Ukiah City Council
October 16, 2024

32 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
c. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or d. Has yielded, or may be likely to yield, information important in prehistory or history.
(4) The fact that a resource is not listed in, or determined to be eligible for listing in the California of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code section 5020.1(j) or 5024.1.
a. “Historical resource” includes, but is not limited to, any object, building, structure, site, area, place record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California.

Section 15064.5 also states that a project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment. “Substantial adverse change in the significance of a historical resource” means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired.

The significance of a historical resource is materially impaired when a project:
a. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or b. Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identification in a historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
c. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

Section 21083.2(g) identifies a unique archeological resource as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. 2) Has a special and particular quality such as being the oldest of its type or the best available example of its type.
3) Is directly associated with a scientifically recognized important prehistoric or historic event or person.

33 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
The California Office of Historic Preservation (OHP) houses the Built Environment Resource Directory (BERD). BERD files provide information regarding non-archaeological resources in OHP’s inventory.

Each resource listed in BERD is assigned a status code, which indicates whether resources have been evaluated as eligible under certain criteria. This tool provides information to assist in identifying potentially historic resources throughout the County.

Environmental Setting: The City of Ukiah is in the traditional ancestral lands of the Northern Pomo, which early ethnographers described as spanning along the coast from Fort Bragg to the Navarro River and stretching eastward to Clear Lake. Ethnographers referred to the people in this indigenous group as the Northern Pomo because they spoke of one of the seven Pomo language dialects that ethnographers distinguished based on geographic location (McLendon and Oswalt 1978; Golla 2007).

Thus, the Northern Pomo lands were bordered to the south by the Central Pomo and to the east by Eastern Pomo. Ethnographers noted Yukian groups living to the north (Welch 2013) The City of Ukiah was first settled in 1856 by Samuel Lowry. Initially incorporated into Sonoma County, an independent Mendocino County government was established in 1859 with Ukiah as the chosen county seat. Logging, cattle, and agricultural ventures contributed to the early settlement and growth of Ukiah throughout the remainder of the 19th century and early 20th century. 1889 is the date recorded for the first arrival of the train to Ukiah, quickly resulting in increased settlement of the City and its environs.

The late 19th century saw slow growth in the community, with a slight decline after the turn of the century. The town grew steadily, though it remained a relatively remote outpost in the hinterlands of Northern California for several more decades. The area around the intersection of the current Perkins and Main streets was one of the earliest settlement locations for the town. Absalom Tidwell Perkins built a house for his family near the southwest corner of the current Perkins and Main streets, and built a feed stable on the Project site around 1857. By 1860, Ukiah had approximately 25 dwellings and a budding commercial district. Ukiah’s sparse population and relative remoteness delayed the arrival of the railroad. In 1886 the Cloverdale and Ukiah Railroad was formed to extend north to Ukiah; and the line was completed in 1889, 20 years after it began in Petaluma in 1869. The improved transportation network did open up Mendocino County to greater commercial and industrial growth, though the population did not expand rapidly.

For 92 years the Northwestern Pacific Railroad (NWP) ran trains through the City, and the broader Mendocino County. Lumber mills and other customers provided significant traffic along the railway.

Passenger service was discontinued in 1958. In 1989, the North Coast Railroad Authority (NCRA) was formed by the State Legislature to ensure continuation of railroad service. In 1998, the entire line was closed due to flood damage, and no trains have operated on the railway since that time. The Great Redwood Trail Agency (GRTA), formed in 2021 from the NCRA currently manages the GRT in Mendocino County. An amended 2020 license agreement between the City of Ukiah and the GRTA authorizes the City to construct, install, maintain, reconstruct, remove, repair and manage a multimodal public path for bicyclists, pedestrians, wheelchairs, joggers, and other non-motorized uses pursuant to the NCRA’s Rails-with-Trails Policy and Procedure Manual (See Appendix C NCRA License Agreement).

Discussion: (a-c) Less than Significant. The Project area has historically been used for municipal (public) purposes and is previously disturbed. Ukiah’s Historic and Architectural Inventory Table shows no historic structures within the Project area. The California Built Environment Resources Directory (BERD) does show that the Northwestern Pacific Railroad Depot at 305 E. Perkins Street north of the Project site as designated historic.

34 Great Redwood Trail – Ukiah (Phase 4)
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Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
On August 13, 2024, the Northwest Information Center (NWIC) was queried for potential sensitive archaeological and historical resources. The results, received on August 28, 2024, indicate that previously recorded historic resources may be present within the Project area. These resources would likely be associated with the main stem railroad line, P-23-0003363, the Northwestern Pacific Railroad. NWIC recommends that, prior to commencement of project activities, P-23-0003363 should be assessed by a qualified professional familiar with the architecture and history of Mendocino County. These NWIC results will be uploaded along with this draft ISMND and forwarded to the Great Redwood Trail Agency (GRTA) for commentary regarding the historical rail line within the Project area. Along with the comments received from the GRTA project engineer on July 23, 2024, any additional information provided for the historical components of P-23-0003363 will be incorporated into the assessment of the final ISMND.

In regard to archaeological resources and human remains, on August 8, 2024, a letter was sent to the Native American Heritage Commission (NAHC) requesting a current SB 18 and AB52 Native American Contact List for the project vicinity. On August 12, 2024, the NAHC provided a list of 31 tribal contacts within the greater Mendocino and Lake County vicinity surrounding Planning Area. The NAHC also indicated that a Sacred Lands File check was positive for a potential Pinoleville Pomo Nation tribal cultural resource within the greater Mendocino and Lake County vicinity. In accordance with AB 52, both the Guidiville Rancheria, who had requested to be notified of projects within the City of Ukiah’s jurisdiction, and the Pinoleville Pomo Nation, were sent a formal letter and project materials on August 13, 2024. As of the drafting of this Initial Study, no request for consultation has yet been received.

As discussed under 3. Biological Resources, the proposed off-site wetland mitigation area west of Wetland D, south of Waters D3 and north of Wetland D, on the west side of the rail would also require shallow excavation for new wetland habitat. While these areas are both previously disturbed, the potential for inadvertent discovery of cultural material or human remains is still present. As part of the project design (See Appendix D), mitigation has been incorporated to address these potentials and reduce impacts to less than significant, including the following:

1. If archaeological resources are discovered at the job site, including chipped or ground stone, historic debris, building foundations, and human bone, do not disturb the resources.

Immediately stop all work within 100 feet of the discovery, protect the discovery area, and notify the Engineer.

2. If human remains of Native American origin are discovered during project construction, it is necessary to comply with state laws relating to the disposition of Native American burials, which fall within the jurisdiction of the Native American Heritage Commission (NAHC) (Public Resources Code 5097). If any human remains are discovered or recognized in any location other than a dedicated cemetery, there will be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until:
• The County Coroner has been informed and has determined that no investigation of the cause of death is required; and
• If the remains are of Native American origin, the descendants of the deceased Native Americans have made a recommendation to the landowner of the person responsible for the excavation work for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code 5097.98

3. If human remains are discovered during any demolition/construction activities, all grounddisturbing activities within a 330 foot radius of the remains shall be halted immediately, and

35 Great Redwood Trail – Ukiah (Phase 4)
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Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
the Mendocino County coroner shall be notified immediately, according to Section 5097.98 of the state Public Resources Code and Section 7050.5 of California’s Health and Safety Code.

If the remains are determined by the County coroner to be Native American, the NAHC shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. The City shall consult with the Most Likely Descendant, if any, identified by the NAHC regarding the treatment and disposition of the remains.

4. Should paleontological resources be identified at any project construction site, the Contractor shall cease operation within a 330-foot radius of the discovery and immediately notify the City.

The City will provide a qualified paleontologist to provide an evaluation of the find and to prescribe mitigation measures to reduce impacts to a less-than-significant level. In considering any suggested mitigation proposed by the paleontologist, the City shall determine whether avoidance is necessary and feasible in light of factors such as the nature of the discovery, project design, costs, land use assumptions, and other considerations. If avoidance is unnecessary or infeasible, other appropriate measures shall be instituted. Work may proceed on other parts of the project site while mitigation for paleontological resources is carried out.

Mitigation Measures: None

36 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

6. Energy
ENERGY
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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?
Significance Criteria: The Proposed Project would significantly impact energy if construction or operation of the Project would result in wasteful, inefficient or unnecessary consumption of energy resources or if the Project would conflict with a state or local plan for renewable energy or energy efficiency.

Environmental Setting: The Environment and Sustainability Element and the Mobility Element of the City’s 2040 General Plan contains goals, policies, and implementing programs to promote energy use efficiency and conservation. Among the goals are the following local goals pertaining to energy conservation: Goal ENV-1.3 Open Space and Renewable Energy Production; MOB-2.1 Vehicle Miles Traveled Reduction (City of Ukiah, 2022).

Discussion:
(a) Less than significant. The Project’s construction would consume energy in the form of diesel and gasoline fuels to power equipment and transport materials to the Project site. Operation and maintenance of the Project is not anticipated to increase consumption of diesel or gasoline fuel, compared to existing conditions. There would be a temporary increase in local truck trips during construction, primarily associated with export of debris from the Project site. However, this energy use would be limited to fuel required to transport materials, haul off debris, and power equipment for restoration of the Project site. No electrical infrastructure or lighting is proposed or required as part of the Project. Therefore, the Project would not increase energy use during operation and maintenance.

Following construction, the park would be maintained in a manner consistent with existing conditions.

Thus, energy use would not be wasteful, inefficient, or unnecessary for construction or operation of the Project. Impacts associated with temporary fuel use during construction of the Project would be less than significant.
(b) No Impact. Although the Project’s construction would include the use of fuels to transport vehicles, materials, and equipment to the Great Redwood Trail, the Project would not interfere with or obstruct the implementation of City energy efficiency goals or policies as outlined in the City’s general plan.

The Project would utilize energy efficient vehicles, as feasible, for construction. No state plans regarding renewable energy would be applicable to the Project. Therefore, the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Under this criterion, there would be no impact.

Mitigation Measures: None

37 Great Redwood Trail – Ukiah (Phase 4)
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Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

7. Geology and Soils

GEOLOGY AND SOILS
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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 or 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
18-1-B 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 waste water
disposal systems where sewers are not available for
the disposal of waste water?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?
Significance Criteria: The Proposed Project would result in a significant impact to geological or soil resources if the Project exposed people or buildings to seismic risk; ruptured a known fault; produced strong seismic ground shaking, ground failure, liquefaction, landslides or substantial soil erosion; is located on expansive soil or unstable ground or create unstable ground; or destroyed a unique paleontological resource or geologic feature.
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38 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
Environmental Setting: The Ukiah Valley is part of an active seismic region that contains the Mayacama Fault, which traverses the Valley in a generally northwest-southeast direction, approximately 0.8-mi east of the City limits at its closets point. The Ukiah Valley is located within the North Coast Range geologic province, comprised of a geologic feature unique to California, the Franciscan Formation. The Franciscan Formation is comprised of serpentine, sandstone, and other sedimentary rocks. Based on California Geological Survey maps and the Background Report for the County of Mendocino General Plan Update (prepared by P.M.C., 2003), the City of Ukiah is outside of known areas of historic faults, Holocene Fault, Late Quaternary Fault and the Alquist-Priolo Earthquake Fault Zone. Because most of the lands within the City are generally flat, slope instability hazards are not a concern, with the exception of lands within the Western Hills.

Three soil types were mapped within the delineation study area based on the Natural Resources Conservation Service (NRCS) Web Soil Survey (2022). These are Cole loam, drained, 0 to 2 percent slopes; Russian loam, 0 to 2 percent slopes; and urban land. Cole loam, drained, 0 to 2 percent slopes is typically a very deep, somewhat poorly drained soil that occurs on alluvial plains and fans. It formed in recent alluvium derived primarily from sedimentary rock (USDA 1991). Russian loam, 0 to 2 percent slopes, is a very deep, well drained soils that occurs on flood plains and low stream terraces. It formed in alluvium derived primarily from sedimentary rock (USDA 1991). Urban land soils occur on terraces and alluvial plains in Ukiah. In the project area the urban land soils unit occurs in areas that have been altered by cutting and filing or grading, specifically for the construction of the railroad. Soils in the project area ranged from very gravelly loam to clay loam and are primarily urban land soils.

The City of Ukiah contains five geologic units: Quaternary alluvium, Quaternary terrace deposits, PlioPleistocene sedimentary rocks, Cretaceous marine sedimentary rocks, and the Franciscan Complex.

Quaternary alluvium underlies the majority of the Planning Area and includes various Holocene-aged deposits including floodplain deposits, active stream channel deposits, alluvial fan deposits, and artificial fill. These various sediment types generally consist of loose to moderately consolidated, gravel, sand, and silt, and due to its Holocene age (e.g. within the past 11,700 years) is generally too young to preserve paleontological resources as fossils and therefore has a low paleontological sensitivity. However, Quaternary terrace deposits underlie portions of the Planning Area, which contain deposits of Pleistocene age (e.g. from around 2.58 million to 11,700 years ago) consisting of moderately to well-cemented, poorly sorted, silty or clayey sand and gravel. No significant fossil localities are known from Pleistocene alluvial deposits in either the City of Ukiah or the broader Mendocino County, but similar sediments in nearby Lake and Sonoma Counties have produced fossils such as mastodon (Mammut), ground sloth (Nothrotheriops, Paramylodon), horse (Equus), bison (Bison), camel, deer, and plants. Given the fossil-producing history of similar sediments in this region of California, Quaternary terrace deposits have high paleontological sensitivity.

Discussion:
(a-e) No Impact. The Project site sits at approximately 597 feet in elevation and is relatively flat.

According to the U.S. Department of Agriculture, Natural Resources Conservation Service’s Web Soil Survey, and the Aquatic Resources Report (Appendix B), the soils within the Project site are characterized as “210 Urban Land”, which is described as soils in highly populated areas containing largely built-out environments. In addition, according to the U.S. Geological Survey (USGS), the site is not susceptible to landslides, nor strong seismic ground shaking. There are no unique geologic features, and no unique paleontological features occur in the Project area. All development and construction for the Project will adhere to California Building Code requirements pertaining to erosion, soil stability and seismic regulations. (See Appendix D). For the above reasons, the Project would have no impact to geology and soils.

39 Great Redwood Trail – Ukiah (Phase 4)
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(f) Less than Significant. Ground disturbance in the areas demarcated for wetland grading and improvements underlain by Quaternary terrace deposits may result in potentially significant impacts to paleontological resources. Ukiah 2040 contains the following proposed goal and policies related to reducing impacts to paleontological resources.

Goals ENV-3: To preserve and protect historic and archaeological resources in Ukiah.

Policy ENV-3.2: Archaeological Resource Impact Mitigation. The City shall ensure appropriate and feasible mitigation for new development that has the potential to impact sites likely to contain archaeological, paleontological, cultural, or tribal resources.

Policy ENV-3.3: Protect Archaeological Resources. The City shall require any construction, grading, or other site altering activities cease if cultural, archaeological, paleontological, or cultural resources are discovered until a qualified professional has completed an evaluation of the site.

Although this proposed goal and policies would reduce impacts, ground disturbing construction activities may impact paleontological resources if previously undisturbed, high-sensitivity Quaternary terrace elements are encountered below the surface. Consequently, damage to or destruction of fossils could occur due to wetland grading. As part of the project design (See Appendix D), mitigation has been incorporated to address this potential and reduce impacts to less than significant, including the following:

1. Should paleontological resources be identified at any project construction site, the Contractor shall cease operation within a 330-foot radius of the discovery and immediately notify the City.

The City will provide a qualified paleontologist to provide an evaluation of the find and to prescribe mitigation measures to reduce impacts to a less-than-significant level. In considering any suggested mitigation proposed by the paleontologist, the City shall determine whether avoidance is necessary and feasible in light of factors such as the nature of the discovery, project design, costs, land use assumptions, and other considerations. If avoidance is unnecessary or infeasible, other appropriate measures shall be instituted. Work may proceed on other parts of the project site while mitigation for paleontological resources is carried out.

Mitigation Measures: None

40 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

8. Greenhouse Gas Emissions

GREENHOUSE GAS EMISSIONS
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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 gases?
Significance Criteria: The Project would have a significant effect on greenhouse gas emissions if it would generate greenhouse gas emissions (GHG), either directly or indirectly, that may have a significant impact on the environment; or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

Environmental Setting: Climate change is caused by greenhouse gases (GHGs) emitted into the atmosphere around the world from a variety of sources, including the combustion of fuel for energy and transportation, cement manufacturing, and refrigerant emissions. GHGs are those gases that have the ability to trap heat in the atmosphere, a process that is analogous to the way a greenhouse traps heat. GHGs may be emitted as a result of human activities, as well as through natural processes.

Increasing GHG concentrations in the atmosphere are leading to global climate change.

The state of California has adopted various administrative initiatives and legislation relating to climate change, much of which set aggressive goals for GHG emissions reductions statewide. Although lead agencies must evaluate climate change and GHG emissions of projects subject to CEQA, the CEQA Guidelines do not require or suggest specific methodologies for performing an assessment or specific thresholds of significance and do not specify GHG reduction mitigation measures. No state agency has developed binding regulations for analyzing GHG emissions, determining their significance, or mitigating significant effects in CEQA documents. Thus, lead agencies exercise their discretion in determining how to analyze GHGs. Because there are no adopted GHG thresholds applicable to the Project, and because the Project is considered “small scale,” meaning that it does not include new large buildings or components requiring significant construction that would result in increased GHGs, the below qualitative analysis is appropriate.

The Mendocino County Air Quality Management District (MCAQMD), under whose air quality jurisdiction the City of Ukiah lies, defers to the Bay Area Air Quality Management District (BAAQMD) guidelines for CEQA review of projects in Mendocino County. The BAAQMD adopted the 2017 Clean Air Plan on April 19, 2017. The 2017 Clean Air Plan, which focuses on protecting public health and the climate, defines an integrated, multi-pollutant control strategy that includes all feasible measures to reduce emissions of ozone precursors (including transport of ozone and its precursors to neighboring air basins), particulate matter (PM), and toxic air contaminants (TAC). To protect public health, the control strategy will decrease population exposure to PM and TACs in communities that are most impacted by air pollution, with the goal of eliminating disparities in exposure to air pollution between communities (BAAQMD 2017).
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41 Great Redwood Trail – Ukiah (Phase 4)
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The 2017 Clean Air Plan does not include control measures that apply directly to individual development projects. Instead, the control strategy includes stationary-source control measures to be implemented through BAAQMD regulations; mobile-source control measures to be implemented through incentive programs and other activities; and transportation control measures to be implemented through transportation programs in cooperation with the Metropolitan Transportation Commission, local governments, transit agencies, and others. Under BAAQMD’s methodology, a determination of consistency with CEQA Guidelines thresholds should demonstrate that a project:
• Supports the primary goals of the 2017 Clean Air Plan; • Includes applicable control measures from the 2017 Clean Air Plan; and • Does not disrupt or hinder implementation of any 2017 Clean Air Plan control measures.

Discussion:
(a) Less than Significant.

Pursuant to the 2022 BAAQMD CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, BAAQMD does not recommend a construction-related climate impact threshold. The proposed thresholds for land use projects are designed to address operational GHG emissions that represent the vast majority of project GHG emissions. Therefore, the evaluation of GHG emissions impacts associated with project implementation is focused on operational emissions.

As described in 3. Air Quality, demolition activities requiring the use of heavy equipment, tools (mechanical ram, dump truck, excavator, pickup truck, backhoe, front end loader, bobcat & stinger for concrete demolition) and vehicle trips (construction workers, equipment transportation, and dump truck haul trips) could result in direct GHG emissions. Demolition activities including the use of diesel engine equipment would be subject MCAQMD/BAAQMD regulations intended to address air quality impacts and GHG emissions. With the temporary nature of demolition activities and adherence to the aforementioned regulations, impacts related to GHGs would be less than significant.

In addition, during operation the Project would help to achieve Ukiah 2040’s Environment and Sustainability Element Goal, ENV-8 To achieve carbon neutrality by or before the year 2045 and match up with the BAAQMD’s 2017 Clean Air Plan, by promoting more sustainable means of transportation across the community reducing per capita vehicle miles traveled. In particular, the Clean Air Plan’s Control Measure TR9 encourages planning for bicycle and pedestrian facilities in local plans, e.g., general and specific plans, fund bike lanes, routes, paths and bicycle parking facilities. The Project supports an efficient and safe bicycle and pedestrian system that would improve the connectivity and accessibility in the southern section of the City, and would fulfill a number of Ukiah 2040 General Plan Policies, namely:
• Policy ENV-7.2 which prioritizes pedestrian and bicycle access, infrastructure, and education to increase active transportation use.
• Goal LU-2 encouraging mixed-use development that creates walkable districts, through pedestrian orientation that creates a comfortable environment for walking (Policy LU-2.4). • Policy LU-4.5 calling for pedestrian access to commercial uses from residential areas. • Goals MOB-1, MOB-2, and MOB-5, along with associated policies, which aim to create a more bikeable and walkable city. Specifically, Policy MOB-1.2 strives for multi-modal access to new development projects; Policies MOB-1.9 and MOB-1.10 encourage a complete bikeway network with bicycle parking; Policy MOB-2.7 encourages public transportation to be bicycle

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accessible; and Policy MOB-5.1 calls for incentives for travel alternatives to single-occupant vehicles such as secure bicycle parking.
(b) Less than Significant.

Pursuant to AB 32, CARB adopted the Climate Change Scoping Plan in January 2009 (reapproved by CARB on August 24, 2011) outlining measures to meet the GHG reduction goal to reduce emissions to 1990 levels by 2020 (CARB, 2009). The Scoping Plan is required by AB 32 to be updated at least every 5 years. On December 14, 2017, CARB approved the current Climate Change Scoping Plan, California’s, 2017 Climate Change Scoping Plan (2017 Scoping Plan Update). The 2017 Scoping Plan Update outlines the proposed framework of action for achieving the 2030 GHG target of 40 percent reduction in GHG emissions relative to 1990 levels. The 2017 Scoping Plan Update identifies key sectors of the implementation strategy, which includes improvements in low carbon energy, industry, transportation sustainability, natural and working lands, waste management, and water. CARB determined that the target statewide 2030 emissions limit is 260 million metric tons of CO2e (MMTCO2e) and that further commitments will be needed to achieve an additional reduction of 50 MMTCO2e beyond current policies and programs (CARB, 2017).

The 2017 Scoping Plan Update establishes the framework for achieving the 2030 statewide GHG reduction target of 40 percent below 1990 levels, established by SB 32. The plan update details local actions that land-use development projects and municipalities can implement to support the statewide goal. For project-level CEQA analyses, the 2017 Scoping Plan Update states that projects should implement feasible mitigation, preferably measures that can be implemented onsite.

CEQA Guidelines Section 15183.5 allows for public agencies to analyze and mitigate GHG emissions as part of a larger plan for the reduction of GHGs and describes the required contents of such a plan.

As described below, the Project would be consistent with CARB’s 2017 Scoping Plan Update.

The 2017 Scoping Plan Update incorporates a broad array of regulations, policies, and state plans designed to reduce GHG emissions. Those that are applicable to the construction and operation of the proposed Project are listed in Table GHG-1. As shown below, the Project would be consistent with goals described in the Scoping Plan Update to reduce energy use and transportation emissions, consistent with statewide strategies and regulations. As a result, the proposed Project would not conflict with applicable Climate Change Scoping Plan strategies and regulations to reduce GHG emissions; and the impact would be less than significant.

Table GHG-1
CONSISTENCY WITH APPLICABLE GREENHOUSE GAS REDUCTION ACTIONS IN 2017

SCOPING PLAN UPDATE
Strategy Description Consistency Analysis
AB 1493
(Pavley
Regulations)
Reduces GHG emissions in new passenger vehicles
from model year 2012 through 2016 (Phase I) and
model years, 2017–2025 (Phase II). Also reduces
gasoline consumption to a rate of 31 percent of
1990 gasoline consumption (and associated GHG
emissions) by 2020.

Consistent. The standards would apply to all
vehicles used by construction workers and
maintenance workers associated with the
Project. The Project would be consistent with
this regulation and would not conflict with
implementation of the vehicle emissions
standards.

Low Carbon
Fuel Standard
(Executive
Order S-01-07)
Establishes protocols for measuring lifecycle carbon
intensity of transportation fuels and helps to
establish use of alternative fuels.

Consistent. The standards would apply to all
vehicles used by construction workers and
maintenance workers associated with the
Project. The Project would be consistent with
this regulation and would not conflict with

43 Great Redwood Trail – Ukiah (Phase 4)
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implementation of the transportation fuel
standards.

Advanced
Clean Cars
Program
In 2012, CARB adopted the Advanced Clean Cars
(ACC) program to reduce criteria pollutants and
GHG emissions for model year vehicles 2015
through 2025. ACC includes the Low-Emission
Vehicle (LEV) regulations that reduce criteria
pollutants and GHG emissions from light- and
medium-duty vehicles, and the ZeroEmission
Vehicle (ZEV) regulation, which requires
manufacturers to produce an increasing number of
pure ZEVs (meaning battery electric and fuel cell
electric vehicles), with provisions to also produce
plug-in hybrid electric vehicles (PHEV) in the 2018
through 2025 model years.

Consistent. The standards would apply to all
vehicles used by construction workers and
maintenance workers associated with the
Project. Therefore, the proposed project
would be consistent with this regulation and
would not conflict with implementation of the
ACC program.

As discussed above, the Project would be consistent with the applicable strategies and policies included in the 2017 Scoping Plan Update. Therefore, the Project would not conflict with applicable plan, policies or regulations adopted for the purpose of reducing the emissions of greenhouse gases and the impact would be less than significant.

Mitigation Measures: None.

44 Great Redwood Trail – Ukiah (Phase 4)
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9. Hazards and Hazardous Materials

HAZARDS AND HAZARDOUS MATERIALS
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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 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 a significant risk of loss, injury or death involving wildland fires?
Significance Criteria: The Project would result in significant hazards or hazardous materials impacts if it exposed people to hazardous materials or placed them into hazardous situations; if it released hazardous materials or emissions into the environment or within 0.25 miles of a school; if it is located on a listed hazardous materials site; if it would create a hazard due to its proximity to a public airport or private airstrip; if it would create excessive noise for people in the area; if it would interfere with an emergency response or evacuation plan; or if it would expose people or structures to significant risks due to wildland fire.

Environmental Setting: The Safety Element of the City of Ukiah 2040 General Plan addresses a wide variety of approaches pertaining to hazard management and mitigation (City of Ukiah, 2022).

Other regional hazards and hazardous materials guidance documents include, but are not limited to, □ □ C8J □
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45 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah
the Community Wildfire Protection Plan, Hazardous Waste Management Plan, Operational Area Emergency Plan, and the Mendocino County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP), which was adopted by the County in December 2020 (Mendocino County, 2020). The MJHMP discusses prevalent hazards within the County; identifies risks to vulnerable assets, people, and property; and provides a strategy to achieve the greatest risk reduction based upon available resources. The four cities within Mendocino County, including the City of Ukiah, contributed to the MJHMP to individually assess hazards, explore hazard vulnerability, develop mitigation strategies, and create their own plan for each respective city. The Jurisdictional Annex to the MJHMP, was adopted by the City of Ukiah in 2020. Hazards identified for the City of Ukiah include earthquakes, wildfire, dam failure, flood, and pandemic (Mendocino County, 2020).

