Willits City Council
April 13, 2022

111 E. Commercial Street
Willits, California 95490
Tel | 707.459.4601
Fax | 707.459.1562
www.cityofwillits.org

WILLITS CITY COUNCIL
AGENDA
APRIL 13, 2022 | 6:30 PM | VIA TELECONFERENCE
Due to the provisions of the Governor’s new Executive Orders N-15-21 (Assembly Bill 361) which continues to suspend certain requirements of the Brown Act, and the Order of the Health Officer of the County of Mendocino to impose/recommend measures to promote social distancing to minimize the spread of COVID-19, the City Council will be participating by tele/video conference.

TELECONFERENCING ATTENDANCE INSTRUCTIONS
How to attend this Council meeting remotely – See end of the agenda

1. OPENING MATTERS
a. Call to Order. | b. Pledge to Flag. | c. Roll Call.

2. PUBLIC COMMUNICATIONS
The City Council welcomes participation in its meetings. Comments shall be limited to three (3) minutes per person so that everyone has an opportunity to address the Council. To expedite matters and avoid repetition, whenever any group of persons wishes to address the Council on the same subject matter, the Mayor may request the group appoints a spokesperson. This item is limited to matters under the jurisdiction of the City Council, which are not on the posted agenda. Public criticism of the City Council, Commission, Boards and Agencies will not be prohibited. The City Council will take no action.

3. PUBLIC MATTERS
a. Continuation of PUBLIC HEARING from February 9, 2022 – Discussion and possible action adopting a resolution to approve Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for the Groundwater Resiliency Improvement Project and conditionally approve the project with the adoption of the Groundwater Operational Use Plan Establishing Parameters for the use of the Groundwater System.

4. ENACTMENT OF ORDINANCES
a. None.

5. CONSENT CALENDAR
The City Council considers matters listed under the Consent Calendar as routine. The Council will take action with a single motion and roll call vote. A Councilmember may request the removal of an item(s) from the Consent Calendar for separate discussion and subsequent action.

The following items as presented are before the City Council for approval or denial:
a. Minutes: None presented.
b. Resolution ratifying and extending for an additional 30-days, approval of continuing Virtual City Council, Commission, and Committee meetings pursuant to AB 361.

Willits City Council Agenda – April 13, 2022.

c. Resolution approving revised 2021/2022 Classification and Compensation Schedule; Resolution approving Wage Adjustments for Swimming Pool Staff.

6. MONTHLY ACTIVITY REPORTS
Matters that do not require action by the City Council but are of public interest. a. None.

7. COMMISSIONS, AGENCIES AND AUTHORITIES
The Willits City Council meets concurrently as the City of Willits Planning Commission & City of Willits Successor Agency.

8. CITY MANAGER REPORTS AND RECOMMENDATIONS
a. Verbal Reports – No Action.

9. DEPARTMENT RECOMMENDATIONS (ACTION ITEMS)
a. Adopt a Resolution announcing the intent of the City Council to adopt an ordinance to enforce provisions of Senate Bill 1383.

Presenting staff member: Building Official Bowles.

10. DEPARTMENT MONTHLY REPORTS – (presented at the second meeting of the month) None.

11. CITY COUNCIL ANNOUNCEMENTS, COMMUNICATIONS AND REPORTS

12. GOOD & WELFARE

13. CLOSED SESSION NOTICE
a. None.

14. ADJOURNMENT
Right to Appeal - Persons who are dissatisfied with the decisions of the City Council may have the right to a review of that decision by a court. The City has adopted Section 1094.6 of the Code of Civil Procedure, which generally limits to 90- days, the time within an individual and/or entity may judicially challenge the decisions of the City Boards and Agencies.

I hereby certify under penalty of perjury under the laws of the State of California that I posted the foregoing Agenda on the bulletin board at the main entrance of the City of Willits City Hall, located at 111 East Commercial Street, Willits, California, not less than 72 hours prior to the meeting set forth on this Agenda.

Dated this 8th day of April, 2022.

Cathy Moorhead, Assistant City Manager
Americans with Disabilities Act (ADA) Compliance
If you need assistance to attend or participate in a City Council meeting, please contact the City Clerk’s office at (707) 459-7121 or Fax (707) 459-1562. Notification at least 48-hours prior to the meeting will assist the City Clerk in assuring the implementation of reasonable accommodations to provide accessibility to the meeting. Our meeting room is wheelchair accessible and ADA parking is available.

