Napa Pipe Comments for the Planning Commission

What follows are my prepared comments on mainly the traffic issue for tonight's .

Comments to Planning Commission

Re: Napa Pipe for March 19, 2012 meeting

Upon reviewing hundreds of pages of material regarding this project, as well as sitting through numerous meetings, I have come to the conclusion that it would be best for the community to leave the property zoned industrial. On almost every point of benefit to the community, over the course of the last seven years since the project was first proposed, those benefits have evaporated.

Also part of the difficulty in responding is that we are now actually responding to two different projects, one of which appears to have been manufactured quickly by the county staff. The staff project purportedly has already been rejected by the developer, so why we are spending all this time on something that is dead before we begin is a mystery and not a productive use of anyone’s time.

What follows is some key points of concern and a more detailed look at the traffic problems this project will generate which is of major concern to me. Since the county reports that most of the impacts are similar between the developer’s project and theirs, assume my comments apply to both except where indicated.

Key points:

*Despite the developer's focus on removing some traffic from the commute from out of town, Napa Pipe will raise traffic levels on all the highways around it requiring costly road improvements that there is no money to pay for. Even if the money were there, many of them are infeasible, and will result in increased traffic problems in the area from then on. The idea that you could build a city of 5,000 people and not increase traffic is preposterous.

* Rail is not going to happen because Federal guidelines require a million or more residents along the line to even consider building it. A short rail line from Napa Pipe to downtown will cost millions of dollars to carry relatively few people—who is going to pay for it?

*Napa Pipe is not a "green" type dense development because it is not near a major transportation hub. It is just another big neighborhood or city in Napa which will have the same transportation uses as everywhere else—pretty much everyone in their cars.

* There are just as many people likely to move to Napa Pipe that work outside the county as will move in from outside who work here, thus adding to traffic and infrastructure issues without reducing work force commuting. This has been touted as a major benefit, perhaps THE major benefit of the project, but it does not hold up under scrutiny.

*Even if Napa Pipe uses groundwater as a backup it will violate longstanding agreements between the cities and county in Napa to only use groundwater for farming, thus threatening farming in Napa.

*Why should city residents in Napa pay high state project water rates to preserve that agreement when new residents are going to be able to tap essentially free local groundwater? If we are going to violate that agreement, shouldn't people already here be first in line?

*Napa Pipe is not in an urban area, it is in an industrial area. It is surrounded by ongoing industrial uses making noise, with air born dirt and chemicals, and is at least two miles from the nearest other house. Urban infill means that the next house over is next door, not next to a rock quarry. Urban centered dense development means you don't have to drive to get basic services like groceries and doctor appointments. This will not be the case with Napa Pipe. Residents will continuously be in their cars as much as anywhere else.

*Contrary to what most people seem to believe, any developer does not pay for the full cost of mitigation of negative impacts of a project. In Napa Pipe's case, many of the mitigations required in road improvements will only require a portion of the costs be paid by the developer. It is called “fair share” and the latest financial accounting states that the project will generate about an additional million a year in taxes. That amount won’t come close to paying for all the road improvements alone that will be required to mitigate the impact of the increased traffic, and the rest of the cost will fall on general taxpayer funds, in total, millions of dollars.

Further detail

Federal government guidelines to even consider intra-city rail is a minimum of 1 million people along the line itself. Even at that level a rail line loses money. At the time the was created, the attempt was actually being made to make that line a passenger line, but it was not financially feasible. The likelihood is that there will never be a rail service in Napa unless the population explodes to the point where it is a no longer a farming community. It is neither cost effective nor will it ease congestion in our situation.

Anywhere from 2,000 to 5,000 people are expected to live there depending on the plan adopted, and there is no reason to think that they will use their cars and go to work or shop any differently than any other neighborhood in Napa.

In an odd way, the fact that it is dense without the major traffic hub infrastructure makes it even worse. It is like a traffic bomb all in one spot, whereas putting the same number of units scattered through the rest of the county would be far more absorbable without as much of the negative impacts. It is in fact the reverse of a sustainable development. And that is even with a number of major road mitigations proposed to make it tolerable, mitigations which are not likely to get done in the next several decades.