The City of Ukiah Emergency Operation Plan (May 2021) is designed to ensure continuity of operations and essential services, such as police, fire, utilities, and other day-to-day operations during and after an emergency or disaster. This plan was developed in consultation with the Ukiah Disaster Council it complies with all local ordinances, state law, and aligns with contemporary emergency planning guidance. This plan serves as the primary guide for reducing emergency and disaster risk within the City of Ukiah and establishes roles and procedures for deployment of the City’s Emergency Operations Center. A current map of evacuation zones and routes is also maintained on the City of Ukiah’s Office of Emergency Management webpage.

Mendocino Council of Governments (MCOG) prepared the Mendocino Evacuation Plan (July, 2020) that identifies evacuation routes within the County. This Plan describes existing conditions, access concerns, and strategies for managing evacuations which exceed the day-to-day capabilities of the various public safety agencies in Mendocino County. The City of Ukiah is identified as being located within “Planning Area 2” and “Zone 2f” of the Evacuation Plan. As noted in the plan, Highways 101 and 20 are identified as primary evacuation routes for the Ukiah area. The selection of specific (additional) evacuation routes (in effect during an emergency) will be done in the field at the Incident Command Post, according to the plan (MCOG, 2020).

The Ukiah Municipal Airport is located within the City of Ukiah jurisdictional limits. The Ukiah Municipal Airport Land Use Compatibility Plan (UKIALUCP) was adopted by the Mendocino County Airport Land Use Commission on May 20, 2021 and adopted by the Ukiah City Council on June 16, 2021. The UKIALUCP identifies areas (known as “compatibility zones”) with potential hazards and impacts to persons using or working within the vicinity of the airport.

Under Government Code Section 65962.5, both the State Water Resources Control Board (SWRCB) and the California Department of Toxic Substances Control (DTSC) are required to maintain databases of sites known to have hazardous substances present in the environment.

All lands within the City of Ukiah are within the jurisdiction of the Ukiah Valley Fire Authority. None of the lands within the City of Ukiah are located within a California Department of Forestry (CalFire) State Responsibility Area (SRA). However, some parcels within the western boundary of the City limits, are designated as “Very High” fire severity within the Local Responsibility Area (LRA). The Project site is not located within a High or Very High fire severity zone.

Discussion:
(a-b) Less than Significant.

Potentially hazardous substances may be used during construction of the project, including fuel, lubricant, and solvents for equipment. However, construction would be subject to implementation of appropriate BMPs to address the use and transport of hazardous materials and the potential discharge of contaminants. The Project’s Special Provisions (Appendix D) incorporates by reference the

46 Great Redwood Trail – Ukiah (Phase 4)
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CalTrans Standard Specifications, in particular section 14-10 Solid Waste Disposal and Recycling (CalTrans, 2018 p. 230), which requires appropriate Best Management Practices (BMPs). Based on the implementation of these BMPs, impacts resulting from hazardous materials during construction are expected to be less than significant.
(c) No Impact.

The Project site is not within 0.25 mile of an existing or proposed school. The closest school is Ukiah Junior Academy, approximately 0.38 miles southwest of the Project site. The Project would not emit or handle hazardous materials, substances, or waste within 0.25 mile of a school. The City and its contractors would be required to comply with existing and future hazardous materials laws and regulations covering the transport, use, and disposal of hazardous materials, and because of the nature and quantity of the hazardous materials to be potentially used by the Project, the impact related to the use of hazardous materials during construction would have no impact. (d) Less than Significant with Mitigation.

The Project is located along an industrial railroad corridor, which is known to include past use of heavy metals, creosote wood products, and other constituents associated with historical railroad activity and construction. Groundwater dewatering is generally not expected but may be required. Groundwater encountered during construction would be from shallow groundwater and not associated with a deeper aquifer. Outside of the Project Area but within the 1/8 mile buffer, there is at least one site classified with a hazard ranking
From the EnviroStor Database of the Department of Toxic Substances (DTSC), The Coast Wood Preserving Federal Super Fund site is located on approximately 8 acres on the southwest corner of Taylor Drive and Plant Road, adjacent to the southern terminus of the Project’s railway corridor. In 1983 the US Environmental Protection Agency placed Coast Wood Preserving on the Superfund List.

However, the DTSC has been the lead regulatory agency for the investigation and cleanup. The effects of an adjacent site’s leaking of chromium into the soil and groundwater has the potential to cause a hazard during project grading and restoration activities.

The remedy for soil and groundwater contamination selected in DTSC’s September 1989 Remedial Action Plan (RAP) and the United States Environmental Protection Agency’s (US EPA) 1989 Record of Decision (ROD) included paving the site with an asphalt or concrete cap to prevent run-off and leaching of wood treatment solutions to the subsurface; installation of a down gradient slurry wall; groundwater extraction, treatment and reinjection; and soil excavation and off-site disposal after plant closure. Institutional controls were also implemented at the site through a Land Use Covenant between DTSC and CWP, which imposes a limitation on the site for non-residential use only.

In July 1999, DTSC approved with US EPA concurrence, an amendment to the 1989 RAP which changed the remedial action for groundwater from extraction and treatment to in situ reduction and fixation of hexavalent chromium via direct injection and infiltration of calcium polysulfide reductant.

The RAP Amendment also included a provision for using the in-situ reduction and fixation for treating hexavalent chromium in soil. Remedial actions have continued by direct injection into the groundwater and infiltration of reductant with the use of infiltration trenches up gradient of the slurry wall. Infiltration of reductant occurred January of 2015 and February 2016. Hexavalent chromium and total chromium contamination in groundwater currently remain above their respective clean up levels in a few isolated areas, and have fluctuated in concentration during this review period, possibly associated with seasonal variation in groundwater levels. In December 2017, DTSC, US EPA, Coast Wood Preserving and Environmental Liability Transfer, Inc. (ELT) signed a Consent Decree for the transfer of cleanup responsibility to ELT. On June 8, 2018, Environmental Liability Transfer, Inc. (ELT) became the new owners of Coast Wood Preserving. In 2018, Coast Wood Preserving closed their operations and in

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accordance of the Consent Decree, ELT began the process of completing the RAP implementation.

Future work, as required by the RAP, includes soil investigation and soil removal. Groundwater monitoring will continue. (EnviroStor, 2019).

In order not to exacerbate existing contamination that may be present within the Project area, and mitigate risks to on-site personnel and the environment, Mitigation Measures HAZ-1 would be implemented. This measure would reduce the impact of potential exposure from hazardous materials to construction workers, nearby receptors, and the environment to a less-than-significant level by conducting site investigatory soil pre-characterization for specific contaminants of concern (COCs), and requiring the proper handling and disposal of hazardous wastes per applicable local, state and federal regulations and/or guidelines. A Sampling Analysis Plan (SAP) shall be prepared to determine if specific COCs are present above regulatory thresholds. Once pre-characterization is complete and depending on the results of pre-characterization, a project-specific Soil and Groundwater Management Plan (SGMP) and/or a Soil Excavation, Stockpiling and Transportation Plan (SESTP) will be prepared. The purpose of the SGMP is to document, in accordance with best risk management practices, the general procedures for worker safety protocols, and for managing excavated soil and/or groundwater removed during construction.
(e) Less than Significant.

The Project is located within Airport Compatibility Zones 2 (Inner Approach/Departure Zone), 3 (Inner Turning Zone) and 5 (Sideline Zone) within the Ukiah Municipal Airport Land Use Compatibility Plan (UKIALUCP). While overflights may be intrusive to some outdoor activities, these zones do not contain any regulations regarding intensity of use or other standards specific to airport safety concerns that would be applicable to the Project. According to Table 3A of the UKIALUCP, local parks are considered conditionally compatible in Zones 2 and 3 provided there are no permanent facilities where people congregate, and that residential intensity criteria is met. As the Project proposes no permanent structures, either residential or commercial, the Project’s use in these areas is compatible. Those areas of the Project in Zone 5 are considered normally compatible. The Project would not result in a safety hazard or excessive noise related to airport operations for people working in the Project area.

Impacts would be less than significant.
(f) Less than Significant.

The primary routes for evacuation from the City of Ukiah are identified as Highways 101 and 20, as these routes are well maintained and have adequate carrying capacity for evacuation purposes (MCOG, 2020). Although there are no specific evacuation routes discussed in either the Mendocino County Emergency Operations Plan, Mendocino County Multi-Hazard Mitigation Plan, nor the City of Ukiah’s jurisdictional annex to the Multi-Hazard Mitigation Plan (Mendocino County, 2016; 2020), Highway 101 is identified as a primary route in the (recently completed) Mendocino County Evacuation Plan (MCOG, 2020). The proposed Project trail alignment would be adjacent to existing streets, not considered major roadways in the City of Ukiah. Emergency access to the Project Area already exists from these streets and would continue to exist under the proposed Project during both construction and operation. Operation and maintenance of the Project would not result in substantial additional daily traffic from maintenance activities or truck trips along local roadways, and would, therefore, not affect emergency services or response times in the area. Additionally, no roadway closures are proposed during construction, nor during normal operation of the Project. A less than significant effect on emergency access would result.
(g) Less than Significant.

Based on mapping by the California Department of Forestry and Fire Protection (CAL FIRE) Forest Resource Assessment Program (FRAP) the Project site is not within a Very High Fire Hazard Severity Zone (CAL FIRE, 2007). The use of construction equipment and the possible temporary on-site

48 Great Redwood Trail – Ukiah (Phase 4)
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storage of fuels and/or other flammable construction chemicals could pose an increased fire risk resulting in injury to workers or the public during construction. However, contractors would be required to comply with hazardous materials storage and fire protection regulations, which would minimize potential for fire creation, and ensure that the risk of wildland fires during construction would be less than significant.

Mitigation Measures:

HAZ-1: Sampling Analysis Plan
Mitigation Measure HAZ-1 would reduce the impact of potential exposure from potential hazardous materials to construction workers, nearby receptors, and the environment to a less-than-significant level by conducting site investigatory soil pre-characterization for specific contaminants of concern (COCs) and requiring the proper handling and disposal of hazardous wastes per applicable local, state and federal regulations and/or guidelines. A Sampling Analysis Plan (SAP) shall be prepared to determine if specific COCs are present above regulatory thresholds in disturbed areas near the proposed terminus of the trail at Plant Road. Once pre-characterization is complete and depending on the results of pre-characterization, a project-specific Soil and Groundwater Management Plan (SGMP) and/or a Soil Excavation, Stockpiling and Transportation Plan (SESTP) will be prepared, if determined necessary. The purpose of the SGMP is to document, in accordance with best risk management practices, the general procedures for worker safety protocols, and for managing excavated soil and/or groundwater removed during construction. The SGMP and/or SESTP shall address specific training requirements for soil and groundwater management, materials handling, dewatering, soil stockpiling, transportation, and disposal procedures.

1. A Sampling Analysis Plan (SAP) shall be prepared by the City or its contractor to define sample locations, boring depths based upon design, estimated soil volumes, and number of borings to adequately pre-characterization project alignment soils and/or groundwater. The SAP shall include precharacterization of soil and groundwater for potential constituents of concern (COCs) and shall include an assessment of CAM-17 metals and petroleum hydrocarbons prior to initiating construction activities. The SAP shall further include specifications for surficial samples that will be collected to the proposed depth of excavation in the areas where ground disturbing activities are proposed.

2. Prior to construction of the Project, limited pre-characterization shall be conducted at SAP identified locations in proximity to the Coast Wood Preserving Federal Super Fund Site where ground disturbance is expected to occur adjacent to Plant Road in conjunction with the project.

3. If pre-characterization analysis results determine COCs above regulatory background thresholds for human and environmental health exposure, then a site-specific Soil and Groundwater Management (SGMP) shall be prepared to address proper handling of potentially impacted soil and groundwater prior to waste stream characterization, proper disposal, and handling requirements for worker protection. The SGMP shall proactively plan for and manage potentially encountered hazardous materials affected soils, and to provide special soil and groundwater handling and stockpiling details throughout the Project Area construction areas for worker protection, final waste disposal purposes and to mitigate potential project construction delays. Key elements of the SGMP will include management options for excavated soils, waste characterization options for excavated soils, areas of impact soil and or groundwater, sampling strategy for stockpiled soils, special handling requirements, record keeping, and HAZWOPER training. The SGMP shall indicate the specific level of protection required for construction workers and include preparation of a site-specific health and safety plan in accordance with federal OSHA regulations (29 CFR 1910.120) and Cal-OSHA

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regulations (8 CCR Title 8, Section 5192) to address worker health and safety issues during construction.

4. Where Project construction design proposes to include demolition or deconstruction of existing structures (bridges), subsequent pre-demolition hazard materials sampling shall occur for asbestos and lead at locations where structural demolition would occur.

5. If required, a Soil Excavation, Stockpiling and Transportation Plan (SESTP) shall be prepared once the areas of Project ground disturbance are confirmed and prior to construction. The SESTP will specify measures to appropriately manage soil spills during Project construction for waste characterization, worker protection, fugitive emissions control and disposal.

Alternatively, soil spoils can be initially field screened (visual, olfactory, photo-ionization detector, etc.) and stockpiled, then subsequently characterized for appropriate disposal methods according to applicable waste facility requirements.

6. If construction activities include dewatering, and if laboratory analysis of pre-construction soil borings indicate elevated total and Soluble Threshold Limit Concentration (STLC) concentrations of 1,000 ppm and 5 mg/L, respectively, then dewatered groundwater will be stored in tanks, and characterized for waste disposal or permitted for treatment and discharge to sanitary sewer, storm drain, or land. - All potentially contaminated materials encountered during Project construction activities shall be evaluated in the context of applicable local, state and federal regulations and/or guidelines governing hazardous waste. All materials deemed to be hazardous shall be remediated and/or disposed of following applicable regulatory agency regulations and/or guidelines. Disposal sites for both remediated and non-remediated soils shall be identified prior to beginning construction. Management of these sites shall be documented in a Material Management Plan acceptable to applicable agencies. All evaluation, remediation, treatment, and/or disposal of hazardous waste shall be supervised and documented by qualified hazardous waste personnel.

With the incorporation of Mitigation Measure HAZ-1, the potential impact to construction workers, nearby receptors, or the environment would be less than significant.

50 Great Redwood Trail – Ukiah (Phase 4)
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10. Hydrology and Water Quality

HYDROLOGY AND WATER QUALITY
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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 a substantial erosion or siltation on- or offsite; 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?
Significance Criteria: The Project would significantly impact hydrology and water quality if it violated water quality standards or waste discharge requirements or substantially degraded surface or groundwater quality; substantially decreased groundwater supplies or impeded sustainable groundwater management; altered drainage patterns in a manner that would cause substantial on- or off-site erosion, polluted runoff or excessive runoff that caused flooding; impeded or redirected flood flows; risked a release of pollutants due to inundation if in a flood hazard, tsunami or seiche zone; or conflicted with a water quality plan or sustainable groundwater management plan.

Environmental Setting: Average rainfall in Ukiah is slightly less than 35 inches. Most of the precipitation falls during the winter. Rainfall is often from brief, intense storms, which move in from the northwest. Virtually no rainfall occurs during the summer months. Surface water supplies for the Ukiah □ C8J □ □
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Valley include the Eel River, from which water is diverted into the Russian River watershed through the Potter Valley Project, Lake Mendocino, and the Russian River. Groundwater is drawn from the Ukiah Valley groundwater basin. The Ukiah Valley groundwater basin is the northernmost basin in the Russian River water system and underlies an area of approximately 60 square miles. Water enters the groundwater system via percolation of surface waters and through the soil. The creeks and streams in the Ukiah Valley provide drainage channels for groundwater recharge, as well as domestic and agricultural water supply.

As discussed under 3. Biological Resources, there are four mapped wetlands in the Project area. Full descriptions of these features may be found within Appendix B Aquatic Resource Report. Wetland Area A is approximately 9,351 sf and is located south of Plant Road. This is a seasonal wetland that is drier in the southern portion and then becomes more wetland as it goes north with saturated soils, algal matting and obligate wetland plants defining this area. The wetland ends at a change in elevation from a long, linear ditch feature to an upland “berm”. Drainage D1 is rock lined with little to no soil development. Drainage D2 contains a total area of 639 sf within the Aquatic Resources Report (Appendix B) study area. The drainage has been altered and disturbed by both the railroad and Highway 101. Wetland Area B is a small 109 sf seasonal wetland dominated by FAC species such as Himalayan blackberry and ryegrass. Refer to photo 6 for this feature. Wetland Area C is also a seasonal wetland, extending approximately 2,489 sf within the Aquatic Resources Report study area.

Water for this area comes from culverts under the railroad tracks. This site is dominated by Himalayan blackberry and Harding grass.

Wetland Area D is approximately 6,502 sf within the study area and is dominated by iris-leaved rush, which is an obligate wetland plant. There were also some willows in the area. This area has been disturbed by homeless encampments and includes a lot of human trash.

In addition, on March 10, 2023, the Project received a North Coast Regional Water Quality Control Board (NCRWQCB) water quality certification (Certification) that identified total permanent impacts to approximately 0.15 acres/49 Linear Feet of waters of the state, including 0.127 acres of wetlands (Wetland C and Wetland D), 0.017 stream channels (D3, D4, D5) and 0.023 acres of riparian areas. (See Appendix E NCRWQCB Water Quality Certification). This report requires mitigation for these impacts that are outlined at the end of Appendix E and entitled “Attachment 2 Avoidance and Minimization Measures.” Updated avoidance and minimization measures are provided in Appendix G, as allowed under Project-Specific Condition 1. Of the NCRWQCB Water Quality Certification. These measures have been integrated as mitigation under BIO-2.

Discussion:
(a) Less than Significant with Mitigation
The Project would include soil disturbing activities such as grading and site contouring, which have the potential to mobilize sediment, silt, and other contaminants through runoff. As construction of the Project would disturb more than 1 acre of soil, compliance with the General Permit for Stormwater Discharges Associated with Construction Activity, Order No. 2009-0009-DWQ (commonly referred to as the Construction General Permit) is required (See Appendix E). Construction activity subject to this permit includes clearing, grading, and ground disturbances such as stockpiling or excavation. The Construction General Permit requires the development of a Stormwater Pollution Prevention Plan (SWPPP) including specific measures to control erosion and limit contamination of ground and surface waters.

The Project’s ground disturbance in the absence of measures to protect riparian vegetation may result in erosional flow towards the Russian River and adjacent wetlands, potentially contributing to sediment into the river. To reduce potential effects Mitigation Measure BIO-2, would be implemented to ensure

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that regulatory requirements consistent with the terms of the Construction General Permit, SWPPP, general wetland avoidance measures, and stormwater BMPs would control and limit runoff from the Project site, consistent with water quality standards. To ensure that ground disturbance does not result in conditions of runoff on or off site and that habitats are protected, Mitigation Measure BIO-1 (described in Section 4, Biological Resources) would also be implemented. These measures would limit disturbance of existing wetlands and riparian woodlands and prevent the Project from contributing to the siltation of the Russian River and adjacent wetlands.

As discussed in Section 9, Hazards and Hazardous Materials, there are existing hazards in proximity to the site which could contaminate ground or surface water quality during construction ground disturbing activities, such as excavation and movement of soils. Mitigation Measure HAZ-1 would be implemented to reduce potential impacts. This measure would require soil, groundwater, and asbestos investigations and the proper handling and disposal of hazardous wastes per applicable local, state and federal regulations and/or guidelines. Impacts associated with the Project’s construction would be less than significant with mitigation implemented. (Refer to Section 9 for the text of Mitigation Measure HAZ-1).

Following construction, the City of Ukiah would be responsible for maintaining the revegetation and managing the Great Redwood Trail in a manner that would provide for ongoing protection of water quality. Water quality impacts during operation and maintenance of the Project would be less than significant.
(b, e) No Impact.

The Project would not utilize groundwater resources during construction or operation but will instead utilize water provided by connections to the Willow County Water District. In excavating waste piles of concrete and other debris, and restoring associated wetlands, the Project improves conditions for groundwater recharge in the project area.
(c.i) Less than Significant with Mitigation.

The Project includes extensive alteration of drainage patterns for the purpose of recontouring the site and restoring wetland habitat areas within and adjacent to the rail corridor. The proposed design for the Project does not include the extensive addition of impervious surface areas. Construction would require implementation of a SWPPP which would include measures to minimize erosion and control runoff on and off-site. Resource avoidance measures, as described in Appendix G, include flagging or fencing of wetlands to prevent contamination of wetlands during construction. To ensure that appropriate measures to limit runoff are taken prior to and during construction including preparation of a SWPPP and an erosion and sediment control plan, Mitigation Measure BIO-2, would be implemented.

With adherence to stormwater and associated water quality regulatory requirements and implementation of Mitigation Measure BIO-1 outlining basic requirements of the SWPPP and erosion control plan to be prepared for the Project, erosion and sedimentation/siltation would be controlled during construction. Impacts would, therefore, be less than significant with mitigation. (c.ii) Less than Significant.

The project may increase the rate or amount of surface runoff due to additional impervious surface area from the paved concrete walkway. BMPs implemented during construction (See Appendix D) would serve to minimize stormwater runoff impacts, and the construction of the culvert extensions would minimize post-construction stormwater runoff impacts. In addition, the Project addresses existing drainage issues through removal of concrete rubble and relic debris to allow for the enhancement of seasonal (existing and constructed) wetlands.

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(c.iii) Less than Significant with Mitigation.

The Project design would allow for appropriate drainage to facilitate wetland restoration as discussed in the Project’s Plans and Special Provisions (Appendices A and D). Although extensive grading and recontouring of the site would be implemented, such work would be subject to the City of Ukiah’s design standards and erosion and sediment control requirements. Consistent with these standards, measures will be taken to minimize or otherwise limit runoff during construction, subject to City engineering review and approval. Site soils would be stabilized and revegetated following disturbance.

With implementation of Mitigation Measure BIO-2 ensuring development of a SWPPP required for the construction general permit, impacts would be reduced to less-than-significant levels. (c.iv) Less than Significant.

The Project meanders in and out of FEMA mapped areas with a 0.2% and 1% annual chance of a flood hazard, and areas with reduced risk of flooding due to levees (FEMA, 2024). BMPs implemented during construction (See Appendix D) and the construction of the culvert extensions would ensure that flood flows are not impeded or redirected into the surrounding site. Through the removal of relic debris from the Project site and restoration of the wetland areas within the Project site, the proposed Project, as implemented, would result in improved conditions for the functionality of flood flows. d) Less than Significant with Mitigation.

The Project site is not located in the coastal zone or in a tsunami inundation zone. The wetlands and drainages adjacent to the site are not large enough or deep enough to produce a seiche. Therefore, there is no risk for release of pollutants associated with these hazards for the site and surroundings.

The Project is within FEMA mapped areas subject to periodic inundation. Under existing conditions there is potential for release of contaminants during inundation. Proposed soil excavation and movement could increase the risk of contamination. Therefore, measures to reduce this risk would be needed during construction of the Project.

Implementation of Mitigation Measure BIO-2 would ensure compliance with water quality requirements including preparation of a SWPPP. Mitigation Measure HAZ-1 would be implemented to ensure that potential hazards are identified and safely removed from the site, thereby limiting contamination of surface and groundwaters. Impacts would be less than significant with mitigation measures implemented.

Mitigation Measures:

BIO-1, BIO-2, BIO-3, HAZ-1

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11. Land Use and Planning

LAND USE AND PLANNING
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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?
Significance Criteria: The Project would significantly impact land use if it physically divided an established community or conflicted with a land use plan, policy or regulation intended to avoid or mitigate an environmental impact, such as the general plan or zoning code.

Environmental Setting: The City of Ukiah includes contiguous lands at the city center, as well as lands owned and managed by the city for a total of approximately 4.72 square miles of incorporated area. Ukiah serves as the County Seat of Mendocino County, as well as the county’s main commercial hub. Zoning and land uses are governed by the City’s Zoning Ordinance, as outlined in Division 9, Chapter 2 of the Ukiah City Code. Predominant land uses in the City include single family residential, multi-family residential, and commercial uses ranging from local commercial to heavy commercial, as well as manufacturing, industrial, agricultural, and public facilities. The City’s 2040 General Plan was adopted by City Council on December 7, 2022, and contains the following goals and policies that are applicable to the Project (City of Ukiah, 2022).

Public Facilities, Services, and Infrastructure Element Goal PFS-12: To provide parks, recreational facilities, and trails for residents and visitors.

Policy PFS-12.1: Connected Park System. The City shall provide an interconnected park system that creates an urban greenbelt and links all trail systems within the City.

Policy PFS-12.2: Expansion of Recreational Amenities and Programs. The City shall expand amenities and recreational programs in parks and recreational facilities that accommodate a variety of ages and address the needs of families.

Policy PFS-12.3: Equitable Access to Parks and Recreation Facilities. The City shall establish new parks and recreation facilities to ensure all residents have access within a one-mile radius of their place of residence regardless of socio-economic status.

Environment and Sustainability Element
Goal ENV-5: To ensure the health and viability of the Russian River and its tributaries. □ □ □ C8J
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Policy ENV-5.1: Local Collaboratives. The City shall participate in local collaborative efforts to restore and preserve the health of the Russian River as a habitat for riparian species.

Policy ENV-5.3: Russian River Riparian Area. The City shall support the County in maintaining the Russian River as a natural riparian corridor.

Goal ENV-6: To preserve and restore creeks, streams, riparian areas, and wetlands.

Policy ENV-6.2: Contamination and Sedimentation Prevention. The City shall require new development to use site preparation, grading, and construction techniques that prevent contamination and sedimentation of creeks and streams. (Source: New Policy) Policy ENV-6.3: Waterway Restoration. The City shall encourage and provide resources to landowners in the city to remove invasive species, plant native plant species, and prevent pollution from entering local creeks and waterways. (Source: New Policy)
Policy ENV-6.4: Waterway Channelization. The City shall actively support the use of natural waterways within the city by avoiding any new waterway channelization within the city and collaborating with local and regional agencies to restore channelized waterways where feasible. (Source: New Policy)
Policy ENV-6.5: Creek Protection. The City shall require new development located adjacent to stream corridors to include appropriate measures for creek bank stabilization, erosion and sedimentation prevention, and natural creek channel and riparian vegetation preservation. (Source: Existing Programs OC-7.5(a), OC-9.2d, OC9.2e, modified) Policy ENV-6.6: Erosion Control Plans. The City shall require new development that requires significant grading near creeks, streams, wetlands, and riparian areas to prepare erosion control plans that address grading practices that prevent soil erosion, loss of topsoil, and drainageway scour, consistent with biological and aesthetic values. (Source: New Policy).

Policy ENV-6.8: Research and Educational Access. The City shall work with public and private landowners adjacent to creeks to allow public access to creeks, streams, waterways, and riparian areas for educational and research programs Land Use Element
Policy LU-11.8: Tree Preservation. The City shall encourage the preservation of trees on public and private property. Priority should be given to the preservation of trees considered significant due to their size, history, unusual species or unique quality.

Discussion:
(a-b) No impact. The Project would consist of restoration and enhancement of a designated public park/recreational facility, with no change of use or other alteration that would physically divide an established community; therefore, there would be no impact under this criterion. The proposed Project would be located within the existing railroad right of way and is not zoned. The Project does not conflict

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with the City’s General Plan and is specifically supported in and is consistent with the elements noted above. Since the rail corridor already exists and has historically acted as a divider in the community, converting a portion of the corridor into a bike path would not introduce a new division. Instead, it could enhance connectivity within the city by providing a safe, alternative route for pedestrians and cyclists, potentially bridging gaps between neighborhoods and other community areas where trail segments already exist. Therefore, the project is unlikely to further divide an established community. In fact, it may help to integrate different parts of the city by creating new, accessible connection.