Additional Meeting Information for Interested Parties
Materials related to an item on this Agenda submitted to the Willits City Council, Planning Commission, or Community Development Agency after distribution of the agenda packet are available for public inspection at City Clerk’s office at 111 E. Commercial Street, Willits, during normal business hours, Monday through Thursday 9 AM to 5:30 PM.

Willits City Council Agenda – April 13, 2022.

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Item No. 3a
Meeting Date: April 13, 2022

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Rod Wilburn, PE, Consulting City Engineer
Agenda Title: PUBLIC HEARING (CONTINUED FROM FEB. 9, 2022) – DISCUSSION AND POSSIBLE

ACTION ADOPTING A RESOLUTION TO APPROVE INITIAL STUDY/MITIGATED NEGATIVE

DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM FOR THE

GROUNDWATER RESILIENCY IMPROVEMENT PROJECT AND CONDITIONALLY APPROVE THE

PROJECT WITH THE ADOPTION OF THE GROUNDWATER OPERATIONAL USE PLAN ESTABLISHING PARAMETERS FOR THE USE OF THE GROUNDWATER SYSTEM.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 30 min.

Summary of Request:

At the direction of Council, the public hearing on February 9th was held over for a future date so that staff could prepare a Groundwater Operational Use Plan to accompany the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring Plan for the Groundwater Resiliency Improvement Project as a condition of the project’s approval. The purpose of this plan is to set policy guidelines for future use of the groundwater system. The plan is separated into the five following categories:

1. Allowable Circumstances for Use of the Groundwater System

2. Use Guidelines

3. Groundwater Level Monitoring

4. Testing

5. Annual Plan Review
The first element establishes the conditions under which the groundwater system will be utilized. These conditions include: Emergency events, when surface water has been compromised or additional water supply is deemed necessary to address an emergency; During routine annual flushing events to reduce brown water issues and provide quality water to water consumers; During maintenance activities related to the reservoirs, the surface water treatment plant, the distribution infrastructure, or other water system maintenance; Regular operation of the groundwater plant to exercise the equipment, ensure operational integrity, and to ensure the availability of groundwater the need arise; if Council determines that it is necessary to support the needs of the community or respond to an emergency; and to supplement the use of surface water for any major fires affecting the area.

The second element discusses the current groundwater production limitations. The groundwater system is permitted by the State of California for an estimated annual production of 400 acre-feet or approximately 130 million gallons per the Drinking Water Well Source Assessment completed in 2015. At 400 acre feet per year, average monthly use will be 10.9 million gallons, unless an emergency situation occurs, or regular operations and maintenance of the City’s water system requires the City to use in excess of that amount.

If that situation were to occur, Council would be apprised of the situation and provided with a plan for the use if the need were to continue.

The third element outlines the City’s groundwater level monitoring efforts. The plan discusses the ongoing groundwater level monitoring program, which focuses on monitoring the effects of the City’s pumping activities to ensure that the City’s activities are not affecting the beneficial use of neighboring wells. As part of this effort, the City is coordinating monitoring activities with the Mendocino County Resource Conservation District (MCRCD), land managers for the State owned mitigation lands adjacent to the Elias Replacement Well. These mitigation lands house several wells that are in the closest proximity to the City’s Elias Replacement Well. Monitoring efforts include groundwater data collection from both shallow, surface water wells and deep, confined aquifer wells. Groundwater levels from two monitoring wells (shallow and deep) approximately 2,500 feet from the Elias Replacement Well will be posted for public viewing on the California Statewide Groundwater Elevation Monitoring (CASGEM) Program website. This is a public platform that gathers and posts groundwater level data from locations throughout the state, including multiple locations in Little Lake Valley. Interested parties can view the most recent data online at the California Department of Water Resources CASGEM portal. Additionally, the City will prepare an annual groundwater report based on this monitoring data for the period extending from April 15th – April 14th of the following year. This report will be presented to Council at the second meeting in May of each year. The focus of this report will be the City’s use of groundwater and the effects of pumping on groundwater levels.

The fourth element of the plan addresses water quality testing. This section discusses the testing regimen established by the Division of Drinking Water. Arsenic has not been detected in the Elias Replacement Well and the City is currently required to test for it every three years; however, as a responsible practice, the City has elected to test for this constituent quarterly.

The fifth and final element establishes an annual review of the plan following the release of the annual groundwater report. The purpose of this annual review is to determine whether any adjustments to the plan are warranted.

This plan was vetted through the Water/Wastewater Committee, as well as Special Counsel Andrew Ramos; therefore, at this time, staff recommends the adoption of the ISMND without further modification and conditional approval the project with the adoption of the groundwater operational use plan, which establishes parameters for the use of the groundwater system.

