Agenda packet — Healdsburg City Council, November 3, 2025 (part 2 of 4)

069 and 089-120-070; however, the APNs for 891 and 893 Grove Street are 089-120-116 and 089-120-117, respectively. This condition #1 should be clarified as follows: “The 13-bed residential care facility shall operate in accordance with Attachment 2 - Project Narrative; except as conditioned or modified herein. The Project Narrative shall be modified to state “The Ruse Treatment LLC seeks approval to expand from the approved use of 891 and 893 Grove St. Healdsburg CA 95548 as a 6 bed In Patient Substance Abuse Facility to a total of 13 beds on both Lots. The combined Lots consist of approximately 3 acres.”

2. Any modifications to the approved project must receive the prior approval of the City of Healdsburg. Minor modifications may be approved by the Community Development Department Director; however, major modifications, including any increase in the number of beds shall require Planning Commission approval.

3. This approval shall lapse and become void one year following the date on which the conditional use permit became effective unless the operation is commenced during such time, or a time extension is approved by the Community Development Director (LUC 20.28.185).

4. This conditional use permit shall be suspended automatically upon violation of any applicable provision of the Healdsburg Municipal Code or any of these conditions and may be revoked by the Planning Commission as provided by Land Use Code Sections 20.20.075 and 20.28.195.

5. The facility shall maintain all State of California licensing at all times (e.g., State Department of Health Care Services (DHCS).

6. Any events, including family group or similar programs, shall be limited to a maximum of 30 attendees and shall not include amplified sound.

7. All outdoor activities or events attended by clients and staff that produce noise outside of a traditional residential noise level as identified in Healdsburg Municipal Code Section 9.32.080, shall conclude by 8:00 p.m.

8. The chipseal driveway shall be maintained in order to minimize dust.

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9. The applicant shall investigate ways to reduce odors associated with the kitchen facilities.

10. Healdsburg Municipal Code Section 8.24.040 (Prohibition of smoking in public spaces and dwellings, multi-unit), prohibits smoking in all enclosed public spaces and multi-unit dwellings. Smoking shall be prohibited within 20 feet of entrances, exits, open windows or ventilation intake systems of any building and shall be restricted to the smoking areas identified below. In addition, smoking areas shall not be closer than 50 feet to any property line. [Note: However, the map associated with the conditions of approval still had the smoking area next to the Koi pond and in the rear center next to the Pickleball area.]
Additional Conditions Proposed by Appellants

1. The facility shall post a code of conduct and client rights, drafted by the facility, in locations clearly visible to clients and their family members.

2. Meal preparation shall be limited to three (3) meals a day – breakfast, lunch, and dinner – prepared and served during specific time periods.

3. The facility shall install ventilation in the kitchen in the pavilion so as to minimize odor and noise to adjacent properties.

4. Prior to commencement of the use, the applicant shall work with the adjacent neighbors to establish a "good neighbor policy" to address potential nuisances such as, for example, noise, loitering, and trash and enforcement mechanisms.

The policy shall include a process for handling and responding to neighborhood and community complaints by providing a 24-hour phone number and email address and shall be delivered to each parcel within 100 feet of the property boundaries.

5. Prior to commencement of the use, the facility shall plant bushes and/or trees along the fence line adjacent to 851Grove Street adequate to provide privacy screening.

6. The facility shall not be rented out to the community for any purposes.

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7. Only staff and clients may use the pickle ball courts and only on a pick-up game basis.

8. There shall be no amplified sound on the site at any time.

9. Clients of the facility may not drive their personal vehicles to the facility and/or park their personal vehicles on site.

10. Clients of the facility will not be free to come and go as long as they are clients.

11. The gates to the site shall remain closed at all times. Clients and visitors must use an intercom system to enter the site.

12. The premises shall prominently display signage identifying the name of the facility and the street address number next to or on the fence and/or call box at the entrance to the premises.

13. The conditions imposed by the Healdsburg Fire Marshal and Healdsburg Police Department in response to agency referrals, both attached hereto.

The October 15, 2025 Meeting
On October 15, 2025, neighbors (appellants plus additional neighbors) and Keith Greenberg met to discuss possible settlement prior to the City Council hearing on the appeal. Both sides expressed interest in coming to an agreement on agreed upon conditions. The following summarized Keith’s position on behalf of the Applicant and Appellants’ counter-proposed condition, where appropriate.

1. The facility shall post a code of conduct and client rights, drafted by the facility, in locations clearly visible to clients and their family members.

Keith confirmed a code of conduct is a state licensing requirement but would not share The Ruse’s code of conduct with the neighbors, only a generic version with us. It is not clear why he would not disclose The Ruse’s code of conduct with the neighbors. Keith would not agree to post the code of conduct on site.

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Appellants’ Proposed-Counter Condition: The facility shall ensure clients and their family members are provided with a code of conduct and client rights.

2. Meal preparation shall be limited to three (3) meals a day – breakfast, lunch, and dinner – prepared and served during specific time periods.

Keith stated that the facility will have set meal hours and not operate like a restaurant open 24/7. That said, the schedule may shift due to activities and he would not commit to a daily set schedule. He further stated the kitchen may be used at night or when intakes are taking place during odd hours on rare occasion. He seemed to be willing to agree that the kitchen would not prepare food after 8 p.m.

Appellants’ Proposed-Counter Condition: Meal preparation shall generally be limited to three (3) meals a day – breakfast, lunch, and dinner – prepared and served during specific time periods with the allowance for the rare, only when necessary, meal preparation outside of this schedule but not past 8:00 p.m.

3. The facility shall install ventilation in the kitchen in the pavilion so as to minimize odor and noise to adjacent properties.

Keith stated that they would investigate options to reduce noise and agreed the fan will be turned off when not in use.

Appellants’ Proposed-Counter Condition: The applicant shall investigate ways to reduce odors and noise associated with the kitchen facilities and shall implement any viable solution. The facility shall install baffling around the kitchen fan and the fan will be turned off when not in use.

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Keith would not agree to this reasonable condition but offered the phone number of the out-of-state executive director of the treatment center named Brian.

Appellants continue to request this condition on appeal.

5. Prior to commencement of the use, the facility shall plant bushes and/or trees along the rear yard fence line adjacent to 851Grove Street adequate to provide privacy screening.

Kieth agreed to raise the height of the rear yard fence to increase privacy.

Appellants’ Proposed-Counter Condition: Prior to commencement of the use, the facility shall raise the rear yard fence line adjacent to 851Grove Street adequate to provide privacy screening.

6. The facility shall not be rented out to the community for any purposes.

Keith stated the facility plans on hosting AA or NA community meetings on site. This use was not revealed in the CUP application nor at the Planning Commission hearing. In fact, at the hearing, he stated the facility would not be rented out for events.

Appellants continue to request this condition on appeal. This use has not been evaluated including the effects of participants’ smoking and traffic.

7. Only staff and clients may use the pickle ball courts and only on a pick-up game basis.

Keith agreed to this however wants it to include consultants to memorialize the fact that not all of their workers or program staff will be employees.

Appellants’ Proposed-Counter Condition: Only staff, including employees and consultants, and clients may use the pickle ball courts and only on a pick-up game basis.

8. There shall be no amplified sound on the site at any time.

Keith agreed generally but then he still wanted to be able to use the speakers to play music by the pool area. I think there needs to be some sort of reasonable sound level that Item 7.b
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is allowed but an agreement for no amplified musical instruments, no microphones for events or meetings outdoors, etc.

Appellants’ Proposed-Counter Condition: There shall be no amplified musical instruments or microphones on the site at any time; however, the facility may play low music (no rap, heavy metal, or the like) in the pool area on occasion.

9. Clients of the facility may not drive their personal vehicles to the facility and/or park their personal vehicles on site.

Keith would not agree to this despite the fact he stated at the Planning Commission hearing “clients will not be driving their personal vehicle” to the facility.

Appellants continue to request this condition on appeal.

10.Clients of the facility will not be free to come and go as long as they are clients.

Keith agreed to this restriction but would not include it as a condition. Appellants’ goal is to capture Keith’s statement at the Planning Commission that clients will not be free to come and go, i.e., will not be walking around town or to the corner 7-11, for example, but will leave the site for planned off-site activities accompanied by staff members or to voluntarily cease treatment at the facility.

Appellants’ Proposed-Counter Condition: Clients of the facility will not be free to come and go as long as they are clients; however, clients may leave the facility to attend planned off-site activities accompanied by staff members.

11. The gates to the site shall remain closed at all times. Clients and visitors must use an intercom system to enter the site.

Keith agreed but would not include it as a condition due to instances when the gate is broken or it needs to be left open on trash pick-up day.

Appellants’ Proposed-Counter Condition: The gates to the site shall remain closed except when necessary to remain open for trash pickup or in the event it is broken. Clients and visitors must use an intercom system to enter the site.

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12. The premises shall prominently display signage identifying the name of the facility and the street address number next to or on the fence and/or call box at the entrance to the premises.

Keith would not include it as a condition because they wish to keep the name of the facility low profile. However, after walking the site with a neighbor, he saw where there were signage issues.

The concern of the adjacent neighbors is to discourage clients and other visitors from mistaking their property for facility and walking up their driveway and knocking on their door, as currently happens.

Appellants’ Proposed-Counter Condition: The premises shall display signage identifying the name of the facility and the street address number next to or on the fence and/or call box at the entrance to the premises. The signage may be low profile but must be visible to clients and other visitors.

13. The conditions imposed by the Healdsburg Fire Marshal and Healdsburg Police Department in response to agency referrals, both attached hereto.

Keith would not agree to this condition.

Appellants continue to request this condition on appeal. Fire and police requested these conditions in response to agency referrals. Agency requests are routinely included as conditions of approval of a project.

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CITY OF HEALDSBURG

CITY COUNCIL AGENDA STAFF REPORT
MEETING DATE: November 3, 2025
SUBJECT: Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for the Badger Park Redevelopment Master Plan project located at 750 Heron Drive and Final Master Plan for the Redevelopment of Badger Park
PREPARED BY: Tom Campbell, Project Manager
STRATEGIC INITIATIVE(S):
- Maintain and Improve Infrastructure and Facilities
- Provide Resident-Driver Community Services
RECOMMENDED ACTION(S):

Adopt a Resolution adopting a Mitigated Negative Declaration (MND) and the Mitigation Monitoring and Reporting Program (MMRP) for the Badger Park Redevelopment Master Plan project and approving the final Badger Park Redevelopment Master Plan COMMUNITY ENGAGEMENT/OUTREACH:

The final redevelopment master plan for Badger Park (the “Badger Park Redevelopment Master Plan” or “Master Plan”) involved significant community outreach, engagement and input including:
• The Parks Design Team, a group of approximately 30 community members representing different demographics in the community, met 13 times throughout the planning process to guide the project.
• 11 focus group work sessions with park user groups, sports associations, partner organizations, outdoor recreation businesses, residents of the Parkland Farms neighborhood, and City officials and staff.
• Open house events (virtual and in-person) and an online survey.

BACKGROUND:

In July 2019, the City launched a public process to develop a master plan for the redevelopment of Badger Park. Fletcher Studio, a landscape architecture firm, led the process with a group of community members called the Parks Design Team who served as the steering team for the Master Plan.

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In 2021, the City Council reviewed a draft of the Badger Park Redevelopment Master Plan, expressed support, and directed staff to move forward with preparation of the appropriate environmental analysis for the City Council’s consideration of the Master Plan.

In March 2023, the City engaged Raney Planning & Management to complete the required analysis in accordance with the California Environmental Quality Act (Pub. Res. Code § 21000, et seq.) (“CEQA”).

In May 2024, the City Council directed that the Badger Park's first phase of redevelopment focus on river access improvements and flush toilet restrooms in accordance with the $1,000,000 matching grant the City was awarded from the Sonoma County Agriculture Preservation and Open Space District.

The City of Healdsburg adopted CEQA Implementation Procedures on April 2, 2012 (City Council Resolution 28-2012). CEQA Guidelines require that each local agency adopt procedures for implementing CEQA. The intended objectives of the CEQA Implementation Measures are to:
• Protect the local and surrounding natural environment to promote a high quality of life, provide a foundation for economic development, and retain the unique aesthetic values of the community.
• Provide a succinct guide for use by City staff, residents, project applicants, City decision makers, and interested organizations, in such a way that the City’s CEQA implementation procedures may easily understood and interpreted.
• Ensure and encourage public access and participation in the environmental review process for projects.
• Promote the integration of project planning and decision making with the environmental review process in order to incorporate project design and measures intended to protect the environment and avoid or reduce environmental impacts.

The City’s process for adopting a Mitigated Negative Declaration (MND) includes the preparation of the MND, Public Notice, distribution to the State Clearinghouse, County Clerk, and complete the public review period of 30 days.

Staff published the Notice of Intent (NOI) to adopt an MND to the Press Democrat and Healdsburg Tribune on August 28, 2025 and mailed to all property owners within 500’. Staff also published the NOI/MND with the State Clearinghouse (SCH 2025090049) and the Sonoma County Clerk.

The public review period ended on September 26, 2025.

In regard to complying with the provisions of CEQA, the Healdsburg Planning Commission is responsible for reviewing, commenting, and forwarding a recommendation on a draft MND and recommending approval or denial of a project subject to action by the City Council.

On October 14, 2025, the Planning Commission conducted a public hearing to consider the Mitigated Negative Declaration and the Mitigation Monitoring and Reporting Program and adopted a resolution recommending that the City Council approve the MND and MMRP for the Badger Park Redevelopment Master Plan.

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DISCUSSION/ANALYSIS:

Park Redevelopment Master Plan
The master plan for the Badger Park redevelopment project is the outcome of numerous requests to install flush-toilet restrooms in the park, the desire to enhance river access for the community, and address aging infrastructure and components like the play structure. Rather than tackle these issues one at a time, the master plan proposes a long-term, comprehensive plan to improve the park and enhance access to the Russian River. The park will be redeveloped in multiple phases due to cost and available funding.

The resulting Badger Park Redevelopment Master Plan (“Master Plan”) incorporates these goals by:
• Opening up the vegetation by removing invasive species and selective clearing, improving trails, and updating amenities;
• Expanding parking;
• Expanding the community garden;
• Adding sports courts (the specific types of sports would be determined during the design development stage);
• Adding restrooms; and
• Adding various river access points including a canoe and kayak launch.

In 2021, City Council reviewed the proposed Master Plan and directed that the proposed Master Plan undergo the required environmental review. As described below, the Master Plan will not have a significant effect on the environment because the City has made certain revisions in the project. A Mitigated Negative Declaration has thus been prepared.

ENVIRONMENTAL STEWARDSHIP:

The Badger Park Redevelopment Master Plan contemplates an overall approach towards low impact design. Implementation of this would be addressed during the detailed design development stage.

ALTERNATIVES:

The City Council could choose not to adopt the Mitigated Negative Declaration (MND) and the Mitigation Monitoring and Reporting Program (MMRP) and/or not approve the Badger Park Redevelopment Master Plan and provide direction to staff.

FISCAL IMPACT:

The Badger Park Master Plan is a conceptual document that will help guide future redevelopment of the park. Approval of the Master Plan will have no direct fiscal impact. Further, adopting the Mitigated Negative Declaration and the Mitigation Monitoring and Reporting Program for the Master Plan project will not have a fiscal impact. However, individual projects that are proposed in the future would need to comply with the Mitigated Negative Declaration and Mitigation Monitoring requirements. These requirements and associated costs would need to be determined and incorporated in the project costs.

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ENVIRONMENTAL ANALYSIS:

Raney Planning and Management prepared a Mitigated Negative Declaration (MND) for the Master Plan project in compliance with the California Environmental Quality Act (CEQA). The MND assessed all environmental factors related to the redevelopment of Badger Park as presented in the Master Plan. The MND was made available for a 30-day public review period from August 28, 2025 to September 26, 2025. The MND document is provided as an attachment and the Resolution for adoption of the MND includes the Mitigation Monitoring and Reporting Program as Exhibit A.

The MND identifies areas where mitigation is necessary to reduce potentially significant impacts to less than significant in the following areas: Biological Resources, Cultural Resources, Geology and Soils, Noise, and Tribal Cultural Resources. There were no impacts that required mitigation in the following areas: Aesthetics, Agriculture and Forest Resources, Air Quality, Energy, Green House Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise, Population and Housing, Public Services, Recreation, Transportation, Utilities and Service Systems, and Wildfire.

The MND is supported by the following studies, which are included in the Appendix to the MND:

Air Quality and Greenhouse Gas Modeling Results, Biological Resources Assessment, Aquatic Resources Delineation, Environmental Noise Assessment, and Transportation Initial Study Checklist.

The conclusions of the environmental assessment are summarized as follows:
• Biological Resources - Given Badger Park’s riverfront location, the Biological Resources Assessment outlines the Master Plan’s potential to result in adverse effects to SpecialStatus Plants and Wildlife. The implementation of several mitigation measures will reduce these impacts to less than significant.
o Mitigation Measures IV-1 and IV-2 require that a qualified biologist conduct protocol rare plant surveys and if any rare plants are found, areas planned for clearing of vegetation or construction of recreational uses shall avoid those locations.
o Mitigation Measures IV-3, IV-4, and IV-5 require that water work in the Russian River be scheduled when water levels are low during dry season and that efforts be made to minimize temporary construction impacts and consequent erosion and sedimentation impacts to habitat for special status fish species. o Mitigation Measures IV-6, IV-7, IV-8, IV-9, and IV-10 require that a qualified biologist complete surveys for Foothill Yellow-Legged Frog, Western Pond Turtle, Osprey, Nesting Bird Species, and Special-Status and Common Roosting Bats. o Mitigation Measure IV-11 requires that post-construction measures be implemented to reduce the adverse effects of unnecessary artificial light, vehicles, and sedimentation. It also requires that the “willow island” portion of the site be treated as a protected habitat area set aside for conservation purposes which visitors shall not access.

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o Mitigation Measures IV-12, IV-13, IV-14, IV-15, IV-16, and IV-17 will reduce potential adverse impacts to riparian habitat by requiring that improvements within the forested portions of the site be placed within areas specifically vegetated with an abundance of non-native vegetations, ensuring no net loss of native trees, developing a Native Tree Mitigation Program, and monitoring and maintaining revegetation efforts for five years.
o Mitigation Measures IV-18, IV-19, IV-20, IV-21, and IV-22 will reduce potential adverse impacts to State of Federally protected wetlands by designing improvements so that they avoid these areas and obtaining the necessary permits from the US Army Corps of Engineers, California Department of Fish and Wildlife, and the Regional Water Quality Control Board.
o Mitigation Measure IV-23 requires that a qualified biologist shall be retained to provide training and monitoring during construction to minimize potential adverse impacts to resident or migratory fish and wildlife species. • Cultural Resources, including Tribal Cultural Resources – The Cultural Resources Study identifies a high potential/sensitivity for archaeological resources on site. The project shall comply with Mitigation Measures V-1, V-2, V-3, V-4 and XVIII-1, which require the engagement of a qualified Secretary of Interior archaeologist to conduct awareness training for construction workers, conduct spot monitoring of project-related ground disturbing activities, and evaluation of any potentially significant cultural resource that is encountered.
• Geology and Soils - The proposed Master Plan has the potential to result in liquefaction and soil expansion on site. The project shall comply with Mitigation Measure VII-1, which requires that a California Civil Engineer or Geotechnical Engineer conduct a Geotechnical Analysis to characterize the subsurface conditions of the project site. The report shall be completed prior to final design-level drawings.
• Noise – Operation of the redeveloped park could result in a permanent increase in ambient noise levels in the vicinity of the park in excess of the City’s noise standard due to noise sources associated with the proposed athletic amenities, such as the sports courts and parking lot traffic circulation. The project shall comply with Mitigation Measure XII-1, which requires the construction of a six-foot-tall noise barrier wall at the northern boundary of the project site if pickleball courts are included in the final design-level drawings.

Conclusions
While it was found that the Master Plan project could have a potentially significant effect in the areas above, there will not be a significant effect in this case because mitigation measures are identified that will reduce those potentially significant effects to less than significant. The Mitigation Monitoring and Reporting Program (MMRP) attached to the resolution was created to track the mitigation measures outlined in the MND, including when they are to be implemented and what department is responsible to ensure that mitigation is completed in accordance with the MND and MMRP. No comments were received on the MND.

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Community Services Department staff will ensure that the Mitigation, Monitoring and Reporting Program put forth in the Mitigated Negative Declaration will be followed during implementation of the Master Plan.

ATTACHMENT(S):

Resolution including Exhibit A: Mitigation Monitoring and Reporting Program Mitigated Negative Declaration
Badger Park Redevelopment Master Plan
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CITY OF HEALDSBURG
RESOLUTION NO. -2025

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

HEALDSBURG ADOPTING A MITIGATED NEGATIVE

DECLARATION AND MITIGATION MONITORING AND

REPORTING PROGRAM FOR THE BADGER PARK

REDEVELOPMENT MASTER PLAN PROJECT LOCATED AT
750 HERON DRIVE (APNS 002-221-021, 002-281-012, 088-141- 012, -015, AND -016) AND APPROVING THE BADGER PARK

REDEVELOPMENT MASTER PLAN
WHEREAS, the City of Healdsburg (the “City”) launched a master planning process in 2019 for the development of a Badger Park Redevelopment Master Plan; and WHEREAS, in September 2021 the City Council received an update on the master planning process and directed staff to move forward with CEQA documentation for the Badger Park Redevelopment Master plan; and
WHEREAS, in August 2023, the City Council approved a Professional Services Agreement with Raney Planning & Management for CEQA work and an aquatic resources jurisdictional delineation for the Badger Park Redevelopment Master Plan project (the “Project”); and
WHEREAS, the City of Healdsburg is the Lead Agency on the project and pursuant to Public Resources Code Section 21080.1 and Section 15063 of the CEQA Guidelines (Title 14, California Cose of Regulations), an Initial Study was prepared for the project to determine whether there are potentially significant effects on the environment attributable to the Project; and
WHEREAS, based on information contained in the Initial Study, included in the project file, that any potential significant effects of the project could be avoided or reduced to less than significant with the addition of mitigation measures, a Mitigated Negative Declaration (MND) was prepared for the project and was circulated for a 30-day public and agency review period, from August 28, 2025 to September 26, 2025; and
WHEREAS, a Notice of Intent to Adopt the Initial Study and Mitigated Negative Declaration was published in the Press Democrat (a newspaper of general circulation in the area), mailed to property owners within 300 feet of the project boundary, posted at the Office of the Sonoma County Clerk, and circulated through the State Clearinghouse; and WHEREAS, the Mitigated Negative Declaration and supporting Initial Study were made available for public review during the public review period noted above; and WHEREAS, at a properly noticed public hearing on October 14, 2025, the Planning Commission reviewed the staff report, the MND (including appendices), and the Mitigation Item 7.c
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Resolution No. ______

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Monitoring and Reporting Program (MMRP), took testimony and considered all comments received on the MND and recommended adoption of the MND and MMRP to the City Council; and
WHEREAS, at a properly noticed public hearing on November 3, 2025, the City Council reviewed the staff report, MND (including all appendices) and the MMRP, took testimony and considered all comments received on the MND and MMRP; and WHEREAS, the Mitigated Negative Declaration is incorporated herein by reference and pursuant to CEQA Guidelines Section 15074, all documents and files which constitute the record of all proceedings upon which these recommendations associated with the Project were made are on file at Healdsburg City Hall, Community Development Center of the City of Healdsburg at 401 Grove Street, Healdsburg, CA 95448; and WHERAS, the MND includes a Mitigation Monitoring and Reporting Program (MMRP), attached hereto as Exhibit “A” and incorporated herein by reference, consistent with the requirements of Public Resources Code Section 21081.6, which lists all of the mitigation measures, specifies the appropriate responsible party for implementing each mitigation measure and approximate time frames for implementing each mitigation measure; and WHEREAS, the City Council finds on the basis of the whole record (including the Initial Study and the comments received) there is no substantial evidence that the Project will have a significant effect on the environment provided that the identified mitigation measures are incorporated into the Project, and that the MND reflects the City’s independent judgement and analysis. The City Council further finds that the MND has been completed in compliance with CEQA Guidelines and the information contained therein has been duly reviewed and considered by the City Council.

NOW, THEREFORE, BE IT RESOLVED as follows:

1. The above recitals are hereby declared to be true and correct findings of the City Council of the City of Healdsburg.

2. The City Council of the City of Healdsburg hereby adopts the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for the Badger Park Redevelopment Master Plan Project at 750 Heron Drive (APNs 002-221-021, 002-281- 012, 088-141-012, -015, AND -016).