The EIR calls for a number of very expensive traffic mitigations which will have to be done on state highways governed by Cal Trans. Some mitigations will have to be done by local governments as well. For example, on "south Soscol" or 221/Napa Vallejo Highway, which runs from Imola to the southern crossing at Hwy 29, this road is rated to carry 24,000-25,000 car trips a day. It now carries around 20,000, busy but within what are considered acceptable limits. If Napa Pipe gets built, the developer's own initial study stated that it would go to 29,000 additional trips per day, for a total of 49,000 a day. The developer then cut the number of units from 3,200 down to 2,580 and came up with only 15,000 additional car trips per day.

As the residential numbers continue to shrink, the actual traffic numbers are not going down further according to the brief additional SEIR prepared for the county for their new plan of 700-940 units, plus light industrial. So we are left with an overcrowded Hwy 221 with no relief in sight.

This includes the fact that the EIR states that 15 percent of the traffic will be taken off the estimate due to things like water taxis and a hired traffic management coordinator to get residents out of their cars. This perhaps accounts for the developer saying that 3200 residential units would cause a 29,000 trips a day increase on 221 and only 15,000 when you go down to 2,580 units.

However, these are things that are highly unlikely to make that kind of impact. How many people are going to go to work downtown in a water taxi that goes 5 miles an hour up the river and takes 45 minutes to go three miles? The other traffic management tools could be done in any other neighborhood or city/town in Napa now and they aren’t. Why? Because people won’t use them.

The proposed mitigation for 221 is to expand that road to 6 lanes, but the first problem with that and all the road mitigations  is that Cal Trans and the local governments have no money to do them, and will not for the foreseeable future. Before the recession, after much effort, Cal Trans put the plans for a "flyover"
at 29 and 221 on their schedule for 2030! Now that the recession and state
budget problems have arrived, they don't have the money for even that, and it may be decades before Cal Trans adds any new major projects. Also, they are so expensive that no developer could really be expected to pay for them.

The second problem is that the Hwy 221 mitigation is not feasible anyway, there is no room or right of way to do it, private property owners along the highway like Syar are highly likely to fight it, and on top of that it does not solve the traffic bottleneck at both ends of that stretch of road. If you don't have a bigger pipe to dump that traffic into at each end you have not improved the flow of traffic.

Moreover, if Cal Trans does the flyover then that means that there will only be one way in and out of the Napa Pipe development going north, and that is up 221. All morning traffic will flow towards downtown and across Imola to 29. This will create a huge bottleneck that there is no real answer for.

If Cal Trans doesn't do the flyover, then there will be an entrance off Soscol Ferry but that presents a whole new set of unsolvable problems, namely vastly increased traffic sitting at those lights which are already at unacceptable levels, which is why Cal Trans was going to do the flyover to begin with.

In the county’s new plan, their brief traffic SEIR supplement states that the negative impacts on intersections on Imola are even worse than the developer’s plan that includes 2,000 residential units. Again, there is no money to do the
mitigations, and even with the mitigations traffic will remain at Service Level
F. That is unacceptable.

An additional issue is that the City of Napa has already approved a new housing development of up to 500 units, plus a hotel, movie theaters and other shopping right on Imola as well. If all this development happens I feel sorry for the people living around Imola because they are going to be inundated with traffic.

Beyond the intersections on Imola, there is a claim in the new amended plan that 15 intersections will be less impacted under the county alternative than the proposed project, but the impacts in the proposed project were already significant.

Looking through the 2030 expected intersection service levels one sees intersections with Level F all through south Napa county as the result of this development. And that is with the mitigations in place, which again we do not have the money to pay for, the developer's fair share is 33 percent at most,
some it is around 4-5 percent of the actual cost. The rest of the cost will fall on
the taxpayers, and even if taxpayers can somehow pony up all this road money to
pay for the mitigations this is still unacceptable.

For instance, at First and Soscol, the level of service with mitigation will move from an E to an F—which the developer will not be responsible to cover. This is detailed on pages 48-52 of the Traffic section, 4.3, of the EIR.

The Second Major Traffic Problem

The other major traffic issue is the commuter traffic. The developer has frequently stated that over 21,000 cars commute into Napa for work every day. Napa Pipe's main selling point has been to be a place where a significant number of those commuters can be taken off the road by moving to Napa Pipe, thus justifying the large expansion of residents.

First of all that 21,000 number is very misleading, if not outright false. There may be 21,000, or even 29,000 as the Developer suddenly discovered at the date of the last planning commission meeting, or perhaps the 17,400 listed by the state Employment Development Department listed in Table 1 of the Napa Pipe fiscal analysis is the correct figure. I include a copy of that table as an attachment for your convenience.