Since the February 9th public hearing, the City received three additional comment letters. Those letters are included in the Council packet. The letters generally request that the City revise the ISMND to include new analysis and adoption of the Groundwater Operational Use Plan as a project mitigation measure. City staff and consultants have reviewed the letters and determined that CEQA does not require further revisions to the ISMND because: (1) The ISMND and Plan serve different functions, and the ISMND has already sufficiently analyzed all potential environmental impacts of the Project; and (2) Further revisions to the ISMND would create delays that could jeopardize completion of the Project this year. Furthermore, the recommended adoption of the Groundwater Operational Use Plan as a condition of Project approval may address the commenters’ concerns regarding the City’s use of groundwater.

The agenda summary presented at the first part of the public hearing held on February 9th is attached for Council reference. The previous agenda summary details the project and the contents of the ISMND. Also attached, is a resolution to approve the ISMND and Mitigation Monitoring Plan and the project with the condition of adopting the Groundwater Operational Use Plan which establishes the policy for using the groundwater system.

Further attachments include: the ISMND, the Groundwater Operational Use Plan, public comments received during the circulation of the ISMND, in addition to comments received after the public hearing on February 9th.

Recommended Action: Conduct a public hearing and adopt a resolution approving the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for the Groundwater Resiliency Improvement Project and conditionally approve the project with the adoption of the Groundwater Operational Use Plan establishing parameters for the use of the groundwater system.

Alternative(s): None
Fiscal Impact: None
Personnel Impact: Some staff time will be required to file a Notice of Determination and finalize the plan.

Reviewed by: City Manager City Attorney Assistant City Manager City Clerk Finance Director Human Resources Risk
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________ Resolution No. 2022-__ Page 1 of 9 April 13, 2022
RESOLUTION 2022-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS ADOPTING AN INITIAL

STUDY/MITIGATED NEGATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING

PROGRAM (MMRP) FOR THE CITY OF WILLITS GROUNDWATER RESILIENCY IMPROVEMENTS

PROJECT, AND CONDITIONALLY APPROVE THE PROJECT WITH THE ADOPTION OF THE GROUNDWATER OPERATIONAL USE PLAN.

WHEREAS, the City of Willits proposes improvements to the existing Willits Groundwater System in order to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes compromised; and WHEREAS, the proposed Project would be located on City-owned parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030-06, and 108-020-05, which currently accommodate the Willits Groundwater System, including the Elias Replacement Well and Groundwater Treatment Plant, and is located adjacent to the City’s Sewer Plant; and
WHEREAS, the City prepared an Initial Study/Mitigated Negative Declaration for the proposed Project consistent with CEQA Guidelines Section 15063; and WHEREAS, an Initial Study/Mitigated Negative Declaration was circulated for public review from December 29, 2020 to January 28, 2021 (State Clearinghouse No. 2020120527); and WHEREAS, the City revised the Initial Study/Mitigated Negative Declaration in response to comments received during the public review period and circulated a Revised Initial Study/Mitigated Negative Declaration for public review from September 10, 2021 to October 11, 2021; and WHEREAS, the City of Willits received 11 written comments from the public, and the City has considered the comments received during the public review process; and WHEREAS, the City of Willits revised the Initial Study/Mitigated Negative Declaration in response to comments received during the public review period; and WHEREAS, the new project revisions, were added in response to written comments on the project’s effects identified in the Revised Initial Study/Mitigated Negative Declaration and are not new avoidable significant effects, in accordance with CEQA Guidelines Section 15073.5(c)(2), recirculation of the Revised Initial Study/Mitigated Negative Declaration is not required; and WHEREAS, a Mitigation Monitoring and Reporting Program, attached hereto as Exhibit “A”, has been prepared based upon the Initial Study/Mitigated Negative Declaration, consistent with the requirements Public Resources Code Section 21081.6, listing all mitigations measures, parties responsible for implementation, and time frames for implementation; and WHEREAS, pursuant to CEQA Guidelines Section 15074, all documents and files which constitute the record of all proceedings upon which the decisions associated with the project are on file with the City of Willits Engineering Department and electronically on the City’s website; and WHEREAS, in accordance with applicable provision of law, the City Council, held a public hearing on, February 9, 2022, which was held over to allow staff to prepare a Groundwater Operational Use Plan, establishing conditions in which the groundwater system will be utilized, and the public meeting was subsequently continued on April 13, 2022, at which time, the Plan was presented as a condition of the approval of the project, and City Council heard and received all relevant testimony and evidence presented orally or in writing regarding the Project; and
Resolution No. 2022-__ Page 2 of 9 April 13, 2022
WHEREAS, adoption of the Plan as a condition of approving the Project would not create new significant environmental effects and is not necessary to mitigate an avoidable significant effect of the Project, therefore, in accordance with CEQA Guidelines Section 15073.5(c)(3), recirculation of the Revised Initial Study/Mitigated Negative Declaration is not required; and WHEREAS, all interested persons were given an opportunity to hear and be heard regarding the Project; and
WHEREAS, the Willits City Council reviewed this Resolution and finds that it accurately sets forth the intentions of the City Council regarding the Project and makes the following findings:

