividing fire sprinkler system into zones so that if one zone is compromised the others are functional), limiting buildings to a single story to enable faster evacuation of buildings, and increasing the number of emergency exits. The applicant has proposed the following special measures as part of the Special Conditions Exception request:
• Concrete walls separating wood chip storage/drying area from the gasification hall.
• Electrical and control room would have one hour minimum fire rated walls.
• A roof structure supported by structural steel with typical Z purlines and metal sheeting (currently propose but not finalized design).
• Limited window and no skylights.
• A minimum of two emergency exits per area.
• A sprinkler system enhanced by additional safety measures such as gas and flame detectors. These detectors trigger an alarm and the gasification process is immediately shut down and all gas is sent to emergency flares. There would also be an automated building exhaust system that would be triggered by these alarms for the building.
Included in the application is a Special Conditions Exception request and a description of special measures included with the Project. Provided the ALUC approves the Special Conditions Exception and makes specific findings as to why to exception is being made and that the land use will neither create a safety hazard to people on the ground or aircraft in flight nor result in excessive noise exposure for the proposed use, and make findings as to the nature of the extraordinary circumstances that warrant the policy exception, the Project may be deemed compatible with the ALUCP.
3. Concentrations of People - Exhibit 5-1 indicates that the Maximum Sitewide Average Intensity (people/area) for Compatibility Zone B1 as 50, and B2 as 100. Intensity criteria apply to all nonresidential uses including ones shown as “Normally Compatible” (green) and “Conditional” (yellow). Usage intensity calculations shall include all people (e.g., employees, customers/visitors) who may be on the property at any single point in time, whether indoors or outdoors. The usage intensities shall be calculated in accordance with the methodologies cited in Section 3.4. For the Project to be consistent with the maximum Sitewide Average Intensity, the APNs would be limited as follows:
• 820 Levitin Way 2.87-acre parcel APN 057-090-087 would be limited to a maximum of 57 people (2.87 x 50), the proposed BCF will have up to three employees and 10 to 20 customers circulating through the parcel at a time, which is less than the maximum and would be considered conditionally compatible.
• 600 Tower Road, APN 057-110-025 8.32-acre would be limited to a maximum of 416 people (8.32 x 50), this parcel is used for storage and typically has no employees onsite.
The proposed project, as designed and as conditioned and allowed under the Special Conditions Exception, can be found to be compatible with the concentration of people requirements noted in the ALUCP.
4. Building Height-ALUCP Chapter 3.52(b) restricts building height to 35-feet or as similarly provided by local ordinance. In addition, as is the case with all other local agencies subject to Napa County ALUC oversight (Napa County and the five incorporated cities/town), the City’s land use regulations allow a process for structures to exceed height limits within an Airport Influence Area subject to a Consistency Determination by the ALUC.
The Project involves the construction of a new 45 foot tall Biomass Gasification Facility. The Project will be designed to comply with all FCC construction requirements, technical standards, interference protection, power limitations, and radio frequency standards.
A Federal Aviation Administration Determination of No Hazard to Air Navigation, was issued on July 29, 2025, which concluded that the proposed structure does not exceed obstruction standards and does not present a hazard to air navigation. The proposed project, as designed, can be found to be compatible with building height requirements noted in the ALUCP.
5. Lighting and Glare - All exterior lighting for the Project would be located, designed, and shielded to confine direct rays (light) to the parcel with the lighting is located. Therefore, the Project would not create a new substantial source of light glare which would adversely affect day or nighttime views in the area.
6. Communications - As proposed, staff does not anticipate that the Project will affect airport communications. Electronic/ radio frequency output of telecommunication facilities are regulated by the FCC. FCC regulations do not enable local agencies to regulate electronic/ radio frequency aspects of these projects. The FCC is responsible for ensuring that all communication facilities subject to their regulations do not substantively impact FAA communication regulations for aviation. As stated above, the project will be designed to comply with all FCC construction requirements, technical standards, interference protection power limitations and radio frequency standards and there is no potential for conflict with the ALUCP.
7. Building Materials - The proposed project would include the use of appropriate building materials to be consistent with the surrounding industrial visual character and would comply with applicable City of Napa design Requirements and there is no potential for conflict with the ALUCP.
