On September 14, 2026, the City Council certified the programmatic EIR for the General Plan. The Certified EIR includes the Draft EIR and the Final EIR including Chapter 3 of the FEIR Errata (edits) to the DEIR, as well as the Mitigation Monitoring Program.
Chapter 2 Response to Comments
Mitigation Monitoring and Reporting Program
Environmental resource topic areas covered in the DEIR are listed below with links to each chapter.
Chapters 1-4 (Introduction, Project Description, Environmental Setting, Environmental Analysis Intro)
4.2 Agricultural & Forestry Resources
4.8 Hazards & Hazardous Materials
CEQA provides a scale that rates the potential environmental impacts of implementing the General Plan. These ratings include:
No Impact: an indicator that the General Plan will have zero adverse effects
Less Than Significant Impact: an impact is minor and falls below the legal threshold
Less Than Significant Impact with Mitigation: an indicator that the impact could be potentially significant, but that with mitigation imposed that impact is reduced to a level below significance
Significant and Unavoidable: Despite the incorporation of proactive General Plan policies and feasible mitigation measures, the potentially significant impact cannot be reduced to a less-than-significant level with certainty and is therefore considered significant and unavoidable.
While the DEIR analyzes all the topics listed above and finds that draft General Plan policies and existing regulations keep most impacts at a "less than significant" level, it identifies certain SU impacts. For long-range city planning documents like a general plan, SU impacts are not uncommon and provide transparency about the trade-offs involved in community growth. An SU finding in a General Plan EIR acknowledges the inherent uncertainty associated with long term planning efforts.
While the programmatic DEIR identifies certain SU impacts, those findings should not be understood as predictions that such impacts will necessarily occur. Rather, they are disclosures required by CEQA at a programmatic level, based on conservative assumptions and without the benefit of project-specific information. Additional environmental analysis will be completed on a project-by-project basis to ensure that all feasible mitigation to lessen impacts will be implemented. Accordingly, impacts identified at this stage may ultimately be avoided or substantially reduced.
It is important to distinguish between the broad goals and policies established in the draft General Plan and the future site specific implementation of those policies. An SU finding acknowledges that while the draft General Plan sets a trajectory for growth, the ultimate extent of potential impacts and the effectiveness of mitigation cannot be fully known until a specific project is proposed and evaluated. It also acknowledges the difficulty and inherent uncertainty involved with forecasting future environmental conditions, particularly where future changes in technology, regulatory standards, and baseline conditions may occur.
Additional project-level environmental analysis will be required as specific developments are proposed and individual projects will undergo site-specific environmental review. Unlike the programmatic analysis in the DEIR, project level determinations are based on precise designs and site specific conditions. This increased level of detail often makes it possible to avoid or reduce impacts that were identified as SU at the program level.
The General Plan DEIR identifies the following areas as having Significant and Unavoidable Impacts:
As the draft General Plan covers the entire planning area over a planning horizon of 25 years, the City cannot guarantee that every future private development or infrastructure project can avoid impact of a historic resource while still meeting mandated goals (such as housing density or safety requirements). Additionally, the draft General Plan cannot definitively identify all historic resources that may become significant over the General Plan planning horizon. Through robust policies and programs, the draft General Plan demonstrates an ongoing commitment to the identification, protection, and preservation of historic resources. The DEIR acknowledges this commitment while disclosing a SU impact due to the inherent uncertainties associated with long range planning. However, the City remains steadfast in our protection of historic resources and the draft General Plan policies remain effective in protecting them while also acknowledging potential worst case scenarios for the purpose of full CEQA disclosure. In other words, the SU finding is a disclosure required by CEQA at the program level, not a statement that the City’s historic preservation policies are ineffective.
Individual projects under the draft General Plan will include mitigation to protect historic resources on a project by project basis. Additionally, the draft General Plan includes goals, policies, and actions that enhance and build upon existing City regulations that protect historic resources by first identifying historical resources and, when historic resources are identified, reducing impacts due to development.
Proposed actions under Policy HR-1.2 would maintain the integrity of historic districts by:
Requiring adherence to City design guidelines, objective design standards, and the Secretary of the Interior’s Standards for review of development projects (Action HR-1.2.1);
Developing new historic district design guidelines to reflect best practices in the preservation field and address current challenges and development pressures to provide additional guidance on compatible and sensitive infill development. (Action HR-1.2.2);
Developing and implementing objective design guidelines for infill development within historic districts and adjacent to individual historic landmarks and to address the sensitive adaptation of existing buildings to retain historic integrity (Action HR-1.2.3).
Under Policy HR-1.3, the loss of designated and eligible historical resources would be minimized by:
Requiring Historic and Cultural Preservation Committee review of projects proposing to demolish designated and eligible resources that are 45 years or older (Action HR-1.3.1);
Requiring mitigative documentation of historic resources approved for full or substantial demolition (Action HR-1.3.4).
Under policy HR-1.4, projects subject to discretionary review must consider potential impacts to age-eligible properties with the potential to qualify as historical resources which is supported by:
Requiring the preparation of a historic resource evaluation early in the development review process (Action HR-1.4.1)
Analyzing project impacts based on the Standards to ascertain whether a development will impact a historic resource listed on or eligible for the NRHP, CRHR, or the local register (Action HR-1.4.2).