Mitigation Measures: None

12. Mineral Resources

MINERAL RESOURCES
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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?
Significance Criteria: Impacts to mineral resources would be considered significant if the proposed Project were to result in the loss of a known mineral resource that has value to the region and state or is otherwise locally important as designated on a local land use plan.

Environmental Setting: The Surface Mining and Reclamation Act of 1975 (SMARA) requires Geologists of the State to classify lands into Mineral Resource Zone (MRZ) categories based on the known or inferred mineral resource potential of that land. The mineral resource land classification supports the protection and wise development of California’s mineral resources (California Department of Conservation, 2019).

Aggregate resource minerals, primarily sand and gravel, found along many rivers and streams in Mendocino County is considered the most prominent mineral resource found in the county, including along the Great Redwood Trail.

Discussion:
(a-b) No impact. According to the California Geological Survey, the land within the Project Site is not assigned as an MRZ indicating a low potential for the presence of valuable mineral resources based on the site geography (California Department of Conservation, 2020.) The United States Geological Survey (USGS) Mineral Resources Data System also indicates no mineral resources within the Project site (USGS, 2020). The City’s 2040 General Plan does not indicate the presence of mineral resources, nor an important mineral resource recovery site within the Project site (City of Ukiah, 2022). Therefore, the Project would not result in the loss of mineral resources or a mineral resource recovery site. Under these criteria, there would be no impact.
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Mitigation Measures: None

13. Noise
NOISE
Would the project result in: Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
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 ground borne vibration
or ground borne 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?
Significance Criteria: The Project would have a significant impact if it temporarily or permanently exceeded local noise standards in the vicinity of the Project, generated excessive ground borne noise or vibration; or would expose people residing or working in the area to excessive noise levels from public airports or private airstrips.

Environmental Setting: The Ukiah City Code’s Noise Ordinance (Division 7, Chapter 1, Article 6) establishes ambient base noise level standards, ranging from 40 to 70 decibels, that apply to specific zoning districts within the City of Ukiah. “Ambient noise” is the all-encompassing noise associated with a given environment, being usually a composite of sounds from many sources near and far. These are specific to operation (not construction). For the purpose of the Noise Ordinance, ambient noise level is the level obtained when the noise level is averaged over a period of fifteen (15) minutes without inclusion of noise from isolated identifiable sources, at the location and time of day near that at which a comparison is to be made. Land uses exceeding these standards for long periods of time are considered to be significant.

Project construction can also generate varying degrees of noise and ground borne vibration, depending on the construction procedure and the construction equipment used. Operation of construction equipment generates noise and vibration that spreads through the atmosphere and ground and diminishes in amplitude with distance from the source. While the Ukiah City Code (UCC) does not contain thresholds for analyzing noise impacts from construction-related noise, UCC §6054 Construction of Buildings and Projects states that it shall be unlawful for any person within a residential zone, or within a radius of five hundred feet (500’) therefrom, to operate equipment or perform any outside construction or repair work on buildings, buildings or projects or to operate any pile driver, power shovel, pneumatic hammer, derrick, power hoist or any other construction type device (between □ □ ~ □
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the hours of 7:00 p.m. of one day and 7:00 a.m. of the next day) in such a manner that a reasonable person of normal sensitiveness residing in the area is caused discomfort or annoyance unless beforehand a permit therefor has been duly obtained from the Director of Public works.

In addition, guidance documents from the Federal Highway Administration and the Federal Highway Administration provide information on maximum noise and vibration levels associated with construction equipment and thresholds of significance for analyzing such impacts.

Discussion:
(a) Less than Significant.

From the Project’s Special Provisions for Great Redwood Trail Phase 4 Specification No. 21-02 (Appendix D), construction activities would generally occur between the hours of 7:00 a.m. and 7:00 p.m. as prescribed by UCC §6054. Project design incorporates policies that will minimize the results of constructions noise, operations not exceeding 86dB at a distance of 50 feet from the noise source.

In addition, the Project will locate all stationary noise generating construction equipment such as air compressors and generators as far as practical from the nearby residences. Unnecessary idling of internal combustion engines will also be prohibited. Once operational, the Project would not include any stationary noise sources. Maintenance would consist of regular checks on the erosion control devices and irrigation systems, mowing upland areas, tree trimming, trash removal, weed control, plant viability monitoring, and overall site good housekeeping measures. The Project would not generate a substantial permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the Ukiah City Code’s Noise Ordinance. This impact would be less than significant.
(b) Less than Significant.

Construction activity can result in varying degrees of ground-borne vibration, depending on the type of soil, equipment, and methods employed. Operation of construction equipment can cause ground vibrations that spread through the ground and diminish in strength with distance. Buildings on the soil near the construction site respond to these vibrations with varying results, ranging from no perceptible effects at the lowest levels, low rumbling sounds and perceptible vibrations at moderate levels, and slight damage at the highest levels. While ground vibrations from construction activities do not often reach the levels that can damage structures, fragile buildings must receive special consideration.

Construction activities may generate perceptible vibration while impact equipment or heavy earth moving equipment are in use. Equipment expected to be used for Project construction, as shown in Table NOI-1, do not include any high vibration generating equipment such as pile drivers, drill rigs or vibratory compactors. The Federal Transit Administration’s Transit Noise and Vibration Impact Assessment Manual identifies 0.2 inches per second peak particle velocity (in/sec PPV) as the level at which potential damage could result to non-engineered timber and masonry buildings. Additionally, Caltrans identifies 0.24 in/sec PPV as the level at which vibration is distinctly perceivable to humans.

Based on ground-borne vibration levels for standard types of construction equipment provided by the FTA, of the equipment proposed to be used for Project construction, the use of the stinger jack hammer would be expected to generate the highest vibration levels (typically 0.035 in/sec PPV at a distance of 25 feet). Since the operation of equipment would produce vibration levels below the aforementioned thresholds, the Project would not result in significant ground borne vibration, and impacts would be less than significant.

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Table NOI-1

TYPICAL NOISE LEVELS FROM CONSTRUCTION EQUIPMENT
Type of Equipment Lmax at 50 feet, dBA Acoustical Usage factor (%) Backhoe 54 40
Dozer 180 40
Dump Truck 76 40
Excavator 81 40
Front End Loader 79 40
Grader 85 40
Pickup Truck 75 40
Roller 80 20
SOURCE: FHWA, 2017
Once operational, the Project would not include any new sources of vibration. Therefore, the Project would have no operational impacts with regard to ground-borne vibration. (c) Less than Significant. A portion of the Project is in proximity to the Ukiah Municipal Airport, and the Project is located within Airport Compatibility Zones 2 (Inner Approach/Departure Zone), 3 (Inner Turning Zone) and 5 (Sideline Zone) within the Ukiah Municipal Airport Land Use Compatibility Plan (UKIALUC). The airport serves as a CalFire Air Attack Base. Throughout fire season, CalFire uses the airport to assist in battling wild and forest fires in the region. The airport is also used for flight training in the area, which is most active during the summer months. This UKIALUCP takes into account potential long-term growth in airport activity as well as the noise impacts associated with busy fire attack aircraft activity. Noises in associated compatibility zones are typically above 55dB, with areas of the Project in Zone 2 consistently above 60dB. Outdoor Non-Group Recreation is considered a Normally Compatible or Conditionally Compatible Land Use, and the trail itself could also be considered a ‘Transportation Route’ which is similarly considered as a Normally Compatible or Conditionally Compatible Land Use.

Mitigation Measures: None

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14. Population and Housing

POPULATION AND HOUSING
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Induce substantial unplanned population growth
in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
Significance Criteria: The proposed Project would result in significant impacts to the local population or housing stock if it directly or indirectly induced substantial unplanned population growth or displaced a substantial number of people or housing such that the construction of replacement housing would be required.

Environmental Setting: The City of Ukiah is approximately 4.72 square miles in size and located within Mendocino County. Overall, the City of Ukiah’s population has increased moderately over the past nearly 30 years, with a more accelerated increase in the last five years. Projections from the California State University Chico Center for Economic Development - Mendocino County Economic/Demographic Profile show this trend continuing. As described in the City’s Housing Element (2019) of the General Plan, the City’s annual growth rate between 1990 and 2018 averaged approximately 0.3%. Between 2000 and 2010, the City added 545 residents, or 3.7%, to its population.

According to the California Department of Finance, the population in the County of Mendocino was 59,985 in 2018 and 16,226 in the City of Ukiah. The 2020 Census data identifies the City of Ukiah population as 16,607.

Discussion:
(a) No Impact. In general, a project would be considered growth-inducing if its implementation would result in substantial population increases and/or new development that would not otherwise occur in the absence of that project. The Project does not include inhabitable structures, such as housing or businesses. Nor would the Project result in permanent employment opportunities that could indirectly induce population growth. The Project’s construction and associated restoration efforts would be likely to require a small, temporary workforce, which is expected to be drawn from the local labor pool or from neighboring counties. Although the Project may enhance the public enjoyment or use of the trail the Project would not lead to substantial increased population. There would be no impact associated with population growth.
(b) No impact. The Project would not displace any existing housing or remove residents. Therefore, no replacement housing would be required to be constructed elsewhere and no impact would occur under this criterion.

Mitigation Measures: None
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15. Public Services

PUBLIC SERVICES
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Result in substantial adverse physical impacts
associated with the provision of new or physically
altered governmental facilities, need for new or
physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public
services:
i. Fire protection?
ii. Police protection?
iii. Schools?
iv. Parks?
v. Other public facilities?
Significance Criteria: The Project would result in a significant impact to public services if it resulted in a requirement for increased or expanded public service facilities or staffing, including fire or police protection, schools and parks.

Environmental Setting: Police protection services for the entire City limits is provided by the Ukiah Police Department, while the Mendocino County Sherriff’s Department provides police services for areas outside of the City limits. Fire protection services in the City are provided by the Ukiah Valley Fire Authority. Educational facilities in the City are provided by the Ukiah Unified School District (UUSD) and County Office of Education. Additionally, there are several private and charter schools serving residents within the City of Ukiah. As mentioned below in Section 16, Recreation, of this Initial Study, there are 13 City parks, a municipal golf course, and a skate park managed by the City of Ukiah, as well as other recreational facilities in the area.

Discussion:
(a.i) No Impact.

The City of Ukiah Fire Department and Ukiah Valley Fire District are two departments that work as one, referred to as Ukiah Valley Fire Authority, maintaining comprehensive coverage for the City and the surrounding Ukiah Valley (City of Ukiah, 2020). The Ukiah Valley Fire District is located within 1 mile of the Project site. The Project would not result in an increase in population or the construction of facilities that would increase demand for fire protection services or impact service ratios, such that new fire protection facilities would be required to be constructed. The Project’s construction and operation would not result in a substantial increase in demand for fire protection services that could not be met by existing local service systems. Therefore, no impact would occur under this criterion. □ □ □ ~
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(a.ii) No Impact.

The City of Ukiah’s Police Department provides law enforcement services to the City of Ukiah. The department’s communications center handles all 9-1-1 calls and non-emergency calls for both the City of Ukiah and City of Fort Bragg police departments. Ukiah’s Police Department is located at 300 Seminary Avenue, approximately 1.6 miles northwest of the Project site. Construction and maintenance of the Project would not result in an increase in demand for police protection or impact service ratios that could not be met by existing local public service providers. As a non-motorized transportation facility, the Project would not necessitate any related new or altered public service facilities. The Project would solely be used for recreational purposes. The Project would facilitate an increase in bicycle, foot, and other non-motorized travel. The Project is not expected to substantially increase the need for patrols by local law enforcement or emergency services. The Project may ultimately have the beneficial effect of reducing the need for patrol by encouraging more formalized and regulated public use and discouraging existing transient activity in the area. Therefore, no impact would occur under this criterion. The trail would be included as a public area monitored by Ukiah Police Department within the City limits and by Mendocino County Sheriff’s Office deputies on unincorporated portions of the trail.
(a.iii) No Impact.

The Ukiah Unified School District serves the City of Ukiah. There are 14 schools servicing grades preschool through High School within the District. As described in Section 2.2.14, Population and Housing, the Project would not result in an increase in housing or population. Therefore, the Project would not generate an increase in demand for local school facilities. No impact would occur under this criterion.
(a.iv) Less Than Significant
As described in 14, Population and Housing, the Project is not expected to result in a temporary or permanent increase of local population. Thus, existing parks or other public facilities would not be impacted and a need for additional parks or public facilities would not be necessary. Although improvements of the trail may attract a slight increase in visitors following construction, that potential increase would be considered a less than significant impact. Operationally, maintenance of the trail is within the City’s existing capacity and already undertaken across existing segments. (a.v) No Impact
The Project would not include any residential development or otherwise increase the local population such that the provision of additional public facilities would be needed. Therefore, there would be no impact pertaining to the construction of such facilities associated with the proposed Project.

Mitigation Measures: None

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16. Recreation

RECREATION
Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
Significance Criteria: Impacts to recreation would be significant if the Project resulted in increased use of existing parks or recreational facilities to the extent that substantial deterioration was accelerated or if the Project involved the development or expansion of recreational facilities that would have an adverse effect on the physical environment.

Environmental Setting: The City maintains a wide variety of park and building facilities to meet the needs of the community. Most parks are open daily to the public between the hours of 6:00 a.m. and 10:00 p.m. Many facilities may also be reserved for a low rental fee. Rental operations include picnic and barbecue facilities, conference and meeting rooms, banquets and wedding facilities, a board room and auditorium, sports stadium and complex, swimming pool, amphitheaters, covered gazebo, and a pavilion. The Project is a park/recreation facility as defined under UCC §1965 and includes all that real property designated in the license agreement between the City of Ukiah and the now named Great Redwood Trail Authority (formerly the North Coast Rail Authority), which includes the entire rail corridor within the City limits. The license agreement also allows the City to develop the railway corridor until the south end of Taylor Drive, bordering properties within the County of Mendocino jurisdiction, and terminating at Plant Road. Former completed phases of the Great Redwood Trail running through the City of Ukiah are currently used by pedestrians, joggers and cyclists for exercise and recreation, and by office professionals on a lunchtime stroll.

Discussion:
(a) No impact. The Project proposes a new recreational amenity within the City of Ukiah and an unincorporated area of Mendocino County. As stated in 14, Population and Housing, the Project would not introduce a new population or induce growth such that substantial deterioration would occur to existing recreational facilities in Ukiah. However, The Project would enhance the recreational experience for residents of the surrounding communities and contribute to the use of an existing recreational facility. The Project would include enhancement of the Great Redwood Trail - Ukiah and support environmental education through native riparian plantings and placement of interpretive signage. Therefore, following construction, the Project would benefit existing neighborhoods and deter potential overuse of other existing and nearby parks. The proposed trail is a recreational facility that could encourage the construction of other facilities, predominantly other connecting trails or related amenities. Such future projects would be subject to CEQA review and other environmental approvals, as applicable, once proposed. There would be no adverse impact under this criterion. ISi ISi

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(b) Less than Significant.

As discussed above, the Project would qualitatively enhance the existing Great Redwood Trail – Ukiah recreational facility. Following construction, operation of the Project would improve recreational resources along with improved site drainage, water quality, wetland habitat, riparian and native vegetation and would not generate long-term adverse physical effects to the environment. Therefore, the impact associated with construction would be temporary and less than significant.

Mitigation Measures: None

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17. Transportation

TRANSPORTATION
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines
§ 15064.3, subdivision (b), Criteria for Analyzing
Traffic Impacts?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
Significance Criteria: Impacts to transportation and traffic would be significant if the Project conflicted with a local plan, ordinance or policy addressing transit, roadway, bicycle and pedestrian facilities; conflicted with CEQA Guidelines Sec. 15064.3(b), which contains criteria for analyzing transportation impacts; substantially increased hazards due to geometric design features; or resulted in inadequate emergency access.

The City of Ukiah’s 2040 General Plan contains a number of goals, policies, and implementation programs pertaining to the circulation and transportation system. Specifically, the Mobility Element of Ukiah 2040 focuses on enhancing transportation options for Ukiah residents, workers, and visitors and improving mobility through increased connectivity and efficient management of existing infrastructure.

The 2040 General Plan increases the emphasis on providing multi-modal street facilities that meet the needs of all users, including pedestrians, bicyclists, motorists, transit, movers of commercial goods, children, seniors, and persons with disabilities (City of Ukiah, 2022).

Additionally, the following local plans have historically addressed transportation issues within the City of Ukiah: 2017 Ukiah Bicycle and Pedestrian Master Plan, City of Ukiah Safe Routes to School Plan (2014), Mendocino County Rail Trail Plan (2012), the Ukiah Downtown Streetscape Improvement Plan (2009), MCOG’s Regional Transportation Plan (RTP) and Active Transportation Plan (ATP) (adopted in 2022) and Section 5, Circulation and Transportation, of the Ukiah Valley Area Plan (2011) addresses transportation within the larger Ukiah Valley.

The RTP/ATP provides an overview of both short- and long-term transportation goals, objectives and policies for the region, as well as a list of potential projects intended for implementation. The RTP/ATP considers all modes of transportation including automobile, trucking, bicycle, pedestrian, air, public transit, rail, maritime, and any related facilities needed for an effective transportation system. The Plan also assesses current and long-range transportation issues, identifies needs and deficiencies, considers funding options and suggests actions to address these items, in an effort to improve the overall transportation system in the region.
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Per CEQA Guidelines Section 15064.3, vehicle miles traveled (VMT) for land use projects exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. In addition, projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

On April 17, 2024, the Ukiah City Council adopted a resolution on measuring potential impacts for VMT which aligns with Ukiah 2040’s General Plan Mobility Element Goal MOB-2 To reduce vehicle miles traveled (VMT) to and from residences, jobs and commercial uses in Ukiah; General Plan Policy MOB-2.1-Reduce vehicle miles traveled (VMT) to and from residences, jobs and commercial uses in Ukiah; and Environment and Sustainability Element, General Plan Goal ENV-8-To achieve carbon neutrality by or before the year 2045. The VMT threshold screening criteria described in the resolution exempts the Project from a quantitative VMT analysis, as it falls within the category of a Transportation Project defined as “Roadway, transit, bicycle, and pedestrian projects that do not lead to a measurable increase in vehicle travel.”
Even so, a lead agency may analyze the project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. Such qualitative analysis of construction traffic utilizing guidance from the Office of Planning and Research (OPR) will be applied below to Project impacts.

In 2018, the OPR published a Technical Advisory on Evaluating Transportation Impacts in CEQA (2018) which is intended to provide advice and recommendations for evaluating VMT, which agencies and other entities may use at their discretion. As discussed further below, the Technical Advisory offers that screening thresholds may be used to identify when land use projects, such as small-scale projects, should be expected to cause a less-than-significant impact without conducting a detailed traffic study.

Environmental Setting: The City of Ukiah generally lies west of U.S. 101 between the U.S. 101/North State Street interchange, and the U.S. 101 / South State Street interchange. Three major interchanges along U.S. 101, Talmage Road, Gobbi Street, and Perkins Street (from south to north), provide access to southern and central Ukiah. The City of Ukiah is developed in a typical grid pattern with streets generally oriented north to south and east to west. Bicycle lanes are located throughout the City and public transit is provided by the Mendocino Transit Authority (MTA).

The Project would be located between the intersection of Commerce Drive and Airport Road in the north, and the eastern terminal end of Plant Road to the south. Crossings would occur at Airport Road, Norgard Lane and Plant Road which will require Encroachment Permits from the City of Ukiah Public Works Department, and with the Mendocino County Department of Transportation. The Standard Specifications and the Standard Plans of the California State Department of Transportation 2018 will be applied to the Project.

Discussion:
(a) Less than Significant.

Construction would result in vehicle trips by construction workers and haul-truck trips for material offhaul and deliveries via Highway 101. Construction-related traffic would be temporary, would vary daily, and would be distributed over the course of a workday and work week. The number of constructionrelated vehicles traveling to and from the Project Area would vary daily. Construction hours would generally be limited to 7:00 a.m. to 7:00 p.m. on weekdays. Nighttime construction is not anticipated, however, the possibility for occasional nighttime work periods cannot be entirely discounted. Due to

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the infrequency of truck traffic and the temporary nature of construction, Project construction is not anticipated to conflict with plans, policies or programs related to the effectiveness of the circulation system.

Once complete, the proposed Project is not expected to increase vehicle traffic on local streets, as it would not increase the area’s population or redirect on-road traffic patterns. The Project would support increased non-motorized travel to and from the area by trail users. Maintenance of the trail is anticipated to be performed by City staff. It is anticipated that Project operation and maintenance would generate minimal traffic trips, as motorized access would be limited to light maintenance, police, and emergency service vehicles.
(b) No Impact.

Transportation Impacts in CEQA (OPR 2018) which contains guidance on methodology and recommendations for establishing screening criteria and thresholds for VMT evaluation, which is used to evaluate impacts in this Initial Study. OPR’s Technical Advisory specifies that transportation impact analysis be based on either a project's VMT per capita (or other efficiency metric like VMT per household, per employee) or total VMT change (before and after project). As noted in OPR’s Technical Advisory, projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis, include additions of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-motorized travel (OPR 2018).

The Project would construct a Class I Trail (pedestrian and bicycle trail). The Project does not include new or expanded parking facilities. The Project would not add additional motor vehicle capacity to the roadway network and would not lead to additional vehicle travel.

The proposed Project does not include any component that could be characterized as resulting in a potential increase to VMT. To the contrary, the Project would promote multi-modal transportation. By its nature, the Project is VMT-reducing. By promoting multi-modal transportation, the Project will reduce VMT throughout the Project Area and would thus not result in an environmental impact under CEQA. Instead, the Project would result in an environmental benefit by reducing the existing VMT in the City.

PRC 21099 (b) (1), upon which the CEQA VMT guidance is based, specifically states the purpose of the VMT criteria is to promote, “the development of multimodal transportation networks,” consistent with the fundamental goals and objectives of the Project. Similarly, the OPR Technical Advisory notes the overall purpose of updating CEQA to include VMT analysis is to help achieve California’s longterm criteria pollution and greenhouse gas emission goals, based on four strategies that include, “plan and build communities to reduce vehicular greenhouse gas emissions and provide more transportation options (OPR 2018),” which is also directly supported by the Project’s goals and objectives related to multi-modal transportation.

Thus, the Project is consistent with the expectations of the OPR guidance for evaluating transportation impacts in CEQA. Lastly, the OPR guidance clarifies that when evaluating impacts to multimodal transportation networks, lead agencies generally should not treat the addition of new transit users as an adverse impact. Therefore, any success the Project ultimately achieves to increasing multi-modal transit (e.g., additional pedestrians and bicyclists using the trail) would not be considered an environmental impact under CEQA. No impact would result. (c) Less than Significant.

Crossing upgrades would require an encroachment permit from the City of Ukiah Public Works Department and with the Mendocino County Department of Transportation. The Project’s Technical Specifications (Specification No. 21-02, Appendix D), informed by the California State Department of

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Transportation’s Standard Specification and Standard Plans (2018), would be implemented during construction in accordance with City requirements, which would include the use of traffic controls, signs, and flaggers, message boards, pedestrian and bicycle control measures, and other measures.

Through required compliance with City of Ukiah traffic control requirements and implementation of Specification No. 21-02, construction activities would not result in substantial adverse effects or conflicts with the local roadway system. The impact would be less than significant.

Railroad crossings within city street crossings would remain unaltered, except when providing connections to existing pedestrian facilities (including curb, gutter and sidewalk) located adjacent to the trail. Consistent with applicable design standards, crossings would include detectable warning surfaces. The proposed trail may have potential conflicts between users who are stationary (such as birdwatchers) and bicyclists due to the difference in these activities. However, since the proposed trail would have striping, signage, and unpaved shoulders on both sides which could be used by birdwatchers and other uses who want to get out of the main travel lanes, substantial safety related conflicts between trail users and stationary individuals would be avoided. Based on the information above, the proposed Project would not substantially increase hazards due to a design feature; therefore, the impact is less than significant.
(d) Less than Significant.

The proposed Project trail alignment would be adjacent to existing streets. Emergency access to the Project Area already exists from these streets and would continue to exist under the proposed Project during both construction and operation.

Since the trail alignment corridor is already served by emergency and law enforcement personnel, the proposed trail would not slow or hinder emergency response, would not require additional emergency services, and would maintain emergency access to all trail segments. Some alignment scenarios would involve limited work on residential streets to paint markings and install signage, which would generally be brief. Ground disturbance on residential streets would not occur. Painting markings, striping, and installing signage on residential streets would be brief in nature and would not impede emergency access or evacuation routes. The potential impact to emergency access would remain less than significant.

Following construction, all properties along the Project alignment would continue to have emergency access. Operation and maintenance of the Project would not result in substantial additional daily traffic from maintenance activities or truck trips along local roadways, and would, therefore, not affect emergency services or response times in the area. Additionally, no roadway closures are proposed during construction, nor during normal operation of the Project. No operational impact on emergency access would result.

Mitigation Measures: None

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18. Tribal Cultural Resources

TRIBAL CULTURAL RESOURCES
Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code section
21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of
the size and scope of the landscape, sacred place,
or object with cultural value to a California Native
American tribe, and that is:

Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in Public
Resources Code section 5020.1(k), or
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.

Significance Criteria: An impact to tribal cultural resources would be significant if the Project were to substantially reduce the significance of a tribal cultural resource, a listed or eligible historic resource, or a resource considered significant by a California Native American tribe. Tribal cultural resources include “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American Tribe” that are eligible for inclusion in the California Register of Historical Resources (California Register) or included in a local register of historical resources. Lead agencies are required to “begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the Proposed Project.” The consultation process must be completed before a CEQA document can be certified.

Environmental Setting: As discussed in Section 5. Cultural Resources, areas that are most typically culturally sensitive include those adjacent to streams, springs, and mid-slope benches above watercourses because Native Americans and settlers favored easy access to potable water.

Tribes known to be present within the Ukiah area include (but are not limited to) the following:
• Coyote Valley Band of Pomo Indians
• Guidiville Indian Rancheria of Pomo Indians
• Hopland Band of Pomo Indians
• Pinoleville Pomo Nation
• Potter Valley Rancheria
• Redwood Valley Little River Band of Pomo Indians
• Sherwood Valley Rancheria of Pomo Indians
• Noyo River Indian Community
• Scotts Valley Band of Pomo Indians
• Yokayo Tribe, not federally recognized

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Discussion:
(a-b) Less than Significant. As discussed under III. Project Background, the City of Ukiah received a report from the Northwest Information Center (NWIC) indicating that unrecorded archaeological sites may be present within the Project area. As part of the draft ISMND circulation, the NWIC results will be forwarded the Great Redwood Trail Agency for assessment of any cumulative impacts regarding archaeological or tribal cultural resources within the Project area. The City also sent an AB 52 notification to the Guidiville Rancheria including Project information and a location map by email and certified mail on August 13, 2024. Commentary or potential mitigation that results from the above communications will be published under the project’s Final Initial Study.

If any previously unrecorded archaeological resources or human remains are identified during grounddisturbing construction activities and are found to qualify as a tribal cultural resource pursuant to PRC Section 21074(a)(1) (determined to be eligible for listing in the California Register or in a local register of historical resources), any impacts to the resource resulting from the Project could be potentially significant.

As discussed under 2. Cultural Resources, as part of the project design (See Appendix D), the following mitigation has been incorporated to address these potentials and reduce impacts to less than significant, including the following:

1. If archaeological resources are discovered at the job site, including chipped or ground stone, historic debris, building foundations, and human bone, do not disturb the resources.