NOW, THEREFORE BE IT RESOLVED, that the City Council of the City of Willits makes the following findings:

1. The Initial Study/Mitigated Negative Declaration has been properly prepared, circulated, and recirculated for public review in accordance with CEQA.

2. The Council has reviewed the Initial Study/Mitigated Negative Declaration and considered the document and all comments received before making a decision on the Project.

3. Pursuant to CEQA Guidelines Section 15073.5, there have been no substantial revisions to the current Initial Study/Mitigated Negative Declaration after public notice of its availability requiring recirculation of the document.

4. On the basis of the whole record before it, including the Initial Study/Mitigated Negative Declaration and comments received therein, the Council finds that there will be no significant environmental effects resulting from the Project or the Plan, provided that mitigation measures identified in the Initial Study/Mitigated Negative Declaration are incorporated into the Project.

5. The Initial Study/Mitigated Negative Declaration reflects the City’s independent judgment and analysis of the potential environmental effects of the project.

6. The project has been processed in accordance with the applicable provisions of CEQA. All noticing and review periods required by CEQA have been satisfied.

BE IT FURTHER RESOLVED, that the City Council of the City of Willits hereby adopts the Initial Study/Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program for the Groundwater Resiliency Improvement Project attached hereto as Exhibit “A”, and further conditionally approves the Project with the adoption of the Groundwater Operational Use Plan, which established parameters by which the groundwater system can be utilized; and The City Council directs the City Manager or his designee to prepare and file a Notice of Determination for the Initial Study/Mitigated Negative Declaration, the associated Mitigation Monitoring and Reporting Program, the Project and the Groundwater Operational Use Plan.

The above and foregoing Resolution was introduced by Councilmember __________ seconded by Councilmember ____________ and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the, 13th day of April, 2022, by the following vote:

AYES:

NOES:

ABSENT:

Resolution No. 2022-__ Page 3 of 9 April 13, 2022
_________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits
ATTEST:
_________________________

DELORES PEDERSEN
City Clerk
Resolution No. 2022-__ Page 4 of 9 April 13, 2022

EXHIBIT A
Mitigation Monitoring and Reporting Program
City of Willits
Groundwater Resiliency Improvements Project
Impact Mitigation Measure Implementation
Responsibility
Monitoring/
Reporting
Responsibility
Timing
Biological
Resources
BIO-1: Prior to the start of construction, specific project locations that are associated with listed species and
sensitive habitats will be identified and designated as Environmentally Sensitive Areas (ESAs) using highvisibility orange fencing, flagging and signage, or silt fencing. This applies specifically to areas with Baker’s meadowfoam and to the Oregon ash, valley oak, and other native trees within the project study area. ESAs shall be shown on project design plans or maps to be provided to construction personnel. The ESA fencing shall remain in place throughout the duration of the project related
construction activities to prevent the encroachment of
construction equipment/personnel into sensitive areas.

Only the minimum area needed for vehicle access and the placement of side cast material shall be allowed; areas that are to be avoided shall be identified as ESAs. To the extent feasible, construction access, staging, storage, and parking areas shall be located in upland areas and outside of any designated ESA.

The bid package special provisions shall clearly describe acceptable fencing material and prohibited constructionrelated activities, vehicle operation, material and equipment storage, and other surface-disturbing activities within ESAs. The final project plans shall depict all locations where ESA fencing or flagging and signage would be
installed and how it would be installed.

Project
Contractor &
Project Engineer
City of Willits Prior to
Construction
Resolution No. 2022-__ Page 5 of 9 April 13, 2022
Biological
Resources
BIO-2: Areas containing Baker's meadowfoam shall be
protected with temporary fencing during construction, and these areas shall be avoided during construction. There shall be no side cast soil material placed in areas fenced for Baker’s meadowfoam protection.