8. Overflight Easement - The ALUCP requires recordation of an overflight and aircraft hazard easement on all developing properties. As such, the current property owners, and future property owners will be aware that they are located in an Airport Influence Area. This will be included as a Condition of Approval No. 2.0(c) whereby there in no potential for conflict with the ALUCP.
9. Caltrans Aeronautics - ALUC staff referred the submittal materials to Caltrans Aeronautics on March 6, 2026, and Caltrans had no issues or comments on the project.
10. Processing - Subject to ALUCP Chapter 2.51, before a Local Agency either makes its general plan, specific plans, zoning ordinance, or district facilities master plan consistent with the ALUCP or Overrules the ALUC’s adoption of the ALUCP or consistency determination on a Land Use Action for which referral to the ALUC is required as enabled by law, the Local Agency must refer all Major Land Use Actions (see list in Policy 2.5.2) to the ALUC for review.
The ALUC defines Major Land Use Actions to include the following in Compatibility Zones B1 and B2:
• Pre-zoning associated with future annexation of land to a city.
• Nonresidential development having a building floor area of 10,000 sq. ft. or greater.
• Any other proposed Land Use Action or Airport Action not listed above as a Major Land Use Action which, as determined by the Local Agency, involves a question of compatibility with Airport activities.
General ALUC Review Process (Chapter 2.8)
Timing of Referral: The precise timing of the ALUC’s review of a proposed Major Land Use Action may vary depending upon the nature of the specific project.
a) Referrals to the ALUC should be made at the earliest reasonable point in time so that the ALUC’s review can be duly considered by the Local Agency prior to when the agency formalizes its Actions. Depending upon the type of Action and the normal scheduling of meetings, ALUC review can be completed before, after, or concurrently with review by the local planning commission and other advisory bodies but must be accomplished before final action by the Lead Agency.
The proposed project has met the processing requirements set forth in the ALUCP.
Decision:
The Review Process for Major Land Use Actions under the ALUCP is detail in Chapter 2.10.4.
The ALUC has four choices of action when making consistency determinations on Major Land Use Actions reviewed in accordance with Policies 2.5.1:
a) Approve the Special Conditions Exception and determine the project consistent with the Airport Land use Compatibility Plan subject to the recommended conditions of approval.
b) Approve the Special Conditions Exception and determine the project consistent with the Airport Land use Compatibility Plan, subject to compliance with such conditions as the ALUC may specify. Any such conditions should be limited in scope and described in a manner that allows compliance to be clearly assessed.
c) Continue the project to a future date if more information is found to be needed.
d) Deny the Special Conditions Exemption, and determine the Project inconsistent with the ALUCP. In making a determination of inconsistency, the ALUC shall note the specific conflicts upon which the determination is based.
a. Subject to ALUCP Section 2.12, the following is the Process for Overruling the ALUC:
i. If the ALUCP determines that a proposed Land use Action is inconsistent with the ALUCP, the ALUC must notify the Local Agency in writing and shall indicate the reasons for the inconsistency determination.
ii. If a Local Agency wishes to proceed with a proposed Land use Action or Airport Action that the ALUC has determined to be inconsistent with the ALUCP, or if the Local Agency wishes to ignore a condition for consistency, the Local Agency must Overrule the ALUC determination in accordance with the provisions of state law.
ALUC Procedural Requirements:
1. Open Public Hearing.
2. Staff Report.
3. Public Comment.
4. Close Public Hearing.
5. Motion, second, discussion and vote on item.
Staff Recommendation:
Approve the Special Conditions Exception and determine the project consistent with the Airport Land use Compatibility Plan subject to the recommended conditions of approval.
Attachments
A. Findings
B. Application
C. Project Description
D. Special Conditions Exception
E. Correspondence
1 Napa Renewable Resources Project 2.0 Draft EIR, RCH Group, Inc, 2026, p. 2-2
2 Group, Inc, 2026, p. 2-2
3 Group, Inc, 2026, p. 2-2
4 Group, Inc, 2026, p. 2-2
5 See Public Utilities Code Section 21670(a), 21676 and 21676.5 for specific procedures for overruling an ALUC. Further guidance is provided in the California Airport Land Use Handbook published by the California Division of Aeronautics (see beginning on page 5-15 of the 2011 edition). Chapter 1 of this ALUCP also summarizes the Overrule process to be followed by a Local Agencies in Napa County.