Immediately stop all work within 100 feet of the discovery, protect the discovery area, and notify the Engineer.

2. If human remains of Native American origin are discovered during project construction, it is necessary to comply with state laws relating to the disposition of Native American burials, which fall within the jurisdiction of the Native American Heritage Commission (NAHC) (Public Resources Code 5097). If any human remains are discovered or recognized in any location other than a dedicated cemetery, there will be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains until:
• The County Coroner has been informed and has determined that no investigation of the cause of death is required; and
• If the remains are of Native American origin, the descendants of the deceased Native Americans have made a recommendation to the landowner of the person responsible for the excavation work for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code 5097.98
If human remains are discovered during any demolition/construction activities, all grounddisturbing activities within a 330 foot radius of the remains shall be halted immediately, and the Mendocino County coroner shall be notified immediately, according to Section 5097.98 of the state Public Resources Code and Section 7050.5 of California’s Health and Safety Code.

If the remains are determined by the County coroner to be Native American, the NAHC shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains. The City shall consult with the Most Likely Descendant, if any, identified by the NAHC regarding the treatment and disposition of the remains.

Mitigation Measures: None

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19. Utilities and Service Systems

UTILITIES AND SERVICE SYSTEMS
Would the project: Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Require or result in the relocation or construction
of new or expanded water, wastewater treatment or
storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
c) Result in a determination by the wastewater
treatment provider, which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of state or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
Significance Criteria: Impacts to utility and service systems would be significant if the Project resulted in the construction or expansion of utilities that could cause significant environmental effects; have insufficient water supplies available to the Project during normal to extremely dry years; resulted in inadequate capacity of the wastewater treatment plant; generated solid waste exceeding the capacity of local infrastructure or impairing the achievement of solid waste reduction goals; or failed to comply with any management and reduction statutes or regulations related to solid waste.

Environmental Setting: The majority of City properties are served by City water, sewer, electricity and trash collection as summarized below.

Electricity. Ukiah has its own Electric Utility Department that provides service to residents in the City.

The City’s Electric Utility Department is a municipally owned utility that maintains its own powergenerating capabilities, such as the 3.5 Megawatt Lake Mendocino Hydroelectric Plant, which is one of the City’s major sources of electricity (City of Ukiah, 2022).

Water. The primary source for water in Ukiah is surface waters of the Russian River, which are diverted from the Eel River and stored in Lake Mendocino. There are five major providers of community water □ □ □ ~
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services in the Ukiah Valley. The City’s water service area comprises nearly 100 percent of the population residing within City limits. Millview County Water District provides water to north Ukiah and an unincorporated area bordering the city to the north. Willow County Water District provides water to south Ukiah and an unincorporated area bordering the City to the south. Calpella County Water District provides water to the community of Calpella (City of Ukiah, 2022). All water suppliers are regulated by the California Department of Health Services. The City of Ukiah adopted the 2020 Urban Water Management Plan (UWMP) in 2021. The UWMP considers multiple growth scenarios and determined there is adequate capacity to serve projected hookups through the 2045 planning horizon.

Sewer and Wastewater. The City of Ukiah provides wastewater collection and treatment for approximately two-thirds of the City and operates its own wastewater treatment plant (WWTP). A separate agency, the Ukiah Valley Sanitation District (UVSD) serves the remaining portions of Ukiah.

The City’s 2020 UWMP identifies that the WWTP has a dry-weather capacity of 3.01 million gallons per day (mgd) and that in 2020, the WWTP collected a total of 2,671 acre-feet per year (AFY), which is equivalent to 2.4 mgd (City of Ukiah, 2022).

Solid Waste. The Ukiah landfill, outside City limits on Vichy Springs Road, stopped receiving municipal solid waste in 2001 and the City is working on capping the landfill. Ukiah contracts its solid waste, recycling, and composting to the private company C&S Waste Solutions. Solid waste is transported to the Ukiah Valley Transfer Station, located at 3151 Taylor Drive in Ukiah. Solid waste generated in Ukiah (not capable of recycling or reuse) is exported from the transfer station for disposal to the Potrero Hills Landfill in Solano County. According to California Department of Resources Recycling and Recovery (CalRecycle) the maximum permitted capacity for the Ukiah Transfer Station is 400 tons per day, with no reported estimated capacity closing date (CalRecycle 2024). As of 2020 the facility receives an average of 120 to 130 tons per day (City of Ukiah, 2022).

Discussion:
(a) No Impact. The Project would not require or result in the relocation or construction of any new wastewater treatment, electric power, natural gas, telecommunication facilities, or other utilities. No change to the City’s facilities maintenance is anticipated. Following construction, the park would continue to be maintained by the City, as under existing conditions. There would be no impact. (b) Less than Significant. Construction of the Project would require water for dust control, which would be provided from municipal sources onsite and/or trucked to the site. A slight increase in water use would also be expected in order to successfully establish native riparian plantings and site landscaping, proposed as part of the Project. Other than temporary irrigation, the Project does not include or require the extension of any water infrastructure. Thus, the Project would not induce growth or increase demand during operation and maintenance. Therefore, the Project would not result in water supply impacts. Under this criterion, there would be a less than significant impact primarily associated with construction.
(c) Less than Significant. Temporary portable toilets may be utilized during construction. Temporary facilities would be provided by the contractor selected to construct the Project and serviced by an approved sanitation facility. Under this scenario, the Project would not incur the need for increased wastewater treatment capacity. The Project would not result in any service change during construction, nor during operation and maintenance. Restrooms are not included in the Project. Therefore, there would be a less than significant impact.
(d) Less than Significant. Solid waste proposed for removal includes concrete sidewalk, curb ramp, meridians, shoulder and curb and gutter, pipe, fences, headers, planters culverts, rubble, walls, walks, steps and similar facilities where necessary for new construction or installation as indicated on the

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project plans (See Appendix A). In addition to these items, existing railroad equipment, including foundation and associated electrical cabinetry is proposed for removal and salvaged to NWP Co.

Existing conduits would be capped and abandoned. The existing concrete foundation for this equipment will be demolished and brought to local facilities, including the Ukiah Transfer Station & Recycling Center, where metal materials would be recycled and non-recyclable materials would be disposed of in accordance with all applicable local, state and federal regulations. The Project would include waste receptacles, spaces for recycling bins, and pet waste stations. Solid waste collected as a part of the Project would be disposed of by the City of Ukiah during regular maintenance activities.

Impacts related to solid waste would be less than significant. (e) Less than Significant. The Project would be required to follow all construction and demolition waste diversion requirements from the 2010 California Green Code. No other federal, state, or local regulations would apply to the Project. As a result, the Project would comply with all federal, state, and local management reduction statutes and regulations related to solid waste Mitigation Measures: None

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20. Wildfire

WILDFIRE
If located in or near state responsibility areas or
lands classified as very high fire hazard severity
zones, would the project:

Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Substantially impair an adopted emergency
response planor emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or that
may result in temporary or ongoing impacts to the
environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
Significance Criteria: Impacts to wildfire would be significant if the Project were located in or near a State Responsibility Area (SRA) or lands classified as very high fire hazard severity zones and substantially impaired an emergency response plan; exposed Project occupants to wildfire pollutants or uncontrolled spread of wildfire due to site conditions such as slope and prevailing winds; require the installation or maintenance of infrastructure that could exacerbate fire risk; or expose people or structures to significant risks as a result of post-fire runoff, slope instability or drainage changes.

Environmental Setting: All lands within the City of Ukiah are within the jurisdiction of the Ukiah Valley Fire Authority. None of the lands within the City of Ukiah are located within a California Department of Forestry (CalFire) State Responsibility Area (SRA). However, some parcels within the western boundary of the City limits are designated as “Very High” fire severity within the Local Responsibility Area (LRA). The Project site is not located in an area identified as having a High or Very High fire severity risk.

As discussed in Section V.9, Hazards and Hazardous Materials, the County’s EOP plan and MJHMP address emergency operations, natural disasters (including wildfire), as well as mitigation strategies to reduce potential risks. The City of Ukiah adopted its “jurisdictional annex” chapter of the MJHMP on November 18, 2020. Hazards identified for the City of Ukiah include earthquakes, wildfire, dam failure, flood and pandemic. Table 1-13 of the City’s jurisdictional annex lists each hazard and mitigation action for City of Ukiah.

Discussion:
(a) Less than Significant. The Project site is accessed via existing driveways and roads, and there are no components of the Project that would conflict with or impair the adopted MJHMP, EOP, or other □ □ ~ □
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adopted emergency response plan or emergency evaluation plan. As described in Section 9, Hazards and Hazardous Materials, the Project site is not located within a High or Very High fire severity zone and is being maintained by the City to reduce fire risk. In addition, although there are no specific evacuation routes discussed in either the Mendocino County Emergency Operations Plan or the Mendocino County Multi-Hazard Mitigation Plan (Mendocino County, 2016; 2020), Highway 101 is described in the Mendocino County Evacuation Plan as a primary evacuation route. The Project site is within 400 feet of a Highway 101 on-ramp from Commerce Drive via Airport Park Boulevard and Talmage Road. The CAL FIRE Mendocino Unit Strategic Fire Plan contains goals and policies that relate to identifying and reducing wildland fire hazards in the region, promoting land use planning processes that reduce wildland fire hazards, and developing the resources necessary to implement fire prevention strategies. The Project would not conflict with the implementation of any of these goals or objectives.
(b) Less than Significant. In general, The trail would be located in the railroad corridor within a fairly flat topographical area. During Project construction, heavy equipment such as excavators, dozers, and dump trucks would be used. The presence and use of heavy equipment and vehicles would introduce a slight risk of ignition, as a spark from a piece of equipment or a vehicle could ignite surrounding vegetation and result in a fire. However, due to the existing site conditions, and proximity to water which could be used in an emergency situation, the risk of a construction ignition resulting in a fire would be very low. Considering the limited duration of the construction period and the small size of the construction crew and equipment required, the increase in fire risk introduced by construction of the Project would be minimal and temporary. The Project involves a park and floodplain restoration with no inhabitable structures proposed as part of the Project. With respect to fire risk, operation of the site and surroundings would continue as under existing conditions. Although the Project is located near lands susceptible to the spread of wildland fire, the physical characteristics of the Project site and proximity to water would decrease that risk. Thus, under operations, the Project would have no impact with regard to increased risk for the spread of wildland fire. Most trail users would be within the Project Area for a short period of time given the purpose is for passive recreational and non-motorized transportation use. Due to the expected intermittent use of the site by pedestrians, that the Project does not provide any structures to be used for human occupancy, and the fact that the Project is located within an area of “moderate” fire risk, it is not anticipated to exacerbate wildfire risks and thereby expose users to pollutants. Overall impacts associated with construction would be less than significant.
(c) Less than Significant. The Project includes the removal of existing debris, grading and recontouring, berm construction, installation of a concrete path, and wetland and vegetation restoration. These components of the Project would not increase fire risk. The Project would not require additional roads, fuel breaks, emergency water sources, power lines or other utilities. Electrical connections for street lights would occur in select locations but would not increase fire risk. Operation and maintenance activities currently occur under existing conditions and, following construction, the Project would not result in the need for substantial additional operation and maintenance activities.

The Project would not require the installation or maintenance of infrastructure which could exacerbate fire risk or result in ongoing impacts to the environment. Impacts, primarily related to construction (as discussed in question b), would be limited in duration and less than significant. (d) Less than Significant. The Project site is relatively level and there are no residences located immediately downslope or downstream of the Project site. The closest residence is located just under 50 feet from of the Project site at Norgard Lane. However, the Project would be designed, constructed, and maintained such that slope instability would not occur. Stormwater from the trail will have a chance to infiltrate into previous material and soil prior to reaching the jurisdiction areas downslope of the proposed trail. However, post-construction hydrology will remain essentially the same, as existing

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flows will not be redirected, and volume will not increase. Therefore, there would be a less than significant impact.

Mitigation Measures: None.

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21. Mandatory Findings of Significance

MANDATORY FINDINGS OF SIGNIFICANCE
Significant
Impact
Less Than
Significant
with
Mitigation
Less Than
Significant
Impact
No Impact
a) Does the project have the potential to degrade the
quality of the environment, substantially reduce the
habitat of a fish or wildlife species, cause a fish or
wildlife population to drop below self-sustaining
levels, threaten to eliminate a plant or animal
community, substantially reduce the number or
restrict the range of a rare or endangered plant or
animal or eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are individually
limited, but cumulatively considerable?
("Cumulatively considerable" means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects)
c) Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?
Discussion:
(a) Less than Significant with Mitigation. Once constructed, the proposed Project has the potential to improve the quality of the environment as the project would remove potentially hazardous debris and enhance wetlands within Great Redwood Trail. However, the analysis presented in this Initial Study has identified potentially significant impacts to Air Quality, Biological Resources, Hazards and Hazardous Materials, and Hydrology and Water Quality, attributable to the Project’s construction. To reduce impacts associated with these resource areas, mitigation measures have been proposed. As required by CEQA, these mitigation measures are required to be implemented as directed herein. With implementation of the prescribed mitigation measures, the Project does not have the potential to degrade the quality of the environment, including fish and wildlife species and their habitat, plant or animal communities, or otherwise eliminate examples of major periods of California history or prehistory. With implementation of mitigation, the impacts identified in this Initial Study would be reduced to less than significant levels.
(b) Less than Significant with Mitigation.

A consideration of past, present, and recently foreseeable future projects in Ukiah indicates that the proposed Project would have a less than significant cumulative impact. Given the type, size, and location of the proposed Project relative to other projects proposed in Ukiah, this analysis of potential □ [83 □ □
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cumulative impacts is focused on the southern portion of the City and adjacent unincorporated communities in Southern Mendocino County.

The City is undertaking municipal development such as current and future housing, municipal infrastructure projects, roadway improvements, and other construction, which has the potential to overlap with construction of the Project.

As described in the various resource sections of this document, the Project would either have no impacts or temporary and less than significant impacts (not requiring mitigation measures) for the following resource categories: Aesthetics, Agriculture, Cultural Resources, Energy, Geology/Soils, Greenhouse Gas Emissions, Land Use/Planning, Mineral Resources, Noise, Population/Housing, Public Services, Recreation, Transportation, Tribal Cultural Resources, Utilities and Wildfire. The Project would not contribute cumulatively considerable impacts for these resources.

The Project could have potentially significant impacts with respect to Air Quality, Biological Resources, Hazards and Hazardous Materials, and Hydrology and Water Quality. However, such impacts would be generally limited to the immediate vicinity of the site and, where necessary, mitigated such that impacts would not substantially combine with other off-site impacts of other projects. Moreover, other projects would also be required to comply with regulatory requirements to reduce effects from these projects. With implementation of mitigation measures and the associated compliance with applicable regulations, the effects from other projects would be reduced and would not be cumulatively considerable when combined with the effects of the Project (also subject to these regulations).

Therefore, the impacts would not be cumulatively significant. (c) Less than Significant with Mitigation. Potentially significant impacts on human beings (that could occur either directly or indirectly) are identified in this IS/MND. These are primarily associated with construction of the proposed Project generating potentially significant impacts to Air Quality, Hazards and Hazardous Materials, and Transportation. In each of these sections of the MND mitigation is provided to reduce impacts to less-than-significant levels. Implementation of the mitigation measures identified in this document, along with the necessary compliance with federal, state, and local agency statutes and regulations, potential impacts to human beings would be reduced to less than significant levels.

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IV. DETERMINATION
Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this Project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.

Aesthetics Agriculture & Forestry Air Quality
Biological Resources Cultural Resources Energy
Geology / Soils Greenhouse Gas Emissions Hazards & Hazardous Materials
Hydrology/Water Quality Land Use / Planning Mineral Resources Noise Population / Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities/Service Systems Wildfire Mandatory Findings of Significance
Summary of Findings: The Great Redwood Trail Phase 4 Project proposes to extend a 1.9-mile portion of the trail through the City of Ukiah and to provide a pedestrian area and bike path connection while simultaneously restoring wetland area and natural vegetation. The trail alignment follows the existing decommissioned Northwestern Pacific Railroad.

The Project comprises preparation of the site, removal of debris, grading/site recontouring, enhancement of wetlands, a new 10-foot-wide asphalt/concrete walkway with 2-foot gravel shoulders, ecologically appropriate landscaping, and signage improvements. Once constructed the proposed Project would improve the quality of the environment as potentially hazardous debris would be removed from the site and wetlands within the rail corridor would be enhanced.

The analysis presented in the Initial Study has identified potentially significant impacts to Air Quality, Biological Resources, Hazards and Hazardous Materials, and Hydrology and Water Quality, attributable to the Project’s construction. However, with implementation of the mitigation measures described throughout the Initial Study, all impacts would be reduced to less than significant levels. □
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On the basis of the initial evaluation that follows:
☐ The proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
☒ Although the proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because mitigation measures and project revisions have been identified that would reduce all impacts to a less than significant level. A MITIGATED NEGATIVE DECLARATION will be prepared.
☐ The proposed Project MAY have a significant effect on the environment. An ENVIRONMENTAL IMPACT REPORT is required.
☐ The proposed Project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact 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.
☐ 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 or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed Project, nothing further is required.

Signature Date
Craig Schlatter, Director
Community Development Department
City of Ukiah
[email protected]

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VI. REFERENCES

1. Bay Area Air Quality Management District (2022). CEQA Thresholds and Guidelines Update. Retrieved from: https://www.baaqmd.gov/plans-and-climate/californiaenvironmental-quality-act-ceqa/updated-ceqa-guidelines

2. Bay Area Air Quality Management District. (2017). Final 2017 Clean Air Plan, Volume 1.

Retrieved from https://www.baaqmd.gov/~/media/files/planning-andresearch/plans/2017-clean-air-plan/attachment-a_-proposed-final-cap-vol-1- pdf.pdf?la=en

3. CalFire (2022) California Fire Hazard Severity Zone Maps. Retrieved from:
https://www.fire.ca.gov/osfm/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones/fire-hazard-severity-zones-maps-2022

4. California Air Resources Board (2024). Maps of State and Federal Area Designations.

Retrieved from: https://ww2.arb.ca.gov/resources/documents/maps-state-and-federalarea-designations

5. California Air Resources Board (2017). 2017 Scoping Plan Documents. Retrieved from: https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scopingplan/2017-scoping-plan-documents

6. California Department of Conservation (2024). United States Geological Survey, U.S.

Quaternary Faults. Retrieved from:
https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9 b0aadf88412fcf

7. California Department of Conservation (2022) Farmland Mapping & Monitoring Program, California Important Farmland Finder. Retrieved from:
https://maps.conservation.ca.gov/DLRP/CIFF/

8. California Department of Conservation (2024) Reported California Landslide Database.

Retrieved from: https://www.conservation.ca.gov/cgs/landslides

9. California Department of Finance (2024) American Community Survey. Retrieved from:
https://www.census.gov/programs-surveys/acs/

10. California Department of Fish and Wildlife (2024) CNDDB Maps and Data. Retrieved from: https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data

11. California Department of Parks and Recreation (2023). Office of Historic Preservation.

Built Environment Resource Directory (BERD). Retrieved from:
https://ohp.parks.ca.gov/?page_id=30338

12. California Department of Resources and Recycling (2024) SWIS Facility/Site Activity Details – Ukiah Transfer Station. Retrieved from:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2863?siteID=1818

82 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

13. California Department of Toxic Substance Control (2024) EnviroStor database.

Retrieved from: https://www.envirostor.dtsc.ca.gov/

14. California Department of Transportation (2018) Standard Specifications. Retrieved from:
https://dot.ca.gov/-/media/dotmedia/programs/design/documents/f00203402018stdspecs-a11y.pdf

15. California Department of Transportation (2024) California State Scenic Highways.

Retrieved from: https://dot.ca.gov/programs/design/lap-landscape-architecture-andcommunity-livability/lap-liv-i-scenic-highways

16. California Department of Transportation (2020). Chapter 1000: Bikeway Planning and Design. Retrieved from: https://dot.ca.gov/-/media/dotmedia/programs/design/documents/chp1000-a11y.pdf

17. California Governor’s Office of Planning and Research (2024) Tribal Cultural resources (AB 52). Retrieved from: https://www.opr.ca.gov/ceqa/tribal/

18. City of Ukiah (2024, April 17). A Resolution of the City Council of the City of Ukiah, California Approving a Citywide Policy Establishing Vehicle Miles Traveled (VMT) as the Standard of Measurement for Potential Vehicle Traffic Impacts and a Methodology for Evaluation of Future Projects Consistent with the California Environmental Quality Act (CEQA) (Resolution – SB 743 VMT Policy). Retrieved from:
https://ukiahca.portal.civicclerk.com/event/1887/overview

19. City of Ukiah (2024) Landmark Tree Program Map. Retrieved from:
https://cityofukiah.com/landmark-tree-program-map/

20. City of Ukiah (2024) Ukiah City Code. Retrieved from:
https://www.codepublishing.com/CA/Ukiah

21. City of Ukiah (2023) City of Ukiah Tree Management Guidelines. Retrieved from:
https://cityofukiah.com/wp-content/uploads/2023/09/Tree-Management-Guidelines2023ApprovedFinal.pdf

22. City of Ukiah (2022) Final Initial Study and Mitigated Negative Declaration for the Ukiah Western Hills Open Land Acquisition and Limited Development Agreement Project.

Retrieved from: https://cityofukiah.com/ukiah-western-hills-open-land-acquisition-limiteddevelopment-agreement-project/

23. City of Ukiah (2022) Ukiah 2040 General Plan and Environmental Impact Report.

Retrieved from: https://ukiah2040.com/

24. City of Ukiah (2022) Ukiah 2040 General Plan Update Draft Environmental Impact Report. Report from: https://cityofukiah.com/wpcontent/uploads/2023/02/Ukiah_2040_Draft_EIR_with_Appendices.pdf

25. City of Ukiah (2021) Emergency Operation Plan. Retrieved from:
https://cityofukiah.com/wp-content/uploads/2021/10/City-of-Ukiah-Emergency-OperationPlan.pdf

26. City of Ukiah (2021) Historic and Architectural Inventory Table. Retrieved from:
https://cityofukiah.com/wp-content/uploads/2021/11/Historic-and-Architectural-InventoryTable.pdf

83 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

27. City of Ukiah (2021) Ukiah Municipal Airport Land Use Compatibility Plan (UKIALUCP).

Retrieved from: http://www.cityofukiah.com/NewWeb/wpcontent/uploads/2021/06/Ukiah-Municipal-Airport-Land-Use-Compatibility-Plan-2021.pdf

28. City of Ukiah (2019) Housing Element Update 2019-2027. Retrieved from:
http://www.cityofukiah.com/projects/housing-element-update/

29. FEMA (2024) Resilience Analysis and Planning Tool (RAPT). Retrieved from:
https://www.fema.gov/about/reports-and-data/resilience-analysis-planning-tool

30. Federal Transit Administration. (2018) Transit Noise and Vibration Impact Assessment Manual. Retrieved from: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/researchinnovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no0123_0.pdf

31. Fehr & Peers, on behalf of the Mendocino Council of Governments. (2020) Senate Bill 743 Vehicle Miles Traveled Regional Baseline Study. Retrieved from:
https://www.mendocinocog.org/vehicle-miles-traveled-vmt-regional-baseline-studycompleted

32. Google (2024) Google Earth (Version 10.59.0.2). Retrieved from:
https://www.google.com/intl/en_us/earth/

33. Great Redwood Trail Agency (2024) Great Redwood Trail Draft Master Plan. Retrieved from: https://www.railstotrails.org

34. Mendocino Council of Governments (2022). 2022 Mendocino County Regional Transportation Plan & Active Transportation Plan. Retrieved from:
https://www.mendocinocog.org/

35. Mendocino Council of Governments (2018). Mendocino County Regional Transportation Plan. Prepared by Davey Bates Consulting. Retrieved from:
https://www.mendocinocog.org/files/742330750/2017+RTP+As+Adopted%28web+forma t%29.pdf

36. Mendocino County (2024) Public GIS Portal. Retrieved from:
https://gis.mendocinocounty.org/portal/home/

37. Mendocino County (2024) Zoning Web Map. Retrieved from:
https://www.mendocinocounty.org/government/planning-building-services/zoning-webmap

38. Mendocino County (2020) Mendocino County Evacuation Plan. Retrieved from:
https://www.mendocinocog.org/files/c99a8053f/EvacuationPlan.pdf

39. Mendocino County (2020) Mendocino Multi-Jurisdictional Hazard Mitigation Plan (MJHMP). Retrieved from: https://mitigatehazards.com/mendocino-county/final-mjhmp/

40. Mendocino County (2012) Mendocino County Rail-with-Trail Corridor Plan. Retrieved from:
https://www.mendocinocog.org/files/9c1141782/MCOGRWT_Final+Document%28web%

29.pdf

41. Mendocino County (2011) Current General Plan - Ukiah Valley Area Plan. Retrieved from: https://www.mendocinocounty.gov/departments/planning-building-services/longrange-plans/current-general-plan

84 Great Redwood Trail – Ukiah (Phase 4)
Commerce Drive to Plant Road
Draft Initial Study and Mitigated Negative Declaration
City of Ukiah

42. Mendocino County (2011) Ukiah Valley Area Plan. Section 3, Land Use and Community Development. Retrieved from: https://www.mendocinocounty.org/home/showpublished document/11871/636414328011170000

43. Mendocino County Air Quality Management District of the California North Coast Air Basin (2005). Particulate Matter Attainment Plan. Retrieved from:
https://www.co.mendocino.ca.us/aqmd/pm-attainment.html

44. Mendocino County Office of Education (2024). Schools & Districts. Retrieved from:
https://www.mcoe.us/schools-districts/

45. Natural Resource Conservation Service, U.S. Department of Agriculture (2022) Web Soil Survey. Retrieved from: https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm

46. Office of Environmental Health Hazard Assessment (2015). Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments. Retrieved from:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf

47. Office of Planning and Research (2018) Technical Advisory on Evaluating Transportation Impacts In CEQA. Retrieved from:
https://www.opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf

48. State Water Resources Control Board (2024). GeoTracker. Retrieved from:
https://geotracker.waterboards.ca.gov.

49. U.S. Department of Fish and Wildlife (2024) Environmental Conservation Online System.

Retrieved from: https://ecos.fws.gov/ecp/

50. U.S. Geological Survey (2018) Interactive Fault Map. Retrieved from:
https://www.usgs.gov/natural-hazards/earthquake-hazards/faults?qtscience_support_page_related_con=4#qt-science_support_page_related_con

51. U.S. Fish and Wildlife Service (2024) Wetlands Mapper. Retrieved from:
https://www.fws.gov/wetlands/data/mapper.html

85 VII. APPENDICES
Appendix A
Phase 4: GRT - Ukiah Plan Sheets
Appendix B
Aquatic Resource Report
Appendix C
NCRA License Agreement
Appendix D
Special Provisions for Great Redwood Trail Phase 4 Spec. no 21-02 Appendix E
NCRWQCB Water Quality Certification
Appendix F
CDFW Lake and Streambed Alteration Agreement
Appendix G
Avoidance and Minimization Measures
All appendices are available via the following City of Ukiah weblink:
https://cityofukiah.com/great-redwood-trail-ukiah-phase-4/

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707) 463-6204 · www.cityofukiah.com Katherine Schaefers
Planning Manager
Community Development Department
300 Seminary Avenue
Ukiah, CA, 95482
October 8, 2024
Subject: Response to CEQA Comments on the Great Redwood Trail - Ukiah (Phase 4) – Initial Study and Mitigated Negative Declaration (SCH# 2024081302)
Pursuant to CEQA, lead agencies are required to consult with public agencies having jurisdiction over a proposed project and provide the general public with an opportunity to comment on the Draft ISMND.