3. The City Council of the City of Healdsburg hereby approves the Badger Park Redevelopment Master Plan.

PASSED, APPROVED AND ADOPTED by the City Council of the City of Healdsburg this 3rd Item 7.c
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day of November 2025 by the following vote:

AYES: Councilmembers: ( )
NOES: Councilmembers: ( )
ABSENT: Councilmembers: ( )
ABSTAINING: Councilmembers: ( )
SO ORDERED: ATTEST:
__________________________________ _________________________________ Evelyn Mitchell, Mayor Raina Allan, City Clerk
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Badger Park Redevelopment Master Plan Project 1
Mitigation Monitoring and Reporting Program September 2025 Badger Park Redevelopment Master Plan Project
Mitigation Monitoring and Reporting Program
September 2025
The California Environmental Quality Act (CEQA) and CEQA Guidelines require Lead Agencies to adopt a program for monitoring themitigation measures required to avoid the significant environmental impacts of a project. The Mitigation Monitoring and Reporting Program (MMRP) ensures that mitigation measures imposed by the City are completed at the appropriate time in the development process. The mitigation measures identified in the Initial Study/Mitigated Negative Declaration for the Badger Park Redevelopment Master Plan Project are listed below in chronological order along with the party responsible for implementation of the mitigation measure, the party responsible for monitoring implementation of the mitigation measure, the milestones for implementation and monitoring, and a sign-off that the mitigation measure has been implemented.

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Badger Park Redevelopment Master Plan Project 2
Mitigation Monitoring and Reporting Program September 2025

MITIGATION MONITORING AND REPORTING PROGRAM

BADGER PARK REDEVELOPMENT MASTER PLAN PROJECT
Mitigation
Number Mitigation Measure
Monitoring
Agency
Implementation
Schedule Sign-off
IV-14 The following shall be noted on project improvement plans, subject to review and approval by the City of Healdsburg Community Development Department: If loss of oak trees and other native trees cannot be avoided for development of picnic area, play area, river access/overlooks, and trails, to ensure no net loss of oak trees and other native trees the following replacement ratios shall be followed:
 1:1 for removal of non-native trees;  1:1 for removal of native trees up to 3 inches DBH  3:1 for removal of native trees greater than 3 inches to 6 inches DBH;
 6:1 for removal of native trees greater than 6 inches DBH;  1:1 for removal of oak trees up to 3 inches DBH;  4:1 for removal of oak trees up to 6 inches DBH;  8:1 for removal of oak trees greater than 6 inches to 15 inches DBH;
 10:1 for removal of oak trees greater than 15 inches DBH.

Where invasive species are removed, oak trees and other native trees shall be used to restore functioning oak woodland of similar composition, density, structure, and function to the selected oak woodland that was impacted. Replacement tree plantings shall consist of a minimum of five-gallon size plantings and shall be native species to the area adapted to the lighting, soil, and hydrological conditions at the replanting site. Replacement oaks shall come from nursery stock grown from locally sourced acorns, or from acorns gathered locally, preferably from the same watershed in which they are planted. All plantings shall be certified by the source as phytophthora free. Single tree planting shall be a minimum of 30 feet from adjacent tree planting site or existing tree. Shrub planting if in groups should be a minimum 10 feet apart and a minimum of 20 feet from a tree planting site or existing tree. All plantings shall occur within a soil pit dug to a minimum of two times diameter and depth of five-gallon City of Healdsburg Community Development Department
Prior to approval of project improvement plans and throughout project construction activities, if oak tree and other native tree loss cannot be avoided.

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Badger Park Redevelopment Master Plan Project 3
Mitigation Monitoring and Reporting Program September 2025

MITIGATION MONITORING AND REPORTING PROGRAM

BADGER PARK REDEVELOPMENT MASTER PLAN PROJECT
Mitigation
Number Mitigation Measure
Monitoring
Agency
Implementation
Schedule Sign-off
container. A mycorrhizal inoculant and slow-release fertilizer shall be added to a tree and shrub planting mix placed around each fivegallon planting. A protective double walled grow tube (Grow Tubes — OrchardValleySupply.com) shall be placed around each planting.

IV-12 The design-level drawings for the Master Plan shall show all improvements within forested portions of the Project Site (e.g., trails, river access and overlooks, picnic areas, children’s adventure play areas, etc.) to be placed within areas specifically vegetated with an abundance of non-native vegetation. Such areas for these facilities shall include areas that are currently overrun with tree privet and English ivy rather than with native trees and understory of California blackberries. Prior to finalizing the designated drawings, areas of extensive growth of non-native vegetation composed primarily of tree privet and English ivy shall be defined using GPS to allow the areas to be mapped so that play areas and picnic areas, etc. can be planned in environmentally benign locations to the extent possible.

City of Healdsburg Community Development Department
Prior to approval of final design-level drawings.

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Badger Park Redevelopment Master Plan Project 4
Mitigation Monitoring and Reporting Program September 2025

MITIGATION MONITORING AND REPORTING PROGRAM

BADGER PARK REDEVELOPMENT MASTER PLAN PROJECT
Mitigation
Number Mitigation Measure
Monitoring
Agency
Implementation
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IV-18 When preparing the final design-level drawings for the Master Plan, the City Community Development Department shall consider the need to avoid USACE and/or RWQCB wetlands. In addition, to the extent feasible as determined by a qualified biologist in coordination with the project architect, an undisturbed vegetated buffer shall be established and maintained between ground-disturbing activities (including vegetation removal) and adjacent wetland areas. The final design-level drawings for the Master Plan shall also show the top of both banks of the unnamed creek that enters the park from the north and traverses the western portion of the project site through the areas of coastal oak woodland and valley foothill riparian habitat before emptying into the Russian River. In addition to the location of the top of both banks of this unnamed creek, the final design-level drawings for the Master Plan shall also show the 25-foot setback from the top of both banks of the stream (City Code Section 20.24.090) where ground disturbance or vegetation removal would not be allowed.

City of Healdsburg Community Development Department
Prior to approval of final design-level drawings.

IV-19 The final design-level drawings for the Master Plan shall include a note that all areas determined to be subject to regulatory jurisdiction of either USACE or the RWQCB in the western and southern portions of the park shall be staked in the field, including vegetation removal for picnic areas, play areas, river access/overlooks, or trails. The aforementioned areas shall be avoided during vegetation removal or construction of park facilities to preserve wetlands in the areas. Locations for development of picnic area, play area, river access/overlooks, and trails shall be field engineered by the architect and qualified biologist/Biological Monitor working with the construction crew so that the features can be implemented in a way that they avoid or minimize impacts to wetlands.

City of Healdsburg Community Development Department
Prior to approval of final design-level drawings.

IV-20 The final design-level drawings for the Master Plan shall include the following language: where impacts to wetlands resulting from construction of new trails or improvements to existing trails are unavoidable, minimize wetland impacts through the use of a boardwalk created by establishing decking supporting by footings City of Healdsburg Community Development Department
Prior to approval of final design-level drawings.

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in wetland areas or through other measures that preserve some wetland functions.

IV-21 The final design-level drawings for the Master Plan shall include the following language: where pedestrian crossings of the unnamed stream are planned as part of Master Plan improvements, the crossings shall be accomplished through the construction of a freespan pedestrian bridge over the stream and footings for the bridge shall not placed between or on the banks of the stream.

City of Healdsburg Community Development Department
Prior to approval of final design-level drawings.

IV-3 Coho Salmon, Steelhead, and Russian River Tule
Perch The following shall be noted on project grading plans, subject to review and approval by the City of Healdsburg Community Development Department: Water work in the Russian River associated with construction of kayak/boat access at both the southwest and southeast corners of the project site shall be scheduled when water levels are low during the dry season between July 1 and September 15 to avoid impacts to immigrating salmonids (especially steelhead and coho salmon) that spawn in the river.

City of Healdsburg Community Development Department
Prior to approval of project grading plans.

XIII-2 Prior to approval of grading and/or building permits, the City shall establish the following as conditions of approval for any permit that results in the use of construction equipment:
 Construction shall be limited to 7:30 AM to 6:00 PM
Monday through Saturday.
 All construction equipment powered by internal
combustion engines shall be properly muffled and maintained.  Quiet construction equipment, particularly air
compressors, are to be selected whenever possible.
 All stationary noise-generating construction equipment such as generators or air compressors are to be located as far as practical from existing residences. In addition, the project contractor shall place such stationary construction City of Healdsburg Community Development Department
Prior to approval of grading and/or building permits.

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equipment so that emitted noise is directed away from sensitive receptors nearest the project site.  Unnecessary idling of internal combustion engines is
prohibited.
 The construction contractor shall, to the maximum extent practical, locate on-site equipment staging areas to maximize the distance between construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction.

Proof of compliance shall be submitted to the City of Healdsburg Community Development Department for review and approval.

VII-1 Prior to final design-level drawings, a Geotechnical Analysis shall be conducted by a California Registered Civil Engineer or Geotechnical Engineer to characterize the subsurface conditions of the project site. The report shall address and make recommendations on the following:
 Road, pavement, and parking area design;  Structural foundations, including retaining wall design (if applicable);
 Grading practices;  Erosion/winterization;  Special problems discovered on-site, (i.e., groundwater, expansive/unstable soils, etc.); and
 Slope stability.

City of Healdsburg Director of Public Works/City Engineer City of Healdsburg Chief Building Official Qualified Geotechnical Engineer Prior to issuance of grading and building permits.

XIII-1 If pickleball courts are included in the final design-level drawings, the proposed project shall include the construction of a six-foot-tall City of Healdsburg Community
Prior to issuance of building permits, if
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barrier at the northern boundary of the project site in the vicinity of the pickleball courts. The barrier height shall be relative to the residential building pads or the pickleball courts/dog park, whichever is greater. Noise barrier walls shall be constructed of concrete panels, concrete masonry units, earthen berms, or any combination of these materials that achieve the required total height. Wood is not recommended due to eventual warping and degradation of acoustical performance. Proof of compliance shall be submitted to the City of Healdsburg Community Development Department prior to issuance of building permits.

Development Department
pickleball courts are included in the final design-level drawings.

IV-4 Coho Salmon, Steelhead, and Russian River Tule
Perch The City shall implement the following mitigation measures prior to commencement of construction activities to minimize temporary construction impacts and consequent erosion and sedimentation impacts to habitat for special status fish species (including listed species of salmonids) in the Russian River:
 Ground disturbing work shall be conducted during dry or low flow periods. If water happens to be present during the period of construction, temporary coffer dams shall be used to redirect any surface water from the interior of the coffer dam area discharged through a filter bag or straw bale siltation basin located in uplands.  Equipment working in streams shall work from wood or
steel mats to minimize soil disturbance.
 Post construction temporarily filled areas shall be restored to the original ground surface elevation with fill material off hauled and disposed of at a suitable upland location.  To prevent erosion and sediment transport coir (coconut), jute, or sterile straw erosion control blankets and logs, and/or loose sterile straw, shall be used as appropriate following seed bed preparation of bare soil areas.

City of Healdsburg Community Development Department
Prior to commencement of construction activities.

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 The project shall not use erosion control materials
containing plastic monofilament netting (erosion control matting) or similar material containing netting within the project area due to documented evidence of birds, amphibians, and reptiles becoming entangled or trapped in such material. Acceptable substitutions include erosion materials contained with burlap netting, burlap tubes filled with natural fiber material, rolls of coconut coirmatting or similar.  Hydroseeding shall follow the installation of natural fiber matting, rolls, and/or loose straw best management practices (BMPs).

Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-6 Foothill Yellow-Legged Frog
Prior to initiation of construction activities, a qualified biologist shall conduct a survey following U.S. Fish and Wildlife Service and California Department of Wildlife guidance for foothill yellow-legged frog within all areas slated for clearing of vegetation within the forested areas of the Russian River floodplain and the Coastal Oak Woodland. Results of the survey shall be submitted to the City of Healdsburg Community Development Department. The qualified biologist shall remain on-site to serve as a Biological Monitor and to monitor any ground disturbing work necessary to establish recreational uses within this area to ensure that no foothill yellowlegged frogs are harmed. If a foothill yellow-legged frog is found on the site within an area slated for removal of vegetation, the work shall be halted until the frog either leaves the area of its own volition or can be relocated by the Biological Monitor to a safe environment.

City of Healdsburg Community Development Department
Prior to the initiation of construction activities.

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development of picnic areas, play areas, river access or overlooks, or trails. Locations for development of picnic area, play area, river access/overlooks, and trails shall be field engineered by the architect and qualified biologist working with the construction crew so that these features can be implemented within areas of nonnative vegetation, avoiding areas of native vegetation to the maximum extent possible. Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-22 The applicant (City of Healdsburg) shall apply for and obtain necessary authorizations for placement of fill material within waters of the United States (WOTUS) and waters of the State (WOTS).

Such authorizations shall include federal Clean Water Act (CWA) Section 404 nationwide permits from the USACE, CWA 401 water quality certification and Porter-Cologne Act Waste Discharge Requirements from the RWQCB, and one or more Fish and Game Code Section 1602 Streambed Alteration Agreements from CDFW. A Mitigation and Monitoring Plan may need to be prepared and submitted to these agencies for review as part of the process for obtaining project authorization. At a minimum the City shall ensure there is no net loss of wetland or stream habitat areal extent and associated function(s). Opportunities may be present for on-site mitigation of wetland impacts to include wetland restoration and enhancement (i.e., removal of exotic/invasive vegetation). On-site mitigation shall be a priority.

U.S. Army Corps of Engineers (USACE) Regional Water Quality Control Board (RWQCB) California Department of Fish and Wildlife (CDFW) Prior to the commencement of construction activities.

IV-23 A qualified biologist shall be retained to serve as a Biological Monitor to provide environmental training to the work crew and monitor the construction activities during periods of ground disturbance or vegetation removal. The Biological Monitor shall conduct an education program for all persons employed on the proposed project prior to performing ground-disturbing activities or vegetation removal. Instruction shall City of Healdsburg Community Development Department
Prior to performing ground-disturbing activities or vegetation removal.

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include a discussion of the biology and general behavior of any sensitive species that may be in the area, how they may be encountered within the work area, and procedures to follow when they are encountered. Training shall include such information about coho salmon, steelhead, Russian River tule perch, foothill yellowlegged frog, western pond turtle, and osprey. Interpretation shall be provided for non-English speaking workers, and the same instruction shall be provided for any new workers prior to on-site project activity. The Biological Monitor shall prepare and distribute wallet-sized cards or a factsheet handout containing this information for workers to carry on-site. Upon completion of the program, employees shall sign an affidavit stating they attended the program, which shall be available to the City. The qualified biologist/Biological Monitor shall remain on-site during work involving vegetation clearing and ground disturbance within the Valley Foothill Riparian and Coastal Oak and Valley Oak Woodland portions of the project site, including areas adjacent to the Russian River or along the unnamed drainage through the northern and western portions of the project site to provide biological monitoring. The Biological Monitor will (1) assist in demarcation of buffer zones to protect habitats or sensitive species (including active bird nests), (2) to ensure impacts to sensitive animal species do not occur, (3) to ensure the relocation of any sensitive animal species encountered according to agency protocols, and (4) to help ensure facilities are implemented in the least environmentally sensitive locations.

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their supervisor and the archaeological monitor. The worker education session shall include visuals of artifacts (prehistoric and historic) that might be found in the project vicinity and take place on the construction site immediately prior to the start of construction. Documentation of the training (i.e., a sign-in sheet) shall be retained at the site and shall be submitted with applicable reports to the City of Healdsburg Community Development Department.

XVIII-1 Implement Mitigation Measures V-1, V-2, V-3 and V-4. See Mitigation Measures V-1, V-2, V3, and V-4
See Mitigation Measures V-1, V-2, V3, and V-4
IV-16 Prior to any ground-disturbing activities which remove oaks and other native trees, the City shall develop and implement of a Native Tree Mitigation Program with the following components:

1. An inventory of all oak trees removed or encroached upon during project activities, separated by species and DBH;

2. Acres of oak habitat impacted, and density, coverage, and abundance of understory vegetation species impacted by life form (i.e., grass, forb, shrub, subshrub, vine);

3. Mitigation ratios applied and total number and/or area of replacement trees and vegetation;

4. Location of restoration areas and a discussion of the adequacy of the location(s) to serve as mitigation (e.g., would support oak trees/oak woodlands; avoid habitat type conversion);

5. The location and assessment of appropriate reference site(s) to inform the appropriate planting rate to recreate the pre-project function, density, percent basal, canopy, and vegetation cover of oak woodland impacted;

6. Scientific names [Genus and species (subspecies/variety if applicable)] of all plants being used for restoration;

7. Location(s) of propagule source. Propagules should be collected or grown from on-site sources or adjacent areas within the same watershed and should not be purchased from a supplier. Seeds must originate from plants/trees of City of Healdsburg Community Development Department
Prior to any grounddisturbing activities which remove oaks and other native trees.

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the same species (i.e., Genus, species, subspecies, and variety) as the species impacted;

8. Species-specific planting methods (i.e., container or bulbs);

9. Planting schedule; 10. Measures to control exotic vegetation and protection from herbivory;

11. Measurable goals and success criteria for establishing self-sustaining populations (e.g., percent survival rate, absolute cover). Measurable success criteria should be based on present site/habitat conditions and/or functional local native oak woodlands as reference sites;

12. Contingency measures should the success criteria not be met;

13. Long-term monitoring for at least 10 years; 14. Adaptive management techniques, including replacement plants if necessary; and

15. Annual reporting criteria and requirements.

The final Native Tree Mitigation Program shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-1 Special-Status Plants
Prior to the commencement of construction, a qualified biologist shall conduct protocol rare plant surveys within the forested riparian scrub and marsh areas of the site within the floodplain of the Russian River. Surveys shall be conducted pursuant to Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018). The surveys shall determine if special-status plant species occur within that portion of the property and vegetation clearing or construction of passive recreational uses could impact populations of the rare species. To span the varying flowering periods of multiple rare plant species that could potentially be found in on-site habitats, protocol surveys shall include a series of three survey dates between April City of Healdsburg Community Development Department
Prior to the commencement of construction, between April and July.

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and July of the survey year. Survey dates depend on dates at which target species are shown to be flowering, but most likely will include surveys in mid-April, mid-to-late May, and late June/early July of the survey year. Rare plant surveys shall be conducted within wetlands and within a zone of approximately 100 feet in adjacent uplands to determine if rare plants may be present that could be indirectly impacted by construction activity. Rare plant surveys within these areas of wetlands should consider the following special-status plant species:
 Sonoma alopecurus (Alopercurus aequalis var.
sonomensis), federally listed as endangered and CRPR 1B.1;  Thurber’s reed grass (Calamagrostis crassiglumis), CRPR 2B.1;
 Bristly sedge (Carex comosa), CRPR 2B.1;  Pitkin Marsh paintbrush (Castilleja uliginosa), state listed and endangered and CRPR 1A (may be extinct);
 Peruvian dodder (Cuscuta obtusiflora var. glandulosa), CRPR 2B.2;
 Swamp harebell (Eastwoodia californica), CRPR 1B.2;  Bogg’s Lake hedge-hyssop (Gratiola heterosepala), state listed endangered, CRPR 1B.2;
 Pitkin Marsh lily (Lilium pardalinum spp. pitkinense), state and federally listed endangered, CRPR 1B.1 ;
 White-beaked rush (Rhynchospora alba), CRPR 2B.2;  California beaked rush (Rhynchospora californica), CRPR 1B.1;
 Brownish beaked rush (Rhynchospora capitellata), CRPR 2B.2;
 Round-headed beaked rush (Rhynchospora globularis),
CRPR 2B.1 ;
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 Kenwood Marsh checkerbloom (Sidalcea oregana ssp.
valida), state and federally listed endangered, CRPR 1B.1; and  Northern slender pondweed (Stuckenia filiformis ssp.
alpina), CRPR 2B.2.

The survey results shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-10 Special-Status and Common Roosting Bats
Prior to any tree removal, a qualified bat biologist shall conduct a habitat assessment for bats. The habitat assessment shall be conducted a minimum of 30 days prior to tree removal and shall include a visual inspection of potential roosting features (e.g., cavities, crevices in wood and bark, or exfoliating bark for colonial species, and suitable canopy for foliage-roosting species). Results of the habitat assessment shall be submitted to the City of Healdsburg Community Development Department. Trees without suitable habitat for bats can be removed. If suitable habitat trees are found, they shall be flagged or otherwise clearly marked and tree trimming or removal shall not proceed without approval in writing from CDFW. These trees with suitable habitat may be removed only if: a) presence of bats is presumed or documented during the surveys described below, and removal using the two-step removal process detailed below occurs only during seasonal periods of bat activity from approximately March 1 through April 15 and September 1 through October 15, or b) after a qualified bat biologist conducts night emergence surveys or complete visual examination of roost features that establish absence of roosting bats. If a two-step removal is used, two-step tree removal shall be conducted over two consecutive days, as follows: 1) the first day (in the afternoon), under direct supervision and instruction by a qualified bat biologist with experience conducting a two-step methodology, limbs and branches shall be removed by a tree cutter using chainsaws only; limbs with cavities, crevices or deep bark City of Healdsburg Community Development Department
A minimum of 30 days prior to tree removal and during tree removal.

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fissures shall be avoided, and 2) the second day the entire tree shall be removed.

IV-8 Osprey
A qualified biologist shall conduct a preconstruction survey of the project site and adjacent areas for osprey nests if vegetation removal or construction of recreational facilities is scheduled during the nesting season (February 1 through August 31). Surveys shall be conducted no more than seven days prior to ground disturbance or vegetation removal by walking transects through all suitable habitat within the project site (especially the Valley Foothill Riparian habitat along the Russian River). Results of the survey shall be submitted to the City of Healdsburg Community Development Department. If an active osprey nest is detected during the surveys, the nest site shall be protected by implementing a minimum 500-foot radius buffer zone around the nest marked with orange construction fencing. If an active nest is located outside of the project site, the buffer shall be extended onto the project site and demarcated where it intersects the project site. The qualified biologist, in consultation with CDFW, may modify the size of buffer zone based on the type of construction activity that may occur, physical barriers between the construction site and active nest, behavioral factors, and the extent that osprey may have acclimated to disturbance. Construction or ground disturbance activity shall not occur within the established buffer zone until it is determined by the qualified biologist that the young have fledged or that the nesting cycle is otherwise determined to be complete based on monitoring of the active nest b y a qualified biologist/Biological Monitor.

City of Healdsburg Community Development Department
No more than seven days prior to ground disturbance or vegetation removal, if vegetation removal or construction of recreational facilities is scheduled during the nesting season (February 1 through August 31).

IV-9 Nesting Bird Species
A preconstruction nesting bird survey shall be conducted by a qualified biologist if construction occurs during the bird nesting season (February 1st to August 31st). The survey shall be conducted within seven days prior to the start of work. The survey shall include the entire project footprint and areas immediately adjacent to the project work area. The survey shall include the trees and shrubs on and immediately adjacent to the project work area to City of Healdsburg Community Development Department
Within seven days prior to the commencement of construction activities, if construction occurs during the bird nesting season (February 1 through August 31).

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the extent the areas are accessible. Other large trees in the project vicinity are on the opposite sides of major roads; birds nesting in these trees are unlikely to be impacted by the proposed project. However, the qualified biologist conducting surveys shall determine the appropriate survey area. Survey results shall be submitted to the City of Healdsburg Community Development Department. If the survey indicates the presence of nesting birds, a buffer shall be placed around the nest and marked with orange construction fencing within which work shall not be allowed until the young have successfully fledged or the nest has otherwise become inactive. The size of the nest buffer shall be determined by the qualified biologist and shall be based to a large extent on the nesting species, its sensitivity to disturbance, and the context of the nest location. In general, typical buffer widths range from 500 feet for large raptors such as buteos, 250 feet for small raptors such as accipiters, and 100 feet for passerines (songbirds) and other bird species. Buffers may be increased or decreased, as appropriate, with approval from CDFW. No construction or earth-moving activity shall occur within the established buffer zone until it is determined by the biologist that the young have fledged or that the nesting cycle is otherwise determined to be complete based on monitoring of the active nest. A copy of the nesting bird survey report shall be provided to the City of Healdsburg Community Development Department prior to construction.

IV-7 Western Pond Turtle
A qualified biologist shall conduct a survey of all areas proposed for installation of recreational facilities within 325 feet of permanently ponded areas for western pond turtles and their nests within 48 hours of the commencement of vegetation clearing or construction activities. Results of the survey shall be submitted to the City of Healdsburg Community Development Department. The qualified biologist shall remain on-site to serve as a Biological Monitor and to monitor any ground disturbing work necessary to establish recreational uses within 325 feet of permanently ponded areas to City of Healdsburg Community Development Department
Within 48 hours of the commencement of vegetation clearing or construction activities.