Project
Contractor City of Willits Prior to
Construction
Biological
Resources
BIO-3: To reduce the potential for the take of migratory birds, including passerines and raptors, and roosting bats, ground and noise disturbance within 100 feet of the on-site trees shall be timed to occur during the nonnesting/roosting season, from September 1 to October 15.

If these seasonal work restrictions cannot be adhered to, the following measures shall be performed in order to avoid or minimize impacts to passerines and raptors that may
potentially nest, and bats that may potentially roost, in the project area:
• A pre-construction nesting bird (both passerine
and raptor) survey of the grasslands and adjacent
trees shall be performed by a qualified biologist
within seven (7) days of ground breaking. If no
nesting birds are observed no further action is
required and grading shall occur within one (1)
week of the survey to prevent “take” of individual
birds that could begin nesting after the survey.

Inactive bird nests, other than those of eagles and
threatened or endangered species, may be
removed.
• A bat habitat assessment of the adjacent trees for
both foliage and cavity roosting bats shall be
conducted by a qualified bat biologist within 14
days of the start of construction.
• If active bird nests (either passerine and/or raptor) or bat roosts are observed during the preconstruction survey, a disturbance-free buffer zone shall be established around the nest/roost
tree(s) until the young have fledged or the roosting
has ceased, as determined by a qualified
biologist.

Project
Contractor &
Qualified
Biologist
City of Willits Prior to
Construction
Resolution No. 2022-__ Page 6 of 9 April 13, 2022
• The radius of the required buffer zone can vary
depending on the species (i.e., 75-100 feet for
passerines and bats, and 200-300 feet for
raptors), with the dimensions of any required
buffer zones to be determined by a qualified
biologist in consultation with CDFW.
• To delineate the buffer zone around a nesting
tree, orange construction fencing shall be placed
at the specified radius from the base of the tree
within which no machinery or workers shall
intrude. After the fencing is in place, there will be
no restrictions on grading or construction activities
outside the prescribed buffer zones.
• Work buffers or construction delays shall be
implemented until all birds have fledged.

Biological
Resources
BIO-4: Prior to the start of construction, specific project locations where native trees and/or their root systems
cannot be avoided by vehicle traffic and construction
equipment, and/or would be utilized for the placement of side cast material, shall have rubber mats or other ground protection placed to minimize soil and root disturbance by vehicle traffic and construction equipment. The bid
package special provisions shall clearly describe
acceptable ground protection material and the final project plans shall clearly depict how and where the ground
protection measures shall be installed. After construction is complete, the ground protection measures shall be
removed, and the areas reseeded, as needed.

Project
Contractor &
Project Engineer
City of Willits Prior to
Construction
Biological
Resources
BIO-5: Before construction activities begin, a qualified biologist shall conduct an education program for all
construction personnel. The training shall include a
description of special status species, including state listed species and associated habitats with potential to occur in the project study area; an explanation of the status of these species and their protection under the California
Endangered Species Act (CESA); the measures to
conserve listed species and their habitats as they relate to Qualified
Biologist City of Willits Prior to
Construction
Resolution No. 2022-__ Page 7 of 9 April 13, 2022
the work being done; proper soil excavation and
replacement techniques; and boundaries within which
construction may occur. A fact sheet conveying this
information will be prepared and distributed to all
construction crews. Upon completion of the program,
personnel shall sign a form stating that they attended the program and understand all of the project mitigation
measures and implications of subject regulations.

Biological
Resources
BIO-6: A Section 404 permit from the U.S. Army Corps of Engineers (USACE) and a Section 401 Water Quality
Certification from the North Coast Regional Water Quality Control Board (NCRWQCB) shall be obtained for impacts
to wetlands, if required by the respective agencies. If required, these permits shall be obtained prior to
implementation of the project. The project shall be
designed to result in no net loss of functions and values of the existing wetlands by incorporating the following impact minimization measures:
• Vehicles and construction equipment shall be
rubber tired, to the extent feasible.
• Ground-protection measures, as described in
Mitigation Measure BIO-4, shall be placed in turnaround areas for vehicles and construction equipment to prevent the removal of vegetation
and soil disturbance.
• Where excavation occurs, soil shall be removed
in lifts with the top 8 to 12 inches of topsoil
removed and cast to one side and the remaining
subsoil placed separately such that when the
access hole is refilled the topsoil, along with all
the seeds, will be in the same position in the soil
profile, thus allowing for quick reestablishment of
existing species and reestablishment of the
wetland functions and values.
• Following construction, the approximate and
original contours of the disturbed areas shall be
restored to pre-project conditions, to the extent
Project
Contractor &
Project Engineer
City of Willits
Prior to
Construction,
During
Construction, Post
Construction
Resolution No. 2022-__ Page 8 of 9 April 13, 2022
feasible, and any areas of bare soil shall be
seeded with a native grass seed mixture
comprised of species known to occur in the area.