On August 29, 2024, the City of Ukiah circulated a Notice of Intent (NOI) for a 30-day period to identify potential significant environmental effects if the project were to be implemented. The NOI was emailed or otherwise provided to public agencies, the CEQA State Clearinghouse, as well as organizations and individuals considered likely to be interested in the project and its potential impacts. The NOI was also posted on the City of Ukiah’s CEQA website and made available at the Ukiah Civic Center.

This Response to Comments consists of the following replies to the California Department of Fish and Wildlife (CDFW), as well as representatives of the Great Redwood Trail Agency (GRTA).

Responses to the Northwest Information Center at Sonoma State University, the California Native American Heritage Commission, and Pacific Gas and Electric Company were not required given the Project’s incorporation of regulations, permits, outreach attempts, and safety protocols. Please see below for more information:

Great Redwood Trail Agency (GRTA) – Staff Response (June 11, 2024) – Exhibit A GRTA Comments in italics

1. Plan calls to remove the RR Signal Cabinet (CIL) at Commerce Drive. The removal of any GRTA property shall be approved and coordinated with GRTA • Agreed. Please advise on steps on process or removal.

2. There is a fiber optic line under much of the project. Has the owner of the utility reviewed the plans?
• Utility companies will be notified to mark their utilities during preconstruction efforts.

Any utilities that are in conflict with the trail plans will be remediated with the City Engineer.

ATTACHMENT 3

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707) 463-6204 · www.cityofukiah.com

3. What is the need for the water tanks at approx. Sta. 404+50, 414+20 and 417+50? • These water tanks are for irrigation purposes in providing water to the native plants that are planned for installation during construction and after by volunteer groups. The City of Ukiah will supply and provide the water.

4. Trail plan states that there may be areas that require slight shift of plans for preservation of existing trees. What type of tree protection will be used? Is there an Arborist Report? • There is no arborist report. Tree protection will be on a case-by-case basis in coordination with the Resident Engineer.

5. There are a total of 9 trees that are marked with an X which the plans indicate as tree removal. Are any of these possible to save?
• The original plan called for the removal of nearly 40 trees. After City/community review and several field walks, these trees were agreed to be eliminated. Had railbanking been facilitated by the CUPC, no tree removal would be required.

6. Does the ramp and stairs to Panda Express at Sta. 406+00 lead to a public walkway? • Yes. The City has an access easement with the property owner and made their site development conditional on granting such trail access to the public.

7. Plan typical section number callouts are the same on 3 plan sheets. This is confusing. • No response.

8. On Sheet C-108 how is the fill constructed around the new 48” CMP extensions? Are there permits we can review? Same questions for the 24” CMP extension. • Refer to C-108 and detail C-503 “Rock Slope Protection”. The project has an approved permit with California Department of Fish and Wildlife under notification no. EPIMSMEN-32359-R1C that can be reviewed upon arranged request.

9. Where are the outlets for the drainage handled for trail segments that have a drainage ditch between RR embankment and trail?
• It’s unclear which area this question is referring to, but all areas of the trail will be properly graded to drain away from both the tracks and trail.

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707) 463-6204 · www.cityofukiah.com

10. Is Airport Park Blvd still closed? If so, will it continue to be closed? If it is to be reopened what safety measures would be implemented?
• Airport Road is still closed. Signage and pedestrian safety including an ADA crosswalk across. Airport Road will be constructed with the anticipation of the road being reopened. See sheet C-402.

11. Sheet C-113 calls out wetland grading on the opposite side of the tracks. Is this required as mitigation? If so, please provide details of the requirement • This wetland mitigation is required and detailed both in the project specifications and North Coast Regional Water Quality Control Board permit ECM PIN CW-882169; WDID 1B22090WNME.

12. Trail Profile is lacking top of rail profile.
• No Response

13. There is approximately 575 ft of existing linear encroachment along GRTA’s east right-ofway. These encroachments coincide with trail stationing from Sta. 471+25 to 477+00. The plans provide how the Ukiah Animal Shelter 330 ft of encroachment is addressed only (See comment 14).
• No Response

14. How will the additional 245 ft of encroachments be addressed? There is a well-used dirt roadway assumed for vineyard overlapping the planned trail. • All the vineyards in question are owned by the City of Ukiah and all contractors employed at those locations are under contract with the City of Ukiah. The animal shelter is in negotiations to move and the City is in coordination with the County on future use of this property. Project plans do no interrupt current operations of this facility.

15. The trail ends at Plant Road. The track crossing at this location is in very poor condition, as is the road itself are there plans to improve these conditions? (see below photo). • This road is outside the project scope and belongs to Mendocino County and not within the City of Ukiah’s pavement rehabilitation program. As a terminus to the trail, the project will provide crosswalk striping within the roadway and an ADA ramp for future connections. See sheet C-404.

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707) 463-6204 · www.cityofukiah.com

16. Sheet C-121 and C-122 (“Drainage Plan 1 & 2”) have five plans that indicate the railroad embankment requires regrading at these locations. Cross sections show catch points with line to edge of trail indicating all drainage of RR embankment drains onto trail? • Any drainage from the RR running across the trail will continue in slope across and off the trail as shown at 1.5%

17. Erosion Control. There are areas where the RR embankment slope is without erosion control. Example Sta. 441+20 below:
• Any area disturbed will have erosion control unless not allowed by State regulatory permits.

18. All existing RR signage is to remain. If RR signage or striping is to be removed or replaced, GRTA approval is required. No track modification or removal is allowed. • Agreed. Please advise on steps on process or removal.

19. Airport Park Blvd. and Commerce Dr. do not have S2 signage (RECTANGULAR RAPID FLASHING BEACON). This seems inconsistent with other crossings on the trail. • Because of the grant funding, this type of improvement was limited.

Great Redwood Trail Agency (GRTA) – Staff Response (September 27, 2024) – Exhibit B GRTA Comments/Questions in italics

1. The stairways at the north end (near Commerce Drive- at Panda Express and Holiday Inn parking lot) need to be tied into their associated parking areas in a way that is safe and supports pedestrians and bicyclists. Please explain how the GRT will safely tie into these two parking areas.
• The City has an access easement with the property owner and made their site development conditional on granting such trail access to the public.

2. Are the water tanks shown on the Phase 4 plans for irrigating plantings associated with the GRT?
• These water tanks are for irrigation purposes in providing water to the native plants that are planned for installation during construction and after by volunteer groups. The City of Ukiah will supply and provide the water.

3. Do you know how deep the existing fiberoptic cable is buried in GRTA’s ROW?

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707) 463-6204 · www.cityofukiah.com • Utility companies will be notified to mark their utilities during preconstruction efforts. Any utilities that are in conflict with the trail plans will be remediated with the City Engineer.

4. Are there plans to eventually open Airport Road and connect to Airport Park Blvd. (where there is currently a gate)?
• Airport Road is still closed. Signage and pedestrian safety including an ADA crosswalk across Airport Road will be constructed with the anticipation of the road being reopened. See sheet C-402.

5. The Norgaard/Highway 101 underpasses have buried fiberoptic cable, drainage ditches, etc. - it appeared to GRTA staff that the best location for the GRT in this area would be west of the railroad tracks; however, it appears the plans show the GRT east of the tracks. We’d like to walk this section with City staff asap to confirm the plans for the GRT, as there is a lot going on in this area.
• This wetland mitigation [at this location and detailed on Sheet C-113] is required and detailed both in the project specifications and North Coast Regional Water Quality Control Board permit ECM PIN CW-882169; WDID 1B22090WNME. Staff is open to any requested evaluation or site visit to the areas planned for the GRT – Ukiah (Phase 4).

6. North of Taylor Drive and Plant Road, there are Mendocino County Animal Controlassociated encroachments into GRTA ROW, as well as fencing, and vineyards on GRTA property. What are the plans for addressing these encroachments as part of the Phase 4 GRT project? We’d like to walk this area with City staff as well, to review the issues and Phase 4 plans.
• All the vineyards in question are owned by the City of Ukiah and all contractors employed at those locations are under contract with the City of Ukiah. The animal shelter is in negotiations to move and the City is in coordination with the County on future use of this property. Project plans do no interrupt current operations of this facility. Staff is open to any requested evaluation or site visit to the areas planned for the GRT – Ukiah (Phase 4).

NAHC – Public Comment (August 12, 2024) – Exhibit C
No Response
SSU-NWIC – Public Comment (August 27, 2024) – Exhibit D No Response
California Department of Fish & Wildlife (August 27, 2024) – Exhibit E CDFW Comments and Recommendations in italics

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707)463-6204 ·www.cityofukiah.com I. Environmental Setting and Related Impact Shortcoming The draft MND does not include an analysis of potential impacts to listed species, Species of Special Concern, rare plants, riparian habitat or other Sensitive Natural Communities. The Project’s identification and analysis of potential impacts to these resources was informed by an Aquatic Resources and Wetland Delineation Report. This report did not include floristic survey results, and the survey documented was conducted outside the blooming period for most plant species with the potential to occur. Within a half mile of the Project, the California Natural Diversity Database (CNDDB) documents occurrences of Baker’s Meadowfoam (Limnanthes bakeri), a State-listed species with a California Plant Rank of 2.B1.

CDFW Recommendation 1: Adequate biological surveys should be conducted at the appropriate time of year to determine whether rare plants, Sensitive Natural Communities, and Species of Special Concern or their habitat are present.
• While it is acknowledged that Biological Surveys and floristic surveys can provide substantial evidence to support conclusions about potential impacts, there is no explicit requirement that an ISMND must include these studies. This ISMND has provided substantial evidence to support its findings on impacts to Biological Resources, specifically to listed species, Species of Special Concern, rare plants, riparian habitat or other Sensitive Natural Communities via queries into the California Natural Diversity Database (CNDDB) Rare Find, and the California Native Plant Society (CNPS) Inventory of Rare Plants, along with adherence to the mitigation measures from the California Department of Fish and Wildlife Lake and Streambed Alteration Agreement (Appendix F), the Aquatic Resources and Wetland Delineation Report (Appendix B), and the North Coast Regional Water Quality Control Board (NCRWQCB) Water Quality Certification (Appendix E).
• In addition, as referenced in Appendix D (Special Provisions) and Appendix G (Avoidance and Minimization Measures), and as conditioned in the ISMND and the NRCWQCB Water Quality Certification (Appendix E), to ensure no impacts to listed species, Species of Special Concern, rare plants, riparian habitat or other Sensitive Natural Communities occur, a qualified biologist shall conduct environmental awareness training for Project contractors prior to initiation of construction. Though no significant impacts on Baker’s meadowfoam or other listed species or habitat are anticipated with adherence to existing project design and mitigation measures, the incorporation of Baker’s meadowfoam will be recommended for inclusion in the training and review.

CDFW Recommendation 2: If Baker’s meadowfoam or other listed species or associated habitat is identified within the Project area, and potential impacts to these species are unavoidable, consult with CDFW to seek the appropriate take authorization for species listed under the Native Plant

300 Seminary Avenue • Ukiah • CA • 95482-5400
Phone: (707) 463-6200 · Fax: (707)463-6204 ·www.cityofukiah.com Protection Act (Fish & G. Code, § 1904) or the California Endangered Species Act (CESA) (Fish & G.

Code, § 2050 et seq.).
• With Project design and mitigation measures, a take is not anticipated.

II. Mitigation Measure or Alternative and Related Impact Shortcoming Issue 1: The Project proposes to remove “trees and other natural vegetative features” (page 24) along the trail alignment, but the species or their natural communities are not identified. The Project proposes revegetation and restoration activities, which include natural regeneration along the trail alignment and planting trees and shrubs within riparian zones to enhance water quality and habitat (page 27).

CDFW Recommendation 3: Revise Mitigation Measure BIO-2 and BIO-4 to require Project revegetation and enhancement plans identify the species and natural community proposed for removal, and propose a planting palette comprised of the appropriate native tree and shrub species that are suitable for that natural community.
• From the Project’s “Special Provisions for the Great Redwood Trail Phase 4” (Appendix D), the Project has been designed to adhere to a Planting Plan, which identifies the species to be removed and introduced (incl. valley oak, common manzanita, ceanothus, and toyon). In addition, Appendix A (Phase 4 GRT – Ukiah Plan Sheets) identifies the location and species of each tree to be removed. The Project will also need to adhere to the City of Ukiah’s Tree Management Guidelines and will be facilitated by Community Services staff and horticulturalists in conjunction with contracted arborists. Appendix G (Avoidance and Minimization Measures) provides the incorporated project requirement that a qualified wetland biologist/ecologist shall monitor the revegetation and restoration activities for up to three years or until the graded areas match the vegetation density of the existing wetland and are dominated by wetland plants. The existing wetland will be used as a benchmark for determining density. If it is determined after year one of monitoring that the vegetation is not progressing at a satisfactory rate to support a functional wetland, the area will be considered for reseeding or plugs (pg. 5). A proposed Wetland Seed Mix table, identifying species and quantity is also included in the analysis. This requirement is also echoed in the ‘Project-Specific Conditions’ of the NCRWQCB Water Quality Certification (Appendix E). As revegetation and enhancement plans are already embedded into the Project’s design, revisions to Mitigation Measure BIO-2 and BIO-4 are not warranted.

Exhibit A: GRTA – Public Comment Dave Anderson (June 11, 2024); Exhibit B (GRTA – Public Comment Louisa Morris (September 27, 2024); Exhibit C: NAHC – Public Comment (August 12, 2024); Exhibit D: SSU-NWIC – Public Comment (August 27, 2024); Exhibit E: CDFW – Public Comment (August 27, 2024)

D&A Enterprises LLC 1

MEMORANDUM
Date: June 11, 2024
To: Elaine Hogan, GRTA Executive Director
From: Dave Anderson, PE
Re: Ukiah Phase 4 review Comments/Questions
1) Plan calls to remove the RR Signal Cabinet (CIL) at Commerce Drive. The removal of any GRTA property shall be approved and coordinated with GRTA.
2) There is a fiber optic line under much of the project. Has the owner of the utility reviewed the plans?
3) What is the need for the water tanks at approx. Sta. 404+50, 414+20 and 417+50? 4) Trail plan states that there may be areas that require slight shift of plans for preservation of existing trees. What type of tree protection will be used? Is there an Arborist Report? 5) There are a total of 9 trees that are marked with an X which the plants indicate as tree removal.

Are any of these possible to save?
6) Does the ramp and stairs to Panda Express at Sta. 406+00 lead to a public walkway? 7) Plan typical section number callouts are the same on 3 plan sheets. This is confusing.

EXHIBIT A

D&A Enterprises LLC 2
8) On Sheet C-108 how is the fill constructed around the new 48” CMP extensions? Are there permits we can review? Same questions for the 24” CMP extension. 9) Where are the outlets for the drainage handled for tail segments that have a drainage ditch between RR embankment and trail?
10) Is Airport Park Blvd still closed? If so, will it continue to be closed? If it is to be reopened what safety measures would be implemented?
11) Sheet C-113 calls out wetland grading on the opposite side of the tracks. Is this required as mitigation? If so, please provide details of the requirement. 12) Trail Profile is lacking top of rail profile.
13) There is approximately 575 ft of existing linear encroachment along GRTA’s east right-of-way.

These encroachments coincide with trail stationing from Sta. 471+25 to 477+00. The plans provide how the Ukiah Animal Sheler 330 ft of encroachment is addressed only (See comment 14).
14) How will the additional 245 ft of encroachments be addressed? There is a well-used dirt roadway assumed for vineyard overlapping the planned trail.

Below is an overall Google Earth view of the area of encroachment. A detailed series of 6 aerial photos follow showing the 575 ft of encroachments. The photos start at the north end and overlap going south:

D&A Enterprises LLC 3

D&A Enterprises LLC 4

D&A Enterprises LLC 5

D&A Enterprises LLC 6

D&A Enterprises LLC 7

D&A Enterprises LLC 8

D&A Enterprises LLC 9

D&A Enterprises LLC 10
15) The trail ends at Plant Road. The track crossing at this location is in very poor condition, as is the road itself are there plans to improve these conditions? (see below photo). 16) Sheet C-121 and C-122 (“Drainage Plan 1 & 2”) have five plans that indicate the railroad embankment requires regrading at these locations. Cross sections show catch points with line to edge of trail indicating all drainage of RR embankment drains onto trail?

D&A Enterprises LLC 11
17) Erosion Control. There are areas where the RR embankment slope is without erosion control.

Example Sta. 441+20 below:
18) All existing RR signage is to remain. If RR signage or striping is to be removed or replaced, GRTA approval is required. No track modification or removal is allowed. 19) Airport Park Blvd. and Commerce Dr. do not have S2 signage (RECTANGULAR RAPID FLASHING BEACON). This seems inconsistent with other crossings on the trail.

From: Morris, Louisa@SCC
To: Katherine Schaefers; Jesse Davis
Cc: Elaine Hogan
Subject: GRTA comments on GRT Ukiah Phase 4 MND/plans
Date: Friday, September 27, 2024 9:33:01 AM
Attachments: image001.jpg
image002.jpg
Importance: High
[EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe.

Dear Katherine and Jesse,
Here are GRTA’s additional comments/questions on the Phase 4 GRT-Ukiah designs and MND:

1. The stairways at the north end (near Commerce Drive- at Panda Express and Holiday Inn parking lot) need to be tied into their associated parking areas in a way that is safe and supports pedestrians and bicyclists.

Please explain how the GRT will safely tie into these two parking areas.

2. Are the water tanks shown on the Phase 4 plans for irrigating plantings associated with the GRT?

3. Do you know how deep the existing fiberoptic cable is buried in GRTA’s ROW?

4. Are there plans to eventually open Airport Road and connect to Airport Park Blvd. (where there is currently a gate)?

5. The Norgaard/Highway 101 underpasses have buried fiberoptic cable, drainage ditches, etc. - it appeared to GRTA staff that the best location for the GRT in this area would be west of the railroad tracks; however, it appears the plans show the GRT east of the tracks.

We’d like to walk this section with City staff asap to confirm the plans for the GRT, as there is a lot going on in this area.

6. North of Taylor Drive and Plant Road, there are Mendocino County Animal Controlassociated encroachments into GRTA ROW, as well as fencing, and vineyards on GRTA property.

What are the plans for addressing these encroachments as part of the Phase 4 GRT project?
We’d like to walk this area with City staff as well, to review the issues and Phase 4 plans.

Thank you! We are excited to work with you to make this next phase of the GRT happen.

Best,
Louisa
Louisa Morris, Project Manager
Great Redwood Trail
State Coastal Conservancy | www.scc.ca.gov
1515 Clay Street, Suite 1000, Oakland 94612
Phone: 510-286-4185

EXHIBIT B

STATE OF CALIFORNIA Gavin Newsom, Governor

NATIVE AMERICAN HERITAGE COMMISSION

August 12, 2024
Katherine Schaefers
City of Ukiah
Via Email to: [email protected]
Re: Native American Consultation, Pursuant to Senate Bill 18 (SB18), Government Codes §65352.3 and §65352.4, as well as Assembly Bill 52 (AB52), Public Resources Codes §21080.1, §21080.3.1 and §21080.3.2, Great Redwood Trail - Ukiah (Phase 4) Project, Mendocino County Dear Ms. Schaefers:

Attached is a consultation list of tribes with traditional lands or cultural places located within the boundaries of the above referenced counties or projects.

Government Codes §65352.3 and §65352.4 require local governments to consult with California Native American tribes identified by the Native American Heritage Commission (NAHC) for the purpose of avoiding, protecting, and/or mitigating impacts to cultural places when creating or amending General Plans, Specific Plans and Community Plans.

Public Resources Codes §21080.3.1 and §21080.3.2 requires public agencies to consult with California Native American tribes identified by the Native American Heritage Commission (NAHC) for the purpose of avoiding, protecting, and/or mitigating impacts to tribal cultural resources as defined, for California Environmental Quality Act (CEQA) projects.

The law does not preclude local governments and agencies from initiating consultation with the tribes that are culturally and traditionally affiliated within your jurisdiction. The NAHC believes that this is the best practice to ensure that tribes are consulted commensurate with the intent of the law.

Best practice for the AB52 process and in accordance with Public Resources Code §21080.3.1(d), is to do the following:

Within 14 days of determining that an application for a project is complete or a decision by a public agency to undertake a project, the lead agency shall provide formal notification to the designated contact of, or a tribal representative of, traditionally and culturally affiliated California Native American tribes that have requested notice, which shall be accomplished by means of at least one written notification that includes a brief description of the proposed project and its location, the lead agency contact information, and a notification that the California Native American tribe has 30 days to request consultation pursuant to this section.

The NAHC also recommends, but does not require that lead agencies include in their notification letters, information regarding any cultural resources assessment that has been completed on the area of potential affect (APE), such as:

CHAIRPERSON
Reginald Pagaling
Chumash

VICE-CHAIRPERSON
Buffy McQuillen
Yokayo Pomo, Yuki,
Nomlaki

SECRETARY
Sara Dutschke
Miwok

PARLIAMENTARIAN
Wayne Nelson
Luiseño

COMMISSIONER
Isaac Bojorquez
Ohlone-Costanoan

COMMISSIONER
Stanley Rodriguez
Kumeyaay

COMMISSIONER
Laurena Bolden
Serrano

COMMISSIONER
Reid Milanovich
Cahuilla

COMMISSIONER
Bennae Calac
Pauma-Yuima Band of
Luiseño Indians

EXECUTIVE SECRETARY
Raymond C.

Hitchcock
Miwok, Nisenan

NAHC HEADQUARTERS
1550 Harbor Boulevard
Suite 100
West Sacramento,
California 95691
(916) 373-3710
[email protected]

EXHIBIT C

1. The results of any record search that may have been conducted at an Information Center of the California Historical Resources Information System (CHRIS), including, but not limited to:
• A listing of any and all known cultural resources have already been recorded on or adjacent to the APE, such as known archaeological sites;
• Copies of any and all cultural resource records and study reports that may have been provided by the Information Center as part of the records search response; • Whether the records search indicates a low, moderate or high probability that unrecorded cultural resources are located in the APE; and
• If a survey is recommended by the Information Center to determine whether previously unrecorded cultural resources are present.

2. The results of any archaeological inventory survey that was conducted, including:
• Any report that may contain site forms, site significance, and suggested mitigation measures.

All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for public disclosure in accordance with Government Code Section 6254.10.

3. The result of the Sacred Lands File (SFL) check conducted through the Native American Heritage Commission was positive. Please contact the Pinoleville Pomo Nation on the attached list for more information.

4. Any ethnographic studies conducted for any area including all or part of the potential APE; and

5. Any geotechnical reports regarding all or part of the potential APE.

Lead agencies should be aware that records maintained by the NAHC and CHRIS is not exhaustive, and a negative response to these searches does not preclude the existence of a tribal cultural resource. A tribe may be the only source of information regarding the existence of a tribal cultural resource.

This information will aid tribes in determining whether to request formal consultation. In the event, that they do, having the information beforehand well help to facilitate the consultation process.

If you receive notification of change of addresses and phone numbers from tribes, please notify the NAHC. With your assistance we can assure that our consultation list remains current.

If you have any questions, please contact me at my email address: [email protected].

Sincerely,
Cameron Vela
Cultural Resources Analyst
Attachment

August 27, 2024 File No.: 24-0237
Katherine Schaefers, Planner
City of Ukiah
Department of Planning & Community Development
300 Seminary Avenue
Ukiah, CA 95482
re: Great Redwood Trail Ukiah - Phase 4/ Commerce Dr (39°07'57"N 123°12'01"W) to Plant Rd (39°06'44"N 123°11'33"W)/ City of Ukiah
Dear Katherine Schaefers,
Records at this office were reviewed to determine if this project could adversely affect cultural resources.

Please note that use of the term cultural resources includes both archaeological sites and historical buildings and/or structures. The review for possible historic-era building/structures, however, was limited to references currently in our office and should not be considered comprehensive.

Project Description:

Phase 4 implementation of Ukiah's Great Redwood Trail. The project (Phase 4 in attached “GRT Phasing Map”) is located within an inactive 1.9-mile segment of railroad corridor/right-of-way subject to the jurisdiction of the Great Redwood Trail Agency. The project will provide a Class 1 walking and biking facility from the existing southern terminus of the Great Redwood Trail in Ukiah at Commerce Drive (39°07'57"N 123°12'01"W) to existing municipal facilities at Plant Road (39°06'44"N 123°11'33"W) that will be improved to feature a small parking area and trailhead with seating and recreational amenities.

Previous Studies:

XX This office has record of the below previous cultural resource studies by a professional archaeologist or architectural historian for portions of the proposed project area (see recommendation below):

Report No Authors Year Ttile
S-000680 Thomas L. Jackson 1977 Archaeological Reconnaissance of the Proposed Ukiah Wastewater Facilities Improvements, Ukiah, California
S-013223 Thomas M. Origer 1991 An Archaeological Survey of the Redwood Business Park, South of Ukiah, Mendocino County, California
S-022729 Lynn Compas 2000 Cultural Resources Inventory for the California Department of Forestry and Fire Protection, Ukiah Air Attack Base Relocation Project, Mendocino County, California S-026863 Allen G. Pastron and Jonathan Goodrich 2003 Phase I Cultural Resources Evaluation of the Wastewater Treatment Plant Improvement Project Area, Located in the City of Ukiah, Mendocino County, California S-033268 Paula Boghosian 1985 Architectural and Historical Resources Inventory Report, Ukiah, California S-036144 Wesley Wills 2009 A Cultural Resources Study for the Recycled Water and Stormwater Development Project in the City of Ukiah, Mendocino County, California
S-051012 Gina Caretti and Courtney Higgins 2018 Cultural Resources Monitoring for the Redwood Fire, Mendocino County, California

EXHIBIT D

Archaeological and Native American Resources Recommendations:

XX The proposed project area has the possibility of containing unrecorded archaeological sites. Due to the lack of full coverage, combined with passage of time since the previous surveys and the changes in archaeological theory and method since that time, we recommend a qualified archaeologist conduct further archival and field study for the entire project area to identify any unrecorded archaeological resources.

XX We recommend the lead agency contact the local Native American tribe(s) regarding traditional, cultural, and religious heritage values. For a complete listing of tribes in the vicinity of the project, please contact the Native American Heritage Commission at 916/373-3710.

The proposed project area has a low possibility of containing unrecorded archaeological site(s). Therefore, no further study for archaeological resources is recommended.

Built Environment Recommendations:

XX The proposed project area contains, or is directly adjacent to P-23-003663, the Northwestern Pacific Railroad. Prior to commencement of project activities, it is recommended that this resource be assessed by a qualified professional familiar with the architecture and history of Mendocino County.

XX Since the Office of Historic Preservation has determined that any building or structure 45 years or older may be of historical value, if the project area contains such properties, it is recommended that prior to commencement of project activities, a qualified professional familiar with the architecture and history of Mendocino County conduct a formal CEQA evaluation.

Due to processing delays and other factors, not all of the historical resource reports and resource records that have been submitted to the Office of Historic Preservation are available via this records search. Additional information may be available through the federal, state, and local agencies that produced or paid for historical resource management work in the search area. Additionally, Native American tribes have historical resource information not in the California Historical Resources Information System (CHRIS) Inventory, and you should contact the California Native American Heritage Commission for information on local/regional tribal contacts.