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ensure that western pond turtles are not harmed. If western pond turtles or the associated nests are detected at any time on the site within an area slated for removal of vegetation, the work shall be halted until the turtle either leaves the area of its own volition or can be relocated by the Biological Monitor to a safe environment.

IV-2 Special-Status Plants
If any of the rare plants are found during protocol surveys, areas planned for clearing of vegetation or construction of passive recreational uses shall avoid locations with growth of any of these species. Adjustment(s) to areas of proposed construction may be warranted to avoid populations of rare plants. If populations cannot be avoided, then transplantation is recommended as a mitigation strategy to avoid impact to any of these plant species. If any specialstatus plant species are observed, the City shall coordinate with the CDFW and USFWS, as appropriate, to prepare a plant salvage and mitigation plan on-site. Work shall not be conducted until the CDFW and USFWS provide written approval of the plan and its successful Implementation. Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

City of Healdsburg Community Development Department
During clearing of vegetation or construction of passive recreational uses, if any rare plants are found during protocol surveys.

IV-5 Coho Salmon, Steelhead, and Russian River Tule
Perch Sites for construction of boat access to the river shall be demarcated with orange construction flagging, and no areas beyond the defined work limits shall be disturbed. Staging and storage areas for equipment, materials, fuels, lubricants, and solvents shall be located outside of the high-water mark of the river. Refueling of vehicles shall not be allowed in areas adjacent to the river. Where feasible, construction of boat ramps shall occur with equipment positioned on the bank of the river. During all activities associated with boat access construction, all trash shall be properly contained and disposed of on a regular basis. Proof of compliance with the aforementioned measures shall be submitted to the City of City of Healdsburg Community Development Department
During all activities associated with boat access construction.

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Healdsburg Community Development Department for review and approval.

V-2 During all construction activities taking place within the forested portions of the project site, a Secretary of Interior (SOI) qualified archaeologist, or an archaeologist working under the direct supervision of a SOI-qualified archeologist, shall conduct spot monitoring of project-related ground disturbing activities within the forested portions of the project area, including during the removal of invasive vegetation and the development of overlook structures, trails, bridges, at-grade creek crossings, bank-stabilizing bioengineered vegetative walls, vehicular drop-off loop, and river access points. Spot monitoring shall consist of the archaeologist conducting regular visits to the project area to monitor the progress of excavation, during which all excavated material, open excavation, recently grubbed areas, and other soil disturbances shall be inspected by the archeological monitor. The archeological monitor shall have the authority to halt construction in the area of a discovery to ensure that an archeological resource is protected from further impact. If a potentially significant archeological resource is identified, the SOI-qualified archeologist shall notify the City of Healdsburg and the contractor, and Mitigation Measure V-3 shall be implemented.

City of Healdsburg Community Development Department See also Mitigation Measure V-3 During all construction activities taking place within the forested portions of the project site. See also Mitigation Measure V-3.

V-3 In the event a potentially significant cultural resource is encountered during subsurface earthwork activities, all construction activities within a 100-foot radius of the find(s) shall cease and workers shall avoid altering the materials until an archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for archaeology has evaluated the find(s). The City shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement. The qualified archeologist shall make recommendations to the Lead Agency on the measures that shall be implemented to protect the discovered resources, including but not limited to, culturally appropriate temporary and permanent treatment, which may include avoidance of cultural resources, in-place preservation, and/or re-burial on City of Healdsburg Community Development Department Northwest Information Center (NWIC) State Historic Preservation Office (SHPO) During subsurface earthwork activities, in the event a potentially significant cultural resource is encountered.

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project property so the resource(s) are not subject to further disturbance in perpetuity. If avoidance is determined to be infeasible, pursuant to CEQA Guidelines Section 15126.4(b)(3)(C), a data recovery plan, which makes provisions for adequately recovering the scientifically consequential information from and about the historical resource, shall be prepared and adopted prior to any excavation being undertaken. Such studies shall be deposited with the California Historical Resources Regional Information Center. If necessary, excavation and evaluation of the find(s) shall comply with Section 15064.5 of the CEQA Guidelines. Potentially significant cultural resources include, but are not limited to, stone, bone, glass, wood, or shell artifacts or features, including hearths, structural remains, or historic dumpsites. Any previously undiscovered resources found during construction within the project site shall be recorded on appropriate Department of Parks and Recreation (DPR) 523 forms and will be submitted to the City of Healdsburg, the NWIC, and the State Historic Preservation Office (SHPO), as required.

V-4 In the event of the accidental discovery or recognition of any human remains, further excavation or disturbance of the find or any nearby area reasonably suspected to overlie adjacent human remains shall not occur until compliance with the provisions of CEQA Guidelines Section 15064.5(e)(1) and (2) has occurred. The Guidelines specify that in the event of the discovery of human remains other than in a dedicated cemetery, no further excavation at the site or any nearby area suspected to contain human remains shall occur until the County Coroner has been notified to determine if an investigation into the cause of death is required. If the coroner determines that the remains are Native American, then, within 24 hours, the Coroner must notify the Native American Heritage Commission, which in turn will notify the most likely descendants who may recommend treatment of the remains and any grave goods. The potential exists that the Native American Heritage Commission may be unable to identify a most likely descendant, the most likely descendant fails to City of Healdsburg Community Development Department County Coroner Native American Heritage Commission (NAHC) During project construction activities, in the event of the accidental discovery or recognition of any human remains.

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Mitigation Monitoring and Reporting Program September 2025

MITIGATION MONITORING AND REPORTING PROGRAM

BADGER PARK REDEVELOPMENT MASTER PLAN PROJECT
Mitigation
Number Mitigation Measure
Monitoring
Agency
Implementation
Schedule Sign-off
make a recommendation within 48 hours after notification by the Native American Heritage Commission, or the landowner or his authorized agent rejects the recommendation by the most likely descendant and mediation by the Native American Heritage Commission fails to provide a measure acceptable to the landowner. In such a case, the landowner or his authorized representative shall rebury the human remains and grave goods with appropriate dignity at a location on the property not subject to further disturbances. Should human remains be encountered, a copy of the resulting County Coroner report noting any written consultation with the Native American Heritage Commission shall be submitted as proof of compliance to the City’s Community Development Department.

IV-11 Post-Construction
Artificial light causes disruption of the behavior of insects, amphibians, mammals, and invertebrates. Unnecessary outdoor lighting shall be turned off from dusk to dawn. If outdoor lighting is necessary, amber lighting along all outdoor areas including roadways shall be used (Amber/Orange nm range 587 - 592 Peak Wavelength 590). Where practicable, fixtures shall be used that shield lamps or glowing lenses from being directly visible. No off-road event vehicle parking and driving is allowed. All parking will be within established parking lots. Oil or mineral salts shall not be applied to roadway or parking areas for dust control. Maximum vehicle speed limits are restricted to 10 mph. A mowed 30-foot margin, where feasible, shall be maintained along both sides of the access road for visibility and fire control. Vehicles shall stop if animals are observed until the animal clears the area. Speed limit and informational species protection signs shall be posted along roadways. Where feasible, electric power-driven equipment and vehicles shall be used. Maximum vehicle speed shall be restricted to 10 mph on all roads.

City of Healdsburg Community Development Department
After the completion of construction activities.

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MITIGATION MONITORING AND REPORTING PROGRAM

BADGER PARK REDEVELOPMENT MASTER PLAN PROJECT
Mitigation
Number Mitigation Measure
Monitoring
Agency
Implementation
Schedule Sign-off
To avoid the potential for sediment being transported into aquatic resource areas, including the Russian River, Mitigation Measure IV4 intended to protect special status fish species in the river should be implemented. Any areas that are barren of vegetation resulting from construction, pedestrian or vehicle access, or animal use shall be restored by seeding with a blend of native erosion control grass seed. Seeded areas shall be mulched. Landscape fabric shall not be used. Revegetation shall be completed as soon as possible if bare soil area(s) are discovered. Seeding placed after October 15 shall be covered with broadcast straw, jute netting, coconut fiber blanket or similar erosion control blanket. Because the on-site stream flows on either side of the willow island before emptying into the Russian River and the willow island portion of the site has been identified as an area of generally high species diversity, proposed land uses in the access, and the remainder of the willow island portion of the project site shall be treated as a protected habitat area set aside for conservation purposes which visitors shall not access.

IV-15 To ensure a successful revegetation effort as required by Mitigation Measure IV-13, all plants shall be monitored and maintained as necessary for five years. At the end of the five years of monitoring, with at least three years without supplemental irrigation, each category of plantings (e.g., oaks, other trees, shrubs, etc.) shall have a minimum of 85 percent survival at the end of the minimum monitoring period and plantings shall attain 70 percent cover after three years and 75 percent cover after five years. Survival and cover criteria shall both be required unless the herbaceous or spreading plants cannot be differentiated by individual, in which case only cover success criteria are required. Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

City of Healdsburg Community Development Department
For five years after the completion of construction activities.

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Community Services Department

Badger Park Redevelopment Master Plan Project
Initial Study/Mitigated Negative Declaration
August 2025
Prepared by
1501 Sports Drive, Suite A, Sacramento, CA 95834
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TABLE OF CONTENTS
A. OVERVIEW.......................................................................................................... 1 B. SOURCES............................................................................................................ 2 C. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED .............................. 3 D. DETERMINATION................................................................................................ 4 E. BACKGROUND AND INTRODUCTION .............................................................. 5 F. PROJECT DESCRIPTION ................................................................................... 5 G. ENVIRONMENTAL CHECKLIST....................................................................... 11 I. AESTHETICS. ......................................................................................... 12 II. AGRICULTURE AND FOREST RESOURCES. ...................................... 15 III. AIR QUALITY. ......................................................................................... 16 IV. BIOLOGICAL RESOURCES. .................................................................. 23 V. CULTURAL RESOURCES. ..................................................................... 49 VI. ENERGY.................................................................................................. 53 VII. GEOLOGY AND SOILS........................................................................... 55 VIII. GREENHOUSE GAS EMISSIONS.......................................................... 59 IX. HAZARDS AND HAZARDOUS MATERIALS. ......................................... 62 X. HYDROLOGY AND WATER QUALITY. .................................................. 65 XI. LAND USE AND PLANNING. .................................................................. 69 XII. MINERAL RESOURCES. ........................................................................ 70 XIII. NOISE...................................................................................................... 71 XIV. POPULATION AND HOUSING. .............................................................. 82 XV. PUBLIC SERVICES................................................................................. 83 XVI. RECREATION. ........................................................................................ 84 XVII. TRANSPORTATION................................................................................ 85 XVIII. TRIBAL CULTURAL RESOURCES......................................................... 88 XIX. UTILITIES AND SERVICE SYSTEMS..................................................... 90 XX. WILDFIRE................................................................................................ 93 XXI. MANDATORY FINDINGS OF SIGNIFICANCE. ...................................... 94 APPENDICES:

Appendix A: Air Quality and Greenhouse Gas Modeling Results Appendix B: Biological Resources Assessment
Appendix C: Aquatic Resources Delineation
Appendix D: Environmental Noise Assessment
Appendix E: Transportation Initial Study Checklist
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INITIAL STUDY
August 2025
A. OVERVIEW

1. Project Title: Badger Park Redevelopment Master Plan Project

2. Lead Agency Name and Address: City of Healdsburg
Community Services Department
1557 Healdsburg Avenue
Healdsburg, CA 95448

3. Contact Person and Phone Number: Mark Themig
Community Services Director
(707) 431-3116

4. Project Location: 750 Heron Drive
Healdsburg, CA 95488
APNs 002-221-021, 002-281-012, 088-141-
012, -015, and -016

5. Project Sponsor’s Name and Address: City of Healdsburg Community Services/ Park and Recreation Department
1557 Healdsburg Avenue
Healdsburg, CA 95448

6. General Plan Designation: Park/Open Space

7. Zoning Designation: Park (P)

8. Required Approvals from Other Public Agencies: None

9. Surrounding Land Uses and Setting:

The project site, identified by Assessor’s Parcel Numbers (APNs) 002-221-021, 002-281- 012, 088-141-012, -015, and -016, is located at 750 Heron Drive in the City of Healdsburg, California. The project site currently consists of the existing approximately 20-acre Badger Park, which is currently developed with a 37,500-square-foot (sf) turf field; play area; community garden; dog play area; picnic areas; utility infrastructure; electrical substation, and a parking lot for 46 vehicles. A large portion of the park is forested and is impacted by invasive vegetation. The project site is bounded by a multi-family apartment complex immediately to the north, single-family residences to the north and west, single-family residences and a residential neighborhood to the east, and the Russian River to the south.

The City of Healdsburg General Plan designates the project site as Park/Open Space and the site is zoned P.

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10. Project Description Summary:

The Badger Park Redevelopment Master Plan Project (proposed project) would include redevelopment of the existing park features and development of new park amenities, including an expanded play area, an expanded parking lot to accommodate an additional 21 spaces, a picnic area, a riverwalk trail, a new restroom building north of the community garden, new sports courts, river outlooks, and a reconstructed dog park. Additionally, the proposed project would include the removal of invasive vegetation within the park’s forested area to open and thin the tree canopy, create better visual access to the river, and reduce fire fuel. Two overlook features would be developed at the existing promontory spots, providing observation areas where the river would be visible, and the existing pedestrian bridge would be replaced. The new bridge would continue to span the drainage channel, and thus avoid directly impacting the channel. The bridge is anticipated to be constructed of wood and metal and would be six feet wide. An additional and substantially similar pedestrian trail bridge would be installed further south. The project would require approval of the Master Plan and a variance to allow minor improvements within the 100- foot Russian River setback.

B. SOURCES
The following documents are referenced information sources used for the purpose of this Initial Study:

1. Bay Area Air Quality Management District. 2022 California Environmental Quality Act Guidelines. April 2023.

2. Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines. April 2023.

3. CalEPA. Cortese List Data Resources. Available at:
https://calepa.ca.gov/sitecleanup/corteselist/. Accessed May 2024.

4. California Department of Conservation. California Earthquake Hazards Zone. February 27, 2009.

5. California Department of Conservation. California Important Farmland Finder. Available at: https://maps.conservation.ca.gov/dlrp/ciff/ Accessed July 2024.

6. California Department of Forestry and Fire Protection. Fire Hazard Severity Zones in State Responsibility Areas. Available at. https://calfireforestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d895 97ab693d008. Accessed July 2024.

7. California Department of Forestry and Fire Protection. California Fire Hazard Severity Zone Viewer. Available at: https://osfm.fire.ca.gov/what-we-do/community-wildfirepreparedness-and-mitigation/fire-hazard-severity-zones. Accessed May 2024.

8. California Department of Resources Recycling and Recovery (CalRecycle). FacilitySite Summary Details: Keller Canyon Landfill (07-AA-0032). Available at https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/4407?siteID=228

9. California Department of Transportation. California Scenic Highway Mapping System.

Available at: https://dot.ca.gov/programs/design/lap-landscape-architecture-andcommunity-livability/lap-liv-i-scenic-highways. Accessed July 2024.

10. City of Healdsburg. 2020 Urban Water Management Plan Update, City of Healdsburg Utility Department. October 2021.

11. City of Healdsburg. City of Healdsburg Emergency Operations Plan. August 2021.

12. City of Healdsburg. Healdsburg 2030 General Plan EIR, SCH No. #2007082030. 2008.

13. City of Healdsburg. Healdsburg 2030 General Plan. Certified July 6, 2009.

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14. City of Healdsburg. Healdsburg Bicycle and Pedestrian Mater Plan, Sonoma County Transportation Authority. 2013.

15. Department of Toxic Substances Control. Hazardous Waste and Substances Site List (Cortese). Available at: https://www.envirostor.dtsc.ca.gov/public/. Accessed April 2024.

16. Evans and De Shazo Archaeology and Historic Preservation. Cultural Resources Study for the Proposed Badger Park Master Plan Project, 750 Heron Drive, Healdsburg, Sonoma County, California. June 13, 2024.

17. Federal Emergency Management Agency. Flood Insurance Rate Map 06097C0051E.

Effective December 3, 2008.

18. Huffman-Broadway Group, Inc. Aquatic Resources Delineation Badger Park Project Healdsburg, California. April 2024.

19. Huffman-Broadway Group, Inc. Biological Resources Assessment Badger Park Project Healdsburg, California. June 2024.

20. Native American Heritage Commission. Badger Park Redevelopment Master Plan Project, Sonoma County. April 12, 2024.

21. Natural Resource Conservation Service. Web Soil Survey. Available at:
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. Accessed May 2024.

22. Northwest Information Center. Cultural Resources Study for the Proposed Badger Park Redevelopment Plan Project at 750 Heron Drive, Healdsburg, Sonoma County, California.

April 15, 2024.

23. Saxelby Acoustics. Environmental Noise Assessment, Bager Park Redevelopment Master Plan, City of Healdsburg, California. July 16, 2024.

24. State Water Resources Control Board. GeoTracker Public Site. Available at:
https://geotracker.waterboards.ca.gov/map/. Accessed May 2024.

25. W-Trans. Draft Transportation Initial Study Checklist for the Badger Park Master Plan Project. July 9, 2024.

C. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is “Less-Than-Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
 Aesthetics  Agriculture and Forest
Resources
 Air Quality
 Biological Resources  Cultural Resources  Energy
 Geology and Soils  Greenhouse Gas Emissions  Hazards and Hazardous Materials  Hydrology and Water
Quality
 Land Use and Planning  Mineral Resources
 Noise  Population and Housing  Public Services
 Recreation  Transportation  Tribal Cultural Resources  Utilities and Service
Systems
 Wildfire  Mandatory Findings of
Significance
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D. DETERMINATION
On the basis of this initial study:
 I find that the Proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
 I find that although the Proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the applicant. A MITIGATED NEGATIVE DECLARATION will be prepared.
 I find that the Proposed Project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
 I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
 I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Mark Themig, Community Services Director City of Healdsburg Printed Name For
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E. BACKGROUND AND INTRODUCTION
This Initial Study/Mitigated Negative Declaration (IS/MND) identifies and analyzes the potential environmental impacts of the proposed project. The information and analysis presented in this document is organized in accordance with the order of the California Environmental Quality Act (CEQA) checklist in Appendix G of the CEQA Guidelines. Where the analysis provided in this document identifies potentially significant environmental effects of the project, mitigation measures sufficient to reduce the impacts to less-than-significant levels are prescribed.

The mitigation measures prescribed for environmental effects described in this IS/MND will be implemented in conjunction with the project, as required by CEQA. The mitigation measures will be incorporated into the proposed project through project conditions of approval. The City will adopt findings and a Mitigation Monitoring and Reporting Program for the project in conjunction with approval of the project.

In 2008, the City of Healdsburg adopted the City of Healdsburg 2030 General Plan1 and certified an Environmental Impact Report (EIR) for the updated General Plan2 . The General Plan EIR is a
program EIR, prepared pursuant to Section 15168 of the CEQA Guidelines (Title 14, California Code of Regulations [CCR], Sections 15000 et seq.). The General Plan EIR analyzed full implementation of the General Plan and identified measures to mitigate the significant adverse impacts associated with the General Plan. The proposed project would be consistent with the land uses anticipated for the site in the General Plan; therefore, in accordance with Section 15150 of the CEQA Guidelines (Section 21083.3 of the Public Resources Code [PRC]), this IS/MND will tier from the previously certified General Plan EIR (SCH# 2007082030), as appropriate.

F. PROJECT DESCRIPTION
The following provides a description of the project site’s current location and setting, as well as the proposed project components and discretionary actions required for the project.

Project Location and Setting
The project site is located at 7560 Heron Drive in the City of Healdsburg, California (see Figure 1 and Figure 2), and is identified by APNs 002-221-021, 002-281-012, 088-141-012, -015, and -016.

The existing approximately 20-acre park consists of a 114,000-sf informal recreation field, a 6,250- sf playground, a 7,500-sf dog run, and a 27,000-sf community garden, as well as picnic areas, and a 46-space parking lot. A large portion of the park is forested and impacted by dense invasive vegetation. The forested area terraces down to the Russian River and two natural promontory areas exist, with informal pathways throughout. The current Badger Park includes utility infrastructure that is managed by the City of Healdsburg, including three wells, two for drinking water and one for irrigation water, the Fitch Water Treatment Building, which provides chemical dosing, electrical distribution, and control for the Fitch well field, a 50 million volt amps (MVA) electrical substation that receives electricity from PG&E power lines, and a UV water treatment structure. The site is designated Park/Open Space pursuant to the City’s General Plan and is zoned P.

The project site is bounded by a multi-family apartment complex immediately to the north, singlefamily residences to the north and west, single-family residences and the Riverview neighborhood, a residential development to the east; and the Russian River to the south. 1 City of Healdsburg. Healdsburg 2030 General Plan. Certified July 6, 2009. 2 City of Healdsburg. Healdsburg 2030 General Plan EIR, SCH No. #2007082030. 2008.

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Figure 1
Regional Project Location
Project Location
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Figure 2
Approximate Project Site Boundaries Map
Note: Project site boundaries are approximate.

Russian
River
SingleFamily
Residences
SingleFamily
Residences
Single-Family
Residences
Syar
Industries
Gravel Plant
Multi-Family
Apartments
Project Site
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Project Components
The proposed project generally consists of a Master Plan to redevelop Badger Park (see Figure 3).

The goal of the proposed Master Plan includes expanding park uses for the community, reconnecting the park to the Russian River, management of invasive species, and the creation of a more resilient climate adaptive park.

The proposed Master Plan would include a variety of active and passive spaces surrounding a central field area bracketed by curvilinear promenades. A secondary path system would connect the park and the adjacent neighborhood to the riverfront through the forested areas.

The park’s primary vehicular entrance and exit would remain at Heron Drive. The parking lot would be expanded to accommodate 67 vehicles, for an increase of 21 spaces, and a turn-around/dropoff loop would be added north of the existing UV treatment structure. The loop would allow vehicles to turn around and/or drop-off park visitors and human-powered watercraft such as canoes and kayaks.

Informal recreation would continue in a renovated central field area. Although the central field area is large enough to accommodate soccer play, the existing field is currently not programmed or permitted for sports practices, games, or tournaments. Due to drought, soccer programs on the existing field ceased in 2021. Games and practices have been relocated to other parks. The City of Healdsburg does not anticipate the soccer program returning to Badger Park in the future, and thus, this IS/MND does not evaluate impacts associated with organized sports games, tournaments, etc., at the park.

The existing playground would remain in approximately the same location as current conditions, and would be reconstructed and expanded to ensure the playground is up to code and meets the Americans with Disability Act (ADA) standards. The new play structures and amenities would embrace natural-universal play and river-related themes would be included.

The existing dog park would be reconstructed on the west side of the park’s vehicular entrance and exit so that it is not adjacent to the electrical substation. The reconstructed dog park would be substantially similar to the existing dog park, with new amenities including water and dog play objects. The existing community garden would be expanded to the south and would approximately double in size.

A portable toilet is currently in use at the existing Badger Park. As such, the proposed project would include the construction of one new restroom building immediately north of the community garden. The restroom building would have flushing toilets and be an energy efficient structure.

The restroom building would connect to the existing sewer gravity main on Heron Drive by either forced lateral or gravity flow depending on elevation changes. In addition, the existing sewer lift station, north of the project site, across from Heron Drive, would be relocated on to the northern portion of the project site, west of the access roadway at some point in the future.

The proposed project would also include the construction of new sports courts, such as three pickleball courts, volleyball courts, and a half-court for basketball south of the relocated and reconstructed dog park. The composition of the type of courts would be decided as part of the final design based on current trends and community needs, and the courts would not host any league play or be lit at night. Three small picnic areas with tables are proposed near the playground, community garden, and central field.

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Figure 3
Master Plan
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The Master Plan also highlights two areas for future utility infrastructure. A cryptosporidium treatment facility will be constructed near the existing wells and south of the community garden.

The facility will include six cartridge filter housings along with ancillary piping and controls modifications, six-foot tall chain link fencing, and a gravel access road. The Master Plan also designates a potential utility expansion area south of the existing UV treatment structure and north of the cryptosporidium treatment facility. However, the future utility infrastructure is not included in the proposed project, and a Notice of Exemption for the cryptosporidium treatment facility was posted by Sonoma County on December 18, 2023.

The proposed project would also include the removal of invasive vegetation within the park’s forested area to open and thin the tree canopy, create better visual access to the river, and reduce fire fuel. Two overlook features would be developed at the existing promontory spots, providing observation areas where the river would be visible (see Number 1 on Figure 3). An existing pedestrian trail bridge, that spans the drainage channel, would be replaced. The new bridge would continue to span the drainage channel, and thus avoid directly impacting the channel. The bridge is anticipated to be constructed of wood and metal and would be six feet wide. An additional and substantially similar pedestrian trail bridge would be installed further south (see Number 16 on Figure 3). Both bridges would connect the park to the adjacent neighborhood by way of a decomposed granite trail that would include stopping places with logs or boulders for adults and children to climb on and explore.