There is definitely a credibility issue with all these various numbers, but in fact it doesn’t really matter. I will stipulate there are a lot of people driving into work from outside the county. But relatively few of them are likely to move in order to live at Napa Pipe to reduce their commute time, which has been repeatedly touted as perhaps the major benefit to the community of building this project.  

Examining the attached table from the 2009 Napa County
Transportation Plan, about 13,610 commuters are listed as driving into Napa
from outside the county, (yet another number for the same thing) and the only
way you can reach close to 21,000 is to include everyone who commutes within Napa, for example from Calistoga to St Helena.

Therefore that figure is including all kinds of commuters who are highly unlikely to move to Napa Pipe, because it would make their commute worse, not better. The fact is, 85 percent of Napans live in the city where they work now.  

The real issue is the number of commuters into Napa from Solano and Sonoma, which totals 9,171, because they are the most likely people to move to improve their commute to a south county location.

Breaking that number down it includes those who drive from Vallejo to American Canyon who are unlikely to move to Napa Pipe, further from their current commute.  

There are over 1,300 from Vallejo and Fairfield that commute into American Canyon, and 2,800 commute to the airport area.  That’s 4,100 commuters who are mostly living in homes and many have children, why would someone from Vallejo want to move to a townhome that costs more than their house to reduce their commute time slightly? Or even from Fairfield?

In Sonoma, we see that around 1,000 commuters live in the city of Sonoma or the unincorporated areas of Sonoma, and work in St. Helena, Calistoga or unincorporated Napa County. Why would those people move south of Napa when most are undoubtedly commuting north, many into Calistoga on 128?

When you go through and break down the actual commuters, where they live, and where in Napa they are going, you probably have a pool of closer to 3,000 people who would significantly improve their commute by moving to the Napa Pipe location, not 21,000. And that doesn't take into account whether they want to or not or whether they can afford to or not.

Another commuter issue that has not even been mentioned in any of the documents yet is affirmed by the NCTPA is that about the same number, 21,000, drive OUT of Napa every day to go to work elsewhere. The Napa Pipe location will be attractive to those who are commuting out, because of its proximity to the freeways, in all directions. It is likely that some of the units will be bought or rented by those who work outside of the county.

We could easily get in a situation where there are just as many or more moving into Napa Pipe who commute out of the county, as those who do work here moving in, such that there is no net commute benefit at all.

In any case, this number of 21,000 commuters being available to take living units at Napa Pipe is wildly misleading.   

The fact is that the majority of people who move into Napa Pipe will likely be new residents of Napa who don't already work here, or those living in Napa already who want to live there for reasons other than a reduced commute. We will simply be adding to the size of the county without reducing the current commute volume much, if at all.

In fact, it is quite possible that Napa Pipe will increase the number of those on the road to work simply by increasing the population of new residents who weren’t already working here. It will be growth-inducing and in the end lead to even more traffic. The last thing Napa needs to do is become even more of a residential community for other counties' workers than we already are. Yet Napa Pipe threatens to make that situation even worse.

Ironically, the one major road improvement that will take place before 2030 is the widening of Jamieson Canyon, which will make the commute from Fairfield even easier, and reduce the desire to move even more. Real estate in Napa will always cost more than Solano, and most people have families that want single family homes with a yard and neighborhood schools.  

Conclusion

There are numerous major negative impacts with insufficient mitigations, which will result in serious increases in the level of traffic congestion all around 221 and Imola Avenue, into downtown Napa and south to American Canyon. There is little money to pay for the mitigations and none coming in the foreseeable future, and the developer will not be responsible to pay for enough of them to make much of a difference, as little as 4 percent in many cases.

The county has said that it is required to show that there are compelling reasons for the benefit of the community to ignore those significant negative impacts which lack mitigations. There are no compelling reasons to ignore all these negative impacts. The county's RHNA state housing requirements no longer require this level of residential development, the City of Napa has offered to provide affordable housing within its city limits, and the city of American Canyon has also offered to build more county housing. This project will not substantially reduce the number of work commuters coming in to the county, in fact it may increase them.

The EIR should not be approved, the rezoning or general plan amendment should not take place, but rather this property should be maintained in its current industrial zoning.