The California Office of Historic Preservation (OHP) contracts with the California Historical Resources Information System’s (CHRIS) regional Information Centers (ICs) to maintain information in the CHRIS inventory and make it available to local, state, and federal agencies, cultural resource professionals, Native American tribes, researchers, and the public. Recommendations made by IC coordinators or their staff regarding the interpretation and application of this information are advisory only. Such recommendations do not necessarily represent the evaluation or opinion of the State Historic Preservation Officer in carrying out the OHP’s regulatory authority under federal and state law.

For your reference, a list of qualified professionals in California that meet the Secretary of the Interior’s Standards can be found at http://www.chrisinfo.org. If archaeological resources are encountered during the project, work in the immediate vicinity of the finds should be halted until a qualified archaeologist has evaluated the situation. If you have any questions please give us a call (707) 588-8455.

Sincerely,
Bryan Much
Coordinator

EXHIBIT
E

ATTACHMENT 4
1 RESOLUTION NO. 2024-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF UKIAH ADOPTING AN INITIAL STUDY AND MITIGATED NEGATIVE DECLARATION FOR THE CONSTRUCTION OF A 1.9 MULTI-MODAL TRAIL SEGMENT OF THE GREAT REDWOOD TRAIL – UKIAH (PHASE 4).

WHEREAS:

1. The City of Ukiah, as the Lead Agency, prepared an Initial Study and Mitigated Negative Declaration (ISMND) for the Great Redwood Trail – Ukiah Phase 4 Project (SCH 2024081302) under the California Environmental Quality Act (CEQA); and

2. The Lead Agency (City) consulted with all responsible agencies and trustee agencies; and

3. The Draft ISMND was circulated for public review on the California State Clearinghouse (CEQANET) website from August 29, 2024 through September 27, 2024; and

4. The Notice of Availability for the public review period for the ISMND, and the Notice of Intent to adopt the ISMND and conduct a public hearing were provided in the following manner, in accordance with the Ukiah City Code and California Environmental Quality Act (CEQA) Guidelines Section 15073: Provided to agencies and departments with jurisdiction or interest over the project on September 16, 2024; posted on the City’s CEQA webpage during the public review period; provided to property owners within 300 feet of the Project, posted at the Civic Center (glass case), and posted at the Project site 72 hours before the hearing; and

5. Based on the findings and conclusions contained in the ISMND, the proposed Project would not have environmental effects which would cause substantial adverse effects on humans, either directly or indirectly; and there is no substantial evidence in light of the whole record before the City of Ukiah (including the ISMND and any comments received) that the Project would have a significant effect on the environment; and

6. The ISMND reflects the City’s independent judgment and analysis of the potential environmental effects of the Project.

NOW, THEREFORE, BE IT RESOLVED that:

1. The above recitals are true and correct, and incorporated herein by this reference.

2. The City Council hereby adopts the Initial Study and Mitigated Negative Declaration which has been completed in compliance with the California Environmental Quality Act (CEQA).

BE IT FURTHER RESOLVED that:

1. The ISMND and record of proceedings of the decision on the Project are available for public review at the City of Ukiah Community Development Department, Ukiah Civic Center, 300 Seminary Avenue, Ukiah, CA.

2. On October 16, 2024, the City Council held a public hearing to receive public comment and consider approval of the ISMND for the Project. The ISMND was approved by the City Council via Resolution and reflects the City Council’s independent judgment and analysis.

ATTACHMENT 5
2 PASSED AND AOPTED this 16th day of October, 2024, by the following roll call vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
_______________________________
Douglas F. Crane, Vice Mayor
ATTEST:
________________________________
_ Araceli Sandoval, Acting Clerk

Great Redwood Trail (GRT) – Ukiah (Phase 4)
CEQA Initial Study – Mitigated Negative
Declaration
City of Ukiah
Department of Community Development
Planning Division
10/16/2024

Phase 4 Overview
• Design Plans approved
May 2024
• Connects Commerce
Drive to Plant Road
• Includes parking area
and recreational
amenities
• Provides multiple
pedestrian access points
Commerce Ln. to Norgard St.

Norgard St. to Plant Rd.

GRT – Ukiah Park Master Plan (2020)

Environmental Review • CEQA review identified
issues: grading, drainage,
tree removal, wetlands
• Adjustments made to
mitigate impacts
• Coordination with
multiple regulatory
agencies
• All necessary permits
obtained
Commerce Lane,
looking south
Plant Road,
looking north

Recommendation
Adopt the resolution adopting an Initial Study and
Mitigated Negative Declaration for the construction
of a 1.0-mile multimodal trail segment of the Great
Redwood Trail (GRT) - Ukiah (Phase 4) as presented
during the public hearing.

Agenda Item No: 13.a.

MEETING DATE/TIME: 10/16/2024

ITEM NO: 2024-522

AGENDA SUMMARY REPORT
SUBJECT: Council will Receive an Update on the Public Benefits Program, Consider Approving Revised Energy Efficiency Programs and Rebates, and Consider a Budget Amendment in the Amount of $30,000 for Energy Efficiency Rebates.

DEPARTMENT: Electric Utility PREPARED BY: Diann Lucchetti, Administrative Secretary PRESENTER: Cindy Sauer, Electric Utility Director
ATTACHMENTS:

1. Residential-Commercial Rebates Charts

2. CARES Program Credits and Rebate Details

3. Ukiah Res DI and Comml DIY Lghtng Prgrm PSA and SOW

4. 13a Presentation given at meeting
Summary: The Electric Utility will provide an overview of the Department's updated Public Benefit Programs and revised rebates for City Council's consideration and approval. Additionally, Council will consider the approval of a budget amendment in the amount of $30,000 for energy efficiency rebates.

Background: Ukiah Electric Utility administers the Public Benefit (PB) Program established under California State Assembly Bill 1890 (AB1890) in 1996. The legislation mandates that electric utilities implement programs benefiting customers in four key areas: Low-Income Assistance, Energy Conservation, Renewable Energy, and Research, Development & Demonstration projects. AB1890 also requires that 2.85% of gross electric energy sales be allocated to these programs.

To ensure optimal use of the available funds, the Electric Utility collaborates closely with its program administrator, Efficiency Services Group (ESG), in designing, implementing, and managing energy efficiency and renewable energy programs for customers.

Discussion: Public Benefit funds are allocated to support Energy Efficiency Programs and Services, as well as Low-Income Billing Assistance. Below is a summary of the existing programs:

The Energy Efficiency Programs and Services are designed to help customers reduce their energy consumption and lower their electric bills. The Utility regularly reviews these programs to ensure they provide meaningful opportunities for customers to reduce energy usage through rebates and other initiatives. In 2023, these programs resulted in 159,395 kilowatt-hours (kWh) of energy savings, a significant increase from 2022’s 77,745 kWh. This improvement is largely due to the second phase of the Direct Install Program, which was approved by the Council in August 2022. A detailed list of available rebates for Ukiah Electric customers is provided for the Council's review (Attachment 1).

The Low-Income Billing Assistance Program offers two options: the Senior Citizen Monthly Discount and the Non-Senior Household Monthly Discount, both designed to help low-income customers manage their electric bills. The City's discount is a fixed amount, based on income level. Due to recent rate increases, Staff recommends raising the discount by 25% for eligible customers (see Attachment 2), which will help those most affected by the higher rates. Customers can also apply for state funding, but it cannot be used simultaneously with these discounts. Increased use of state programs has reduced the Utility's expenditures, making sufficient

funds available for the proposed increase. Ukiah dedicates over 40% of its Public Benefits budget to lowincome assistance, a significantly higher proportion than other utilities.

The Electric Yard Equipment Rebate program, approved by Council on June 21, 2023, aimed to reduce carbon emissions by offsetting the cost of new electric yard equipment. Unfortunately, abuse of the program has been identified, with customers allowing individuals outside of city limits to apply using their Ukiah address. This has led to the rebate benefiting people in areas like Willits, Ft. Bragg, and even outside the county, making management of the program increasingly difficult. As a result, Staff has reconsidered the program for rebate items that are not installed in the home and recommends discontinuing the program.

The Residential Direct Install (DI) Program, which aims to deliver energy savings while enhancing the customer experience with the Electric Utility. This program provides immediate energy-saving measures, identifies additional opportunities for efficiency, and raises awareness of Ukiah's Energy Efficiency Programs.

Historically, the program has focused on low-income customers who already participate in the City’s bill assistance programs. The City's low income customers have had the opportunity to participate in this program in FY23 and FY24. Staff proposes opening participation to all income levels on a first-come, first-served basis, with customers contacting ESG to enroll. Staff recommends allocating $30,000 toward this program.

The Commercial DIY Lighting Program helps business customers upgrade inefficient lighting by providing LED fixtures at no cost. Customers are responsible for installation, which they can perform themselves or hire an electrician to complete. ESG will verify all installations. This program has been successful in neighboring cities, encouraging participation from businesses that might not have engaged in Ukiah's standard lighting program. Benefits include enhanced customer relationships, significant energy and cost savings, reduced maintenance costs, improved security, and progress toward AB2021 energy efficiency targets. This opportunity will initially be offered to small, locally owned commercial customers. Staff recommends allocating $70,000 for this program.

These Direct Install and Commercial Lighting programs not only help customers reduce their energy bills but also support the Utility's broader goals for energy efficiency and decarbonization. They contribute to efforts to restore a safe climate by incentivizing energy-efficient upgrades in both residential and commercial properties.

All programs are offered as budget allows and may be adjusted based on funding availability. Currently, there is $100,000 budgeted for energy efficiency programs and rebates. Staff is requesting a budget amendment in the amount of $30,000, to ensure funding for both programs and the standard energy efficiency rebates.

Upon Council approval, the Utility will move forward with implementing these initiatives. Please refer to Attachment 3 for the detailed Scope of Work for both the Residential and Commercial Direct Install Programs.

Recommended Action: Approve revised customer programs and rebates, and a budget amendment in the amount of $30,000 for energy efficiency rebates.

BUDGET AMENDMENT REQUIRED: No
CURRENT BUDGET AMOUNT: 80626450.52135 $342,500
PROPOSED BUDGET AMOUNT: N/A
FINANCING SOURCE: 80626450; Public Benefits Fund
PREVIOUS CONTRACT/PURCHASE ORDER NO.: N/A
COORDINATED WITH: N/A
DIVERSITY-EQUITY INITIATIVES (DEI): Goal 2 – Eliminate internal and external barriers to Diversity, Equity, and Inclusion within the systems of our organization.

CLIMATE INITIATIVES (CI): 1c – Install energy-efficient outdoor lighting. 1f – Continue to explore rebate programs.

GENERAL PLAN ELEMENTS (GP):GP-A4 - Public Facilities, Services, and Infrastructure Element

Form No. CATEGORY / MEASURE BLDG VINTAGE BLDG TYPE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Screw-In or Pin-Based LED (up to 22W) New / Existing Single-Family / Multifamily / Manufactured Homes Standard (Incandescent or Halogen) Unit ENERGY STAR® Certified Unit (up to 22W) Bulb $5.00 ENERGY STAR® Certified and bring old string into
the office
Up to 100% of
purchase price
ENERGY STAR® Certified Unit $15.00
Ceiling Fan New / Existing Single-Family / Multifamily / Manufactured Homes Standard Efficiency Unit ENERGY STAR® Certified Unit Fan $25.00 16 SEER (15.3 SEER2) and 13 EER (12.5 EER2) $75.00
17 SEER (16.2 SEER2) and 13.3 EER (12.8 EER2) $100.00
Ductless Mini-Split AC Existing Single-Family / Manufactured Homes Standard Efficiency Unit 16 SEER (15.3 SEER2) and 13 EER (12.5 EER2) Ton $100.00 Air Source Heat Pump (includes ductless) Existing Single-Family / Manufactured Homes Standard Efficiency Unit 16 SEER (15.3 SEER2) and 13 EER (12.5 EER2) Ton $300.00 Smart Thermostats Existing Single-Family / Manufactured Homes Central AC or Heat Pump with programmable or non-programmable thermostat Central AC or Heat Pump with ENERGY STAR® Certified Smart Thermostat Unit $50.00 RH & RCDS Duct Sealing with Duct Blaster Pre- and Post- Test Existing Single-Family Central AC with Existing Duct System with Excessive Leakage of Conditioned Air into Unconditioned Space Central AC with Existing Duct System Sealed and Repaired and Overall CFM Reduction of 20% or Greater System $75.00 Approved Electric-CARE customer E-Bike New / Existing Single-Family / Manufactured Homes Income approved applicants only. Intended to
replace trips otherwise taken by automobile: Ebikes purchased solely for recreation do not qualify (i.e. Mountain Bikes).

New E-Bike; maximum one E-Bike rebate per
account Bike $700.00
E-Bike purchased at a local Ukiah retailer New / Existing Single-Family / Manufactured Homes Intended to replace trips otherwise taken by automobile: E-bikes purchased solely for recreation do not qualify (i.e. Mountain Bikes). New E-Bike; maximum one E-Bike rebate per account Bike $400.00 E-Bike purchased from a retailer outside of Ukiah New / Existing Single-Family / Manufactured Homes Intended to replace trips otherwise taken by automobile: E-bikes purchased solely for recreation do not qualify (i.e. Mountain Bikes). New E-Bike; maximum one E-Bike rebate per account Bike $300.00E-Bike conservation kit New / Existing Single-Family / Manufactured Homes Intended to replace trips otherwise taken by automobile: E-bikes purchased solely for recreation do not qualify (i.e. Mountain Bikes). New E-Bike; maximum one E-Bike rebate per account Bike $50.00 EV-C Home Level 2 Charger New / Existing Single-Family / Manufactured Homes No existing home charger; Pre-approval is required to ensure eligibility and availability of funds Level 2 Qualifying Charger Charger $500.00 Seasonal Energy Efficiency Rating (SEER/2), Energy Efficiency Ratio (EER/2) and Heating Seasonal Performance Factor (HSPF/2) represent the efficiency ratings 12,000 Btuh = 1 Ton of Cooling
Cubic Feet per Minute (CFM) represents the amount of airflow EV-B

RESIDENTIAL HVAC

RESIDENTIAL REBATE CHART
LED Holiday Lights New / Existing Single-Family / Multifamily / Manufactured Homes RL Standard (Incandescent) Unit 70 Lamp String

RESIDENTIAL LIGHTING
RH
Standard Efficiency Unit Ton Single-Family / Manufactured Homes Central AC Existing

RESIDENTIAL ELECTRIC VEHICLES
Attachment 1

Ceiling/Attic Insulation Existing Single-Family / Multifamily Central AC or Electric Space Heat with Insulation Less Than or Equal To R-19 Central AC or Electric Space Heat with Insulation R- 30 or Greater Sq/Ft $1.00 Wall Insulation Existing Single-Family / Multifamily Central AC or Electric Space Heat with Insulation R-0 Central AC or Electric Space Heat with Insulation R- 13 or Greater Sq/Ft $0.50 Solar Attic Fan Existing Single-Family / Multifamily Hard wire or plug-in Electric-Powered Unit Solar-Powered Unit (before and after photos showing disconnected electric fan are required) CFM $0.20 Replacement Windows Existing Single-Family / Multifamily Central AC or Electric Space Heat with Single or Dual-Pane Windows Central AC or Electric Space Heat with Replacement Windows with U-Value 0.32 or Less and SHGC 0.25 or Less Sq/Ft $3.00 RW & RWAS Air Sealing with Blower Door Pre- and Post- Test Existing Single-Family Central AC with Air Leakage of 0.35 ACH or Greater Central AC with Building Air Gaps Sealed and Overall ACH Reduction of 30% or Greater Home $25.00 NC New Construction New Single Family & Multi Family Title 24 minimum required to meet code Rebate is based on annual kWh's saved over Title 24 minimum, documented by Title 24 report kWh $0.20 Clothes Washer New / Existing Single-Family / Multifamily / Manufactured Homes Electric Water Heat with Standard Efficiency Unit Electric Water Heat with ENERGY STAR® Certified Unit with Integrated Modified Energy Factor (IMEF) of 2.06 minimum Unit $100.00 Clothes Dryer New / Existing Single-Family / Multifamily / Manufactured Homes Standard efficiency electric unit Electric ENERGY STAR® Certified Unit with 2.68 Combined Energy Factor (CEF) minimum Unit $100.00 Standard Size Dishwasher New / Existing Single-Family / Multifamily / Manufactured Homes Electric Water Heat with Standard Size (8+ place settings) and Efficiency Unit Electric Water Heat with ENERGY STAR® Certified Unit with 270 kWh maximum Annual Energy Use Unit $50.00 Induction Range Existing Single-Family / Multifamily / Manufactured Homes Existing natural gas range Electric oven with Induction cooktop or standalone Induction cooktop (before and after photos required to document existing gas appliance) Unit $750.00 Portable Induction Cooktop New / Existing Single-Family / Multifamily / Manufactured Homes Existing electric resistance range or cooktop Portable Induction cooktop Unit $100.00 Refrigerator New / Existing Single-Family / Multifamily / Manufactured Homes Standard Size Efficiency Unit >7.75 cu. ft. Compact < 7.75 cu. ft. are not eligible. ENERGY STAR Certified Unit >7.75 cu. ft. Unit $100.00 Forced Air Electric Space Heat with Electric
Resistance Unit with EF 0.89 or Lower
ENERGY STAR® Certified Minimum 2.8 Uniform
Energy Factor (UEF) Unit $150.00
Heat Pump Space Heat with Electric Resistance
Unit with EF 0.89 or Lower
ENERGY STAR® Certified Minimum 2.8 Uniform
Energy Factor (UEF) Unit $500.00
Smart Power Strip New / Existing Single-Family / Multifamily / Manufactured Homes Single Switch Unit without Control Mechanism Smart Unit with Control Device Unit $15.00Variable Speed Pool Pump Existing Single-Family Standard Unit 1 hp or Greater Variable Speed Unit with Variable Speed Unit Control no greater than 3 HP Unit $400.00 V_05/23

RESIDENTIAL WEATHERIZATION
Heat Pump Water Heater New / Existing Single-Family / Multifamily / Manufactured Homes Some measures may be subject to additional installation and specification requirements - Call (707) 467-5700 for more information.

R-Value represents resistance to heat transfer
All rebates are limited to 100% of purchase/installation cost and $2000 per measure

RESIDENTIAL EQUIPMENT
RE-N
Additional Terms and Conditions
All rebates are subject to availability of funds and may be changed or discontinued at any time.

All rebate requests must be received within 6 months of purchase/installation.

Solar Heat Gain Coefficient (SHGC) represents the solar transmittance Air Changes per Hour (ACH) represents the amount of air leakage RW

Form No. INSULATION BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Attic Insulation Exisitng R-19 or Less Minimum R-44 Sq/Ft $1.00 Form No. HVAC BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Central AC: <65,000 Btuh Existing Standard Efficiency Unit 16 SEER (15.3 SEER2) minimum Ton $400.00 Central AC: 65,000 and <134,000 Btuh Existing Standard Efficiency Unit 12 EER (11.5 EER2) and 19 IEER minimum Ton $75.00 Central AC: 135,000 and <239,000 Btuh Existing Standard Efficiency Unit 12 EER (11.5 EER2) and 17.5 IEER minimum Ton $50.00 Central AC: 240,000 and 759,000 Btuh Existing Standard Efficiency Unit 10.8 EER (10.3 EER2) minimum Ton $25.00Heat Pump: <55,000 Btuh Existing Standard Efficiency Unit 16 SEER (15.3 SEER2) minimum Ton $200.00Heat Pump: 55,000-64,000 Btuh Existing Standard Efficiency Unit 16 SEER (15.3 SEER2) minimum Ton $125.00 Heat Pump: 65,000-239,000 Btuh Existing Standard Efficiency Unit 12 EER (11.5 EER2) minimum Ton $100.00 Heat Pump: 240,000 Btuh Existing Standard Efficiency Unit 10 EER (9.6 EER2) Ton $125.00 Package Terminal Air Conditioner, Hotel/Motel Existing Standard Efficiency Unit <7,000 Btuh - Min 11.29 EER (10.8 EER2)
7,000-15,000 Btuh - Min 10.27 EER (9.8 EER2)
>15,000 Btuh - Min 9.29 EER (8.9 EER2)
Ton $350.00
Package Terminal Heat Pump, Hotel/Motel Existing Standard Efficiency Unit <7,000 Btuh - Min 11.17 EER (10.7 EER2) 7,000-
15,000 Btuh - Min 10.15 EER (9.7 EER2) >15,000 Btuh - Min 9.13 EER (8.7 EER2) Ton $175.00
Form No. ELECTRIC VEHICLE CHARGER BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Workplace or Public Level 2 Single Hose Exisitng / New No existing EV charger. Pre-approval is required to ensure eligibility and availability of funds. Level 2 Qualifying Charger Unit $3,000.00 Workplace or Public Level 2 Dual Hose Exisitng / New No existing EV charger. Pre-approval is required to ensure eligibility and availability of funds. Level 2 Qualifying Charger Unit $4,000.00 Form No. REFRIGERATION BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Ice Maker, Air-Cooled New or Existing Standard efficiency unit air-cooled ice making machine Qualifying models must meet ENERGY STAR® Version 3.0 specifications and be listed in the California Energy Commission database. Valid for machines generating 60 grams (2 oz.) or lighter ice cubes, as well as flaked, crushed, or fragmented ice machines. Only air cooled machines are eligible. Performance data is based on AHRI Standard 810. See Qualified Products List.

Unit $200.00
Glass or Solid-Door Refrigerator New or Existing Standard efficiency unit Qualifying models must meet ENERGY STAR® Version 4.0 specification and must be listed in the California Energy Commission database. Products on this list qualify for purchases from the date they are added until the date they are removed. See Qualified Products List.

Unit $250.00
Glass or Solid-Door Freezer New or Existing Standard efficiency unit Qualifying models must meet ENERGY STAR® Version 4.0 specification and must be listed in the California Energy Commission database. Products on this list qualify for purchases from the date they are added until the date they are removed. See Qualified Products List
Unit $250.00
EC Motor for Walk-In New or Existing Shaded-Pole Evaporator Fan Motor High Efficiency EC Motor with 66% Efficiency or Greater Motor $75.00 EC Motor for Reach-In New or Existing Shaded-Pole Evaporator Fan Motor High Efficiency EC Motor with 66% Efficiency or Greater Motor $50.00 EV-C

COMMERCIAL REBATE CHART
CH
Energy Efficiency Ratio (EER/2), Seasonal Energy Efficiency Ratio (SEER/2), Integrated Energy Efficiency Ratio (IEER), and Heating Seasonal Performance Factor (HSPF/2) represent the efficiency ratings 12,000 Btuh = 1 Ton of Cooling
CR

EC Motor with Controller for Walk-In New or Existing Shaded-Pole Evaporator Fan Motor with No Controls High Efficiency EC Motor with 66% Efficiency or Greater and Controller Motor $100.00 Strip Curtains for Walk-In New or Existing Existing Doorway Between Refrigerated and Non- Refrigerated Spaces without Infiltration Barrier New Strip Curtains Sq Ft of Door $5.00 New Refrigerated Case New or Existing Existing Refrigerated Display Case with No Doors New Refrigerated Display Case with Doors, EC Evaporative Fan Motors and T8 Lamps with Electronic Ballast Lin Ft of Case $125.00 Auto Door Closer for Walk-In New or Existing Main Walk-In Door of Walk-In Cooler or Freezer without Auto-Closer New Auto-Closer Unit $100.00Anti-Sweat Heater Control New or Existing Refrigerated Display Case with Anti-Sweat Heaters without Controller Refrigerated Display Case with Anti-Sweat Heaters with Controller Lin Ft of Case $50.00 Vending Machine Controller New or Existing Standard Unit with No Controls Unit with Occupancy Sensor Controller Installed Unit $125.00 Form No. APPLIANCES BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Electric Combination Oven Existing Construction Standard Electric Combination Oven - Various Sizes of pans for Half and Full Size Ovens Qualifying electric combination oven/steamer models must have a tested steam mode cooking energy efficiency of ≥ 50% and convection mode cooking energy efficiency of ≥ 70% utilizing ASTM F2861, and meet the idle rate requirements in Table 1. (see below) ASTM F2861 Idle Rate Requirements for Commercial Comination Oven/Steamers. See Qualified Products List.

Cavity $2,500 per Cavity
Electric Convection Oven Existing Construction Standard Electric Convection Oven - Half and Full Size Electric ovens must meet ENERGY STAR specifications and have a tested heavy load potato cooking energy efficiency of 71% or more, utilizing ASTM Standard F1496.

Full-size electric ovens must have an idle rate of 1.6 kW or less. Half-size electric ovens must have an idle rate of 1.0 kW or less. See Qualified Products List.

Oven
$600 for Half size
$750 for Full size per
cavity
Electric Deck Oven Existing Construction Standard, Full Size Electric Deck Oven Qualifying electric deck ovens must have a tested heavy load cooking energy efficiency of ≥ 60% and an idle energy rate ≤ 1,300 W, utilizing ASTM Standard F1965. Multiple-deck oven configurations are paid per qualifying oven deck. See Qualified Products List.

Cavity $1,500 per cavity
Electric Conveyor Toaster Existing Construction Standard performance electric conveyer toaster Only countertop and standalone machines are eligible. Qualifying electric conveyor toasters must have an energy per sandwich less than or equal to 3.75 W/sandwich utilizing ASTM Standard F2380. See Qualified Products List. Unit $600 per unit Electric Fryer Existing Construction Electric Fryer < and > 18 inch Vats Qualifying electric fryer models (vat width < 18-inches) must meet ENERGY STAR specifications for energy efficiency and have a tested heavy load cooking energy efficiency of 83% and an idle energy rate ≤ 800 W utilizing ASTM Standard F1361.

Qualifying electric fryer models (vat width ≥ 18-inches) must meet ENERGY STAR specifications for energy efficiency and have a tested heavy load cooking energy efficiency of 80% and an idle energy rate ≤ 1,100 W utilizing ASTM Standard F2144.

See Qualified Products List.

Unit $650 per vat
Electric Griddle Existing Construction
Electric Griddle - Need base case info for
Cooking Efficiency; Idle Energy Rate (KW);
Preheat Energy (kWH); Production Capacity
(Lb/Hr)
Qualifying electric griddle models must have a tested heavy-load cooking energy efficiency of 70% or greater and an idle energy rate of 355 Watts per ft² of cooking surface or less, utilizing ASTM Standard F1275. See Qualified Products List.

Ft $200 per ft (nominal width)
Electric Insulated Hot Food Holding Cabinet Existing Construction Half Size (10 Cu Ft) or Full Size (25 Cu Ft) Measure does not include cook and hold equipment. All measures must be electric hot food holding cabinest that are fully insulated. Qualifying full-size cabinets must have an idle energy rate ≤ 25 W/cu.ft. and qualifying half-size cabinets must have an idle energy rate ≤ 35 W/cu.ft. in accordance with ASTM F2140. See Qualified Products List.