In addition, the site’s existing topography and habitat along the riverfront in the park’s southwest corner would be preserved. A series of bank stabilizing bioengineered vegetative walls would be installed to support an existing island, which is two feet in elevation above the river. The walls would slow the flow of water at select locations and provide erosion control to protect against flooding. Two at-grade creek crossings constructed of stones would cross the drainage channel and lead to a hidden beach nestled among willow trees with river access for swimming (see Number 17 on Figure 3).

An existing informal trail along the riverbank would be widened by approximately one foot for a total width of four feet and resurfaced with decomposed granite to make the trail more navigable and maintained. The riverbank trail would connect the vehicular drop-off loop to two river access points at the project’s southeast and southwest corners, which would consist of a kayak put-in constructed of wood treads and risers and/or informal rocks (see Number 19 on Figure 3).

The operational hours of Badger Park, which are 6:00 AM to 11:00 PM, would not change with redevelopment of the park. However, the project would improve visual and physical access to the Russian River, which would likely result in increased visitors. In addition, the construction of new sports courts (pickleball, half-court basketball and volleyball), the reconstruction of the playground, and the construction of a new, permanent restroom building would likely draw more visitors as well. Peak times for river access would be summer weekends.

Discretionary Actions
The proposed project would require the following approvals from the City of Healdsburg:
• Adoption of the IS/MND;
• Adoption of a Mitigation Monitoring and Reporting Program; and • Approval of a Master Plan.
• Approval of a Variance to allow minor improvements within the 100-foot Russian River setback.

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G. ENVIRONMENTAL CHECKLIST
The following checklist contains the environmental checklist form presented in Appendix G of the CEQA Guidelines. The checklist form is used to describe the impacts of the proposed project. A discussion follows each environmental issue identified in the checklist. For this checklist, the following designations are used:

Potentially Significant Impact: An impact that could be significant, and for which no mitigation has been identified. If any potentially significant impacts are identified, an EIR must be prepared.

Less Than Significant with Mitigation Incorporated: An impact that requires mitigation to reduce the impact to a less-than-significant level.

Less-Than-Significant Impact: Any impact that would not be considered significant under CEQA relative to existing standards.

No Impact: The project would not have any impact.

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I. AESTHETICS.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect on a scenic vista?     b. Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a State scenic highway?
   
c. In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and
other regulations governing scenic quality?
   
d. Create a new source of substantial light or glare
which would adversely affect day or nighttime views
in the area?
   
Discussion
a,b. Examples of typical scenic vistas include mountain ranges, ridgelines, or bodies of water as viewed from a highway, public space, or other area designated for the express purpose of viewing and sightseeing. In general, a project’s impact to a scenic vista would occur if development of the project would substantially change or remove a scenic vista. According the City’s General Plan, primary scenic vistas within the City of Healdsburg are wooded ridges and hillsides, and the Russian River. Pursuant to Figure IV.B-11 of the City’s General Plan EIR, the project site is not located within the vicinity of an identified scenic landscape unit (i.e., landscape of special importance to Sonoma County). The City’s General Plan EIR does identify a number of scenic ridgelines as shown in Figure 8 of the City’s General Plan. However, none of the scenic ridgelines shown therein are located in the direct vicinity of the project site. In addition, according to the California Scenic Highway Mapping System, the project site is not located within the vicinity of an officially designated State Scenic Highway3
. The nearest designated highway is located 9.81 miles southwest and the nearest eligible highway is State Route (SR) 128, located 4.76 miles northeast of the project site. In addition, the proposed project consists of a Master Plan for Badger Park, which is located adjacent to the Russian River. The Master Plan calls for removal of invasive vegetation which would create better visual access to the river. In addition, while the proposed project would include the expansion of park uses at the site, such uses are consistent with the type of development currently associated with the existing Badger Park.

Based on the above, development of the proposed project would not have a substantial adverse effect on a scenic vista and would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway. Thus, a less-than-significant impact would occur. c. Currently, the project site consists of the existing Badger Park. The project site is bounded by single-family and multi-family residences to the north and west, single-family residences to the east, and the Russian River to the south. The site is designated Park/Open Space pursuant to the City’s General Plan and is zoned P. Because the site is 3 California Department of Transportation. California Scenic Highway Mapping System. Available at:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways.

Accessed July 2024.

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substantially surrounded by urban uses, the project site is located in an urbanized area.

Pursuant to Appendix G of the CEQA Guidelines, because the project site is located in an urbanized area, the relevant threshold is whether the approved project would conflict with applicable zoning and other regulations governing scenic quality.

The proposed project would include a Master Plan for Badger Park. The proposed Master Plan would include expanding the park uses for the community, reconnecting the park to the Russian River, management of invasive species, and the creation of a more resilient climate adaptive park. As noted previously, the proposed project would be consistent with the General Plan land use designation and zoning designation for the project site. In addition, the only structure proposed for development on the project site would be the restroom building. Thus, the project site has been previously anticipated for development of park and open space uses by the City’s General Plan, and impacts related to degradation of visual character and quality were analyzed in the General Plan EIR.

In addition, the proposed project would require Master Plan approval by City Council. The Master Plan would use the existing topography along the riverfront to preserve the habitat and natural features of the river. Furthermore, the proposed project would be subject to the Healdsburg Design Guidelines, which includes set design principles for the development of public infrastructure. Specifically, the Saggio Hills Area Plan within the Healdsburg Design Guidelines focuses on conserving open space in relation to parks, public trails, and resource protection. Compliance with such would help ensure that the proposed redevelopment would not conflict with applicable zoning and other regulations governing scenic quality.

Based on the above, the project site is in an urbanized area and the proposed project would be consistent with the site’s current zoning designation. Thus, the proposed project would not conflict with applicable zoning and other regulations governing scenic quality, and a less-than-significant impact would occur.
d. Currently, the existing on-site park includes lighting features in the form of pole-mounted fixtures in the parking lot. In addition, streetlights are provided along the project frontages at Heron Drive and at the electrical substation within the park. Due to the urban nature of the project area, the project area experiences light and glare from existing development in the site vicinity. The proposed park redevelopment may include the installation of new lighting features within the project site; however, the improvements would not substantially increase on-site lighting intensity relative to what currently exists. Furthermore, new sources of lighting would be required to comply with such standards set forth in Healdsburg Municipal Code Section 20.16 (General Development Standards), which include such requirements such as all illumination, including security lighting, shall be arranged so as to reflect downward and away from the night sky, adjoining properties, and right-of-ways. Compliance with such standards would help to ensure that the light and glare created by the proposed project would be consistent with the levels of light and glare currently emitted in the surrounding environment by existing residential uses. In addition, the proposed park project would be subject to the 2022 Building Energy Efficiency Standards (Title 24, Part 6 CCR), which regulates outdoor lighting characteristics of new development such as maximum power and brightness, shielding, and controls to turn lighting on and off.

Given the proposed project’s consistency with the site’s General Plan land use designation, implementation of the project would result in a less-than-significant impact Item 7.c
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with respect to creating a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

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II. AGRICULTURE AND FOREST
RESOURCES.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?
   
b. Conflict with existing zoning for agricultural use, or a Williamson Act contract?    
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
   
d. Result in the loss of forest land or conversion of forest land to non-forest use?    
e. Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
   
Discussion
a,e. Pursuant to the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP), the entirety of the project site is characterized as “Urban and Built-Up Land.”4 The project site does not contain, and is not located adjacent to, Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Given the designation of the site as Urban and Built-Up Land, the proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a non-agricultural use, or otherwise result in the loss of Farmland to non-agricultural use. Therefore, no impact would occur as a result of the proposed project.
b. The project site is not under a Williamson Act contract and is not zoned for agricultural uses. The project site is designated Park/Open Space and the site is zoned P. According to the General Plan EIR, parcels within the City are not subject to Williamson Act contracts.

Therefore, the proposed project would not conflict with existing zoning for agricultural use or a Williamson Act contract, and no impact would occur. c,d. The project site is not considered forest land (as defined in PRC Section 12220[g]), timberland (as defined by PRC Section 4526), and is not zoned Timberland Production (as defined by Government Code Section 51104[g]). The City of Healdsburg General Plan designates the project site as Park/Open Space and the site is zoned P. Tree removal for the proposed project is addressed in Section IV, Biological Resources, of this IS/MND.

Therefore, the proposed project would have no impact with regard to conversion of forest land or any potential conflict with forest land, timberland, or Timberland Production zoning. 4 California Department of Conservation. California Important Farmland Finder. Available at:
https://maps.conservation.ca.gov/dlrp/ciff/ Accessed July 2024.

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III. AIR QUALITY.

Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Conflict with or obstruct implementation of the applicable air quality plan?    
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
   
c. Expose sensitive receptors to substantial pollutant
concentrations?    
d. Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
   
Discussion
a,b. The City of Healdsburg is located in the North Coast Air Basin (NCAB), which is under the jurisdiction of the Northern Sonoma County Air Pollution Control District (NSCAPCD). The NCAB is in attainment or unclassified (meaning there is insufficient data to determine attainment) for all California Ambient Air Quality Standards (CAAQS). As a result, numerical thresholds of significance for air pollutants have not been established by the NSCAPCD for CEQA analysis purposes, as such thresholds of significance are typically developed based on attainment goals set forth within an air quality plan.

Based on the recommendation of the NSCAPCD,
5 this analysis applies the thresholds of
significance used for CEQA analyses within the nearby San Francisco Bay Area Air Basin (SFBAAB), formulated by the Bay Area Air Quality Management District (BAAQMD). The BAAQMD thresholds of significance are based on the SFBAAB’s current nonattainment status of ozone and particulate matter (PM) emissions and the subsequent air quality attainment plans. Because the NCAB is in attainment or unclassified for all AAQS, using the BAAQMD thresholds of significance for the proposed project analysis would allow for a conservative analysis. If a project were to exceed the BAAQMD’s criteria pollutant emission thresholds during construction or operations, the project could be considered to result in an adverse air quality impact.

In compliance with regulations, due to the nonattainment designations of the area, the BAAQMD periodically prepares and updates air quality plans that provide emission reduction strategies to achieve attainment of the AAQS, including control strategies to reduce air pollutant emissions through regulations, incentive programs, public education, and partnerships with other agencies. The current air quality plans are prepared in cooperation with the Metropolitan Transportation Commission and the Association of Bay Area Governments (ABAG).

The most recent federal ozone plan is the 2001 Ozone Attainment Plan, which was adopted on October 24, 2001 and approved by the California Air Resources Board (CARB) on November 1, 2001. The plan was submitted to the USEPA on November 30, 2001 for review and approval. The most recent State ozone plan is the 2017 Clean Air Plan, adopted on April 19, 2017. The 2017 Clean Air Plan was developed as a multi-pollutant plan that provides an integrated control strategy to reduce ozone, PM, toxic air 5 Personal communication between Alex Saschin, Air Quality Engineer, Northern Sonoma County Air Pollution Control District, and Briette Shea, Senior Associate/Air Quality Technician, Raney Planning & Management, Inc., October 12, 2021.

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contaminants (TACs), and greenhouse gases (GHGs). Although a plan for achieving the State PM10 standard is not required, the BAAQMD has prioritized measures to reduce PM in developing the control strategy for the 2017 Clean Air Plan. The control strategy serves as the backbone of the BAAQMD’s current PM control program.

The aforementioned air quality plans contain mobile source controls, stationary source controls, and transportation control measures to be implemented in the region to attain the State and federal AAQS within the SFBAAB. Adopted BAAQMD rules and regulations, as well as the thresholds of significance, have been developed with the intent to ensure continued attainment of AAQS, or to work towards attainment of AAQS for which the area is currently designated nonattainment, consistent with applicable air quality plans. The BAAQMD’s established significance thresholds associated with development projects for emissions of the ozone precursors reactive organic gases (ROG) and oxides of nitrogen (NOX), as well as for PM10 and PM2.5, expressed in pounds per day (lbs/day) and tons per year (tons/yr), are listed in Table 1. Thus, by exceeding the BAAQMD’s mass emission thresholds for emissions of ROG, NOX, PM10, or PM2.5, a project would be considered to conflict with or obstruct implementation of the BAAQMD’s air quality planning efforts.

Given the NSCAPCD recommends using BAAQMD’s thresholds in the absence of their own, by exceeding the mass emissions thresholds presented in Table 1, a project would also be considered to conflict with or obstruct implementation of the NSCAPCD’s air quality planning efforts.

Table 1
BAAQMD Thresholds of Significance
Pollutant
Construction Operational
Average Daily
Emissions
(lbs/day)
Average Daily
Emissions
(lbs/day)
Maximum Annual
Emissions
(tons/year)
ROG 54 54 10
NOx 54 54 10
PM10 (exhaust) 82 82 15
PM2.5 (exhaust) 54 54 10
Source: BAAQMD, CEQA Guidelines, May 2017.

PM can be split into two categories: fugitive and exhaust. The BAAQMD thresholds of significance for exhaust are presented in Table 1. BAAQMD does not maintain quantitative thresholds for fugitive emissions of PM10 or PM2.5, rather, BAAQMD requires all projects within the district’s jurisdiction to implement Basic Construction Mitigation Measures (BCMMs) related to dust suppression.

The proposed project’s construction emissions were quantified using the California Emissions Estimator Model (CalEEMod) software version 2022.1.1.25 – a statewide model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify air quality emissions, including GHG emissions, from land use projects. The model applies inherent default values for various land uses, including construction data, trip generation rates, vehicle mix, trip length, average speed, etc. Where project-specific information is available, such information should be applied in the model. For the proposed project, the following project-specific details were included in the modeling:
• Construction would begin in May 2025 and last for two years.

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• A total of approximately 4,481 cubic yards (CY) of vegetation would be exported during remediation activities.

The proposed project’s estimated emissions associated with construction and operations are provided below. All CalEEMod results are included as Appendix A to this IS/MND.

Construction Emissions
According to the CalEEMod results, the proposed project would result in maximum unmitigated construction criteria air pollutant emissions as shown in Table 2.

Table 2
Maximum Unmitigated Construction Emissions (lbs/day)
Pollutant
Proposed Project
Emissions
Threshold of
Significance
Exceeds
Threshold?
ROG 0.85 54 NO
NOX 7.68 54 NO
PM10 (exhaust) 0.31 82 NO
PM2.5 (exhaust) 0.29 54 NO
Source: CalEEMod, July 2024 (see Appendix A).

As shown in the table, the proposed project’s construction emissions would be below the applicable thresholds of significance for ROG, NOx, PM10, and PM2.5.

In addition, NSCAPCD recommends that the following BAAQMD BCMMs be implemented during project construction:

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.

2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.

6. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.

7. All trucks and equipment, including their tires, shall be washed off prior to leaving the site.

8. Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a six- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.

9. Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations.

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The proposed project’s required implementation of the BAAQMD’s BCMMs listed above would help to further minimize construction-related emissions. In particular, implementation of the foregoing measures would reduce fugitive dust emissions resulting from project construction.

Even without consideration of BAAQMD’s Basic Construction Mitigation Measures, as shown in Table 2, construction of the proposed project would result in emissions of criteria air pollutants below BAAQMD’s thresholds of significance. Consequently, the proposed project would not conflict with or obstruct implementation of the applicable air quality plans during the proposed redevelopment activities.

Operational Emissions
According to the CalEEMod results, redevelopment of the existing Badger Park would result in maximum unmitigated operational criteria air pollutant emissions as shown in Table 3. As shown in the table, the proposed project’s operational emissions of ROG, NOx, and PM2.5 would be below the applicable thresholds. Consequently, the proposed project would not conflict with or obstruct implementation of the applicable air quality plans during project operation.

Table 3
Maximum Unmitigated Operational Emissions
Pollutant
Proposed Project
Emissions
Threshold of
Significance Exceeds
lbs/day tons/yr lbs/day tons/yr Threshold?
ROG 0.72 0.11 54 10 NO
NOX 0.24 0.02 54 10 NO
PM10* <0.005 <0.005 82 15 NO
PM2.5* <0.005 <0.005 54 10 NO
* Emissions from exhaust only. BAAQMD has not yet adopted thresholds for fugitive PM emissions.

Source: CalEEMod, July 2024 (see Appendix A).

Conclusion
Because the proposed project would not result in construction-related or operational emissions of criteria air pollutants in excess of BAAQMD’s thresholds of significance, conflicts with or obstruction of implementation of the applicable regional air quality plans would not occur. In addition, the project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State AAQS. Thus, a less-than-significant impact would result. c. Some land uses are considered more sensitive to air pollution than others, due to the types of population groups or activities involved. Heightened sensitivity may be caused by health problems, proximity to the emissions source, and/or duration of exposure to air pollutants. Children, pregnant women, the elderly, and those with existing health problems are especially vulnerable to the effects of air pollution. Sensitive receptors are typically defined as facilities where sensitive receptor population groups (i.e., children, the elderly, the acutely ill, and the chronically ill) are likely to be located. Accordingly, land uses that are typically considered to be sensitive receptors include residences, schools, playgrounds, childcare centers, retirement homes, convalescent homes, hospitals, and medical clinics. The nearest existing sensitive receptors are the single-family residences located approximately 100 feet from the project site boundary to the east.

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The major pollutant concentrations of concern are localized carbon monoxide (CO) emissions and TAC emissions, which are addressed in further detail below.

Localized CO Emissions
Localized concentrations of CO are related to the levels of traffic and congestion along streets and at intersections. High levels of localized CO concentrations are only expected where background levels are high, and traffic volumes and congestion levels are high.

Emissions of CO are of potential concern, as the pollutant is a toxic gas that results from the incomplete combustion of carbon-containing fuels such as gasoline or wood.

In order to provide a conservative indication of whether a project would result in localized CO emissions that would exceed the applicable threshold of significance, the BAAQMD has established screening criteria for localized CO emissions. According to BAAQMD, a proposed project would result in a less-than-significant impact related to localized CO emission concentrations if all of the following conditions are true for the project:
• The project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans;
• The project traffic would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour; and
• The project traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, underpass, etc.).

The proposed project would consist of redevelopment of an existing park; upon completion of the proposed redevelopment, the project would generate an average of 91 additional trips per day, for the pickleball courts. In addition, the project would not conflict with the Sonoma County Comprehensive Transportation Plan. As such, based on the BAAQMD screening criteria, the proposed project would result in a less-than-significant impact related to localized CO emissions concentrations and would not expose sensitive receptors to substantial concentrations of localized CO.

TAC Emissions
Another category of environmental concern is TACs. The CARB’s Air Quality and Land Use Handbook: A Community Health Perspective (Handbook) provides recommended setback distances for sensitive land uses from major sources of TACs, including, but not limited to, freeways and high traffic roads, distribution centers, and rail yards. The CARB has identified diesel particulate matter (DPM) from diesel-fueled engines as a TAC; thus, high volume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic are identified as having the highest associated health risks from DPM. Health risks associated with TACs are a function of both the concentration of emissions and the duration of exposure, where the higher the concentration and/or the longer the period of time that a sensitive receptor is exposed to pollutant concentrations would correlate to a higher health risk.

The proposed project would not involve any land uses or operations that would be considered major sources of TACs, including DPM. As such, the project would not generate any substantial pollutant concentrations during operations.

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Short-term, construction-related activities could result in the generation of TACs, specifically DPM, from on-road haul trucks and off-road equipment exhaust emissions.

However, construction is temporary and occurs over a relatively short duration in comparison to the operational lifetime of the proposed project. Health risks are typically associated with exposure to high concentrations of TACs over extended periods of time (e.g., 30 years or greater), whereas the construction period associated with the proposed project would likely be two years.

All construction equipment and operation thereof would be regulated per the CARB InUse Off-Road Diesel Vehicle Regulation, which is intended to help reduce emissions associated with off-road diesel vehicles and equipment, including DPM. Project construction would also be required to comply with all applicable BAAQMD rules and regulations, particularly associated with permitting of air pollutant sources. In addition, construction equipment would operate intermittently throughout the day and only on portions of the site at a time.

Because construction equipment on-site would not operate for long periods of time and would be used at varying locations within the site, associated emissions of DPM would not occur at the same location (or be evenly spread throughout the entire project site) for long periods of time. Due to the temporary nature of construction and the relatively short duration of potential exposure to associated emissions, the potential for any one sensitive receptor in the area to be exposed to concentrations of pollutants for a substantially extended period of time would be low. Therefore, construction associated with the proposed project would not be expected to expose any sensitive receptors to substantial pollutant concentrations.

It should be noted that redevelopment of the proposed park project would require vegetation hauling activities primarily associated with removal of invasive vegetation from the site, thereby generating temporary heavy-duty truck traffic on local roadways.

However, all haul truck traffic would be confined to the City’s established truck routes, as defined in Chapter 10.40 of the City’s Municipal Code. Consistent with the City’s established truck routes, haul trucks leaving the project site would be routed through Heron Drive. Given that the project site is located directly adjacent to an established truck route, the proposed project would not generate any haul truck traffic on roadways that were not previously anticipated for such traffic by the City. In addition, construction activities would be temporary, and hours of operation for construction equipment and haul truck traffic would be restricted pursuant to Section 9.32.070 of the Municipal Code.

Conclusion
Based on the above, the proposed project would not expose any sensitive receptors to substantial concentrations of localized CO or TACs during construction or operation.

Therefore, the proposed project would result in a less-than-significant impact related to the exposure of sensitive receptors to substantial pollutant concentrations. d. Emissions of concern include those leading to odors, emission of dust, or emissions considered to constitute air pollutants. Air pollutants have been discussed in sections “a” through “d” above. Therefore, the following discussion focuses on emissions of odors and dust.

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Pursuant to the BAAQMD CEQA Guidelines, odors are generally regarded as an annoyance rather than a health hazard.6 Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). The presence of an odor impact is dependent on a number of variables including: the nature of the odor source; the frequency of odor generation; the intensity of odor; the distance of odor source to sensitive receptors; wind direction; and sensitivity of the receptor.

Due to the subjective nature of odor impacts, the number of variables that can influence the potential for an odor impact, and the variety of odor sources, quantitative analysis to determine the presence of a significant odor impact is difficult. Typical odor-generating land uses include, but are not limited to, wastewater treatment plants, landfills, and composting facilities. The proposed project would not introduce any such land uses.

Construction activities often involve diesel-fueled equipment and heavy-duty trucks, which could create odors associated with diesel fumes that may be considered objectionable.

However, construction activities would be temporary, and hours of operation for construction equipment would be restricted per Section 9.32.070 of the Municipal Code.

Project construction would also be required to comply with all applicable BAAQMD rules and regulations, particularly associated with permitting of air pollutant sources. The aforementioned regulations would help to minimize emissions, including emissions leading to odors. Accordingly, substantial objectionable odors would not be expected to occur during construction activities.

As noted previously, all projects under the jurisdiction of BAAQMD are required to implement the BAAQMD’s Basic Construction Mitigation Measures, as recommended by NSCAPCD. The measures would act to reduce construction-related dust by ensuring that haul trucks with loose material are covered, reducing vehicle dirt track-out, and limiting vehicle speeds within the project site, among other methods, which would ensure that the proposed ground-disturbing activities do not result in substantial emissions of dust.

Following project construction, all areas of the project site would be paved or landscaped.

Thus, project operations would not generate significant amounts of dust that could adversely affect a substantial number of people.

For the aforementioned reasons, the proposed project would not result in emissions (such as those leading to odors) adversely affecting a substantial number of people, and a lessthan-significant impact would result. 6 Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines [pg. 5-16].

April 2017.

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IV. BIOLOGICAL RESOURCES.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
   
b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the
California Department of Fish and Wildlife or US Fish and Wildlife Service?
   
c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
   
d. Interfere substantially with the movement of any resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors, or impede the use of wildlife nursery sites?
   
e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
   
f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Conservation Community
Plan, or other approved local, regional, or state habitat conservation plan?
   
Discussion
a. The following discussion is based primarily on a Biological Resources Assessment (BRA) prepared by Huffman-Broadway Group, Inc. (HBG) for the proposed project. (see Appendix B).7
Currently, the site is developed with an existing approximately 20-acre park, which consists of a 114,000-sf informal recreation field, a 6,250-sf playground, a 7,500-sf dog run, and a 27,000-sf community garden, as well as picnic areas and a 46-space parking lot. A large portion of the park is forested and impacted by dense growth of invasive plant species which include English Ivy and Himalayan blackberry. From the maintained portion of the park’s recreational areas, a forested area transitions down to the Russian River where two natural promontory areas, situated on river terraces, and a number of informal pathways are located.

