TO: Napa County Climate Action Committee
FROM: Brian D. Bordona, Director of Napa County Planning, Building & Environmental Services
REPORT BY: Jesse Gutiérrez, Principal Planner, Sustainability
SUBJECT: Updates and discussion on the Napa Regional Climate Action and Adaptation Plan (RCAAP)
RECOMMENDATION
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Receive a presentation on the status of the Final Napa County RCAAP and its accompanying Initial Study/Proposed Mitigated Negative Declaration (IS/MND) and direct staff to either 1) continue to prepare a CEQA-Qualified RCAAP for CAC vote for recommendation at the October 23 CAC meeting, or 2) prepare a Non-CEQA Qualified “framework” plan.
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BACKGROUND AND DISCUSSION
On August 28, 2026, the Climate Action Committee (CAC) received a presentation from Ascent Environmental on the Final RCAAP and the draft Initial Study/Proposed Mitigated Negative Declaration (IS/MND). The public comment period for the draft IS/MND closed on August 31. Staff are currently considering and drafting responses to comments received. Many of the comments received addressed policy choices in the RCAAP rather than the IS/MND or the adequacy of the environmental review. As required by CEQA, the Board of Supervisors as the lead agency, and the incorporated jurisdictions’ legislative bodies as responsible agencies, will consider every comment received before taking action on the project, which is the adoption of the RCAAP.
The RCAAP is a roadmap of strategies, measures, and actions to help the region reduce greenhouse gas emissions and adapt to climate change. Shaped by input from residents, businesses, community organizations, and staff across all six jurisdictions, it offers regionally-tailored solutions that reflect the unique environmental, economic, and social character of Napa County, and its cities and town. The plan builds on existing climate action and sustainability efforts already underway across the county, coordinating and amplifying them through a unified regional approach - one that will require bold, collaborative action across jurisdictional boundaries.
Structure of the Climate Action Committee. The Regional Working Group on Climate Change began meeting in September 2019, which became the CAC in October 2019. The following year the CAC moved forward with a Joint Powers Agreement (JPA) establishing the collaborative framework among the six jurisdictions. The purpose of the JPA is to establish a collaborative framework to allow member agencies to work on coordinated actions to reduce greenhouse gas emissions and limit the effects of future climate change. The twelve member CAC acts to share information, provide public education, promote events and grants, develop a regional climate action and adaptation plan, and identify mutually agreed upon climate goals and actions for consideration by member agencies. In 2021 and 2022, all six jurisdictions adopted resolutions or proclamations declaring a climate emergency and committed to a goal of net zero climate pollution by or before 2030.
The road to the CEQA Qualified RCAAP. The RFP for an RCAAP Consultant was released on September 15, 2023. Guided by direction from the CAC to develop a CEQA-qualified RCAAP, the RFP called for qualified consultants to develop a document that identifies specific actions and strategies to reduce greenhouse gas emissions and adapt to climate change within the jurisdictions in Napa County including City of American Canyon, City of Calistoga, City of Napa, County of Napa, City of St. Helena, and Town of Yountville.
The RFP stated that successful proposals will ensure compliance and consistency with CEQA Guidelines Section 15183.5 (Tiering and Streamlining the Analysis of Greenhouse Gas Emissions) to analyze and mitigate the significant effects of GHGs under CEQA at a programmatic level.
CEQA Section 15183.5 states that “Lead agencies may analyze and mitigate the significant effects of greenhouse gas emissions at a programmatic level, such as in a general plan, a long-range development plan, or a separate plan to reduce greenhouse gas emissions. Later project-specific environmental documents may tier from and/or incorporate by reference that existing programmatic review.”
Ascent Environmental was selected as the lead consultant to develop the RCAAP and signed a professional services agreement for the project on December 19, 2023.
Based on the 2019 Napa County GHG Emissions Inventory (published 2022) and on the RCAAP GHG Emissions Forecast (published 2024) in alignment with statewide GHG reduction targets and the ambitious goals and GHG reduction measures set forth in the RFP, the RCAAP outlines a feasible plan for achieving zero carbon emissions by 2045, with incremental targets for 2030 and 2035.
The magnitude of the RCAAP goals and the speed at which they should be implemented will require real commitments, through the adoption of ordinances, coordinated education and outreach efforts, and program development and come with financial obligations.
CEQA-Qualified RCAAP vs. Non-Qualified RCAAP
On August 28, 2026, the financial commitment and resources required to implement a CEQA-qualified RCAAP were expressed as concerns by several CAC members. In response to CAC members’ questions staff are providing additional details on a CEQA-Qualified RCAAP and Non-Qualified RCAAP.
CEQA-Qualified RCAAP
The RCAAP was developed to meet the requirements of a “plan for the reduction of greenhouse gases” as defined by CEQA Guidelines Section 15183.5 (i.e, CEQA-qualified). These requirements generally provide that the GHG analyses and specificity of measures and actions in such a plan must be based on substantial evidence and, where applicable, be specific and enforceable at the project level. The RCAAP includes many measures and detailed actions that support aggressive and immediate action, including 17 quantifiable GHG reduction measures to reach the initial 2030 and 2035 targets and keep the region on track to achieving the ultimate net-zero goal by 2045.