Unit $200 for 1/2 size $750 for full size
Electric Steam Cooker Existing Construction Electric Steam Cooker various pan configurations Qualifying electric steam cooker models must have a tested heavy load potato cooking energy efficiency of ≥50% and meet the idle rate requirements in Table 2 utilizing ASTM Standard F1484. See Qualified Products List. Unit $2,000 per cavity Dishwasher, Under-Counter Existing Construction Existing Under-Counter standard efficiency dishwasher Qualifying high temperature sanitizing under counter dishwashers must meet ENERGY STAR® Version 3.0 specifications and have an idle energy rate ≤ 0.30 kW, a washing energy of ≤ 0.35 kWh/rack, and a water consumption ≤ 0.86 gal/rack to meet Tier 1 requirements. High temperature sanitizing under counter machines must have an idle energy rate ≤ 0.30 kW, a washing energy ≤ 0.30 kWh/rack, and a water consumption ≤

0.73 gal/rack to meet Tier 2 requirements. Qualifying low temperature sanitizing under counter dishwashers must meet ENERGY STAR® Version 3.0 specifications and have an idle energy rate ≤ 0.25 kW, a washing energy of ≤ 0.15 kWh/rack, and a water consumption ≤ 1.19 gal/rack to meet Tier 1 requirements. Low temperature sanitizing under counter machines must have an Tier 2 requirements. idle energy rate ≤ 0.25 kW, a washing energy ≤ 0.13 kWh/rack, and a water consumption ≤ 1.01 gal/rack to meet Tier 2 requirements. See Qualified Products List.

Unit $500 per unit
CA

Dishwasher, Door-Type Existing Construction Existing Door-Type standard efficiency dishwasher Qualifying high temperature sanitizing door-type dishwashers must have an idle energy rate ≤ 0.55 kW, a washing energy ≤ 0.35 kWh/rack, and a water consumption ≤ 0.76 gallons/rack per the ENERGY STAR test method. Qualifying low temperature sanitizing door-type dishwashers must have an idle energy rate ≤ 0.30 kW, a washing energy ≤ 0.15 kWh/rack, and a water consumption ≤ 1.00 gallons/rack per the ENERGY STAR test method. See Qualified Products List.

Unit $500 per unit
Hand Wrap Machine Existing Always-on hand wrap machine
Qualifying models must be from the utility qualified products list. On-demand machine must utilize a mechanical or optical sensor to activate the largest heating element. See Qualified Products List.

Unit $250 per unit
Induction Range Existing Existing natural gas range Electric oven with Induction cooktop or standalone Induction cooktop (before and after photos required documenting existing gas appliance) Unit $750.00Portable Induction Cooktop New / Existing Existing electric resistance range or cooktop Portable Induction cooktop Unit $100.00Multifamily Clothes Washer, In Tenant Unit New or Existing Electric Water Heat with Standard Efficiency Unit Electric Water Heat with ENERGY STAR Unit with minimum 2.06 Modified Energy Factor and maximum 4.3 Integrated Water Factor Unit $100.00 Multifamily Clothes Washer, In Common Area New or Existing Electric Water Heat with Standard Efficiency Unit Electric Water Heat with ENERGY STAR Unit with minimum 2.20 Modified Energy Factor and maximum 4.0 Integrated Water Factor Unit $300.00Kitchen Demand Ventilation Control New or Existing Type I Standard Unit with No Control Type I Unit with VFD Control Exhaust Fan Hp $450.00 Form No. ELECTRONICS BUILDING VINTAGE EXISTING CONDITION FINAL CONDITION REBATE UNIT REBATE PER UNIT Uninterrupted Power Supply New or Existing Standard Unit ENERGY STAR Certified Unit Unit $175.00Plug-Load Occupancy Sensor New or Existing Standard Unit with No Control Mechanism Occupancy Sensor-Controlled Unit Unit $20.00Smart Power Strip New or Existing Standard Unit with No Control Mechanism Smart Unit Unit $25.001-For-1 or Other Upgrades Varies Varies Annual kWh $0.15 N/A Special Projects with Pre-Approval Varies Varies Project Varies V_05/23
Some measures may be subject to additional installation and specification requirements - Call (707) 467-5700 for more information.

LIGHTING
CUSTOM
Additional Terms and Conditions
All rebates are subject to availability of funds and may be changed or discontinued at any time.

All rebate requests must be received within 6 months of purchase/installation.

Commercial Rebates are limited to 70% of job cost up to $7,500 per project.

CE

Attachment 2
Current Programs Less than 100%
of *FPIG
101% - 150%
of *FPIG
151% - 200% of
*FPIG Payments
Senior Citizen Monthly Discount $40 $30 $20 Monthly bill credits Non-Senior Household Monthly Discount $30 $20 $10 Monthly bill credits Proposed Programs Less than 100%
of *FPIG
101% - 150%
of *FPIG
151% - 200% of
*FPIG Payments
Senior Citizen Monthly Discount $50 $37.50 $25 Monthly bill credits Non-Senior Household Monthly Discount $37.50 $25 $12.50 Monthly bill credits Ukiah C.A.R.E.S. Program Assistance Levels

1 Attachment 3

EXHIBIT A

RESIDENTIAL AND COMMERCIAL DIRECT INSTALL

PROGRAM

SCOPE OF WORK
Efficiency Services Group (ESG) is pleased to present this Scope of Work to the City of Ukiah (Ukiah) for a Residential Income-Qualified (IQ) Direct Install (DI) Program (Residential IQ DI Program) and a Commercial DIY and Lighting Program (Commercial Program). The scope of work is divided into two sections below.

The budget for this Scope of Work is $100,000: allocated as $30,000 for residential and $70,000 for commercial. Allocations can be adjusted with written notice from the City of Ukiah.

1.RESIDENTIAL DIRECT INSTALL PROGRAM
The goal of the Residential Direct Install (DI) Program is to deliver energy savings and provide a great customer experience with Ukiah. The program will provide customers with instant savings measures, identify opportunities for additional major measures, and increase customer awareness of Ukiah’s Energy Efficiency programs. In the past, this program has focused on lower-income customers who are currently participating in Ukiah’s bill assistance programs. ESG proposes to expand participation to any income level on a first-come first-served. This will require participants to contact ESG to sign up for the service. The funding mechanism for this program is Ukiah’s Public Benefit Fund.

The Residential Direct Install Program provides all residential customers with a program that delivers instant energy savings and benefits and is not cost-restrictive for their participation. ESG recommends the installation of energy and water-saving measures to deliver real savings on customer electric, water, and sewer costs. These measures can be installed in the customer’s home at no charge to them while helping Ukiah reach their energy savings goals. In addition, ESG recommends completing a snapshot audit while in the customer’s home.

2 Benefits
ESG believes that offering this program will provide the following benefits to Ukiah:
• Strengthen residential customer relationships by providing a great customer experience • Provide energy and cost savings to targeted customers • Serve customers that are not traditionally able to participate in PB programs • Collect information and site data to be used in future offerings and targeted marketing Customer Eligibility
The program will be open to Ukiah residential customers. ESG will coordinate with Ukiah to finalize a strategy to approach customers and generate sign-ups for the program.

Pricing
The fees for the DI Program are on a per-measure-installed basis. Prices include all labor, materials and expenses associated with installation of the products and delivery of services. Fees for direct installed measures and snapshot audits are shown in the following table. Additional measures can be added to the program with prior approval.

Measure Cost Unit
Fee per
Cost
Unit
kWh Saved per
Unit
Home Snapshot Audit Audit $40 0
Screw-In LEDs (DI) Lamp $18
Varies based on
wattage and
location
installed
Standard Showerhead 1.5 GPM (DI) Showerhead $20 87.8
Handheld Showerhead 1.5 GPM (DI) Showerhead $30 87.8
Thermostatic Shower Valve (DI) Valve $50 72.1
Combo TSV and Showerhead 1.5 GPM (DI) Unit $70 136
Faucet Aerator (DI) Kitchen 1.5 GPM Aerator $5 71.8
Faucet Aerator (DI) Bathroom 1.0 GPM Aerator $5 81.7
Advanced Power Strips (DI) Power Strip $90 64.33
Door Sweeps (DI) Door Sweep $75 25.58
Door Sweeps (Requested Leave Behind) Door Sweep $30 12.79 Smart Thermostat (Requested Leave Behind) Google Nest Thermostat $160 57.2 Note: DI: Measures are installed by an Energy Efficiency Advisor Requested Leave Behind: Measures are left with the customer for the customer to install

3 Measure Descriptions
Home Snapshot Audit
While in the customer's home installing products, Energy Efficiency Advisors (EEAs) will acquire the customer demographic and site/equipment data, which will help develop and market programs.

LED Lamps (screw-in based)
All LED lamps, reflectors, globes, and candelabras offered in the program will be UL-listed and ENERGY STAR-certified.

Advanced Power Strips
Advanced Power Strips (APS) utilize infrared, motion detection, and load sensing paired with a configurable countdown timer to manage both active and standby power loads for controlled devices connected to the device. If the timer is not reset by activity, the power strip turns off power to that connected device eliminating its “phantom” or standby power usage.

High-Performance Showerheads
High-performance showerheads reduce the amount of water used to shower, saving costs on water, sewer, and energy. Only customers with electric water heating will qualify for this measure.

Thermostatic Shower Valves
Thermostatic shower valves are designed to reduce water and energy waste by reducing the water flow of a shower to a trickle once the water reaches 95 degrees. This prevents the waste that occurs when people leave the shower running to get warm before they get in.

Thermostatic Shower Valve and Showerhead Combination
This unit combines the valve and high-performance 1.5 gallons per minute showerhead. This is available to homes with electric water heaters only.

Faucet Aerators
High-performance aerators reduce the flow rate of water without compromising on pressure, which means less water is heated and used overall. This reduction in hot water usage directly translates to lower energy consumption, as less energy is needed to heat the water. Only homes with electric hot water will qualify.

Door Sweeps
Adding door sweeps to exterior doors with air gaps is an effective way to reduce energy waste. Door sweeps seal the gap between the bottom of the door and the threshold, preventing drafts from entering and conditioned air from escaping. This helps maintain a consistent indoor temperature, reducing the need for heating and cooling systems to work harder. As a result, you can save on energy costs and improve the overall efficiency of your home. Plus, door sweeps can also help keep out dust, insects, and noise, making homes more comfortable.

Smart Thermostats
Replacing programmable and manual thermostats with smart thermostats is a great way to save energy.

Smart thermostats learn your schedule and preferences, automatically adjusting the temperature to

4 optimize energy use. They can detect when you’re home or away and adjust the settings accordingly, thereby ensuring you’re not heating or cooling an empty house.

Professional Installations
All DI services will be performed by experienced staff, with an emphasis on providing a great customer experience.

Customer Satisfaction
The program is designed to be easy for customers to participate in, and all staff are focused on providing a great customer experience. ESG and our partners understand the importance of emphasizing to the customer that the program is coming from Ukiah and using the program experience to help Ukiah build and strengthen its relationships with its customers.

Reporting and Invoicing
ESG thoroughly understands the SB1037 reporting requirements for utility energy efficiency programs.

DI program activity will be included in Ukiah’s monthly EE program reports.

Marketing Activities
ESG will work with Ukiah to develop marketing materials for the Residential Program. This may include a letter informing the customers about the Residential Program and requesting that they call in to schedule an appointment, a flyer discussing the benefits of the measures installed, and any other promotional materials as agreed upon to be distributed by the EEAs.

Implementation Partner
ESG will serve as the program administrator. We plan to utilize RD Energy Solutions in the implementation of the program. ESG has had a relationship with this partner for several years and has successfully delivered utility programs with them.

RD Energy Solutions is the installation partner for our commercial and residential direct install programs.

ESG and RD have partnered to implement EE programs for over twenty utilities in California and the Northwest. RD will perform the following tasks:
• Contacting customers to schedule DI visits
• Ordering product needed to complete DI installs
• Installing DI measures
• Entering DI activity for each home served
• Providing all DI measure install data to ESG for each home served Payment Schedule
ESG will submit invoices to Ukiah monthly, accompanied by detailed reports on services performed for each customer served. ESG’s payment terms are Net 20 days. If an invoice error is identified by Ukiah, a corrected invoice will be submitted by ESG within five business days of receiving notification from Ukiah.

5 2. COMMERCIAL DIY LIGHTING PROGRAM
The goal of the Commercial DIY Lighting Program is to help business customers upgrade their inefficient lighting.

The Program is designed to have a focused, efficient approach to helping customers upgrade their lighting. Fixtures are provided to the customer at no cost and the customer is responsible for the installation. Customers may install the fixtures themselves or hire an electrician to install the fixtures for them. ESG has found that most customers hire an electrician to install the fixtures. ESG verifies the installation of all LED fixtures before invoicing Ukiah. The program has proven to effectively persuade some customers to pay for the installation that would otherwise not participate in Ukiah’s standard lighting program.

ESG believes that the Program will provide the opportunity for Ukiah to:
• Continue to strengthen and build on the relationships established with customers through the standard rebate program
• Afford significant energy and cost savings to targeted customers • Reduce customer maintenance costs and increase customer security • Contribute savings toward AB2021 targets
Mix of Measures
The Program includes options for LED upgrades to existing exterior and interior fixtures. The Program will include the following measures:
• LED Screw-In Base Retrofit Lamps: Screw directly into existing screw-in base HID fixtures.

Requires rewiring the fixture to bypass the existing ballast. • LED Canopy Lighting: Replace existing HID fixtures commonly found in gas station island canopies and building overhangs.
• LED Pole/Wall Lighting: LED Shoebox and Cobra head fixtures replace existing HID fixtures commonly found throughout commercial parking lots, roadways, auto dealerships, and building perimeters.
• LED Wall packs: replace pre-existing HID wall packs found on commercial buildings. • LED Commercial New Fixture replacements for existing T5/T8/T12 fluorescent lighting, such as wraparounds, strip/channels, troffers, etc.
• LED Retrofit Lamps and Ballasts to replace existing T8/T12 fluorescent lighting, while keeping the original housing in place and replacing only the internal lamps and ballasts.

Subscribing the Program
Energy Efficiency Advisors (EEAs) visit customer sites, explain the program, and encourage the customer to participate. During customer site visits, the EEA will:
• Ask to talk with the decision-maker.
• Explain the Program offer to the customer.
• Encourage the customer to agree to install/upgrade their lighting with LEDs.

6 • If the customer agrees, verify the quantity and type of fixtures or upgrade kits needed for the lights.
• Schedule follow-up visits with the customer to deliver the LED lighting equipment and schedule installations.

When the EEA delivers the LED lighting equipment to the customer, the EEA will schedule another appointment with the customer to return and verify the installation of the fixtures. This will provide the customer with an installation deadline.

ESG has learned through experience that it can take several contacts with a customer and can be a timeintensive task to get them ready to take delivery of LED lighting equipment for installation. EEAs have demonstrated the persistence needed to accomplish this task. Additionally, offering interior T8/T12 LED installations will help motivate the customer. Please note that kWh and demand kW savings vary based on existing/replacement wattage, location, as well as time of use.

Measure Descriptions Utility Pricing
Site Visit & Program Presentation $100.00
Completed Project Administration $375.00
Fluorescent CFL Pin Base 13W-45W $33.00
CFL/Incandescent Edison 13W-100W $18.00
4', 2-Lamp T8 $126.50
4', 3-Lamp T8 $230.00
4', 4-Lamp T8 $276.00
2', 2-Lamp T12 $120.75
3', 2-Lamp T12 $80.50
4', 1-Lamp T12 $97.75
4', 2-Lamp T12 $172.50
4', 3-Lamp T12 $270.08
4', 4-Lamp T12 $276.51
8', 1-Lamp T8 $51.75
8', 1-Lamp T8, HO $115.00
8', 2-Lamp T8 $189.75
8', 2-Lamp T8, HO $189.75
8', 1-Lamp T12 $218.50
8', 1-Lamp T12, HO $241.50
8', 2-Lamp T12 $371.80
8', 2-Lamp T12, HO $451.29
4', 2-Lamp T5, HO $230.00
4', 4-Lamp T5, HO $403.36
4', 6-Lamp T5, HO $374.08
Metal halide, (1) 150W lamp $320.55

7 Metal halide, (1) 175W lamp $354.84
Metal halide, (1) 250W lamp $388.33
Metal halide, (1) 400W lamp $417.98
Metal halide, (1) 750W lamp $476.43
Metal halide, (1) 1000W lamp $605.05
Wall Pack 70W MH $293.00
Wall Pack 100W MH $293.00
Wall Pack 150W MH $316.00
Wall Pack 175W MH $350.00
Wall Pack 250W MH $383.00
Wall Pack 400W MH $560.00
HID – Ballast Bypass 70 Watt $163.00
HID - Ballast Bypass 100 Watt $188.00
HID - Ballast Bypass 150 Watt $188.00
HID - Ballast Bypass 175 Watt $213.00
HID - Ballast Bypass 250 Watt $383.00
HID - Ballast Bypass 400 Watt $413.00
HID - Ballast Bypass 750 Watt $475.00
HID - Retrofit Kit w/Driver 750 Watt $572.00
HID - Ballast Bypass 1000 Watt $655.00
HID - Retrofit Kit w/Driver 1000 Watt $700.00
Canopy Parking/Perimeter 70W HID $240.00
Canopy Parking/Perimeter 100W HID $240.00
Canopy Parking/Perimeter 150W HID $280.00
Canopy Parking/Perimeter 175W HID $304.00
Canopy Parking/Perimeter 250W HID $327.00
Canopy Parking/Perimeter 400W HID $520.00
Canopy Gas Stations 175W HID $396.00
Canopy Gas Stations 250W HID $425.00
Canopy Gas Stations 320W HID $599.00
Canopy Gas Stations 400W HID $638.00
Area Light (Pole/Wall) 150W HID $490.00
Area Light (Pole/Wall) 175W HID $665.00
Area Light (Pole/Wall) 250W HID $687.00
Area Light (Pole/Wall) 400W HID $770.00
Area Light (Pole/Wall) 750W HID $985.00
Area Light (Pole/Wall) 1000W HID $985.00

8 Customer Satisfaction
A final verification inspection will be performed on all completed projects. During the final visit, the EEA will ensure that any customer questions or concerns are addressed and resolved before closing the project and invoicing Ukiah. ESG understands the importance of emphasizing to the customer that the program is coming from Ukiah and using the program experience to help Ukiah build and strengthen its relationships with its customers.

Reporting and Invoicing
ESG thoroughly understands the CEC reporting requirements for utility energy efficiency programs.

Because of this, ESG can generate complete and accurate activity reports and invoice formats that make it easy for Ukiah to track budgets, and program expenses, and report program results to the CEC. ESG will prepare monthly activity reports and invoices as required by Ukiah.

Program Administration
ESG will provide complete program administration, including:
• Program development (product selection, marketing materials, customer outreach) • Customer service/support
• Delivery of LED lighting equipment
• Warranty information
• Reporting/invoicing
• CEC compliance support
Incentive Structure
Interior and exterior LED fixtures/lamps will be provided at no cost to the customer. The customer will be responsible for their installation (either maintenance staff or hiring an electrician).

Pricing
ESG’s fees for this program include:
• A fee for marketing and presenting the program offer to each customer • A program subscription/administration fee for projects completed in the program • Cost per fixture/lamp installed
Program fees cover all costs, including program development activities, marketing/outreach, labor, materials (including mounting hardware and photocells), state sales tax, travel expenses and admin/overhead.

If needed, additional measures can be added with prior approval by Ukiah.

Energy Savings
Energy savings values for all measures are based on calculations based on pre/post wattages, assumes exterior fixtures are on all night and fluorescent fixtures are on a minimum of 8 hours per day. Based on quantities per business in other programs, ESG estimates 80,000 kWh per $50,000 of program budget.

9 Strategic Partners
ESG will serve as the program administrator. We plan partner with RD Energy Solutions of 7333 SE Ellis St, Portland OR on the implementation of the program. ESG has had a relationship with this partner for over ten years and has successfully delivered utility programs with them; including the Residential Direct Install Program for Ukiah.

Marketing Activities
ESG will work with Ukiah to develop/assemble any program or marketing collateral Ukiah would like presented to the customers during the EEAs visit. The remainder of the marketing/sales activities will be relational, face-to-face discussions between the customers and the EEA. It may take several conversations and/or site visits by the EEA to subscribe and complete projects under this program.

Payment Schedule
ESG will submit invoices to Ukiah monthly, accompanied by detailed reports showing each site visited and work performed at each customer/business site. ESG’s payment terms are net 30 days. If an invoice error is identified by Ukiah, a corrected invoice will be submitted by ESG within five business days of receiving notification from Ukiah.

October 16, 2024

Research,
Development &
Demonstration
History of Public Benefits
1996
AB 1890
Public Benefits
Low Income
Assistance
Energy
Conservation
Renewable
Energy &
Solar
Public Benefits Charge is a
nonbypassable, usage based
charge on local distribution service.

2.85% of Revenues

Public Benefit Expenditures FY 23/24

Utility Percentage of PB funds to Low
Income Assistance
Alameda 25%
Healdsburg 25%
Lassen 25%
Lodi 30%
Shasta Lake 25%
Ukiah 41%
Ukiah 2020 2021 2022 2023 2024
Energy Conservation $36,421 $22,860 $54,671 $100,627 $78,896 Low Income Assistance $172,325 $179,045 $140,731 $107,842 $110,112 Research & Demonstration $8,596 4,884 $1,307 $1,050 $1,050 Marketing Materials $1,812 $965 $1,986 $3,687 $2,882
Utility Public Benefit Low Income Assistance Comparison

Low Income Discount Increase Recommendation
Current Programs Less than
100% of *FPIG
101% - 150%
of *FPIG
151% - 200% of
*FPIG Payments
Senior Citizen Monthly Discount $40 $30 $20 Monthly bill credits Non-Senior Household Monthly Discount $30 $20 $10 Monthly bill credits Proposed Programs Less than
100% of *FPIG
101% - 150%
of *FPIG
151% - 200% of
*FPIG Payments
Senior Citizen Monthly Discount $50 $37.50 $25 Monthly bill credits Non-Senior Household Monthly Discount $37.50 $25 $12.50 Monthly bill credits *Federal Poverty Income Guidelines
Ukiah C.A.R.E.S. Program Assistance Levels

Residential Direct Install Program
• Two previous cycles focused on low-income customers
• Open program to all residential customers
• Customers must enroll
Commercial DIY Lighting Program
• Provides commercial customers with new fixtures at no cost • Customers will perform installation themselves, or with an electrician • Efficiency Services Group will verify installation
• Offered to small, locally owned businesses

• In June 2023, Council approved rebates for conversion of outdoor yard equipment
• Extremely generous rebates, 50% of cost of new gas-powered equipment • No other Northern California Utility provides such a rebate • Is being misused

Agenda Item No: 14.a.

MEETING DATE/TIME: 10/16/2024

ITEM NO: 2024-686

AGENDA SUMMARY REPORT
SUBJECT: Consider Adopting a Resolution Authorizing the Issuance of Tax and Revenue Revolving Notes.

DEPARTMENT: Finance PREPARED BY: Dan Buffalo, Finance Director PRESENTER: Dan Buffalo, Finance Director
ATTACHMENTS:

1. Ukiah 2024-25 Tax and Revenue Anticipation Note - Resolution_v4_2

2. Ukiah - Final Revised Term Sheet $10MM TRAN_ signed

3. Ukiah Umpqua TRAN Note Purchase Agreement 4881-2220-3627 v.3 Summary: Council will consider adoption of a resolution authorizing the issuance of tax and revenue revolving notes.

Background: The City of Ukiah has ongoing infrastructure projects, notably the Recycled Water System, which require significant upfront expenditures. These projects are largely funded through grants and other revenue sources, but there are timing discrepancies between when expenditures are incurred and when revenues are received; given that most grants work on a reimbursement basis. The City typically sees larger revenue collections later in the fiscal year, primarily from property tax revenues, while significant disbursements occur earlier in the year for construction and development projects.

To address this cash flow mismatch, the City and its Municipal Advisor (NHA Advisors) evaluated various short-term financing options over the past 12 months and identified a Tax and Revenue Revolving Note program as the most efficient and cost-effective solution. This program has been successfully implemented by many municipalities across the state to cover short-term liquidity needs. The revolving note will provide immediate access to funds and must be repaid within the fiscal year (by June 30), ensuring alignment with the City's financial planning and fiscal discipline.

Discussion: The Tax and Revenue Revolving Note with Umpqua Bank is structured to provide up to $10,000,000 in financing at any given time, with the ability to reborrow amounts as long as the total outstanding does not exceed 85% of the City’s anticipated uncollected tax, income, and other revenues for FY 2024-25. The facility will allow the City to cover expenditures for key projects, including Phase 4 of the Recycled Water Project, without depleting its reserves.

Key elements of the financing structure include:
• Amount: Maximum $10,000,000, revolving, with reborrowing allowed under certain conditions. • Term: Maturity on June 30, 2025. The City retains the right under this action to renew the Note annually by adopting a new resolution and entering into a new Note Purchase Agreement each fiscal year, as necessary. The terms for future years, including the interest rate, will be subject to prevailing conditions at the time of renewal.
• Interest Rate: Variable, currently 6.33%, tied to the Federal Funds Rate. • Fees: Umpqua Bank has agreed to waive the annual loan fee of $25,000 if the City opens a second operating account with the bank within three months of closing the facility. Additionally, Umpqua will provide an Earnings Credit Rate (ECR) for all analyzed accounts of 1.1% to offset monthly banking

services fees. (The ECR is the imputed interest rate calculated by banks to account for the money they hold in non-interest-bearing accounts. ECRs are calculated on a daily basis and are often tied to the price of low-risk government bonds. ECRs are often used by banks to credit customers for services, reduce fees, or offer incentives for new depositors.)
• Repayment Source: General fund revenues or revenues from the fund in which temporary cash flow is needed, supplemented by grant reimbursements.
• Payment structure: Revolving loan with required monthly interest payments, balance due at maturity which shall occur no late than June 30 each year in which the Note is available. • Issuance costs (one-time): The following costs are one-time, irrespective of the total term of the Note.
o Municipal Advisor (NHA Advisors): $49,500 for analysis and managing financing evaluation process over last 12 months
o Bank Counsel (Nixon Peabody): $25,000 for legal document drafting The flexible interest-only repayment structure ensures that the City is only charged when funds are drawn, offering a prudent approach to managing cash flow fluctuations.

Staff sees the benefits to the City of the financing as follows:

1. Liquidity for Critical Projects: This revolving note provides immediate access to $10 million, ensuring that the City has the liquidity needed to continue critical infrastructure projects like the Recycled Water System without delay, even if revenue from grants and taxes is received later in the fiscal year.

2. Prudent Cash Flow Management: By matching disbursements with revenue collection, the financing helps smooth out cash flow timing differences, allowing the City to meet its obligations without tapping into its reserves.

3. Cost-Effective: The financing structure includes flexible interest payments, which means the City only incurs costs when the funds are actually drawn. This minimizes the financial burden on the City by reducing unnecessary interest costs.

4. Low Fees: Umpqua Bank's waiver of the $25,000 annual loan fee, in exchange for opening a second operating account, represents a significant cost-saving opportunity for the City, further enhancing the attractiveness of the deal.

5. Potential Interest Rate Decline: The variable interest rate allows the City to potentially benefit from lower interest rates in the future, if economic conditions change favorably.

6. Annual Renewal Option: The City retains the ability to renew the Note annually, ensuring continued liquidity for future fiscal years if needed. This flexibility allows the City to respond to evolving financial needs and project timelines.

Potential Risks:

1. Variable Interest Rate Exposure: While the current interest rate is favorable, it is tied to the Federal Funds Rate. Should interest rates rise, the cost of borrowing could increase, leading to higher-thananticipated interest payments. This risk can be mitigated through careful financial monitoring and potentially locking in rates in future fiscal years.

2. Repayment Obligation: The note must be repaid by the end of the fiscal year (June 30, 2025). If revenue collections do not align as expected or if grant reimbursements are delayed, the City may need to draw on reserves or find alternative funding sources to meet this repayment obligation.