Several species of plants and animals within the State of California have low populations, limited distributions, or both. Such species may be considered “rare” and are vulnerable to extirpation as the state’s human population grows and the habitats the species occupy are converted to agricultural and urban uses. State and federal laws have provided the California Department of Fish and Wildlife (CDFW) and the U.S. Fish and Wildlife Service (USFWS) with a mechanism for conserving and protecting the diversity of plant and animal species native to the state. A sizable number of native plants and animals have been formerly designated as threatened or endangered under state and federal endangered 7 Huffman-Broadway Group, Inc. Biological Resources Assessment Badger Park Project Healdsburg, California. June 2024.

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species legislation. Others have been designated as “candidates” for such listing. Still others have been designated as “species of special concern” by CDFW. The California Native Plant Society (CNPS) has developed its own set of lists of native plants considered rare, threatened, or endangered. Collectively, these plants and animals are referred to as “special-status species.” Although CDFW Species of Special Concern generally do not have special legal status, they are given special consideration under CEQA. Specialstatus species include the following:
• Plant and wildlife species that have been formally listed as threatened or endangered, or are candidates for such listing by the USFWS or National Marine Fisheries (NMFS);
• Plant and wildlife species that have been listed as threatened or endangered or are candidates for such listing by the CDFW;
• CDFW Species of Special Concern, which are species that face extirpation in California if current population and habitat trends continue; • CDFW Fully Protected Species; and
• Species on CNPS Lists 1 and 2, which are considered to be rare, threatened, or endangered in California by the CNPS and CDFW.

In addition to regulations for special-status species, most birds in the U.S., including nonstatus species, are protected by the Migratory Bird Treaty Act (MBTA) of 1918. Under the MBTA, destroying active nests, eggs, and young is illegal.

In order to identify potential biological resource constraints and assess the suitability of habitats on the project site to potentially support State- and federally-protected species the BRA’s analysis included review of background literature to determine the potential presence of sensitive vegetation communities, aquatic communities, and special-status plant and wildlife species. Resources reviewed for sensitive vegetation and aquatic features included aerial photography, mapped soil types, the CNPS Online Databases, the CDFW’s California Natural Diversity Database (CNDDB), and the USFW’s Information for Planning and Consultation (IPC) database. Additionally, field surveys were conducted on February 28, 2024, March 21, 2024, and June 12, 2024, to identify on-site habitats which could potentially support special-status species, and to determine the likelihood of any occurrences of special-status species.

Based on the results of the database review and field surveys, on-site habitats were determined to include valley foothill riparian, coastal oak woodland, valley oak woodland, urban, non-native grasslands and riverine habitat. The study area’s vegetation communities are summarized in Table 4 and presented in Figure 4, and are discussed in further detail below.

Table 4
Vegetation Communities Within the Study Area
Habitat Type Acreage of Project Site
Valley Foothill Riparian 9.5
Coastal Oak Woodland 1.21
Valley Oak Woodland 0.38
Urban 5.95
Non-Native Grasslands 0.73
Riverine 0.87
Source: Huffman-Broadway Group, 2024
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Figure 4
Vegetation Map
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Valley Foothill Riparian
Mature riparian ecosystems include canopy trees with a canopy cover of 20 to 80 percent, a subcanopy tree layer, and an understory shrub layer. The valley foothill riparian habitat on the project site consists of the forested area between the developed portion of Badger Park and the Russian River. Dominant species in the canopy layer of the on-site riparian habitat include but are not limited to arroyo willow (Salix lasiolepis), black cottonwood (Populus trichocarpa), box elder (Acer negundo), and a lesser number of other native trees. The canopy layer of the valley foothill riparian habitat on the project site also includes a considerable number of non-native tree privet (Ligustrum lucidum) and a single Canary Island palm (Phoenix canariensis). The understory of the extensive valley foothill riparian habitat within the park is thick growth of mostly non-native plants that includes species such as greater periwinkle (Vinca major), English ivy (Hedera helix), poison hemlock (Conium maculatum), sweet fennel (Foeniculum vulgare), giant reed (Arundo donax), blue lily (Agapanthus praecox), and purple dead nettle (Lamium purpureum).

Coastal Oak Woodland
The overstory of coastal oak woodlands consists of deciduous and evergreen hardwoods (mostly oaks), and sometimes mixed with scattered conifers. The coastal oak woodland on the project site is continuous with the valley foothill riparian habitat but is found further inland from the Russian River. Tree canopy composition of coastal oak woodlands on the project site is dominated by Coast live oak, with several California buckeye (Aesculus californica) and a large numbers of non-native tree privet. Typical understory plants in the on-site coast live oak woodlands include California blackberry, English ivy, elderberries, poison oak (Toxicodendron diversiloba), and multiflora rose (Rosa multiflora), among others.

Valley Oak Woodland
Valley oak woodland varies from savanna-like to forest-like stands with partially closed canopies, comprised mostly of winter-deciduous, broad-leaved species. The valley oak woodland on the project site consists of a patch of the valley oak woodland habitat at the northern end of the project site between the Badger Park parking lot and Heron Drive. A small stream enters the habitat through a culvert under the park entrance road and continues west into the coastal oak woodland and then south into the riparian habitat before emptying into the Russian River near the southwest corner of the site. The dominant canopy tree in the patch of valley oak habitat on-site is valley oak, but other trees such as native Coast live oak and arroyo willow and non-native tree privet are also present, especially along the small stream. Typical understory plants include California blackberry, English ivy, and poison oak, along with grasses such as wild oat (Avena fatua), rattlesnake grass (Briza maxima), foxtail barley (Hordeum murinum), ripgut brome (Bromus diandrus), and others.

Urban
The structure of urban vegetation on-site varies, with five types of vegetative structure defined: tree grove, street strip, shade tree/lawn and shrub cover. The urban habitat on the project site consists primarily of the developed portions of the project site (including the play fields, tot-lot, parking lot and other amenities where some remnant native trees may be present but where most vegetation consists of non-native species or plants used in landscaping), the community garden, and an adjacent small field of non-native grasses and herbaceous species that is considered a ruderal habitat.

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Non-Native Annual Grassland
Annual Grassland habitat occurs mostly on flat plains to gently rolling foothills. Annual Grassland habitats are open grasslands composed primarily of annual plant species.

Many of these species also occur as understory plants in woodlands and other habitats.

The annual grassland area on the project site consists of a ruderal field vegetated primarily with non-native weedy species in the eastern portion of the project area between the community garden and the forest habitat along the river. The ruderal field is not mowed.

Vegetation includes but is not limited to the non-native grasses and forbs found in the play fields such as wild oat, ripgut brome, foxtail barley, spring vetch, dandelion, and cut-leaf geranium, but also species such as curly dock, greater periwinkle, and bedstraw.

Riverine
Intermittent or continually running water distinguishes rivers and streams. A stream originates at some elevated source, such as a spring or lake, and flows downward at a rate relative to slope or gradient and the volume of surface runoff or discharge. Velocity generally declines at progressively lower altitudes, and the volume of water increases until the enlarged stream finally becomes sluggish. Over this transition from a rapid, surging stream to a slow, sluggish river, water temperature and turbidity will tend to increase, dissolved oxygen will decrease, and the bottom will change from rocky to muddy. Riverine systems are often lacking in vegetation.

Special-Status Plants
Based on the database search, literature review, and habitat types found in the project site, 14 special-status plant species were identified as having a moderate to high potential to occur within the project site. Special-status plant species with a moderate to high potential for presence in the on-site areas of valley foothill riparian habitat with associated areas of freshwater marsh include Sonoma Alopecurus (Alopercurus aequalis var. sonomensis), thurber’s reed grass (Calamagrostis crassiglumis), bristly sedge (Carex comosa), pitkin marsh paintbrush (Castilleja uliginosa), Peruvian dodder (Cuscuta obtusiflora var. glandulosa), swamp harebell (Eastwoodia californica), bogg’s lake hedgehyssop (Gratiola heterosepala), pitkin marsh lily (Lilium pardalinum spp. pitkinense), white-beaked rush (Rhynchospora alba), round-headed beaked rush (Rhynchospora globularis), kenwood march checkerbloom (Sidalcea oregana ssp. valida), and northern slender pondwood (Stuckenia filiformis ssp. alpina). All other plant species identified in the database search were determined to be absent due to the lack of potentially suitable habitat as documented by the CNDDB database.

Field studies conducted for the BRA did not find special-status plants on-site. However, the surveys were not conducted during the flowering period of the target plant species.

Given the potential for special-status plant species within the project site, on-site construction activities could result in an adverse impact to special-status plants.

Plant community impacts would result from the clearing of vegetation within the various habitats comprising the existing Badger Park. The impacts would occur within the 6.25- acre project footprint and would specifically result from the construction of trails, overlooks, a small canoe/kayak launch ramp into the river, trail improvements along the berm adjacent to the river, clearing of vegetation related to construction of picnic areas, or children’s adventure play areas at the east end of the site. The impacts of the planned improvements within the various plant communities that occur within Badger Park are shown in Figure 5.

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Figure 5
Vegetation Impacts From Project Ground Disturbing Activities Item 7.c
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It should be noted that although the current trail is five feet in width, the temporary work area for improvements would include a 10-foot buffer on either side of the trail, for a total width of 25 feet.

Special-Status Wildlife
The proposed project’s potential to result in adverse effects to special-status wildlife species is discussed in further detail below.

Coho Salmon, Steelhead, and Russian River Tule Perch
The Russian River, which forms the southern boundary of the project site, is a documented spawning stream for coho salmon (Oncorhynchus kisutch) and steelhead (Oncorhynchus mykiss). Russian River tule perch (Hysterocarpus traski pomo) may also be present within the portion of the Russian River adjacent to the project site. The nearest recorded sightings of coho salmon, steelhead, and Russian River tule are located just under one mile from the project site.

A moderate potential exists that coho salmon, steelhead, and Russian River tule could occasionally pass by the project site within the Russian River. Direct impacts to listed salmonids are possible if in-water work is conducted during months when the aforementioned fish are moving through the Russian River during spawning season, generally between November and April. Off-site migration of soil leading to possible siltation of salmon streams is an important consideration as excessive siltation can result in covering spawning gravels. In addition, disruption of the soil would be required within the floodplain of the Russian River during vegetation clearing activities and the construction /installation of recreational facilities such as play equipment or picnic facilities, facilities for river access of overlooks, or trails.

Given the potential for coho salmon, steelhead, and Russian River tule to be present within the Russian River adjacent to the project site, on-site construction activities could result in an adverse impact to coho salmon, steelhead, and Russian River tule. In addition, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on the project site could cause disruption to the behavior of coho salmon, steelhead, and Russian River tule present within the Russian River adjacent to the project site.

Foothill Yellow-Legged Frog
Foothill yellow-legged frog (Rana boylii) is a Species of Special Concern. The species require partly shaded, shallow streams and riffles with rocky substrate in a variety of habitats. The freshwater marsh and riparian scrub on the project site within the floodplain of Russian River may be suitable habitat for foothill yellow-legged frog.

Foothill yellow-legged frog are known to occur within approximately 2.2 miles from Badger Park. Thus, the presence of the species is possible on the project site.

As part of the proposed project, clearing of vegetation is planned, to prepare the area for construction of picnic areas, play areas, river access, overlooks, or trails. Thus, given the potential for foothill yellow-legged frog to be present within the site, on-site construction activities could result in an adverse impact to the species. In addition, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on Item 7.c
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the project site could cause disruption to the behavior of foothill yellow-legged frog. As such, a potentially significant impact could occur.

Western Pond Turtle
Western pond turtles (Emys marmorata) occupy ponds, marshes, rivers, streams, and irrigation ditches with aquatic vegetation. The turtles prefer aquatic habitats with calm waters, vegetated banks and emergent logs or rocks to use as basking sites. Western pond turtle is known from the stretch along the Russian River extending from Alexander Valley Road east of Healdsburg downstream to approximately one mile downstream of Wohler Bridge, an area that encompasses the stretch of the Russian River adjacent to Badger Park. Ponded areas within the forested floodplain area within the western and southern portions of Badger Park could potentially provide suitable breeding habitat for western pond turtle. Additionally, suitable upland habitat for the species may be present within the coastal oak woodland that is continuous with the riparian habitat. Thus, given the potential for western pond turtle to be present within the site, on-site construction activities could result in an adverse impact to the species. Furthermore, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on the project site could cause disruption to the behavior of western pond turtle. As such, a potentially significant impact could occur.

Osprey
Ospreys (Pandion haliaetus) are associated strictly with large, fish bearing waters, primarily in ponderosa pine through mixed conifer habitats. The osprey nest from late March to Late August in nests built in large snags or open trees near large bodies of water.

Osprey have been noted in the vicinity of the project site in the past and were noted flying over the project site during the March 21, 2024, field survey of the site.

In addition, suitable nest trees are present on both the project site and in the project vicinity. If osprey are found to be nesting on or near the project site during the construction period, disturbance to the nesting birds could occur. In addition, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on the project site could cause disruption to the behavior of osprey. Thus, given the potential for osprey to be present within the site, on-site construction activities could result in an adverse impact to the species. As such, a potentially significant impact could occur.

Other Nesting Raptors and Migratory Birds
The potential exists for migratory birds and raptors to nest in the existing on-site trees.

According to HBG, avian diversity within the project site was generally greatest in the riparian habitat immediately along the Russian River and along the stretch of creek that passes through the coastal oak woodland and valley foothill riparian habitats before emptying into the Russian River at the southwest corner of the site in the vicinity of the willow island.

Most birds in the U.S., including those not qualifying as special-status species, are protected by the MBTA of 1918. Under the MBTA, destroying active nests, eggs, and young is illegal. Mechanized work and vehicle traffic associated with the proposed development activities could disturb nesting birds and result in nest abandonment if individuals are present during initiation of ground-disturbing activity. In addition, Section 3503.5 of the California Fish and Game Code (CFGC) states, “It is unlawful to take, Item 7.c
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possess, or destroy any birds in the order Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by the code or any regulation adopted pursuant thereto.” Furthermore, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on the project site could cause disruption to the behavior of nesting raptors and migratory birds. Thus, if such birds are present on-site, a potentially significant impact could occur.

Bats protected by the California Fish and Game Code
Under the CFGC Section 4150, destruction of an occupied, nonbreeding, bat roost, resulting in the death of bats, or disturbance that causes the loss of a maternity colony of bats (resulting in the death of young), is prohibited. Bats have the potential to roost in existing vegetation. Suitable habitat may be present on-site for bat species primarily in the form of mature vegetation with exfoliating bark and/or cavities. The proposed project could affect special status and common roosting bat species during the removal of trees.

Furthermore, increased outdoor lighting, traffic volumes, and noise levels associated with post construction activities on the project site could cause disruption to the behavior of roosting bats if they are present within the project site. Thus, the proposed project could result in adverse impacts to special status and common roosting bats, and a potentially significant impact could occur.

Conclusion
Thus, the proposed project could have an adverse effect, either directly or through habitat modifications, on species identified as special-status species in local or regional plans, policies, or regulations, or by the CDFW or the USFW, and a potentially significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

Special-Status Plants
IV-1 Prior to the commencement of construction, a qualified biologist shall conduct protocol rare plant surveys within the forested riparian scrub and marsh areas of the site within the floodplain of the Russian River. Surveys shall be conducted pursuant to Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018). The surveys shall determine if special-status plant species occur within that portion of the property and vegetation clearing or construction of passive recreational uses could impact populations of the rare species. To span the varying flowering periods of multiple rare plant species that could potentially be found in on-site habitats, protocol surveys shall include a series of three survey dates between April and July of the survey year. Survey dates depend on dates at which target species are shown to be flowering, but most likely will include surveys in mid-April, mid-to-late May, and late June/early July of the survey year.

Rare plant surveys shall be conducted within wetlands and within a zone of approximately 100 feet in adjacent uplands to determine if rare plants may be present that could be indirectly impacted by construction activity.

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Rare plant surveys within these areas of wetlands should consider the following special-status plant species:
• Sonoma alopecurus (Alopercurus aequalis var. sonomensis), federally listed as endangered and CRPR 1B.1;
• Thurber’s reed grass (Calamagrostis crassiglumis), CRPR 2B.1; • Bristly sedge (Carex comosa), CRPR 2B.1;
• Pitkin Marsh paintbrush (Castilleja uliginosa), state listed and endangered and CRPR 1A (may be extinct);
• Peruvian dodder (Cuscuta obtusiflora var. glandulosa), CRPR 2B.2; • Swamp harebell (Eastwoodia californica), CRPR 1B.2;
• Bogg’s Lake hedge-hyssop (Gratiola heterosepala), state listed endangered, CRPR 1B.2;
• Pitkin Marsh lily (Lilium pardalinum spp. pitkinense), state and federally listed endangered, CRPR 1B.1 ;
• White-beaked rush (Rhynchospora alba), CRPR 2B.2;
• California beaked rush (Rhynchospora californica), CRPR 1B.1; • Brownish beaked rush (Rhynchospora capitellata), CRPR 2B.2; • Round-headed beaked rush (Rhynchospora globularis), CRPR 2B.1 ;
• Kenwood Marsh checkerbloom (Sidalcea oregana ssp. valida), state and federally listed endangered, CRPR 1B.1; and
• Northern slender pondweed (Stuckenia filiformis ssp. alpina), CRPR 2B.2.

The survey results shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-2 If any of the rare plants are found during protocol surveys, areas planned for clearing of vegetation or construction of passive recreational uses shall avoid locations with growth of any of these species. Adjustment(s) to areas of proposed construction may be warranted to avoid populations of rare plants. If populations cannot be avoided, then transplantation is recommended as a mitigation strategy to avoid impact to any of these plant species. If any special-status plant species are observed, the City shall coordinate with the CDFW and USFWS, as appropriate, to prepare a plant salvage and mitigation plan on-site. Work shall not be conducted until the CDFW and USFWS provide written approval of the plan and its successful Implementation.

Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

Coho Salmon, Steelhead, and Russian River Tule Perch
IV-3 The following shall be noted on project grading plans, subject to review and approval by the City of Healdsburg Community Development Department:

Water work in the Russian River associated with construction of kayak/boat access at both the southwest and southeast corners of the project site shall be scheduled when water levels are low during the dry season between Item 7.c
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July 1 and September 15 to avoid impacts to immigrating salmonids (especially steelhead and coho salmon) that spawn in the river.

IV-4 The City shall implement the following mitigation measures prior to commencement of construction activities to minimize temporary construction impacts and consequent erosion and sedimentation impacts to habitat for special status fish species (including listed species of salmonids) in the Russian River:
• Ground disturbing work shall be conducted during dry or low flow periods. If water happens to be present during the period of construction, temporary coffer dams shall be used to redirect any surface water from the interior of the coffer dam area discharged through a filter bag or straw bale siltation basin located in uplands. • Equipment working in streams shall work from wood or steel mats to minimize soil disturbance.
• Post construction temporarily filled areas shall be restored to the original ground surface elevation with fill material off hauled and disposed of at a suitable upland location.
• To prevent erosion and sediment transport coir (coconut), jute, or sterile straw erosion control blankets and logs, and/or loose sterile straw, shall be used as appropriate following seed bed preparation of bare soil areas.
• The project shall not use erosion control materials containing plastic monofilament netting (erosion control matting) or similar material containing netting within the project area due to documented evidence of birds, amphibians, and reptiles becoming entangled or trapped in such material. Acceptable substitutions include erosion materials contained with burlap netting, burlap tubes filled with natural fiber material, rolls of coconut coirmatting or similar. • Hydroseeding shall follow the installation of natural fiber matting, rolls, and/or loose straw best management practices (BMPs).

Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-5 Sites for construction of boat access to the river shall be demarcated with orange construction flagging, and no areas beyond the defined work limits shall be disturbed. Staging and storage areas for equipment, materials, fuels, lubricants, and solvents shall be located outside of the high-water mark of the river. Refueling of vehicles shall not be allowed in areas adjacent to the river. Where feasible, construction of boat ramps shall occur with equipment positioned on the bank of the river. During all activities associated with boat access construction, all trash shall be properly contained and disposed of on a regular basis. Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

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Foothill Yellow-Legged Frog
IV-6 Prior to initiation of construction activities, a qualified biologist shall conduct a survey following U.S. Fish and Wildlife Service and California Department of Wildlife guidance for foothill yellow-legged frog within all areas slated for clearing of vegetation within the forested areas of the Russian River floodplain and the Coastal Oak Woodland. Results of the survey shall be submitted to the City of Healdsburg Community Development Department.

The qualified biologist shall remain on-site to serve as a Biological Monitor and to monitor any ground disturbing work necessary to establish recreational uses within this area to ensure that no foothill yellow-legged frogs are harmed. If a foothill yellow-legged frog is found on the site within an area slated for removal of vegetation, the work shall be halted until the frog either leaves the area of its own volition or can be relocated by the Biological Monitor to a safe environment.

Western Pond Turtle
IV-7 A qualified biologist shall conduct a survey of all areas proposed for installation of recreational facilities within 325 feet of permanently ponded areas for western pond turtles and their nests within 48 hours of the commencement of vegetation clearing or construction activities. Results of the survey shall be submitted to the City of Healdsburg Community Development Department. The qualified biologist shall remain on-site to serve as a Biological Monitor and to monitor any ground disturbing work necessary to establish recreational uses within 325 feet of permanently ponded areas to ensure that western pond turtles are not harmed. If western pond turtles or the associated nests are detected at any time on the site within an area slated for removal of vegetation, the work shall be halted until the turtle either leaves the area of its own volition or can be relocated by the Biological Monitor to a safe environment.

Osprey
IV-8 A qualified biologist shall conduct a preconstruction survey of the project site and adjacent areas for osprey nests if vegetation removal or construction of recreational facilities is scheduled during the nesting season (February 1 through August 31). Surveys shall be conducted no more than seven days prior to ground disturbance or vegetation removal by walking transects through all suitable habitat within the project site (especially the Valley Foothill Riparian habitat along the Russian River).

Results of the survey shall be submitted to the City of Healdsburg Community Development Department. If an active osprey nest is detected during the surveys, the nest site shall be protected by implementing a minimum 500-foot radius buffer zone around the nest marked with orange construction fencing. If an active nest is located outside of the project site, the buffer shall be extended onto the project site and demarcated where it intersects the project site. The qualified biologist, in consultation with CDFW, may modify the size of buffer zone based on the type of construction activity that may occur, physical barriers between the construction site and active nest, behavioral factors, and the extent that osprey may have acclimated to disturbance. Construction or ground disturbance activity shall not occur within the established buffer zone until Item 7.c
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it is determined by the qualified biologist that the young have fledged or that the nesting cycle is otherwise determined to be complete based on monitoring of the active nest by a qualified biologist/Biological Monitor.

Nesting Bird Species
IV-9 A preconstruction nesting bird survey shall be conducted by a qualified biologist if construction occurs during the bird nesting season (February 1st to August 31st). The survey shall be conducted within seven days prior to the start of work. The survey shall include the entire project footprint and areas immediately adjacent to the project work area. The survey shall include the trees and shrubs on and immediately adjacent to the project work area to the extent the areas are accessible. Other large trees in the project vicinity are on the opposite sides of major roads; birds nesting in these trees are unlikely to be impacted by the proposed project. However, the qualified biologist conducting surveys shall determine the appropriate survey area. Survey results shall be submitted to the City of Healdsburg Community Development Department.

If the survey indicates the presence of nesting birds, a buffer shall be placed around the nest and marked with orange construction fencing within which work shall not be allowed until the young have successfully fledged or the nest has otherwise become inactive. The size of the nest buffer shall be determined by the qualified biologist and shall be based to a large extent on the nesting species, its sensitivity to disturbance, and the context of the nest location. In general, typical buffer widths range from 500 feet for large raptors such as buteos, 250 feet for small raptors such as accipiters, and 100 feet for passerines (songbirds) and other bird species. Buffers may be increased or decreased, as appropriate, with approval from CDFW. No construction or earth-moving activity shall occur within the established buffer zone until it is determined by the biologist that the young have fledged or that the nesting cycle is otherwise determined to be complete based on monitoring of the active nest. A copy of the nesting bird survey report shall be provided to the City of Healdsburg Community Development Department prior to construction.

Special-Status and Common Roosting Bats
IV-10 Prior to any tree removal, a qualified bat biologist shall conduct a habitat assessment for bats. The habitat assessment shall be conducted a minimum of 30 days prior to tree removal and shall include a visual inspection of potential roosting features (e.g., cavities, crevices in wood and bark, or exfoliating bark for colonial species, and suitable canopy for foliage-roosting species). Results of the habitat assessment shall be submitted to the City of Healdsburg Community Development Department.