Biological
Resources
BIO-7: To prevent the inadvertent entrapment of animals during construction, all excavated, steep-walled access holes more than 1-foot deep shall be covered at the close of each working day with plywood or other suitable
material(s) or provided with one or more escape ramps
constructed of earth fill or wooden planks. Before such holes are filled, they must be thoroughly inspected for trapped animals. All replacement pipes, culverts, or similar structures stored overnight will be inspected before they are subsequently moved, capped, and/or buried. If at any time a listed species is discovered, the contractor and qualified biologist shall be immediately informed. The
animal shall be allowed to move out of the area on its own volition or until the qualified biologist notifies the contractor to resume work in the area.

Project
Contractor &
Qualified
Biologist
City of Willits During Construction
Cultural
Resources
CUL-1: In the event archaeological resources or cultural resources, including human remains, are inadvertently
unearthed or discovered during construction, the contractor shall immediately halt all grading/land-clearing activities and contact the City of Willits Community Development
Department (CDD). All activity in the vicinity of the
resources shall cease until it can be evaluated by a
qualified archaeologist and a Native American
representative. If the archaeologist and Native American representative determine that the resources may be
significant, they shall notify the CDD and develop an
appropriate treatment plan for the resources. The
archaeologist shall consult with Native American
representatives in determining appropriate treatment for prehistoric or Native American cultural resources. In
considering any suggested mitigation proposed by the
archaeologist and Native American representative, the
CDD will determine whether avoidance is necessary and
feasible in light of factors such as the nature of the find, Project
Contractor City of Willits During Construction
Resolution No. 2022-__ Page 9 of 9 April 13, 2022
project design, costs, and other considerations. If
avoidance is infeasible, other appropriate measures (e.g., data recovery) will be instituted. Work may proceed in other parts of the project area while mitigation for cultural resources is being carried out.

Cultural
Resources
CUL-2: A note shall be placed on all grading plans that the project contractor and/or the City shall notify a qualified cultural monitor with general knowledge of the project area prior to any excavation for the purposes of installing the proposed water line, and agree to open the Site to the
cultural monitor to oversee the subsurface construction activities in order to ensure appropriate treatment of any artifacts uncovered.

Project
Contractor &
Project Engineer
City of Willits
Prior to
Construction,
During Construction
Geology and
Soils
GEO-1: The proposed clear well installation shall comply with the recommendations pertaining to site preparation and grading, foundation, seismic design parameters,
construction considerations, and future geotechnical
services provided in the Soils Report, prepared by LACO Associates and dated June 30, 2020 (see Appendix D).

Prior to construction of the project, the City of Willits Engineering Department shall review and approve of the
site development plans, which must demonstrate project
compliance with the recommendations of the Soils Report (LACO, 2020), in addition to any seismic requirements of the latest adopted edition of the CBC. All on‐site
geotechnical engineering activities shall be conducted
under the supervision of a licensed Geotechnical Engineer or Certified Engineering Geologist.

Project
Contractor &
Project Engineer
City of Willits
Prior to
Construction,
During Construction
Hydrology and
Water Quality
HYDRO-1: In the event groundwater is encountered during foundation excavation activities, the contractor shall
dewater the excavation area prior to placing concrete.

Extracted groundwater shall be discharged in a manner
that does not cause erosion at the discharge point. Any dewatering activities on-site shall be conducted under the supervision of a Qualified Stormwater Practitioner (QSP).

Project
Contractor City of Willits During Construction

ATTACHMENT

AGENDA SUMMARY FROM FIRST PART OF PUBLIC HEARING
Item No. 3a
Meeting Date: February 9, 2022

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Rod Wilburn, PE, Consulting City Engineer
Agenda Title: PUBLIC HEARING – DISCUSSION AND POSSIBLE ACTION APPROVING A

RESOLUTION TO ADOPT AN INITIAL STUDY/MITIGATED NEGATIVE DECLARATION AND

MITIGATION MONITORING PLAN FOR THE CITY OF WILLITS GROUNDWATER RESILIENCY IMPROVEMENTS PROJECT AND APPROVE SAID PROJECT.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 30 min.