3. Dependence on Future Revenue: This financing relies heavily on the timely collection of tax revenues and grant reimbursements. Any unforeseen delays in these revenues could create cash flow challenges, although the City's strong financial planning mitigates this risk.

4. Impact on Future Borrowing Capacity: While the note provides short-term liquidity, the City must consider its long-term borrowing capacity and ensure that future borrowing needs are not hampered by the revolving nature of this note.

This financing solution provides the City with a tool to address short-term liquidity needs while ensuring the continuity of infrastructure projects. While variable interest rate exposure poses a risk, the City's active financial monitoring and close relationship with its financial advisor will enable timely responses to any significant rate changes. Additionally, should the City's anticipated revenues not materialize as expected, Staff is prepared to explore alternative funding sources or temporarily draw on reserves, ensuring compliance with repayment obligations. The added flexibility of renewing the Note annually gives the City a long-term option for managing future financial demands. However, careful attention to interest rate movements and cash flow timing is essential to mitigate the risks associated with this type of short-term financing.

Looking ahead, the City will continue to evaluate its financing options for future years, including the potential of locking in more favorable interest rates if market conditions improve. Given the City’s ongoing infrastructure needs and the timing discrepancies between revenue collection and project expenditures, adopting this resolution is a crucial step toward ensuring the successful and timely completion of key projects without impacting the City’s reserves or overall fiscal health.

Timing:

Upon Council adoption of the resolution, Staff and the financing team plan to close the issuance of the 2024 Notes in late October or early November 2024.

Note Purchase Agreement:

To proceed with the issuance of the 2024 Notes, the City Council must adopt the Resolution recommended above. As referenced in the recommended resolution, Staff recommends the Director of Finance or authorized designees be authorized to execute and deliver the 2024 Note and that the Director of Finance, or authorized designees, be authorized to enter into and deliver the 2024 Note Purchase Agreement (Purchase Agreement) described below.

The Note Purchase Agreement is between the City and the Bank. The Purchase Agreement sets forth requirements under which the Bank will purchase the new portion of the 2024 Note, establishes the interest rate mechanism, outlines repayment terms, contains representations and warranties of the City and the Bank, and specifies conditions precedent to the Bank entering into the Purchase Agreement.

Budget Amendment:

A budget amendment is required for the issuance costs and interest expenditures in the event draws are made. An estimate of interest expenditures for the remainder of the current fiscal year is provided below. Issuance costs are provided as well. A budget amendment is not required for draws against the revolving note nor to the principal repaid, as the receipt and use of proceeds are not considered either revenues, expenditures, other financing sources or uses. The draw and repayment of principal are for shortterm cash flow purposes at the balance sheet level.

Staff recommends the City Council adopt a resolution authorizing the issuance of Tax and Revenue Revolving Notes. These notes will provide the necessary liquidity to maintain the City's fiscal stability during the construction of its critical infrastructure projects, including the Recycled Water System.

Recommended Action: Adopt a resolution that 1) authorizes the issuance and sale of the City of Ukiah 2024 Tax and Revenue Revolving Note in an aggregate principal amount not to exceed $10,000,000, to be sold through a direct bank placement; and 2) approves in substantially final form the Note Purchase Agreement and authorizes the Finance Director or other authorized officers to execute the Note Purchase Agreement with Umpqua Bank N.A., and other related documents as necessary in connection with the issuance of the 2024 Notes and authorizes other related actions.

BUDGET AMENDMENT REQUIRED: Yes
CURRENT BUDGET AMOUNT: 0
PROPOSED BUDGET AMOUNT: $25,000 interest expense (20000000.70102), $74,500 issuance costs (20000000.70110)
FINANCING SOURCE: Tax Revenue Anticipation Revolving Note PREVIOUS CONTRACT/PURCHASE ORDER NO.: N/A
COORDINATED WITH: Sage Sangiacomo, City Manager
DIVERSITY-EQUITY INITIATIVES (DEI): N/A
CLIMATE INITIATIVES (CI): N/A
GENERAL PLAN ELEMENTS (GP): N/A

1 City of Ukiah
Issuance Resolution
2024-25 TRANs
RESOLUTION NO. ______

A RESOLUTION OF THE COUNCIL OF THE CITY OF UKIAH PROVIDING FOR THE BORROWING OF FUNDS FOR FISCAL YEAR 2024-25 AND THE ISSUANCE AND SALE OF THE CITY OF UKIAH 2024-25 TAX AND REVENUE ANTICIPATION NOTE AND APPROVING

THE EXECUTION OF A NOTE PURCHASE AGREEMENT RELATING TO SUCH NOTE AND

AUTHORIZING OTHER ACTIONS IN CONNECTION THEREWITH
WHEREAS, pursuant to Sections 53850 to 53858, both inclusive, of the California Government Code, being Article 7.6, Chapter 4, Part 1, Division 2, Title 5 thereof (the “Law”), the City Council (the “Council”) of the City of Ukiah (the “City”) has found and determined that at least $10,000,000 is needed by the City in Fiscal Year 2024-25 to satisfy obligations of the City (including, but not limited to, to help manage cash flow during construction of the City’s Recycled Water System and other infrastructure projects) payable from the General Fund of the City (the “General Fund”) during Fiscal Year 2024-25 before the receipt of taxes, income, revenue, cash receipts and other moneys of the City to be received for or accrued to the General Fund during Fiscal Year 2024-25 will be available for such purpose, and that it is necessary that at least such sum be borrowed for such purpose by the issuance of a temporary note in anticipation of such receipt; and WHEREAS, the City intends to initially borrow up to $10,000,000 to be outstanding at any time for such purpose by the issuance and sale of its 2024-25 Tax and Revenue Anticipation Note (as defined more particularly in Section 3 hereof, the “Note”), which such principal may be repaid and reborrowed up to a principal amount that, when added to the interest payable thereon and to all previous principal amounts borrowed, in the aggregate, does not exceed eighty-five percent (85%) of the estimated amount of the estimated uncollected taxes, income, revenue, cash receipts and other moneys of the City anticipated to be received for or accrued to the General Fund during Fiscal Year 2024-25 that will be available for the payment of the interest on and the principal of the Note (such amount, the “Maximum Amount”); and
WHEREAS, it appears, and the Council hereby finds and determines, that the total principal amount of the Note, when added to the interest payable thereon, will not exceed eighty-five percent (85%) of the estimated amount of the estimated uncollected taxes, income, revenue, cash receipts and other moneys of the City anticipated to be received for or accrued to the General Fund during Fiscal Year 2024-25 that will be available for the payment of the interest on and the principal of the Note; and
WHEREAS, no money has heretofore been borrowed by the City in anticipation of the receipt of, or payable or secured by, any taxes, income, revenue, cash receipts or other moneys of the City to be received for or accrued to the General Fund during Fiscal Year 2024-25; and WHEREAS, in compliance with Government Code Section 8855, the City has previously adopted a local debt policy and the Council hereby finds and determines that the Note will be issued in conformance with said policy; and
WHEREAS, pursuant to Government Code Section 5852.1, the Council has obtained from NHA Advisors, its Municipal Advisor (the “Municipal Advisor”), certain good faith estimates of (a) the true interest cost of the Note, (b) the finance charge of the Note, (c) the amount of proceeds received for the sale of the Note, less the finance charge and any reserves or capitalized interest paid or funded with the proceeds of the Note, and (d) the total payment amount calculated to the final maturity of the Note, and such estimates are disclosed and set forth in Exhibit C attached hereto; and
ATTACHMENT 1

2 City of Ukiah
Issuance Resolution
2024-25 TRANs
WHEREAS, the City wishes to authorize the issuance of the Note (to be issued in portions) to be purchased by Umpqua Bank (including its successor and assigns, the “Bank”) in an amount not to exceed the Maximum Amount from the City in accordance with a note purchase agreement by and between the City and the Bank, as originally executed and as they may be amended from time to time in accordance with its terms (the “Note Purchase Agreement”); and WHEREAS, pursuant to the Law, certain taxes, income, revenue, cash receipts and other moneys of the City which will be received for or accrued to the General Fund during Fiscal Year 2024-25 can and will be pledged for the payment of the principal of and interest on the Note; and WHEREAS, pursuant to the Law and this Resolution, the City has pledged all Revenues (as such terms are defined in the Note Purchase Agreement) to the payment of the principal of and interest on the Note.

NOW THEREFORE, the City Council of the City of Ukiah does hereby resolve, find, and determine as follows:

Section 1. Recitals. All of the recitals hereinabove set forth are true and correct, and the Council so finds and determines and the Council further finds and determines that all acts, conditions and things required by law to exist, to have occurred and to have been performed precedent to the issuance and sale of the Note do exist, have occurred and have been performed in regular and due time, form and manner as required by law, and that the Council is empowered under the Law to issue and sell the Note as provided herein.

Section 2. Defined Terms. Unless otherwise defined herein, capitalized terms used in this Resolution shall have the meanings given such terms in the Note Purchase Agreement.

Section 3. Issuance of Note.
a. Solely for the purpose of anticipating taxes, income, revenue, cash receipts and other moneys of the City to be received for or accrued to the General Fund during Fiscal Year 2024-25, the City hereby determines at this time to and shall borrow up to the initial principal sum of $10,000,000 by the issuance of the Note under the Law, designated the “City of Ukiah 2024-25 Tax and Revenue Anticipation Note.”
b. The Note is subject to optional prepayment, without premium, prior to the maturity date thereof, in accordance with the terms of the Note Purchase Agreement; and each draw thereupon can be prepaid without premium or penalty. Amounts repaid under the Note may be reborrowed in an amount not to exceed $10,000,000 at any time; provided, however, that such additional principal amount, when added to the interest payable thereon and to all previous principal amounts borrowed under the Note, does not exceed the Maximum Amount.
c. The Note shall be dated the date of issuance thereof and shall mature and be payable as provided in the Note Purchase Agreement. Interest on the Note shall be calculated upon the amount of principal outstanding for each Interest Period (as such term is defined in the Note Purchase Agreement), in no event to exceed ten percent (10%) per annum The principal amount of the Note (including the portions purchased by the Bank thereof) and the then applicable

3 City of Ukiah
Issuance Resolution
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interest rate shall be noted by the Bank on the form of the Note in accordance with the Note Purchase Agreement and shall not exceed the Maximum Amount.
d. The Note shall be issued in the name of the City and registered in the name of the Bank, as the registered owner thereof (together with any of the Bank’s successors or assigns as permitted in the Note Purchase Agreement, the “Owner”), and shall be evidenced by a single note. The Bank shall have the right to sell or transfer the Note or to otherwise directly or indirectly transfer or assign any interest in the Note only to the extent permitted in the Note Purchase Agreement. The City shall be entitled to treat the Bank as the “Owner” of the Note as indicated therein and as the absolute owners of the Note for all purposes under this Resolution and for purposes of payment of principal of and interest on such Note, notwithstanding any notice to the contrary received by the City.
e. The City Manager, the Director of Finance or their authorized designees (each an “Authorized Representative”), each acting alone, are hereby authorized and directed to provide any notices or other directions of the City to the Bank pursuant to the Note Purchase Agreement.
f. An Authorized Representative will maintain or cause to be maintained, at his or her office in Ukiah, California, sufficient books for the registration of the Note.

Section 4. Form of Note. The Note shall be issued without coupons and shall be substantially in the form thereof set forth in Exhibit A attached hereto and incorporated herein, together with such changes, additions, and deletions thereto as deemed necessary and as approved by an Authorized Representative before the execution, authentication and delivery of the Note.

Section 5. Execution of Note. Each Authorized Representative (including officials acting in this position on an interim basis) acting alone are authorized to execute the Note by their manual or facsimile signature, and the City Clerk (including officials acting in this position on an interim basis) is hereby authorized to countersign the Note by manual or facsimile signature. The Note shall not be valid, however, unless and until an Authorized Representative (including the person acting in such position on an interim basis) shall have manually authenticated such Note by executing the Certificate of Authentication printed thereon.

Section 6. Use of Proceeds of Note. The City shall, immediately upon receiving the proceeds of the sale of the Note or portions thereof, deposit in the General Fund all amounts representing the proceeds of the Note received from such sale, and such proceeds shall be used for the purpose specified in the Note Purchase Agreement or otherwise permitted by applicable law.

Section 7. Security for Note; Security Interest.
a. The City hereby pledges all Revenues (as that term is defined in the Note Purchase Agreement) excluding moneys which, when received by the City, will be encumbered for a special purpose (collectively, the “Pledged Revenues”) to the payment of the principal of and interest on the Note. The Note shall be equally and ratably secured by the Pledged Revenues. This pledge is valid and binding in accordance with the terms of this Resolution and the Pledged

4 City of Ukiah
Issuance Resolution
2024-25 TRANs
Revenues shall immediately be subject to the pledge, and the pledge shall constitute a first lien and security interest which shall immediately attach to the Pledged Revenues and be effective, binding, and enforceable against the City, its successors, creditors, and all others asserting the rights therein, to the extent set forth, and in accordance with this Resolution irrespective of whether those parties have notice of the pledge and without the need for any physical delivery, recordation, filing, or further act.
b. Subject to written consent from the Bank, nothing in this Resolution shall prohibit the City from issuing additional tax and revenue anticipation notes payable from the Pledged Revenues or other available funds on a basis subordinate to the Note (“Subordinate Notes”); provided that with respect to any such Subordinate Notes, the City shall not, prior to the payment in full of the Note, (i) make any scheduled payments of principal of or interest on such Subordinate Notes prior to the payment of principal of or interest on the Note, (ii) make any prepayment thereof, or (iii) issue any such Subordinate Notes that have a maturity date earlier than the stated maturity date of the Note.

Section 8. Sale of Note. The Note Purchase Agreement, in the form thereof set forth in Exhibit B attached hereto and incorporated herein, is hereby approved, and the Authorized Representatives, or their designee, each acting alone, are hereby authorized and directed, for and in the name and on behalf of the City, to execute and deliver to the Bank the Note Purchase Agreement in said form (which Note Purchase Agreement shall contain the maturity date and the interest rates and the prepayment provisions for the Note), with such changes as such Authorized Representative may require, deem necessary, or approve upon consultation with the City Attorney, such approval to be conclusively evidenced by the execution and delivery thereof; provided however, the maximum rate of interest on the Note shall not exceed 10.00%, for the utilized portion of the Note.

Section 9. Further Actions. Each Authorized Representative is hereby authorized and directed to execute and deliver the Note to the Bank in accordance with the Note Purchase Agreement, and the City Manager, the Director of Finance, and the City Clerk are hereby authorized and directed, for and in the name and on behalf of the City, to do any and all things and take any and all actions and execute any and all certificates, agreements and other documents, including but not limited to an agreement relating to the breakage fee related to the Note, which they, or any of them, may deem necessary or advisable in order to consummate the lawful issuance and delivery of the Note in accordance with this Resolution, and all actions heretofore taken by such officers with respect to the sale and issuance of the Note are hereby approved, confirmed and ratified. Any authority delegated under this Resolution to a specified official (including officials acting in these positions on an interim basis) of the City may also be exercised by the specified official’s authorized designee.

Section 10. Resolution to Constitute Contract. It is hereby covenanted and warranted by the City that all representations and recitals contained in this Resolution are true and correct, and that the City, and its appropriate officials, have duly taken all proceedings necessary to be taken by them, and will take any additional proceedings necessary to be taken by them, for the levy and collection and deposit of the Revenues (as defined in the Note Purchase Agreement) pledged hereunder in accordance with the Law and with this Resolution and for carrying out the

5 City of Ukiah
Issuance Resolution
2024-25 TRANs
provisions of this Resolution. It is hereby further covenanted and warranted by the City that the provisions of the Note and of this Resolution shall constitute a contract between the City and the Owner, and such provisions shall be enforceable by mandamus or any other appropriate suit, action or proceeding at law or in equity in any court of competent jurisdiction; provided, that notwithstanding any other provision hereof to the contrary, upon the City’s failure to observe, or refusal to comply with, the covenants contained herein, no one other than the Owner or former Owner of the Note shall be entitled to exercise any right or remedy under this Resolution on the basis of the City’s failure to observe, or refusal to comply with, such covenants.

Section 11. Amendments. This Resolution may be amended by a supplemental resolution adopted by the Council with the written consent of the Owners of one hundred percent (100%) of the principal amount of the Note outstanding.

Section 12. Severability. If any one or more of the provisions of this Resolution shall to any extent be declared invalid, unenforceable, void or voidable for any reason whatsoever by a court of competent jurisdiction, the decision, finding, order or decree of which becomes final, none of the remaining provisions of this Resolution shall be affected thereby, and such provisions shall be valid and enforceable to the fullest extent permitted by applicable law.

Section 13. Effective Date. This Resolution shall take effect from and after its adoption.

Section 14. Certification. The City Clerk shall certify as to the adoption of this Resolution.

ADOPTED this 16th day of October, 2024, by the following vote:

AYES:

NOES:

ABSTAIN:

DISQUALIFIED:

_______________________________
Douglas F. Crane, Vice Mayor
ATTEST:
_______________________________
Kristine Lawler, City Clerk

A-1

EXHIBIT A

FORM OF NOTE
R-__

ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR VALUE OR OTHERWISE

BY OR TO ANY PERSON IS WRONGFUL SINCE THE REGISTERED OWNER HEREOF HAS AN INTEREST HEREIN. THIS NOTE IS NON-NEGOTIABLE AND THE OWNER HEREOF HAS

THE RIGHT TO SELL OR TRANSFER THE NOTE OR TO OTHERWISE DIRECTLY OR

INDIRECTLY TRANSFER OR ASSIGN ANY INTEREST IN THE NOTE ONLY TO THE EXTENT PERMITTED BY THE NOTE PURCHASE AGREEMENT.

CITY OF UKIAH
2024-25 Tax and Revenue Anticipation Note

INTEREST RATE DATED DATE MATURITY DATE
As set forth in the Note
Purchase Agreement
October__, 2024 June 30, 2025
REGISTERED OWNER: UMPQUA BANK (including its successors and assigns) PRINCIPAL AMOUNT: UP TO $10,000,000 TO BE OUTSTANDING AT ANY

TIME AND NOT TO EXCEED THE MAXIMUM AMOUNT
(AS DEFINED HEREIN)
FOR VALUE RECEIVED, the City of Ukiah, California (“City”) acknowledges itself indebted to and promises to pay to the Registered Owner hereof (together with any of its successors and assigns as permitted under the Note Purchase Agreement (defined below), the “Bank”), at the office of the City, the principal sum stated above, in lawful money of the United States of America, on the dates and in the amounts, together with interest on the principal amount outstanding hereunder from time to time, calculated upon the amount of principal outstanding for each Interest Period (as such term is defined in the Note Purchase Agreement) at the rate or rates per annum set forth above and computed on the basis set forth in that certain Note Purchase Agreement (the “Note Purchase Agreement”) by and between the City and the Bank dated as of _________, 2024 in like lawful money from the date hereof until payment in full of said principal sum. Interest hereon shall be payable to the Registered Owner at the address shown on the registration books of the City; provided that the address may be changed pursuant to the terms of the Note Purchase Agreement, and at such other times as may be required under the Note Purchase Agreement. The principal of and interest at maturity on this Note shall be payable only to the Registered Owner and in the manner provided in the Note Purchase Agreement. This Note is subject to a default rate upon the occurrence of an Event of Default, as provided in the Note Purchase Agreement. Upon payment in full of this Note, this Note shall be surrendered for cancellation.

It is hereby certified, recited and declared that this Note is entitled “City of Ukiah 2024-25 Tax and Revenue Anticipation Note” (the “Note”), and is authorized and issued under and pursuant to the authority of Article 7.6, Chapter 4, Part 1, Division 2, Title 5 of the Government Code of the State

A-2
City of Ukiah
Issuance Resolution
2024-25 TRANs
of California and in accordance with Resolution No. _____ adopted by the City Council of the City on October 16, 2024, (together with the Note Purchase Agreement appended thereto, the “Resolution”), and that all acts, conditions and things required to exist, happen and be performed precedent to and in the issuance of this Note have existed, happened and been performed in regular and due time, form and manner as required by law, and that this Note, together with all other indebtedness and obligations of the City does not exceed any limit prescribed by the Constitution or laws of the State of California. Capitalized terms not otherwise defined herein shall have the meaning ascribed thereto in the Resolution.

The Note is subject to optional and mandatory prepayment prior to the maturity date thereof, in accordance with the terms of the Note Purchase Agreement. Amounts repaid under this Note may be reborrowed in an amount not to exceed $10,000,000 at any time pursuant to the terms of the Note Purchase Agreement; provided, however, that such additional principal amount, when added to the interest payable thereon and to all previous principal amounts borrowed under the Note, does not exceed eighty-five percent (85%) of the estimated amount of the estimated uncollected taxes, income, revenue, cash receipts and other moneys of the City anticipated to be received for or accrued to the General Fund during Fiscal Year 2024-25 that will be available for the payment of the interest on and the principal of the Note (such amount, the “Maximum Amount”).

Pursuant to the Resolution, the City has pledged all Revenues to the payment of the principal of and interest on the Note. The Note shall be equally and ratably secured by the Pledged Revenues.

The Note is a general obligation of the City and is payable from the Pledged Revenues and the income derived from the investment of moneys held in the accounts as provided in the Resolution.

The principal of the Note and the interest thereon shall constitute a first lien and charge on such Pledged Revenues, and shall be payable therefrom, and to the extent not so paid from any other moneys of the City lawfully available therefor.

This Note shall not be valid or become obligatory for any purpose until the Certificate of Authentication hereon shall have been signed by the Director of Finance of the City, or their designee.

IN WITNESS WHEREOF, the City of Ukiah has caused this Note to be executed by the manual or facsimile signature of its Director of Finance and countersigned by the manual or facsimile signature of the City Clerk, all as of the first day of ______, 2024.

CITY OF UKIAH

By:

Its: Director of Finance

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City of Ukiah
Issuance Resolution
2024-25 TRANs

Countersigned:

By:

Its: City Clerk

CERTIFICATE OF AUTHENTICATION
This Note is the City of Ukiah, California 2024-25 Tax and Revenue Anticipation Note described in the within mentioned Resolution.

Date of Authentication: ____________, 2024
[Authorized Representative]

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City of Ukiah
Issuance Resolution
2024-25 TRANs

TRANSACTION ON
2024-25 Tax and Revenue Anticipation Note
DATE
NOTE

PORTION
AMOUNT

REMAINING

MAXIMUM

AMOUNT INTEREST RATE

AMOUNT OF

PRINCIPAL
PAID

DATE TO
WHICH

INTEREST
PAID

NOTATION

MADE BY

B-1

EXHIBIT B

FORM OF NOTE PURCHASE AGREEMENT
[TO BE ATTACHED]

C-1

EXHIBIT C

GOOD FAITH ESTIMATES
The good faith estimates set forth herein are provided with respect to the Note authorized by this Resolution. Such good faith estimates have been provided to the City by NHA Advisors (the “Municipal Advisor”) reflecting the market interest rates and terms provided in the proposal from Umpqua Bank
Estimated Principal Amount. The Municipal Advisor has informed the City that, based on the City’s financing plan and current market conditions, the good faith estimate of the aggregate principal amount of the Note is $10,000,000 (the “Estimated Principal Amount”).

True Interest Cost. The Municipal Advisor has informed the City that the good faith estimate of the true interest cost of the Note, which means the rate necessary to discount the amounts payable on the respective principal and interest payment dates to the purchase price received for the Note, is 6.4141185%.

Finance Charge. The Municipal Advisor has informed the City that the good faith estimate of the finance charge for the Note, which means the sum of all fees and charges paid to third parties for costs in connection with the issuance and sale of the Note (the “Finance Charge”), is $74,500. The City has stated that all costs of issuance will be paid from funds on hand and not from proceeds of the Note.

Amount of Proceeds to be Received. The Municipal Advisor has informed the City that the good faith estimate of the amount of proceeds of the Note expected to be received by the City, less the Finance Charge, and any reserves or capitalized interest paid or funded with proceeds of the Note, is $10,000,000.

Total Payment Amount. The Municipal Advisor has informed the City that the good faith estimate of the total payment amount, which means the sum total of all principal and interest payments made for the Note, plus the Finance Charge, not paid with proceeds of the financing, calculated to the final maturity of the Note, is $10,420,241.67, assuming a $10,000,000 draw on the closing date.

The foregoing estimates constitute good faith estimates only. The estimates above may differ from the actual amounts due to (a) the actual dated date of the Note being different from the date assumed for purposes of such estimates, (b) the actual aggregate principal amount of the Note being different from the Estimated Principal Amount, (c) the actual interest rate on the Note, (d) the actual amortization of the debt service on the Note being different from the amortization assumed for purposes of such estimates, (e) other market conditions, or (f) alterations in the City’s financing plan, or a combination of such factors. The actual dated date of the Note and the actual aggregate principal amount of the Note will be determined by the City based on market conditions and other factors.

Together for Better
City of Ukiah
Revised Term Sheet Dated 9/25/2024
Tax Revenue Anticipation Revolving Note
Umpqua Bank (“Umpqua”) would like to express its interest in underwriting and obtaining credit approval for the following loan (the “Credit Facility”) for the City of Ukiah (the “City”) on the terms and conditions outlined below.

Preface: Umpqua’s expression of interest in underwriting and obtaining credit approval for the Credit Facility is for discussion purposes only and does not constitute a commitment from Umpqua. Any commitment to lend that we might make is subject to the fulfillment of a number of conditions that include, but are not limited to, our normal credit approval process, an in-depth investigation of the purpose of the purpose of the loan, the City, and collateral the results of which are deemed satisfactory to Umpqua in our sole discretion.

Confidentiality: Except as required by law, neither this expression of interest nor its contents will be disclosed publicly or privately except to those individuals who are your officers, employees or advisors who have a need to know as a result of being involved in the proposed financing. The foregoing confidentiality provisions shall not apply to the disclosure of the federal income tax structure or treatment of the proposed financing.

Loan Amount: $ 10,000,000
Loan Purpose: Allow the City to adequately manage cash flow during the construction of the City’s Recycled Water System and other infrastructure projects. The City may utilize the line to cover construction disbursements for phase 4 of the City’s Water Recycling Project and other projects supported by grant revenue.

Structure / Security Primary: Annual ordinary general fund revenue sources as approved by annual budget and current investment balances as required.

Secondary: Grant Revenue Reimbursements for cash funds used to pay current period expenses.

Term Initially, maturity shall be June 30, 2025, and, thereafter, 12 months with annual renewal provision, provided that such annual renewal will require the City to approve a new resolution and documentation which will be substantially similar to the documents created for the original Credit Facility.

Rate • Indicative Taxable Variable Rate of 6.33% (Based on the Federal Funds Rate as of 9/24/2024 of (4.83%+1.50%)), with a floor of 4% going forward • Rate lock 2 weeks prior to closing
Fees • Umpqua will waive the annual loan fee of $25,000 if the City opens their second operating account with Umpqua, within 3 months of the closing of the initial Credit Facility.
• Additionally, Umpqua will provide an ECR rate for all analyzed accounts of

1.1% to offset monthly banking services fees.

Payment Structure Revolving loan with required monthly interest payments, balance due at maturity which shall occur no later June 30 of each fiscal year.

Cost of Issuance All documents to be prepared by Umpqua Bank's counsel Rudy Salo of Nixon Peabody, LLP. Legal fees and expenses of Nixon Peabody, LLP shall be $25,000, assuming no delays or protracted negotiations. All other filing fees and related fees shall be paid by the City in connection with the issuance, including CDIAC fees. Umpqua will also require an opinion of the City Attorney regarding the Attachment 2