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Letter: Housing at W. Napa hotel site reduces environmental impacts

Posted on July 7, 2017 by Sonoma Valley Sun

Including housing in the Hotel Project Sonoma plan for West Napa Street, as required by the parcel’s zoning, reduces the project’s environmental impacts. This is the conclusion of an analysis I have prepared on behalf of the appeal of the certification of the EIR by the Planning Commission, and in the absence of any formal analysis by the EIR consultants.

In fact, including housing reduces the traffic impact (trip calculation per the Institute of Traffic Engineers Trip Generation Manual, 9th edition) by a whopping 26% (midday afternoon peak) and reduces sewer flows (and contributing water use) by 30% (using the calculation methodology employed in the Draft EIR).  These reductions, as shown in the tables below, reflect having 24 housing units including eight studio apartments of 675 sq. ft., eight one-bedroom apartments of 820 sq. ft., and eight  two-bedroom apartments of 1,215 sq. ft. That leaves room for 21 hotel rooms of existing plan size in the remaining roughly 50% of the 67,478 sq. ft. project. The zoning requirement is that 50% of the built area is required to be housing, unless that requirement is waived.

During the appeal hearing on the 22nd of June, city staff spent one hour and fifteen minutes making its presentation, most of which was devoted to refuting the basis of the appeal of the EIR. In addition, the project applicant used thirty minutes to oppose our appeal, a total of one hour and forty-five minutes. The opportunity of appellants to present arguments and rebut staff’s position was thirty minutes, and there was no opportunity given for appellants to rebut the arguments of the project applicant’s attorney or architect.

Despite Planning Director Goodison’s opinion that a housing alternative was not necessary in the EIR, he nonetheless provided a verbal, off-the-cuff example of “twenty rooms” on an upper floor, and declared such a plan would not change the EIR impact analysis. He provided no basis for that opinion. Similarly, the project architect Michael Ross offered the same opinion, while complaining that “housing had not come up before.” A consultant who works with the Sonoma County Water Agency proffered the opinion that a 50/50 split of “31 units of housing and 31 hotel rooms” would increase water and sewer use. He did not explain the basis of his example or the methodology of his once again off-the-cuff analysis, though the idea of housing units the size of a hotel room was unique, if rather silly.

The point of my analysis is not to do the work of the EIR consultant, but to demonstrate that an analysis of housing has a legitimate role in a complete and thorough EIR. My analysis took approximately ten hours of work and calculation, which seems a modest amount of time to ascertain the environmental effects of adding housing to the project.

If the developers believe 21 hotel rooms is too small, they have the option of reconfiguring their plans; at present the current project plan uses less than 50% lot coverage on a site that allows up to 100% lot coverage. I am not an architect and will not presume to do that design work.

My hope is that this material will incline the City Council to take this issue seriously and ask the EIR consultant and city staff to include a proper housing alternative and its impact analysis in the EIR. It should have been included from the very beginning due to the zoning, and it’s not too late to include it now.

David Eichar, Sonoma Valley

NOTES: Water use is calculated using both the numbers given during public comment by the consultant to the SC Water Agency (100 gal/day per hotel room, 160 gal/day per apartment, which, incidentally don’t match the DEIR) and the DEIR APPENDIX  L:Water Analysis, Attachment 1 – Development Water Demand Calculations, shown below.

Water usage by hotel (exclusive of restaurant) = 17,544 gal/day before 30% reduction for water saving devices = 12280.8 gal/day (198.08 gal/day/room)

Attachment 3 – Water Connection and Service Fees
City of Sonoma, Resolution #56-2014
ESD = 561 Gal/day (ESD = equivalent single family dwelling)
Apartment: .47 ESD = 236.67 gal/day/unit.  Assume same 30% reduction = 184.569 gal/day/apt

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