The primary advantage of having a CEQA-qualified RCAAP is the potential to streamline the GHG emissions analysis portion of environmental review for discretionary development projects. GHG emissions is one of the 21 environmental issues that may be analyzed in an environmental document under CEQA. To streamline the GHG analysis process for projects that are eligible for streamlining, projects must be found to be consistent with the RCAAP by demonstrating consistency with the RCAAP’s assumptions and incorporating applicable GHG reduction measures into the project. Streamlining GHG analysis can reduce developer and municipal costs associated with preparation of an environmental document such as an environmental impact report (EIR). However, such projects would still be required to conduct analysis on the 20 other environmental issues required by CEQA.
If JPA municipalities adopt the RCAAP in its current CEQA-qualified form but do not take action to implement measures as laid out in the plan, the RCAAP may lose its ability to be CEQA-qualified, and GHG analysis streamlining would no longer be an option for eligible discretionary projects in the region. Similarly, if some jurisdictions adopt and implement the plan but others do not, the RCAAP can no longer serve as a CEQA-qualified plan.
The RCAAP is a long-range 20-year plan and though not all implementation details are yet known, taking active coordinated steps towards implementation and monitoring and reporting on progress over time can provide insights into the feasibility and success (or shortcomings) of implementing certain measures. This information can then be used to make adjustments during the 5-year RCAAP updates to determine if some measures are not working as planned, need more time, or if alternate or new measures are needed.
The RCAAP currently provides a broad strategy for regional implementation and monitoring including preliminary funding and financing options, in-depth implementation cost estimates for 17 measures, and primary roles and responsibilities. After adoption of the RCAAP, the development of comprehensive and coordinated implementation strategies will be imperative and prioritized by jurisdictions for all near-term actions in the plan. Staff presented details to the CAC on April 24, 2026, regarding staff’s recommended RCAAP implementation and coordination approach and estimated costs.
Non-Qualified RCAAP
Having a CEQA-qualified RCAAP is voluntary. However, maintaining the CEQA-qualified status of the RCAAP is not necessary to realize the municipality’s shared commitment to a comprehensive climate action strategy, working towards the RCAAP’s established GHG reduction and climate adaptation goals, monitoring progress, pursuing grants, and implementing measures. An alternative path provides jurisdictions with the flexibility to implement measures and actions tailored to their specific needs and available resources by adopting a non-CEQA-qualified plan, or “framework” plan.
A Non-CEQA-Qualified or “framework” plan would offer the following features:
• could still drive action and maintain data-driven elements such as quantified measures and GHG emissions reduction targets through implementation, monitoring, reporting, and future 5-year updates to track each jurisdiction’s success in implementing GHG reduction measures.
• would maintain the intent of the RCAAP by keeping the goals, targets, and GHG reduction measures and adaptation measures in the plan intact, while giving jurisdictions more flexibility in implementing the measures and actions in the plan.
• would lose the benefit and eligibility of discretionary projects to streamline their GHG emissions analysis and mitigation under CEQA.
Budget Considerations
Moving forward with either option will require additional funding. The project budget for consultant support specifically for adoption hearings was re-directed by the CAC to support jurisdictions during presentations to their respective councils in summer 2025. Extensive public comments were received also necessitating additional support from Ascent to develop responses. However, the budget adopted by the CAC for FY 26/27 included placeholder amounts which can be utilized to provide support to jurisdictions at their adoption hearings, as originally intended. Therefore, it will not be necessary for CAC representatives to return to their respective councils for approval of additional funds.
If the CAC recommends continuing to pursue a CEQA-qualified plan, additional budget will be needed to prepare an errata sheet memorializing minor editorial changes necessary to complete the plan. If the CAC recommends pursuing a non-CEQA-qualified “framework” plan pathway, additional funding will be needed to make the necessary revisions to the RCAAP text, removing the CEQA-qualified elements in the plan, and providing a clean version of the Final RCAAP that reflects these changes.
Cost Estimates
Option 1: Keep RCAAP As Is (CEQA-Qualified)
• No revisions to RCAAP document
• Consultant attendance at all final adoption hearings and extend project management through February 2027
• Estimated contract amendment cost: $32,000
Option 2: Shift to Non-CEQA-Qualified RCAAP
• Produce Revised Final RCAAP document
• Limited attendance at adoption hearings and extend project management through December 2026
• Estimated contract amendment cost: $28,000
Next Steps
Receive a presentation on the status of the Final Napa County RCAAP and its accompanying Initial Study/Proposed Mitigated Negative Declaration (IS/MND) and direct staff to either 1) continue to prepare a CEQA-Qualified RCAAP for CAC vote for recommendation at the October 23 CAC meeting, or 2) prepare a Non-CEQA Qualified “framework” plan.
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.