Summary of Request: The City of Willits’ past reliance on the singular source of surface water made the City especially vulnerable to prolonged drought situations and potential emergency situations in which the surface water supply was unattainable, either via earthquake or other uncontrollable circumstances. In early 2014, the City faced such an event, when due to lack of rain; the City had a less than a 90-day supply of water left in the reservoirs. At that time Stage 5 water conservation measures were implemented and work began on an emergency project to supply the City with a secondary source of water from groundwater resources. This project was successful in providing a portion of the water needed to supply the City in an emergency; however, it laid the foundation for further improvements to increase capacity and act as a fully redundant secondary source of water for the City in the event that such an emergency presented itself in the future. Under present circumstances, the City remains vulnerable to emergency circumstances; therefore, it is recommended that the City considers making these improvements to provide resiliency to such circumstances.

For the City Council’s consideration this evening, is the approval of a proposed project to improve the existing Willits Groundwater System and adoption of the proposed project’s environmental review document. The purpose of the project is to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes untenable.

The proposed project is located northeast of the City center on City-owned parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030-06, and 108-020-05 (Site). The Site currently contains the Willits Groundwater System, including the Elias Replacement Well and Groundwater Treatment Plant, which is located adjacent to the City’s Wastewater Plant. Proposed improvements include: the installation of 3,600 lineal feet of new water line and the abandonment of 3,600 lineal feet of existing water line within the Willits Groundwater System, the removal of the existing 30-horsepower pump in the Elias Replacement Well and the installation of a 40-horsepower pump in the Elias Replacement Well, the installation of a 250,000-gallon clear well (chlorine contact tank) adjacent to the west of the groundwater treatment plant and the installation of a booster pump at the clear well.

In December 2020, the City prepared and circulated a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) for the proposed project. The Draft IS/MND was submitted to the State Clearinghouse (SCH No. 2020120527) and circulated for public review and comment from December 29, 2020 to January 28, 2021. Following circulation of the Draft IS/MND and the receipt of comments, the City revised the Draft IS/MND to include additional detail on the proposed improvements, the City’s water

ATTACHMENT

AGENDA SUMMARY FROM FIRST PART OF PUBLIC HEARING
use, the City’s existing wells and monitoring practices, and the conditions of the Little Lake Valley groundwater basin. The City subsequently recirculated a Revised Draft IS/MND for public review and comment from September 10, 2021 to October 11, 2021. Following the recirculation of the Draft IS/MND and the receipt of additional comments, the City revised the IS/MND by removing the Long 20 Well from the project. As discussed in the IS/MND, the project has the potential to cause significant impacts to Biological Resources, Cultural Resources, Geology and Soils, Hydrology and Water Quality, Tribal Cultural Resources, and Mandatory Findings of Significance. However, with implementation of the mitigation measures described in the IS/MND and provided in the Mitigation Monitoring and Reporting Program (MMRP), the potential impacts will be reduced to less than significant levels.

CEQA does not require the City to prepare individual responses to comments as part of considering an IS/MND. The following summary responses respond to the most frequent themes raised by the public comments and are grouped into three main categories: 1) Overdraft of the aquifer and groundwater monitoring; 2) Growth inducement; and 3) Potential impacts to the bypass mitigation project. Comments related to arsenic in the Long 20 Well were addressed by removing the Long 20 from the project.

1. Overdraft of the Aquifer and Groundwater Monitoring.

The groundwater capacity in the basin is estimated to be anywhere between 35,000 acre-feet to 91,600 acre-feet and the Little Lake Basin is classified as very low priority based on the following evaluation criteria; 1) The population overlying the basin or subbasin; 2) The rate of current and projected growth of the population overlying the basin or subbasin; 3) The total number of public supply wells that draw from the basin or subbasin; 4) The total number of wells that draw from the basin or subbasin; 5) The irrigated acreage overlying the basin or subbasin; 6) The degree to which persons overlying the basin or subbasin rely on groundwater as their primary source of water; 7) Any documented impacts on the groundwater within the basin or subbasin, including overdraft, subsidence, saline intrusion, and other water quality degradation; and 8) Any other information determined to be relevant by the department, including adverse impacts on local habitat and local stream flows (Water Code Sec. 10933 b). Low and very low priority groundwater basins “have few people, limited irrigation, and little to no groundwater use” (California Groundwater Elevation Monitoring Basin Prioritization Process, June 2014). Past studies of the basin, which are discussed in the IS/MND, have shown that the basin is healthy and generally recharges regularly from groundwater pumping.