Trees without suitable habitat for bats can be removed. If suitable habitat trees are found, they shall be flagged or otherwise clearly marked and tree trimming or removal shall not proceed without approval in writing from CDFW. These trees with suitable habitat may be removed only if: a) presence of bats is presumed or documented during the surveys described below, and removal using the two-step removal process detailed below occurs only during seasonal periods of bat activity from approximately Item 7.c
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March 1 through April 15 and September 1 through October 15, or b) after a qualified bat biologist conducts night emergence surveys or complete visual examination of roost features that establish absence of roosting bats.

If a two-step removal is used, two-step tree removal shall be conducted over two consecutive days, as follows: 1) the first day (in the afternoon), under direct supervision and instruction by a qualified bat biologist with experience conducting a two-step methodology, limbs and branches shall be removed by a tree cutter using chainsaws only; limbs with cavities, crevices or deep bark fissures shall be avoided, and 2) the second day the entire tree shall be removed.

Post Construction
IV-11 Artificial light causes disruption of the behavior of insects, amphibians, mammals, and invertebrates. Unnecessary outdoor lighting shall be turned off from dusk to dawn. If outdoor lighting is necessary, amber lighting along all outdoor areas including roadways shall be used (Amber/Orange nm range 587 - 592 Peak Wavelength 590). Where practicable, fixtures shall be used that shield lamps or glowing lenses from being directly visible.

No off-road event vehicle parking and driving is allowed. All parking will be within established parking lots. Oil or mineral salts shall not be applied to roadway or parking areas for dust control. Maximum vehicle speed limits are restricted to 10 mph. A mowed 30-foot margin, where feasible, shall be maintained along both sides of the access road for visibility and fire control.

Vehicles shall stop if animals are observed until the animal clears the area.

Speed limit and informational species protection signs shall be posted along roadways.

Where feasible, electric power-driven equipment and vehicles shall be used. Maximum vehicle speed shall be restricted to 10 mph on all roads.

To avoid the potential for sediment being transported into aquatic resource areas, including the Russian River, Mitigation Measure IV-4 intended to protect special status fish species in the river should be implemented. Any areas that are barren of vegetation resulting from construction, pedestrian or vehicle access, or animal use shall be restored by seeding with a blend of native erosion control grass seed. Seeded areas shall be mulched.

Landscape fabric shall not be used. Revegetation shall be completed as soon as possible if bare soil area(s) are discovered. Seeding placed after October 15 shall be covered with broadcast straw, jute netting, coconut fiber blanket or similar erosion control blanket.

Because the on-site stream flows on either side of the willow island before emptying into the Russian River and the willow island portion of the site has been identified as an area of generally high species diversity, proposed land uses in the access, and the remainder of the willow island portion of the project site shall be treated as a protected habitat area set aside for conservation purposes which visitors shall not access.

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b, e. Within the project footprint, impacts to approximately 4.49 acres of Urban habitat (previously disturbed areas of the existing Badger Park) and approximately 0.73 acres of the non-native annual grassland area near the community garden would not be considered significant pursuant to CEQA guidelines, as the aforementioned areas have limited ecological value. The project would also impact limited areas within the approximately

11.09 acres of more sensitive forested habitat consisting of approximately 9.5 acres of valley foothill riparian habitat mostly along the Russian River, approximately 1.21 acres of coastal oak woodland in the western portion of the site, and approximately 0.38 acres of valley oak woodland in the northeast portion of the site near Heron Drive. Improvements in these forested areas may result in impacts within the valley foothill riparian forest (see Figure 5). Many locations within the forested areas of the site contain extensive growth of non-native trees and other vegetation. Large areas of the coastal oak woodland, for instance, are vegetated with a combination of tree privet and English ivy.

A Heritage Tree Survey was completed by HBG for the proposed project. As defined in the City of Healdsburg Heritage Tree Ordinance, a heritage tree is any tree that has a diameter of 30 inches or more, measured two feet above the level ground. According to the Heritage Tree Survey a total of 32 heritage trees were identified within the project site.

Tree diameters ranged from 30 to 64 inches as measured 24 inches above the ground.

Tree species include Black cottonwood, Coast redwood, Coast live oak, tree privet, Oregon ash, and Valley oak. In addition, a multitrunked Bay laurel and a multitrunked tree privet were inventoried. The multitrunked trees are likely deep rooted given the size and the nature of the sandy soils which both are grown within as neither have fallen during flooding by the Russian River.

Conceptual plans developed to date for the proposed project suggest that several heritage trees may need to be removed within the valley foothill riparian habitat during construction of the river access trail. Other heritage trees would not need to be removed to accommodate the proposed recreational improvements, including clearing of vegetation prior to the installation of picnic areas, children’s adventure play areas, or other facilities within the project site. Although a particular heritage tree may not need to be removed, grading or construction activity in close proximity to a tree’s root system may impact the long-term survivability of the tree if the tree’s root system is damaged during construction.

The City’s Heritage Tree Protection and Tree Report Requirements (Land Use Code Chapter 20.24, Article II) require permits for removal of heritage trees and require the preparation of a plan for the replacement of removed trees and tree protection guidelines to “protect and preserve heritage trees to the fullest extent possible.” Based on the above, the proposed project could have an adverse effect related to riparian habitat or other sensitive natural community identified in local regional plans, polices, and regulations, or by the CDFW or UFWS, or related to conflicting with local policies or ordinances protecting biological resources and a potentially significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

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within areas specifically vegetated with an abundance of non-native vegetation. Such areas for these facilities shall include areas that are currently overrun with tree privet and English ivy rather than with native trees and understory of California blackberries. Prior to finalizing the designated drawings, areas of extensive growth of non-native vegetation composed primarily of tree privet and English ivy shall be defined using GPS to allow the areas to be mapped so that play areas and picnic areas, etc. can be planned in environmentally benign locations to the extent possible.

IV-13 Prior to the initiation of construction activities, locations within the valley foothill riparian and coastal oak woodland habitats with a preponderance non-native vegetation (e.g., tree privet and English ivy) shall be staked in the field prior to any vegetation removal for development of picnic areas, play areas, river access or overlooks, or trails. Locations for development of picnic area, play area, river access/overlooks, and trails shall be field engineered by the architect and qualified biologist working with the construction crew so that these features can be implemented within areas of non-native vegetation, avoiding areas of native vegetation to the maximum extent possible.

Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-14 The following shall be noted on project improvement plans, subject to review and approval by the City of Healdsburg Community Development Department: If loss of oak trees and other native trees cannot be avoided for development of picnic area, play area, river access/overlooks, and trails, to ensure no net loss of oak trees and other native trees the following replacement ratios shall be followed:
• 1:1 for removal of non-native trees;
• 1:1 for removal of native trees up to 3 inches DBH
• 3:1 for removal of native trees greater than 3 inches to 6 inches DBH;
• 6:1 for removal of native trees greater than 6 inches DBH; • 1:1 for removal of oak trees up to 3 inches DBH;
• 4:1 for removal of oak trees up to 6 inches DBH;
• 8:1 for removal of oak trees greater than 6 inches to 15 inches DBH; • 10:1 for removal of oak trees greater than 15 inches DBH.

Replacement oaks shall come from nursery stock grown from locally sourced acorns, or from acorns gathered locally, preferably from the same Item 7.c
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watershed in which they are planted. All plantings shall be certified by the source as phytophthora free.

Single tree planting shall be a minimum of 30 feet from adjacent tree planting site or existing tree. Shrub planting if in groups should be a minimum 10 feet apart and a minimum of 20 feet from a tree planting site or existing tree. All plantings shall occur within a soil pit dug to a minimum of two times diameter and depth of five-gallon container. A mycorrhizal inoculant and slow-release fertilizer shall be added to a tree and shrub planting mix placed around each five-gallon planting. A protective double walled grow tube (Grow Tubes — OrchardValleySupply.com) shall be placed around each planting.

Survival and cover criteria shall both be required unless the herbaceous or spreading plants cannot be differentiated by individual, in which case only cover success criteria are required.

Proof of compliance with the aforementioned measures shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-16 Prior to any ground-disturbing activities which remove oaks and other native trees, the City shall develop and implement of a Native Tree Mitigation Program with the following components:

1. An inventory of all oak trees removed or encroached upon during project activities, separated by species and DBH;

2. Acres of oak habitat impacted, and density, coverage, and abundance of understory vegetation species impacted by life form (i.e., grass, forb, shrub, subshrub, vine);

3. Mitigation ratios applied and total number and/or area of replacement trees and vegetation;

4. Location of restoration areas and a discussion of the adequacy of the location(s) to serve as mitigation (e.g., would support oak trees/oak woodlands; avoid habitat type conversion);

6. Scientific names [Genus and species (subspecies/variety if applicable)] of all plants being used for restoration;

7. Location(s) of propagule source. Propagules should be collected or grown from on-site sources or adjacent areas within the same watershed and should not be purchased from a supplier. Seeds Item 7.c
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must originate from plants/trees of the same species (i.e., Genus, species, subspecies, and variety) as the species impacted;

8. Species-specific planting methods (i.e., container or bulbs);

9. Planting schedule;

10. Measures to control exotic vegetation and protection from herbivory;

11. Measurable goals and success criteria for establishing selfsustaining populations (e.g., percent survival rate, absolute cover).

Measurable success criteria should be based on present
site/habitat conditions and/or functional local native oak woodlands as reference sites;

12. Contingency measures should the success criteria not be met;

13. Long-term monitoring for at least 10 years;

14. Adaptive management techniques, including replacement plants if necessary; and

15. Annual reporting criteria and requirements.

The final Native Tree Mitigation Program shall be submitted to the City of Healdsburg Community Development Department for review and approval.

IV-17 The alignment of the river access trail in the final design-level designated drawings for the Master Plan shall be designed to avoid heritage trees and their root systems. In addition, the construction of the river access trail shall be field engineered by the architect and a qualified arborist working with the construction crew so that heritage trees and their root systems can be avoided. Trail construction shall be no closer than three feet from the base of a tree. To avoid impacts to tree root systems, trail construction shall consist of overlaying with porous trail material such as gravel, decomposed granite, or coarse sand. The arborist shall work with the City to prepare the Tree Replacement Plan and tree protection guidelines, as necessary to comply with the City Code Chapter 20.24. Proof of compliance shall be submitted to the City of Healdsburg Community Development Department for review and approval.
c. An Aquatic Resources Delineation (ARD) was prepared by HBG for the proposed project. (see Appendix C).8
Aquatic resources including wetlands and tributary drainages were identified and delineated during field surveys within the forest areas of the project site (see Figure 6). The wetlands and other waters are potentially subject to the jurisdiction of the United States Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), and CDFW. Based on plans developed to date, construction may need to be completed within wetlands/waters potentially subject to regulation by the USACE or RWQCB and could involve disturbance to streams regulated by CDFW. Work would not be conducted until the RWQCB, CDFW, and USACE provide authorizations for work in the aquatic resource areas that include wetlands and other waters. 8 Huffman-Broadway Group, Inc. Aquatic Resources Delineation Badger Park Project Healdsburg, California. April 2024.

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Figure 6
Aquatic Resources Subject to CWA Jurisdiction
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The project as currently proposed would result in permanent impacts to approximately

0.40 acres of wetlands and other waters as a result of the placement of fill material to construct a pedestrian trail system; a total of approximately 1.20 acres of temporary fill impacts to wetlands and other waters as a result of pedestrian trail and footbridge construction; and a total of approximately 0.032 acres of permanent impact and approximately 0.037 acres of temporary impact associated with construction of a canoe/kayak launch ramp into the river. The extent of such impacts is presented in Figure 7, Figure 8, and Figure 9.

However, it should be noted that while the areas of impact presented in the figures below were determined based on the professional judgement of Huffman-Broadway, the extent of the impacts to wetlands and other waters potentially subject to the jurisdiction of the USACE, RWQCB, and CDFW would ultimately be determined by the aforementioned agencies. As such, the impact areas presented in the figures are approximate.

It should also be noted that according to Section 20.24.090 of the Healdsburg Municipal Code, no building, structure, or permanent or temporary improvement shall be allowed within 100 feet of the Russian River, 35 feet within Foss Creek, or 25 feet within all other streams and creeks. Mitigation Measure IV-14, below, would ensure that the proposed project would comply with the 25-foot setback to the unnamed creek located within the project site. In addition, Foss Creek is not located within the project vicinity. With respect to Russian River, the minor improvements related to invasive species removal and soft surface trails would be anticipated to be exempt from the setback requirements, but construction of the two river access points would require a variance. As noted in Section

20.24.095 of the Healdsburg Municipal Code, variances to the standards set forth in Healdsburg Municipal Code Section 20.24.090 may be granted where the provision of the required setback is infeasible. As such, the proposed project would require approval of a variance to allow such minor improvements within the 100-foot Russian River setback.

Approval of the variance would require the preparation of a riparian mitigation plan to ensure no net loss of acreage or of functional value of riparian habitat occurs.

Nonetheless, based on the above, the proposed project could have an adverse effect on State or federally protected wetlands through direct removal, filling, hydrological interruption, or other means, and a potentially significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

IV-18 When preparing the final design-level drawings for the Master Plan, the City Community Services Department shall consider the need to avoid USACE and/or RWQCB wetlands. In addition, to the extent feasible as determined by a qualified biologist in coordination with the project architect, an undisturbed vegetated buffer shall be established and maintained between ground-disturbing activities (including vegetation removal) and adjacent wetland areas.

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Figure 7
Impacts to Existing Land Use/Cover and Aquatic Resources Subject to U.S. Army Corps of Engineers
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Figure 8
Impacts to Existing Land Use/Cover and Aquatic Resources Subject to North Coast Bay Regional Water Quality Control Board Jurisdiction Item 7.c
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Figure 9
Impacts to Existing Land Use/Cover and Aquatic Resources Subject to CDFW Jurisdiction
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The final design-level drawings for the Master Plan shall also show the top of both banks of the unnamed creek that enters the park from the north and traverses the western portion of the project site through the areas of coastal oak woodland and valley foothill riparian habitat before emptying into the Russian River. In addition to the location of the top of both banks of this unnamed creek, the final design-level drawings for the Master Plan shall also show the 25-foot setback from the top of both banks of the stream (City Code Section 20.24.090) where ground disturbance or vegetation removal would not be allowed.

IV-19 The final design-level drawings for the Master Plan, all areas determined to be subject to regulatory jurisdiction of either USACE or the RWQCB in the western and southern portions of the park shall be staked in the field, including vegetation removal for picnic areas, play areas, river access/overlooks, or trails. The aforementioned areas shall be avoided during vegetation removal or construction of park facilities to preserve wetlands in the areas. Locations for development of picnic area, play area, river access/overlooks, and trails shall be field engineered by the architect and qualified biologist/Biological Monitor working with the construction crew so that the features can be implemented in a way that they avoid or minimize impacts to wetlands.

IV-20 The final design-level drawings for the Master Plan shall include the following language: where impacts to wetlands resulting from construction of new trails or improvements to existing trails are unavoidable, minimize wetland impacts through the use of a boardwalk created by establishing decking supporting by footings in wetland areas or through other measures that preserve some wetland functions.

IV-21 The final design-level drawings for the Master Plan shall include the following language: where pedestrian crossings of the unnamed stream are planned as part of Master Plan improvements, the crossings shall be accomplished through the construction of a free-span pedestrian bridge over the stream and footings for the bridge shall not placed between or on the banks of the stream.

IV-22 The applicant (City of Healdsburg) shall apply for and obtain necessary authorizations for placement of fill material within waters of the United States (WOTUS) and waters of the State (WOTS). Such authorizations shall include federal Clean Water Act (CWA) Section 404 nationwide permits from the USACE, CWA 401 water quality certification and PorterCologne Act Waste Discharge Requirements from the RWQCB, and one or more Fish and Game Code Section 1602 Streambed Alteration Agreements from CDFW. A Mitigation and Monitoring Plan may need to be prepared and submitted to these agencies for review as part of the process for obtaining project authorization. At a minimum the City shall ensure there is no net loss of wetland or stream habitat areal extent and associated function(s). Opportunities may be present for on-site mitigation of wetland impacts to include wetland restoration and enhancement (i.e., removal of exotic/invasive vegetation). On-site mitigation shall be a priority.

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d. Wildlife corridors are segments of land that provide a link between different habitats while also providing cover. Habitat loss, fragmentation, and degradation have the potential to alter the use and viability of wildlife movement corridors (i.e., linear habitats that naturally connect and provide passage between two or more otherwise distinct larger habitats or habitat fragments). The suitability of a habitat as a wildlife movement corridor is related to, among other factors, the habitat corridor’s dimensions (length and width), topography, vegetation, exposure to human influence, and the species in question.

The Valley Foothill Riparian habitat in the southern portion of the project site is part of a wildlife corridor extending along the Russian River. The unnamed creek traversing the western portion of the site through the coastal oak woodland and valley foothill riparian before emptying into the Russian River is also a wildlife corridor but on a smaller scale.

Avian diversity within the project site was generally greatest in the riparian habitat immediately along the Russian River and along the stretch of creek that passes through the coastal oak woodland and valley foothill riparian habitats before emptying into the Russian River at the southwest corner of the site in the vicinity of the willow island Both areas provide a movement corridor for local insects, and amphibian, reptile, bird, and mammal species. The Master Plan provides for protection of the area adjacent to the Russian River and the length of the unnamed creek in the western portion of the project site (including a 25-foot setback), so the integrity of the aforementioned wildlife corridors would be maintained and impacts associated with the use of the corridors by wildlife would be minimal. However, wildlife species were observed on the project site during winter/early spring and summer season field surveys by an HBG wildlife biologist, including 50 bird species, and significant impacts to wildlife species could occur without implementation of mitigation measures.

Mitigation measures that would protect wildlife species include mitigation to minimize impacts to riparian areas, wetlands, native vegetation, and heritage trees (Mitigation Measures IV-13 through IV-19), mitigation measures to protect any populations of special status plant and animal species (Mitigation Measures IV-1 through IV-7 and Mitigation Measures IV-11 and IV-12), and measures to protect any on-site populations of nesting birds (Mitigation Measures IV-8) or bats (Mitigation Measure IV-9). Even with implementation of these mitigation measures, some impacts to wildlife in the forested portions of the project site are possible; therefore, additional mitigation is required.

Thus, the proposed project could interfere substantially with the movement of any resident or migratory fish or wildlife species or with established resident or migratory wildlife corridors and a potentially significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level.

The Biological Monitor shall conduct an education program for all persons employed on the proposed project prior to performing ground-disturbing activities or vegetation removal. Instruction shall include a discussion of the Item 7.c
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biology and general behavior of any sensitive species that may be in the area, how they may be encountered within the work area, and procedures to follow when they are encountered. Training shall include such information about coho salmon, steelhead, Russian River tule perch, foothill yellow-legged frog, western pond turtle, and osprey. Interpretation shall be provided for non-English speaking workers, and the same instruction shall be provided for any new workers prior to on-site project activity. The Biological Monitor shall prepare and distribute wallet-sized cards or a factsheet handout containing this information for workers to carry on-site. Upon completion of the program, employees shall sign an affidavit stating they attended the program, which shall be available to the City.

The qualified biologist/Biological Monitor shall remain on-site during work involving vegetation clearing and ground disturbance within the Valley Foothill Riparian and Coastal Oak and Valley Oak Woodland portions of the project site, including areas adjacent to the Russian River or along the unnamed drainage through the northern and western portions of the project site to provide biological monitoring. The Biological Monitor will (1) assist in demarcation of buffer zones to protect habitats or sensitive species (including active bird nests), (2) to ensure impacts to sensitive animal species do not occur, (3) to ensure the relocation of any sensitive animal species encountered according to agency protocols, and (4) to help ensure facilities are implemented in the least environmentally sensitive locations. f. The project site is not located in an area that has an approved Habitat Conservation Plan, Natural Community Conservation Plan, or local, regional, or state habitat conservation plan. Therefore, the proposed project would not conflict with a Habitat Conservation Plan, Natural Conservation Community Plan, and no impact would occur.

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V. CULTURAL RESOURCES.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?     b. Cause a substantial adverse change in the significance of a unique archaeological resource pursuant to Section 15064.5?
   
c. Disturb any human remains, including those interred
outside of dedicated cemeteries.    
Discussion
The following is based on a Cultural Resources Study prepared for the proposed project by Evans and De Shazo Archeology and Historic Preservation.9
a. Historical resources are features that are associated with the lives of historically-important persons and/or historically-significant events, that embody the distinctive characteristics of a type, period, region or method of construction, or that have yielded, or may be likely to yield, information important to the pre-history or history of the local area, California, or the nation. Examples of typical historical resources include, but are not limited to, buildings, farmsteads, rail lines, bridges, and trash scatters containing objects such as colored glass and ceramics.

The Cultural Resources Study consisted of a literature review to identify any previously recorded historical resources and a field survey, conducted on May 13, 2024, of the entire project site. On May 1, 2024, a records search of the California Historic Resources Information System (CHRIS) was performed by the Northwest Information Center (NWIC) for cultural resource site records and survey reports within the project area. The NWIC concluded that portions of the project site have been previously surveyed for cultural resources as part of five studies. In addition, twelve additional studies have been completed with 0.25-mile of the project site. According to the records search, previously recorded historic resources are not located within the project site. In addition, historic resources were not found during the field survey. Therefore, the proposed project would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5, and a less-than-significant impact would occur. b,c. Based on the results of CHRIS records search conducted as part of the Cultural Resources Study, the NWIC concluded that the project site does not contain any recorded archaeological resources. In addition, cultural resources, including precontact or historicperiod artifacts or other indications of archaeological resources, were not discovered onsite during the field survey. However, while precontact period archeological sites have not been recorded within 0.25-mile of the project site, a lithic scatter on the property adjacent to and east of the project site was identified in a previous cultural resources survey of the project area. A search of the Native American Heritage Commission (NAHC) Sacred Lands File was also conducted as part of the Cultural Resources Study and returned positive results for the presence of Tribal Cultural Resources within the project site. The site has been subject to extensive disturbance associated with the current use of the site 9 Evans and De Shazo Archaeology and Historic Preservation. Cultural Resources Study for the Proposed Badger Park Master Plan Project, 750 Heron Drive, Healdsburg, Sonoma County, California. June 13, 2024.

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as a park. Any subsurface resources would likely have been uncovered as part of the previous site disturbance.

Nonetheless, according to the Cultural Resources Study, the project site has a high potential/sensitivity for archeological resources. Thus, previously unrecorded archaeological resources, including human remains, have the potential to exist on-site, and such resources could be encountered during ground-disturbing activity related to project construction. As a result, the proposed project could cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5 and/or disturb human remains, including those interred outside of formal cemeteries, should any such resources be encountered during construction.

Consequently, impacts could be considered potentially significant.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

V-1 Prior to initiation of ground-disturbing activities, a qualified archaeologist shall conduct a short awareness training session for all construction workers and supervisory personnel. The course shall explain the importance of, and legal basis for, the protection of significant archaeological resources. Each worker shall also learn the proper procedures to follow in the event cultural resources or human remains/burials are uncovered during construction activities, including work curtailment or redirection and to immediately contact their supervisor and the archaeological monitor. The worker education session shall include visuals of artifacts (prehistoric and historic) that might be found in the project vicinity and take place on the construction site immediately prior to the start of construction. Documentation of the training (i.e., a sign-in sheet) shall be retained at the site and shall be submitted with applicable reports to the City of Healdsburg Community Development Department.

V-2 During all construction activities taking place within the forested portions of the project site a Secretary of Interior (SOI) qualified archaeologist, or an archaeologist working under the direct supervision of a SOI-qualified archeologist, shall conduct spot monitoring of project-related ground disturbing activities within the forested portions of the project area, including during the removal of invasive vegetation and the development of overlook structures, trails, bridges, at-grade creek crossings, bankstabilizing bioengineered vegetative walls, vehicular drop-off loop, and river access points. Spot monitoring shall consist of the archaeologist conducting regular visits to the project area to monitor the progress of excavation, during which, all excavated material, open excavation, recently grubbed areas, and other soil disturbances shall be inspected by the archeological monitor. The archeological monitor shall have the authority to halt construction in the area of a discovery to ensure that an archeological resource is protected from further impact. If a potentially significant archeological resource is identified, the SOI-qualified archeologist shall notify the City of Healdsburg and the contractor, and Mitigation Measure V-3 shall be implemented.