For more information on significant and unavoidable impacts on cultural resources , please see Chapter 4.5 Page 4.5-20 CUL-1.
CEQA requires comparing the draft General Plan’s total emissions against strict state targets, such as reducing emissions to 40% below 1990 levels by 2030 and achieving carbon neutrality by 2045. The City’s Blueprint for Climate Action establishes a pathway toward carbon neutrality in keeping with both state mandates and community values. This pathway includes a number of key actions to adopt a series of REACH codes, including a decarbonization REACH code, a solar plus storage REACH code, and CalGreen Tier 2 electric vehicle parking, and water efficiency standards. Other actions in the Blueprint rely heavily on voluntary private action such as participating in Sonoma Clean Power’s Evergreen program and exclusive use of electric lawn and garden equipment.
Recent state and federal mandates have created regulatory challenges that reduce Petaluma’s ability to adopt stricter local building regulations recommended in the Blueprint. This in turn has limited the City’s ability to conclude that the regulatory framework will ensure greenhouse gas emissions will be reduced by 40% below 1990 levels by 2030. As such, the DEIR identifies a SU greenhouse gas impact for the General Plan.
The City remains committed to greenhouse gas reduction as a primary climate initiative, and while there are currently federal and state regulatory limitations that prohibit the City from taking specific actions to reduce emissions, the City will continue to evaluate options for achieving carbon neutrality in alignment with the draft General Plan. The draft General Plan includes numerous goals, policies, and actions intended to reduce greenhouse gas emissions by supporting infill development, multimodal transportation, energy efficiency, electrification, and other climate-responsive land use and development strategies. Ongoing focus will be given to education and incentives to encourage the voluntary actions on behalf of Petalumans, consistent with the direction in the Blueprint. Additionally, at such time as there are lawful pathways to an effective regulatory approach consistent with the actions called for in the Blueprint, this SU impact may be reduced to less than significant.
For more information on significant and unavoidable GHG impacts, please see Chapter 4.7 Page 4.7-16 Impact GHG-1.
Facilitating urban infill means construction will inevitably occur near sensitive land uses (such as existing residences, schools, churches, and hospitals). While best available technology will be imposed to dampen these effects, there is a limit to how much heavy machinery noise can be suppressed during active construction. The SU finding does not mean that future projects will necessarily cause unacceptable noise levels, but it does acknowledge that over the 25+ years of the planning horizon under the draft General Plan update we cannot guarantee no significant impacts related to construction noise. The SU finding discloses the temporary, physical reality of urban infill and acknowledges that noise may be briefly perceptible above strict numeric thresholds during construction.
For more information on significant and unavoidable noise impacts, please see Chapter 4.11 Page 4.11-19 Impact NOI-1.
The draft General Plan includes an aggressive plan for increasing mobility options in Petaluma, including transit-oriented policies, increasing density around major transit hubs and along major transit routes, adding bike lanes, and eliminating parking minimums. CEQA analysis focuses on vehicle miles traveled (VMT) and sets standards for per capita VMT reduction. However, the draft General Plan would result in per capita vehicle miles traveled (VMT) that exceeds the City’s adopted threshold (16.8% below average) as well as the state's 2022 Scoping Plan reduction targets (25% below 2019 average by 2030 and 30% below 2019 average by 2045). This reflects the "VMT Paradox" where even strong policies may not fully offset regional travel patterns, such as commuting to nearby cities and a long-standing single family suburban development pattern.
Even so, the draft General Plan update actively shifts growth toward infill locations, station areas, and 15-minute activity centers to shorten trip lengths, encourage multimodal transit, and reduce per-capita VMT within the Plan Area relative to the existing General Plan. However, a VMT gap remains due to necessary regional commutes to major employment centers like Marin, San Francisco, and Santa Rosa. While ongoing regional transit improvements, such as SMART service expansions, will help reduce this VMT over time, an SU finding reflects the reality of current conditions, including regional travel patterns that rely heavily on single-occupancy vehicles, and the uncertainty around how regional travel patterns may change over the Planning horizon.
For more information on significant and unavoidable transportation impacts, see Chapter 4.14, Page 4.14-16, Impact TRA-2.
Notice of Preparation (NOP). The NOP is an important milestone in the General Plan update process. It initiates the environmental review process and is intended to provide an opportunity for the public, as well as local and state agencies, to provide comments on the scope of the environmental analysis. This NOP public comment period began on August 8, 2025, and closed on September 8, 2025.
Scoping Meeting. The City held an in-person scoping meeting on August 21, 2025, at the Petaluma Community Center. The scoping meeting provided an opportunity for the public to learn about the environmental review process and provide verbal comments on the scope of the environmental review.
Draft EIR. The DEIR was available for a 45-day public review period from March 27, 2026 to May 18, 2026.
Final EIR. The project team is preparing a Final EIR (FEIR), which will include written responses to comments received. The City Council held a public hearing and certified the EIR on September 14, 2026.