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V-3 In the event a potentially significant cultural resource is encountered during subsurface earthwork activities, all construction activities within a 100-foot radius of the find(s) shall cease and workers shall avoid altering the materials until an archaeologist who meets the Secretary of Interior’s Professional Qualification Standards for archaeology has evaluated the find(s). The City shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement. The qualified archeologist shall make recommendations to the Lead Agency on the measures that shall be implemented to protect the discovered resources, including but not limited to, culturally appropriate temporary and permanent treatment, which may include avoidance of cultural resources, in-place preservation, and/or re-burial on project property so the resource(s) are not subject to further disturbance in perpetuity. If avoidance is determined to be infeasible, pursuant to CEQA Guidelines Section 15126.4(b)(3)(C), a data recovery plan, which makes provisions for adequately recovering the scientifically consequential information from and about the historical resource, shall be prepared and adopted prior to any excavation being undertaken. Such studies shall be deposited with the California Historical Resources Regional Information Center. If necessary, excavation and evaluation of the find(s) shall comply with Section 15064.5 of the CEQA Guidelines.

Potentially significant cultural resources include, but are not limited to, stone, bone, glass, wood, or shell artifacts or features, including hearths, structural remains, or historic dumpsites. Any previously undiscovered resources found during construction within the project site shall be recorded on appropriate Department of Parks and Recreation (DPR) 523 forms and will be submitted to the City of Healdsburg, the NWIC, and the State Historic Preservation Office (SHPO), as required.

If the coroner determines that the remains are Native American, then, within 24 hours, the Coroner must notify the Native American Heritage Commission, which in turn will notify the most likely descendants who may recommend treatment of the remains and any grave goods. The potential exists that the Native American Heritage Commission may be unable to identify a most likely descendant, the most likely descendant fails to make a recommendation within 48 hours after notification by the Native American Heritage Commission, or the landowner or his authorized agent rejects the recommendation by the most likely descendant and mediation by the Native American Heritage Commission fails to provide a measure acceptable to the landowner. In such a case, the landowner or his authorized representative shall rebury the human remains and grave goods Item 7.c
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with appropriate dignity at a location on the property not subject to further disturbances. Should human remains be encountered, a copy of the resulting County Coroner report noting any written consultation with the Native American Heritage Commission shall be submitted as proof of compliance to the City’s Community Development Department.

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VI. ENERGY.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
   
b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?    
Discussion
a,b. The main forms of available energy supplies are electricity, natural gas, and oil. Through existing infrastructure, electrical services are provided by the City’s Electric Utility Department. During construction, the proposed park project would be subject to regulations regulated by CARB. During operations, the proposed park project would be subject to the 2022 Building Energy Efficiency Standards, the 2022 California Green Building Standards Code, otherwise known as the CALGreen Code (CCR Title 24, Part 11), and the Healdsburg Reach code, as applicable. Discussions related to the proposed project’s potential effects regarding energy demand during construction and operations are provided below.

Construction Energy Use
Construction of the proposed project would involve on-site energy demand and consumption related to the use of oil in the form of gasoline and diesel fuel for construction worker vehicle trips, hauling and material delivery truck trips, and operation of off-road construction equipment. In addition, diesel-fueled portable generators may be necessary to provide additional electricity demands for temporary on-site lighting, welding, and for supplying energy to areas of the site where energy supply cannot be met via a hookup to the existing electricity grid. Project construction would not involve the use of natural gas appliances or equipment.

All construction equipment and operation thereof would be regulated per the CARB InUse Off-Road Diesel Vehicle Regulation. The In-Use Off-Road Diesel Vehicle Regulation is intended to reduce emissions from in-use, off-road, heavy-duty diesel vehicles in California by imposing limits on idling, requiring all vehicles to be reported to CARB, restricting the addition of older vehicles into fleets, and requiring fleets to reduce emissions by retiring, replacing, or repowering older engines, or installing exhaust retrofits. In addition, as a means of reducing emissions, construction vehicles are required to become cleaner through the use of renewable energy resources. The In-Use Off-Road Diesel Vehicle Regulation would therefore help to improve fuel efficiency for equipment used in construction. Technological innovations and more stringent standards are being researched, such as multi-function equipment, hybrid equipment, or other design changes, which could help to reduce demand on oil and limit emissions associated with redevelopment and construction.

Operational Energy Use
The proposed park project would consume a relatively small amount of electricity during operations associated with the restroom building and outdoor lighting. Maintenance activities, such as landscape and field maintenance, would involve the use of electric or gas-powered equipment. In addition to on-site energy use, the proposed park project would result in transportation energy use associated with vehicle trips generated by park Item 7.c
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users. The restroom building would be subject to all relevant provisions of the most recent update of the California Building Code Standards (CBSC) including the Building Energy Efficiency Standards. Adherence to the most recent CALGreen Code and the Building Energy Efficiency Standards would ensure that the proposed structure would consume energy efficiently through the incorporation of such features as door interlocks and high efficiency outdoor lighting.

Based on the above, the temporary increase in energy use during project redevelopment and construction activities would not result in a significant increase in peak or base demands or require additional capacity from local or regional energy supplies. The proposed project would be required to comply with all applicable regulations related to energy conservation and fuel efficiency, which would help to reduce the temporary increase in demand.

Conclusion
Based on the above, implementation of the proposed project would not result in wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and a less-than-significant impact would occur.

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VII. GEOLOGY AND SOILS.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State
Geologist for the area based on other substantial
evidence of a known fault? Refer to Division of
Mines and Geology Special Publication 42.
   
ii. Strong seismic ground shaking?    
iii. Seismic-related ground failure, including
liquefaction?    
iv. Landslides?    
b. Result in substantial soil erosion or the loss of topsoil?     c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
   
d. Be located on expansive soil, as defined in Table 18-1B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
   
e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
   
f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?    
Discussion
ai-aii The project site is not located within the boundaries of an Earthquake Fault Zone, as designated pursuant to the Alquist-Priolo Earthquake Fault Zoning Act.10 As noted in the City’s General Plan, the City is located within the vicinity of the San Andreas fault system, located 19 miles to the east of the planning area. Other, more distinct, active faults in the region include the West Napa, Green Valley, Hayward, San Gregorio, Calaveras, Concord, and Greenville faults. However, pursuant to Figure IV.G-1 of the General Plan, the project site is not underlain by any active faults or trace lines. Thus, fault rupture hazard is not a significant geologic hazard at the site.

Based on the proximity of the project site to local and regional faulting, as well as historical seismic activity, the project site is considered subject to relatively high ground shaking risk and related effects. The proposed park redevelopment would not include construction of any habitable structures. Construction of features such as the new pedestrian bridges, a new restroom building, new play structures would be properly engineered in accordance with the CBSC, which includes engineering standards appropriate for the seismic area in which the project site is located. Projects designed in accordance with the CBSC should be able to: 1) resist minor earthquakes without damage; 2) resist moderate earthquakes without structural damage, but with some non-structural damage; and 3) resist major earthquakes without collapse, but with some structural, as well as non-structural, damage.

Although conformance with the CBSC does not guarantee that substantial structural 10 California Department of Conservation. California Earthquake Hazards Zone. February 27, 2009.

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damage would not occur in the event of a maximum magnitude earthquake, conformance with the CBSC can reasonably be assumed to ensure that the proposed structures would be survivable, allowing park users to safely evacuate in the event of a major earthquake.

Thus, the proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death associated with seismic-related ground failure, including rupture of a known earthquake fault or strong seismic ground shaking. Therefore, a less-than-significant impact would occur. b. Issues related to erosion and degradation of water quality during construction are discussed in further detail in Section X, Hydrology and Water Quality, of this Initial Study.

As noted therein, the proposed project would not result in substantial soil erosion or the loss of topsoil. Thus, a less-than-significant impact would occur. aiii,aiv, The proposed project’s potential effects related to liquefaction, landslides, lateral c, d. spreading, and subsidence are discussed in detail below.

Liquefaction
Liquefaction is the temporary transformation of loose, saturated granular sediments from a solid state to a liquefied state as a result of seismic ground shaking. In the process, the soil undergoes transient loss of strength, which commonly causes ground displacement or ground failure to occur. Because saturated soils are a necessary condition for liquefaction, soil layers in areas where the groundwater table is near the surface have higher liquefaction potential than those in which the water table is located at greater depths. Additionally, loose unsaturated sandy soils have the potential to settle during strong seismic shaking. As noted in the City’s General Plan, soils in and around the Russian River, especially near the banks, are susceptible to liquefaction during a seismic event. Therefore, the proposed project could be subject to risk from liquefaction.

Lateral Spreading
Lateral spreading is horizontal/lateral ground movement of relatively flat-lying soil deposits towards a free face such as an excavation, channel, or open body of water; typically, lateral spreading is associated with liquefaction of one or more subsurface layers near the bottom of the exposed slope. The amount of movement depends on the soil strength, duration and intensity of seismic shaking, topography, and free face geometry. Given that the project site does not contain any free faces, the potential for lateral spreading to pose a risk to the proposed park redevelopment is negligible.

Landslides
Seismically-induced landslides are triggered by earthquake ground shaking. The risk of landslide hazard is greatest in areas with steep, unstable slopes. Lateral spreading or lurching is a situation in which soil mass deforms laterally toward a free face, such as an excavation, channel, or open body of water, during a seismic event. The failure occurs along a liquefiable or weak subsurface layer. The City has determined the potential for seismically induced land sliding to occur would depend on a number of factors, such as the type of bedrock, type and depth of soils, angle and direction of the slope, and moisture content. The project site does not feature varying degrees of slope commonly associated with areas at risk for earthquake-induced landslides. Thus, landslides would not occur onsite as a result of the proposed project.

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Subsidence/Settlement
Subsidence is the settlement of soils of very low density generally from either oxidation of organic material, desiccation and shrinkage, or both, following drainage. Subsidence takes place gradually, usually over a period of several years. According to the City of Healdsburg’s General Plan EIR, subsidence is not likely to occur within the City.

Additionally, compliance with General Plan polices would ensure future developments would be required to employ structurally sound building practices. Therefore, the potential for subsidence/settlement to pose a risk to the proposed development is relatively low.

Expansive Soils
According to the City of Healdsburg General Plan EIR, portions of the City are underlain by expansive soils. Such soils occur most frequently in areas underlain by rocks of the Great Valley Sequence or Sonoma Volcanics. Expansive soils can undergo significant volume change with changes in moisture content. Specifically, such soils shrink and harden when dried and expand and soften when wetted. Expansive soils can shrink or swell and cause heaving and cracking of slabs-on-grade, pavements, and structures founded on shallow foundation. Pursuant to the Natural Resource Conservation Service (NRCS) Web Soil Survey, the soils underlying the project site are made up of approximately 12.4 acres of Yolo sandy loam content, with the remainder of the project site being a mix of riverwash, Pleasanton loam, and Pleasanton gravelly loam.11 Soils with a linear extensibility rating of between three and six percent and a clay content of 25 to 35 percent are characterized by a moderate shrink-swell class (i.e., moderate expansive potential). Soils with a linear extensibility rating of between six and nine percent with a clay content of 35 to 45 percent are characterized by a high shrink-swell class.

According to the NRCS Web Soil Survey, the Yolo sandy loam soils on-site have a linear extensibility rating of 1.5 percent, the Pleasanton loam has a linear extensibility rating of

3.6, and Riverwash 1.5. In addition, the on-site Yolo sandy loam soil has a clay content of

21.4 percent. Therefore, the project site contains soil types that are considered to be moderate to highly expansive.

Based on the above, the proposed project has the potential to create substantial direct or indirect risks to life or property related to being located on expansive soil.

Conclusion
Based on the above discussion, the proposed project would not result in potential hazards or risks related to landslides, lateral spreading, or subsidence/settlement. However, the potential exists for liquefaction and soil expansion to occur on-site. Therefore, the proposed project could create substantial direct or indirect risks to life or property and a potentially significant impact could occur.

Mitigation Measure(s)
Implementation of the following mitigation measure would reduce the above potential impact to a less-than-significant level.

VII-1 Prior to final design-level drawings, a Geotechnical Analysis shall be conducted by a California Registered Civil Engineer or Geotechnical 11 Natural Resource Conservation Service. Web Soil Survey. Available at:
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. Accessed May 2024.

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Engineer to characterize the subsurface conditions of the project site. The report shall address and make recommendations on the following:
• Road, pavement, and parking area design;
• Structural foundations, including retaining wall design (if applicable);
• Grading practices;
• Erosion/winterization;
• Special problems discovered on-site, (i.e., groundwater, expansive/unstable soils, etc.); and
• Slope stability.

The design-level drawings for the Master Plan shall be reviewed and approved by the Director of Public Works/City Engineer, Chief Building Official, and a qualified Geotechnical Engineer prior to issuance of grading and building permits to ensure that all geotechnical recommendations specified in the Geotechnical Analysis are properly incorporated and utilized in the project design.
e. The construction or operation of septic tanks or other alternative wastewater disposal systems is not included as part of the project. The proposed bathroom would connect to the City sewer system. Therefore, no impact regarding the capability of soil to adequately support the use of septic tanks or alternative wastewater disposal systems would occur. f. The City’s General Plan EIR indicates that rocks of the Franciscan Assemblage, which have been known elsewhere to contain paleontological remains, underlie a small area in the northern portion of the City of Healdsburg. However, the Franciscan Assemblage rocks are located approximately 1.4 miles south of the project site and would not have the potential to be impacted by the proposed project. As further noted in the City’s General Plan, the City is underlain by alluvium, which consists mainly of unconsolidated gravel, sand, silt, and clay deposits. Such soil types are not considered unique geologic features and are common within the geographic area of the City. Furthermore, the City’s General Plan does not note the existence of any unique geologic features within the City.

Consequently, implementation of the proposed project would not be anticipated to have the potential to result in direct or indirect destruction of unique geologic features. In addition, the project site has been subject to previous disturbance associated with the current use of the site as a park. Nonetheless, the proposed project would include thinning areas of forest which have not been previously disturbed. As such, previously undiscovered paleontological resources could be present in such undisturbed areas.

However, if any subsurface resources are discovered during project construction activities, the proposed project would implement Mitigation Measures V-1 through V-4, which would reduce all impacts to unknown paleontological resources.

Therefore, the proposed project would not result in the direct or indirect destruction of a unique paleontological resource, and a less-than-significant impact would occur.

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VIII. GREENHOUSE GAS EMISSIONS.

Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
   
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gasses?
   
Discussion
a,b. Emissions of GHGs contributing to global climate change are attributable in large part to human activities associated with the industrial/manufacturing, utility, transportation, residential, and agricultural sectors. Therefore, the cumulative global emissions of GHGs contributing to global climate change can be attributed to every nation, region, and city, and virtually every individual on Earth. An individual project’s GHG emissions are at a micro-scale level relative to global emissions and effects to global climate change; however, an individual project could result in a cumulatively considerable incremental contribution to a significant cumulative macro-scale impact. As such, impacts related to emissions of GHG are inherently considered cumulative impacts.

Implementation of the proposed project would cumulatively contribute to increases of GHG emissions. Estimated GHG emissions attributable to the project would be primarily associated with increases of carbon dioxide (CO2) and, to a lesser extent, other GHG pollutants, such as methane (CH4) and nitrous oxide (N2O) associated with area and mobile sources. The primary source of GHG emissions for the project would be associated with the construction equipment and haul trucks to be used for the proposed remediation activities. The common unit of measurement for GHG is expressed in terms of annual metric tons of CO2 equivalents (MTCO2e/yr).

Similar to the discussion of criteria pollutant emissions included in Section III, Air Quality, of this IS/MND, the NCAB has not adopted thresholds of significance for GHG emissions for CEQA analyses purposes. Thus, this analysis applies the thresholds of significance used for CEQA analysis within the nearby SFBAAB, formulated by the BAAQMD.

The most recent BAAQMD Air Quality Guidelines were released in April 2023.12 The updated GHG thresholds address more recent climate change legislation, including Senate Bill (SB) 32 (signed into law on September 8, 2016), and provide qualitative thresholds related to Buildings and Transportation.

Construction GHG emissions are a one-time release and are, therefore, not typically expected to generate a significant contribution to global climate change. Neither the City nor BAAQMD has an adopted threshold of significance for construction-related GHG emissions and does not require quantification. Nonetheless, the proposed project’s construction GHG emissions, as well as operational emissions, have been estimated using CalEEMod under the same assumptions discussed in Section III, Air Quality, of this IS/MND (see Appendix A). The emissions estimates prepared for the proposed project determined that construction of the project would result in total unmitigated GHG emissions of 300 MTCO2e over the entire construction period. 12 Bay Area Air Quality Management District. 2022 California Environmental Quality Act Guidelines. April 2023.

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In addition, operational GHG emissions are presented in Table 5. However, as noted previously, the BAAQMD’s applicable threshold of significance for GHG emissions are qualitative, and the foregoing information is provided for disclosure purposes only.

Potential impacts related to GHG emissions resulting from implementation of the proposed project are considered in comparison with BAAQMD’s adopted thresholds of significance below.

Table 5
Unmitigated Operational GHG Emissions
Source Project Emissions (MTCO2e/yr)
Mobile 324
Area –
Energy 28.7
Water 61.9
Waste 3.31
Total Operational GHG Emissions 418
Source: CalEEMod, May 2024 (see Appendix A).

Operational GHG Thresholds of Significance
According to the BAAQMD thresholds of significance, a project must either include specific project design elements (e.g., exclude use of natural gas, achieve a specific reduction in project-generated vehicle miles traveled (VMT) below the regional average) or be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).13
The City of Healdsburg adopted their Climate Mobilization Strategy (CMS) in October 2023 which meets the criteria under State CEQA Guidelines Section 15183.5(b). As such, the analysis of the proposed project’s operational GHG emissions discussed below is based on consistency with the City’s Climate Mobilization Strategy.

City of Healdsburg CMS Consistency
The City of Healdsburg CMS is intended to create a roadmap to achieve emissions reductions of 40 percent below 1990 levels by 2030, and carbon neutrality (i.e., net zero carbon emissions) by 2045. The CMS contains reduction strategies and measures, consistent with State climate mitigation targets, which were developed to reduce the City’s GHG emissions to reach its adopted reduction targets for 2030 and 2045.

The reduction measures included within the City’s CMS are targeted for implementation at the City level, are related to implementation of future citywide policies and programs that have not yet been developed within the City, or are otherwise only applicable to projects which include the development of new residential or commercial uses, and, therefore, are not directly applicable to the proposed project. However, implementation of the project would be consistent with the overarching goal of the CMS, which is to ensure that future GHG emissions comply with the State’s climate mitigation goals. In addition, the proposed project would include redevelopment of an existing park. The projections and GHG reduction targets included in the CMS anticipated use of the site as a park, and, therefore, the proposed project would not result in an increase in GHG emissions beyond what has already been anticipated by the City for the site. In fact, as discussed throughout this IS/MND, one of the main goals of the redevelopment project is to create a more 13 Bay Area Air Quality Management District. 2022 California Environmental Quality Act Guidelines. April 2023.

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resilient climate adaptive park. Given that the proposed project would be built in compliance with the requirements of the 2022 Building Energy Efficiency Standards, the 2022 CALGreen standards, and the Healdsburg Reach Code, the proposed project is anticipated to be built more efficient than the existing park uses. For example, as discussed previously, the 2022 Building Energy Efficiency regulates outdoor lighting characteristics of new development such as maximum power and brightness, shielding, and controls to turn lighting on and off, which would help to reduce GHG emissions related to energy usage. The proposed park project would also include a new path system, which would connect the park and the adjacent neighborhood to the riverfront through the forested areas, and would include widening and resurfacing of an existing informal trail along the riverbank to make the trail more navigable and maintained. Such improvements would encourage walkability and would generally result in the reduction of mobile source GHG emissions associated with the park. In addition, as discussed in Section XVII, Transportation, of this IS/MND, while the proposed project is anticipated to result in an increase in 91 trips per day associated with the proposed pickleball courts, such an increase in trips is not anticipated to substantially increase VMT. The proposed project would also comply with all applicable regulations associated with vehicle and fuel economy.

Conclusion
Based on the above, the proposed project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, or could conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs. Thus, a less-than-significant impact would occur.

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IX. HAZARDS AND HAZARDOUS
MATERIALS.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
   
b. Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the likely release of
hazardous materials into the environment?
   
c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
   
d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
   
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
   
f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
   
g. Expose people or structures, either directly or indirectly, to the risk of loss, injury or death involving wildland fires?     Discussion
a. Park uses are not typically associated with the routine transport, use, disposal, or generation of substantial amounts of hazardous materials. Upon completion of the proposed redevelopment, the proposed project may involve the use of herbicides and/or fertilizers on-site associated with the proposed landscaping, either of which could contain potentially hazardous chemicals; however, such products would be expected to be used in accordance with label instructions, and use would be consistent with what currently occurs on-site. Due to the regulations governing use of such products and the amount anticipated to be used on the site, routine use of such products would not represent a substantial risk to public health or the environment. Therefore, the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, and a less-than-significant impact would occur.
b. The proposed project’s potential effects related to the likely release of hazardous materials through existing site conditions and/or construction activities are discussed in detail below.

The project site is currently developed with the existing approximately 20-acre Badger Park, which consists of a 114,000-sf informal recreation field, a 6,250-sf playground, a 7,500-sf dog run, and a 27,000-sf community garden, as well as picnic areas and a 46- space parking lot. Hazardous materials, with the exception of fertilizers, are not associated with the current park use.

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Construction Activities
Construction activities associated with the proposed project would involve the use of heavy equipment, which would contain fuels and oils, and various other products such as concrete, paints, and adhesives. Small quantities of potentially toxic substances (e.g., petroleum and other chemicals used to operate and maintain construction equipment) would be used at the project site and transported to and from the site during construction.

However, the project contractor would be required to comply with all California Health and Safety Codes regulating the handling, storage, and transportation of hazardous and toxic materials. Pursuant to California Health and Safety Code Section 25510(a), except as provided in subdivision (b), the handler or an employee, authorized representative, agent, or designee of a handler, shall, upon discovery, immediately report any release or threatened release of a hazardous material to the unified program agency (in the case of the proposed project, the Sonoma County Department of Environmental Health) in accordance with the regulations adopted pursuant to Section 25510(a). The handler or an employee, authorized representative, agent, or designee of the handler shall provide all State, city, or county fire or public health or safety personnel and emergency response personnel with access to the handler's facilities. In the case of the proposed project, the contractors are required to notify the Sonoma County Department of Environmental Health in the event of an accidental release of a hazardous material, who would then monitor the conditions and recommend appropriate remediation measures.

Conclusion
Based on the above, the proposed project would result in a less-than- significant impact related to creating a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment.
c. The nearest schools relative to the project site are Healdsburg Elementary School and St.

John the Baptist Catholic School, located 0.50-mile and 0.70-mile from the project site, respectively. Therefore, schools are not located within one-quarter mile of the project site, and the proposed project would result in no impact related to hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school. d. Government Code Section 65962.5 requires the California Environmental Protection Agency to annually develop an updated Cortese List. The components of the Cortese List include the Department of Toxic Substances Control (DTSC) Hazardous Waste and Substances Site List, the list of leaking underground storage tank (UST) sites from the State Water Resources Control Board’s (SWRCB) GeoTracker database, the list of solid waste disposal sites identified by the SWRCB, and the list of active Cease and Desist Orders (CDO) and Cleanup and Abatement Orders (CAO) from the SWRCB. The project site is not included on the DTSC Hazardous Waste and Substances Site List,14 or the list of solid waste disposal sites.15 Additionally, the SWRCB’s GeoTracker database does not identify the project site as containing any Leaking Underground Storage Tanks (LUSTs), which is another portion of the Cortese List.16 Finally, the project site is not on the list of 14 Department of Toxic Substances Control. Hazardous Waste and Substances Site List (Cortese). Available at:
https://www.envirostor.dtsc.ca.gov/public/. Accessed April 2024. 15 CalEPA. Cortese List Data Resources. Available at: https://calepa.ca.gov/sitecleanup/corteselist/. Accessed May 2024. 16 State Water Resources Control Board. GeoTracker Public Site. Available at:
https://geotracker.waterboards.ca.gov/map/. Accessed May 2024.

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active CDO and CAO from the SWRCB. Thus, the proposed project would not create a significant hazard to the public or the environment, and no impact would occur. e. The nearest airport to the project site is the Healdsburg Municipal Airport, located approximately 5.5 miles northwest of the site. The site is not covered by an airport land use plan. Therefore, no impact would occur related to a safety hazard or excessive noise for people working in the project area.
f. The proposed project would not alter the existing circulation system in the surrounding area. During operation, the proposed project would provide adequate access for emergency vehicles and would not interfere with potential evacuation or response routes used by emergency response teams. During construction of the proposed project, all construction equipment would be staged on-site so as to prevent obstruction of local and regional travel routes in the City that could be used as evacuation routes during emergency events.

The City of Healdsburg adopted the City of Healdsburg Emergency Operations Plan (EOP) in August 2021.
17 The plan provides a basis for future responses to a wide range of citywide hazards and vulnerabilities. The plan provides a description of the emergency management organization and how it is activated. Additionally, the EOP establishes the foundational policies and procedures that define how the City would respond to, recover from, and mitigate against natural or human-caused disasters. Implementation of the proposed project would not result in any substantial modifications to the existing roadway system and, thus, would not physically interfere with the EOP, particularly with any emergency evacuation routes. Furthermore, the proposed project would be consistent with what has been planned for the site and would not include land uses or operations that could impair implementation of the plan. Therefore, the proposed project would not interfere with an emergency evacuation or response plan, and a less-than-significant impact would occur.
g. Issues related to wildfire hazards are discussed in Section XX, Wildfire, of this Initial Study.

As noted therein, the project site is not located within a Very High Fire Hazard Severity Zone.18 In addition, the project site is located within a central area of the City of Healdsburg and is surrounded by existing development. The developed nature of the area surrounding the project site would help to reduce the potential spread of wildfire to the site, and the Master Plan includes removal of invasive vegetation within the park’s forested area to open and thin the tree canopy and reduce fire fuel. Thus, the potential for wildland fires to reach the project site would be relatively limited. Furthermore, the project would not include the construction of any housing or habitable structures. Therefore, the proposed project would not expose people or structures to the risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands, and a less-than-significant impact would occur.
17 City of Healdsburg. City of Healdsburg Emergency Operations Plan. August 2021. 18 California Department of Forestry and Fire Protection. Fire Hazard Severity Zones in State Responsibility Areas.

Available at. https://calfireforestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d89597ab693d008. Accessed July 2024.

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X. HYDROLOGY AND WATER
QUALITY.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
   
b. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater
management of the basin?
   
c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or
off-site;    
ii. Substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or offsite;
   
iii. Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff; or
   
iv. Impede or redirect flood flows?    
d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?    
e. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management
plan?
   
Discussion
a. The following discussion provides a summary of the proposed project’s potential to violate water quality standards/waste discharge requirements or otherwise degrade water quality during redevelopment/construction and operation.

Construction
During the early stages of construction activities, topsoil would be exposed in portions of the site due to excavation of the areas of the site proposed for redevelopment, such as the development of structures at the river’s edge. After completion of groundwork and prior to overlaying the ground surface with pavement and landscaping, the potential exists for wind and water erosion to discharge sediment and/or urban pollutants into stormwater runoff, which could adversely affect water quality downstream.

The SWRCB regulates stormwater discharges associated with construction activities where clearing, grading, or excavation results in a land disturbance of one or more acres.

The City’s National Pollutant Discharge Elimination System (NPDES) permit requires applicants to show proof of coverage under the State’s General Construction Permit prior to receipt of any construction permits. Because the disturbance area associated with the proposed project would over one acre, the proposed project would be subject to the requirements of the State’s General Construction Permit. The State’s General Construction Permit requires a Storm Water Pollution Prevention Plan (SWPPP) to be prepared for the site. A SWPPP describes BMPs to control or minimize pollutants from Item 7.c
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entering stormwater and must address both grading/erosion impacts and non-point source pollution impacts of the development project. Additionally, the project would be required to comply with Chapter 13.28, Urban Stormwater Quality Management and Discharge Controls, of the City’s Municipal Code, which includes standards for managing stormwater runoff during construction and operation, and the requirement to test or monitor for prohibited discharges. Furthermore, Mitigation Measure IV-4, from Section IV, Biological Resources, of this IS/MND, would ensure erosion control measures are being met.

Compliance with the aforementioned requirements would ensure that the proposed project would not discharge sediment or urban pollutants through soil erosion, violate any water quality standards or waste discharge requirements, or otherwise substantially degrade surface or ground water quality during the proposed remediation and construction activities.

Operation
The proposed Master Plan would include a variety of active and passive spaces, consisting of natural open space, as well as new pervious surfaces (i.e., grass sports fields, dog park, landscaping, etc.) and impervious surfaces (i.e., parking lot, playground, sports courts, bathroom, etc.). As such, the proposed park project would be required to include on-site stormwater facilities to provide storm water quality treatment and volume capture in accordance with the current Low Impact Development Technical Design Manual pursuant to the City's municipal separate storm sewer systems (MS4) permit requirements, as well as peak management at pre-project levels for on-site runoff.

Consistent with State requirements, the on-site stormwater system would be required to be sufficient to adequately handle the project’s stormwater runoff, which would ensure that the proposed park project would not have the potential to violate any storm water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. All projects within the City of Healdsburg must comply with Chapter

13.28 of the City of Healdsburg Municipal Code which would help reduce pollutants in storm water discharges to the maximum extent practicable and by prohibiting non-storm water discharges to the public storm drain system. Additionally, implementation of Mitigation Measures IV-4 and IV-10 would avoid the potential for sediment being transported into aquatic resources areas, including the Russian River.

Conclusion
Based on the above, the proposed project would not result in the violation of water quality standards or degradation of water quality, and a less-than-significant impact would occur.
b,e Water supplies in the central and southern portions of the City of Healdsburg, including the project site, are provided by the City of Healdsburg Utility Department. Pursuant to the 2020 Urban Water Management Plan (UWMP) for the City of Healdsburg, the City does not currently pump from groundwater basins or aquifers. 19 As noted previously, two
drinking wells and one irrigation well are currently located on-site. However, as discussed in the 2020 UWMP the water wells located on the project site are supplied water through Russian River surface water rights dating back to 1949, 20 as water from the Russian River
is diverted into the wells.
19 City of Healdsburg Utility Department. 2020 Urban Water Management Plan Update. [pg. 31]. October 2021. 20 City of Healdsburg Utility Department. 2020 Urban Water Management Plan Update. [pg. 62]. October 2021.

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The proposed project would involve water demand associated with irrigation of the proposed landscaping elements and sports field. However, such demand would not represent a substantial increase from existing conditions at the site. In addition, given that the proposed project would be consistent with the site’s current General Plan land use and zoning designations, the project would not result in increased use of groundwater supplies beyond what has been generally anticipated for the site by the City and accounted for in the UWMP. Per the 2020 UWMP, water supplies are projected to meet expected demand for normal year, single dry year, and multiple dry year scenarios through 2040. In addition, the proposed project would not result in a substantial increase in impervious surfaces relative to existing conditions and, thus, would not substantially alter groundwater recharge conditions at the project site.

Therefore, the proposed project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management. In addition, the project would not conflict with or obstruct implementation of a water quality control plan. Thus, a less-than-significant impact would occur.
c.i-iii. The proposed project would include a variety of active and passive spaces, consisting of natural open space, as well as new pervious surfaces (i.e., grass sports fields, dog park, landscaping, etc.) and impervious surfaces (i.e., parking lot, playground, sports courts, bathroom, etc.).

As discussed above, the proposed park project would be required to include on-site stormwater facilities to provide storm water quality treatment and volume capture in accordance with the current Low Impact Development Technical Design Manual pursuant to the City's MS4 permit requirements, and peak management at pre-project levels for onsite runoff. Flows would be allowed to percolate or outflow off-site at such a rate that downstream stormwater would not be overwhelmed ensuring that the proposed park project would not have the potential to violate any storm water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Additionally, implementation of Mitigation Measures IV-4 and IV-10 would avoid the potential for erosion.

Therefore, the proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion, siltation, or flooding on- or off-site, create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems, or provide substantial additional sources of polluted runoff. Consequently, the proposed project would result in a less-than-significant impact.
c.iv. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map number 06097C0551E, the project site is located within Zone A, Zone V, and Zone A99, which are considered Special Flood Hazard Zones (SFHZs).21 Because the proposed project is an expansion of an existing use, implementation of the proposed project is not anticipated to substantially affect flood flows. In addition, Chapter

17.28 of the City of Healdsburg Municipal Code, specifically Section 17.28.160, includes 21 Federal Emergency Management Agency. Flood Insurance Rate Map 06097C0051E. Effective December 3, 2008.

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standards of construction for all areas of special flood hazards. For example, all new construction and substantial improvements of structures shall be constructed with floodresistant materials, and utility equipment resistant to flood damage for areas below the base flood elevation. The proposed project includes construction of only one building, the bathroom, which would be subject to the standards established in the aforementioned City Municipal Code section.

Therefore, implementation of the proposed project would not impede or redirect flood flows and a less-than-significant would result.
d. As discussed under question ‘c.iv’ above, the project site is located within a SFHZ.

However, compliance with the aforementioned requirements would ensure that the proposed project would not be subject to substantial flooding risks. Tsunamis are defined as sea waves created by undersea fault movement, whereas a seiche is a longwavelength, large-scale wave action set up in a closed body of water such as a lake or reservoir. Due to the project site’s substantial distance from the coast, the proposed project would not be exposed to flooding risks associated with tsunamis. Seiches do not pose a risk to the proposed project, as the project site is not located adjacent to any closed body of water. Therefore, the proposed project would not pose a risk related to the release of pollutants due to project inundation due to flooding, tsunami, or seiche, and a lessthan-significant impact would occur.

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XI. LAND USE AND PLANNING.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Physically divide an established community?    
b. Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
   
Discussion
a. A project risks dividing an established community if the project would introduce infrastructure or alter land uses so as to change the land use conditions in the surrounding community, or isolate an existing land use. The proposed project would include redevelopment of the existing on-site park, and would result in the continuation of current site conditions. In addition, the proposed park project would also include a new path system, which would connect the park and the adjacent neighborhood to the riverfront through the forested areas, and would include widening and resurfacing of an existing informal trail along the riverbank to make the trail more navigable and maintained, which would increase connectivity of the park with the surrounding neighborhood. As such, the proposed project would not physically divide an established community, and no impact would occur.
b. The project site is designated Park/Open Space pursuant to the City’s General Plan and is zoned P. The project site is currently developed as a public park, which would be redeveloped as part of the proposed project. Thus, the project would be consistent with the site’s current land use and zoning designations.

As discussed throughout this IS/MND, the proposed project would not result in any significant environmental effects that cannot be mitigated to a less-than-significant level by the mitigation measures provided herein. In addition, the proposed project would not conflict with City policies and regulations adopted for the purpose of avoiding or mitigating an environmental effect, including, but not limited to, the City’s noise standards and applicable SWRCB regulations related to stormwater, and the City’s Heritage Tree Protection and Tree Report Requirements. In addition, as discussed in Section IV, Biological Resources, of this IS/MND, Mitigation Measure IV-14 would ensure that the proposed project would comply with the 25-foot setback to the unnamed creek located within the project site, as required by Section 20.24.090 of the Healdsburg Municipal Code. With respect to Russian River, the minor improvements related to invasive species removal and soft surface trails would be anticipated to be exempt from the setback requirements, but construction of the two river access points would require a variance. As noted in Section 20.24.095 of the Healdsburg Municipal Code, variances to the standards set forth in Healdsburg Municipal Code Section 20.24.090 may be granted where the provision of the required setback is infeasible. As such, the proposed project would require approval of a variance to allow such minor improvements within the 100-foot Russian River setback. Approval of the variance would require the preparation of a riparian mitigation plan to ensure no net loss of acreage or of functional value of riparian habitat occurs.

Therefore, the proposed project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental impact.

Thus, a less-than-significant impact would occur.

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XII. MINERAL RESOURCES.

Would the project:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
   
b. Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?
   
Discussion
a,b. Pursuant to the City’s General Plan, a State-designated Mineral Resource Zone-2 (MRZ2) is located in the southeastern portion of the City of Healdsburg, primarily located along the banks of the Russian River. Classification of an area as a MRZ-2 indicates the existence of a deposit that meets certain criteria for value and marketability. One gravel extraction site, Syar Industries, is currently located within the City limits southeast of the Russian River and north of the intersection of Healdsburg Avenue and Bailhache Avenue.

The proposed project is located adjacent to the Russian River. However, the General Plan EIR concluded that buildout of the Planning Area would result in a less-than-significant impact to mineral resources with implementation of applicable General Plan policies, including Policy NR-G-1, which allows for continued operation of existing sand and gravel mines on the Russian River as long as environmental regulations are being met. In addition, the site is currently developed with the existing Badger Park, and is not used for mineral resource extraction. Therefore, impacts to a known mineral resource that is of value to the region and residents of the state would be less than significant.

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XIII. NOISE.

Would the project result in:

Potentially
Significant
Impact
Less-ThanSignificant
with
Mitigation
Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
   
b. Generation of excessive groundborne vibration or
groundborne noise levels?    
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or
public use airport, would the project expose people
residing or working in the project area to excessive noise levels?
   
Discussion
The following discussion is based on an Environmental Noise Assessment prepared for the project by Saxelby Acoustics (see Appendix D).22
a. The following sections present information regarding sensitive noise receptors in proximity to the project site, the existing noise environment, and the potential for the proposed project to result in noise impacts during project construction and operation. The following terms are referenced in the sections below:
• Decibel (dB): A unit of sound energy intensity. An A-weighted decibel (dBA) is a decibel corrected for the variation in frequency response to the typical human ear at commonly encountered noise levels. All references to decibels (dB) in this analysis are A-weighted unless noted otherwise.
• Average, or equivalent, sound level (Leq): The Leq corresponds to a steady-state Aweighted sound level containing the same total energy as a time varying signal over a given time period (usually on hour).
• Day-Night Average Level (Ldn): The average sound level over a 24-hour day, with a +10 decibel weighing applied to noise occurring during nighttime (10:00 AM to 7:00 AM) hours.
• Maximum Sound Level (Lmax): The maximum sound level over a given time-period. • Median Sound Level (L50): The sound level exceeded 50 percent of the time over a given time-period.
• The 10th percentile value (L10): The sound level exceeded 10 percent of the time during the monitoring period.
• Community Noise Equivalent Level (CNEL): The 24-hour average noise level with noise occurring during evening (7:00 PM to 10:00 PM) hours weighted by a factor of three and nighttime hours weighted by a factor of ten prior to averaging.

City Noise Standards
Section 9.32.060 of the City of Healdsburg Municipal Code exempts noise sources associated with or vibration created by construction, repair, remodeling, or grading, 22 Saxelby Acoustics. Environmental Noise Assessment, Bager Park Redevelopment Master Plan, City of Healdsburg, California. June 7, 2024.

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provided such activities do not take place between the nighttime hours of 6:00 PM and 7:30 AM daily, or at any time on Sunday or a legal holiday, and provided the noise level created by such activities does not endanger the public health, welfare, and safety.

The City of Healdsburg noise level standards, established in Section 9.32.060 of the Municipal Code, require that new projects in the vicinity of existing sensitive receptors generate noise levels not greater than 60 dBA L10 during daytime (7:00 AM to 10:00 PM) hours at residential-zoned properties.

Additionally, the City of Healdsburg General Plan includes policies, such as Policy S-25, which would require construction that would result in a potentially significant impact on noise sensitive uses to use noise-reducing measures.

Sensitive Noise Receptors
Some land uses are considered more sensitive to noise than others, and, thus, are referred to as sensitive noise receptors. Land uses often associated with sensitive noise receptors generally include residences, schools, libraries, hospitals, and passive recreational areas. Noise sensitive land uses are typically given special attention in order to achieve protection from excessive noise. In the vicinity of the project site, the nearest existing noise sensitive land uses are single-family and multi-family residences to the north, east, and west of the site with the nearest residence located approximately 450 feet away, as measured from the center of the site.

Existing Noise Environment
The existing noise environment in the project area is primarily defined by traffic on Matheson Street, activity at the existing park, and natural sounds such as birds and insects.

To quantify the existing ambient noise environment in the project vicinity, Saxelby Acoustics conducted continuous (24-hour) noise level measurements at three locations on the project site, as well as two short-term noise level measurements (see Figure 10).

A summary of the noise level measurement survey results is provided in Table 6.

Project Construction Noise
During the proposed park redevelopment activities, heavy equipment would be used for excavation, grading, and paving which would temporarily increase ambient noise levels when in use. Noise levels would vary depending on the type of equipment used, how the equipment is operated, and how well the equipment is maintained. In addition, noise exposure at any single point outside the project site would vary depending on the proximity of construction activities to that point. Standard construction equipment, such as graders, backhoes, loaders, and trucks would be used in association with the proposed activities.

Table 7 shows maximum noise levels associated with typical construction equipment.

Based on the table, activities involved in typical construction would generate maximum noise levels up to 90 dB at a distance of 50 feet. As one increases the distance between equipment, or increases separation of areas with simultaneous construction activity, dispersion and distance attenuation reduce the effects of combining separate noise sources. The noise levels from a source decrease at a rate of approximately 6 dB per every doubling of distance from the noise source.

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Figure 10
Noise Measurement Sites
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Table 6
Summary of Existing Background Noise Measurement Data
Location Date Ldn
Daytime
Leq
Daytime
L50
Daytime
Lmax
Nighttime
Leq
Nighttime
L50
Nighttime
Lmax
LT-1: Northwestern Project
Boundary
Saturday
3/16/24 47 47 48 61 38 39 49
Sunday
3/17/24 46 45 47 62 38 38 53
Monday
3/18/24 46 46 46 62 37 38 48
LT-2: Southwest of Proposed
Central Lawn
Saturday
3/16/24 47 46 47 61 38 40 50
Sunday
3/17/24 46 46 47 65 37 37 52
Monday
3/18/24 46 47 47 65 37 38 48
LT-3: Northeast of the Project
Site
Saturday
3/16/24 55 55 57 74 47 44 67
Sunday
3/17/24 55 51 56 73 47 43 66
Monday
3/18/24 55 55 57 73 47 43 66
Notes:

All values shown in dBA
Daytime hours: 7:00 AM to 10:00 PM.

Nighttime Hours: 10:00 PM to 7:00 PM.

Source: Saxelby Acoustics, Environmental Noise Assessment, 2024.

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Table 7
Construction Equipment Noise
Type of Equipment Maximum Level, dB at 50 feet
Auger Drill Rig 84
Backhoe 78
Compactor 83
Compressor (air) 78
Concrete Saw 90
Dozer 82
Dump Truck 76
Excavator 81
Generator 81
Jackhammer 89
Pneumatic Tools 85
Source:Federal Highway Administration, Roadway Construction Noise Model User’s Guide, January 2006.

The City of Healdsburg has not adopted a formal standard for evaluating temporary construction noise which occurs within allowable hours. However, Caltrans defines a significant increase due to noise as an increase of 12 dBA over existing ambient noise levels. In absence of City standards, Saxelby Acoustics used the Caltrans 12 dBA criterion to evaluate increases due to construction noise associated with the proposed project.

Construction equipment is predicted to generate noise levels of up to 90 dBA Lmax at 50 feet. Construction noise is evaluated as occurring at the center of the site to represent average noise levels generated over the duration of construction across the project site.

The nearest noise-sensitive residential uses are located approximately 450 feet from the center of the project site. At such distance, maximum construction noise levels would be up to 71 dBA. Daytime maximum noise levels in the vicinity of the sensitive receptors were measured to range from 49 to 71 dBA. Therefore, project construction would not cause an increase of greater than 12 dBA over existing ambient noise levels.

It should be noted that in addition to on-site construction noise sources, noise would also be generated during the construction phase by increased truck traffic on area roadways.

A project-generated noise source would be truck traffic associated with transport of heavy materials and equipment to and from the construction site. This noise increase would be of short duration and would occur during daytime hours.

Although construction activities are temporary in nature and would occur during normal daytime working hours, construction-related activities could result in sleep interference at existing noise-sensitive land uses in the vicinity of construction if construction activities were to occur outside the normal daytime hours. Therefore, impacts resulting from noise levels temporarily exceeding the threshold of significance due to construction could be potentially significant.

Project Operational Noise
The project would result in the redevelopment of the exiting Badger Park. Parks are not typically associated with the generation of substantial noise. Based on the noise level measurements conducted by Saxelby, the existing ambient noise level in the project vicinity was measured to be 55 dBA Ldn. According to the Federal Interagency Committee on Noise (FICON) noise level criteria, the significance threshold for ambient noise Item 7.c
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environments less than 60 dBA Ldn is +5.0 dBA Ldn. Although the FICON recommendations were specifically developed to assess aircraft noise impacts, it has been accepted that the recommendations are applicable to all sources of noise described in terms of cumulative noise exposure metrics such as Ldn. Based on the projected addition of 91 daily project trips for the pickleball courts, as determined in the Transportation Initial Study Checklist prepared for the proposed project by W-Trans, 23 Saxelby Acoustics predicted an increase in traffic noise level of 0.3 dB. A 0.3 dB increase is well below the +5.0 dBA Ldn threshold for significance. Therefore, impacts resulting from increased traffic noise would be considered to be less than significant.

The primary noise sources associated with operation of the proposed project would be outdoor recreational noise associated with the proposed athletic amenities, such as the pickleball courts and parking lot traffic circulation. Project operational noise is assumed to occur during daytime (7:00 AM to 8:00 PM) hours only. The City of Healdsburg noise level standards require that new projects in the vicinity of existing sensitive receptors generate noise levels not greater than 60 dBA L10 during daytime hours at residential-zoned properties. Figure 11 shows noise level contours generated by the project during a peak hour of use. Inputs to the model included sound power levels for the proposed amenities, such as the pickleball courts, existing and proposed buildings, terrain type, and locations of sensitive receptors. The predicted noise exposure of 61 dBA L10 at the northeast and southeast boundaries of the site would exceed the City’s noise level standard. To mitigate this impact, Saxelby Acoustics recommended the construction of a six-foot-tall sound wall along the northern boundary of the project site. Figure 12 shows the location of the proposed wall and the resulting noise level contours. With the wall, project noise levels would be reduced from 61 dBA L10 to 55 dBA L10 at the property boundary, which is less than the City’s 60 dBA L10 standard. Therefore, without inclusion of the sound wall, impacts resulting from project operational noise levels exceeding the threshold of significance could be potentially significant.

Conclusion
Based on the above, construction and operation of the proposed project could result in an increase ambient noise levels in the vicinity of the project in excess of the City’s noise standards if construction activities were to occur outside the normal daytime hours and during project operation without implementation of a sound wall. Therefore, the proposed project would generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the City’s Noise Ordinance, and a potentially significant impact would occur.

Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.

XIII-1 If pickleball courts are included in the final design-level drawings, the proposed project shall include the construction of a six-foot-tall barrier at the northern boundary of the project site in the vicinity of the pickleball courts. The barrier height shall be relative to the residential building pads or the pickleball courts/dog park, whichever is greater. Noise barrier walls shall be constructed of concrete panels, concrete masonry units, earthen berms, or any combination of these materials that achieve the required total height. 23 W-Trans. Draft Transportation Initial Study Checklist for the Badger Park Master Plan Project. July 9, 2024.

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Figure 11
Noise Level Contours
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Figure 12
Project Noise Levels With Sound Wall
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Wood is not recommended due to eventual warping and degradation of acoustical performance. Proof of compliance shall be submitted to the City of Healdsburg Community Development Department prior to issuance of building permits.

XIII-2 Prior to approval of grading and/or building permits, the City shall establish the following as conditions of approval for any permit that results in the use of construction equipment:
• Construction shall be limited to 7:30 AM to 6:00 PM Monday through Saturday.
• All construction equipment powered by internal combustion engines shall be properly muffled and maintained.
• Quiet construction equipment, particularly air compressors, are to be selected whenever possible.
• All stationary noise-generating construction equipment such as generators or air compressors are to be located as far as practical from existing residences. In addition, the project contractor shall place such stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the project site. • Unnecessary idling of internal combustion engines is prohibited. • The construction contractor shall, to the maximum extent practical, locate on-site equipment staging areas to maximize the distance between construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction.

Proof of compliance shall be submitted to the City of Healdsburg Community Development Department for review and approval.
b. Similar to noise, vibration involves a source, a transmission path, and a receiver. However, noise is generally considered to be pressure waves transmitted through air, whereas vibration usually consists of the excitation of a structure or surface. As with noise, vibration consists of an amplitude and frequency. A person’s perception to the vibration depends on their individual sensitivity to vibration, as well as the amplitude and frequency of the source and the response of the system which is vibrating.

Vibration is measured in terms of acceleration, velocity, or displacement. A common practice is to monitor vibration in terms of peak particle velocities (PPV) in inches per second (in/sec). Standards pertaining to perception, as well as damage to structures, have been developed for vibration levels defined in terms of PPV.

Human and structural response to different vibration levels is influenced by a number of factors, including ground type, distance between source and receptor, duration, and the number of perceived vibration events. Table 8, which was developed by Caltrans, shows the vibration levels that would normally be required to result in damage to structures. As shown in the table, the threshold for architectural damage to structures is 0.20 in/sec PPV and continuous vibrations of 0.10 in/sec PPV, or greater, would likely cause annoyance to sensitive receptors.

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Healdsburg City CouncilNovember 3, 2025

Healdsburg City Council
November 3, 2025