The City’s total water consumption of treated or potable water was 868.7 acre-feet in 2019 and 718 acrefeet in 2020. The groundwater consumption of water treated at the Groundwater Treatment Plant was

41.7 acre-feet in 2019 and zero in 2020 due to maintenance issues. The City’s total water usage is a small fraction of the published storage capacity of the Little Lake Groundwater Basin. The Project proposes a conjunctive use of surface water and groundwater, but the surface water source could be compromised due to drought, vandalism, a major seismic event, wildfire, contamination, land slide, terrorism, or any number of events that could damage the single water main that connects the surface water treatment plant to the City.

Based on storage capacity of the aquifer, the basin’s ability to recharge from pumping, and the historical water demands by the City residents, the City’s additional use of groundwater for its conjunctive use program will not have a significant impact under CEQA. The City currently monitors several wells that are within its control and will look to gather additional well data from surrounding wells when available.

Coordination with the other stakeholders in the Little Lake Basin like the County of Mendocino is critical to this monitoring effort by the City as the City strives to build on its understanding of the groundwater quantity and quality in the basin.

2. Growth Inducement.

Some commenters were concerned that the project could have growth-inducing impacts. However, the project will not have a significant impact on this issue under CEQA because City growth is constricted by its storage facilities, and those facilities will not be impacted by the project. The State of California

ATTACHMENT

AGENDA SUMMARY FROM FIRST PART OF PUBLIC HEARING
Division of drinking water calculates the number of water service connections the City has the capacity to support based on the water storage tank volumes within the City’s distribution system. The 1.5-milliongallon chlorine contact tank at the surface water treatment plant is not included in this calculation because it is considered part of the treatment process. For this same reason the 250,000-gallon chlorine contact tank proposed as part of this Project will not be included in future capacity calculations. The storage capacity of Morris and Centennial Reservoirs is not a factor in the calculation of connection capacity, the only question associated with the reservoirs is whether they have the capacity to fill the storage tanks and keep them full throughout a given year. For this same reason the amount of groundwater that can be pumped at the Elias Replacement well would not be a value included in the calculation of the number of water service connections that can be supported by the City. Therefore, this project is not considered growth inducing.

3. Potential Impacts to the Bypass Mitigation Project.

In 2013 and 2014 the City had extensive correspondence with the California Department of Fish and Wildlife (CDFW) pertaining to the possible hydraulic connectivity between the Elias Well and Outlet Creek. The City was proposing to turn the Elias Well into a public water source and CDFW was concerned about impacts to surface water and, by relation, first encountered groundwater. The City was able to prove to CDFW through aquifer tests and data analysis that there is no hydraulic connectivity between the Elias Well and Outlet Creek, which would include surface water and first encountered groundwater. Based on this analysis, the installation of the Elias Replacement Well was able to move forward.

The potential impacts to the Mitigation Project would not be significant because it is our understanding that the Mitigation Project is comprised of wetlands creations and tree plantings that are dependent on surface water and first encountered groundwater.

Attached for Council review are the following: IS/MND dated September 2021, written public comments received during the IS/MND circulation period, and a resolution to adopt the IS/MND and MMRP and approve the project.

Recommended Action: Conduct a public hearing and adopt a Resolution adopting the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program and approve said project.

Alternative(s): None
Fiscal Impact: None
Personnel Impact: Some staff time will be required to finalize and submit the plan.

Reviewed by: City Manager City Attorney City Clerk Finance Director Human Resources Risk
Council Action: Approved Denied Other:
________________________________________
Records: Agreement Resolution #_________ Ordinance #_________ Other _________
1 Groundwater Operational Use Plan
City of Willits Groundwater Resiliency Improvement Project Per City Council direction, the Groundwater Operational Use Plan is proposed to provide guidelines for operations of the City of Willits groundwater treatment plant and the use of the City’s Elias Replacement Well. More specifically, this plan would regulate the use of groundwater to supplement the City’s water system both routinely and during emergency circumstances. The City recognizes the benefits of utilizing this valuable resource, and is committed to using the groundwater treatment plant responsibly to benefit the City water consumers, while not adversely affecting the beneficial use of the wells in the vicinity of the Elias Replacement well.

This plan establishes guidelines for the use of the groundwater treatment plant based on operational circumstances and is meant to employ adaptive management techniques, in which groundwater levels are monitored to better understand the aquifer characteristics. The guidelines established in this plan will be reassessed in the future in conjunction with groundwater monitoring data to determine whether the guidelines need to be adapted so as to better manage the resource.  ALLOWABLE CIRCUMSTANCES FOR USE OF THE GROUNDWATER SYSTEM  During emergency events when the Public Works Director determines there is a risk to surface water or additional supplies are necessary to offset the emergency. The Public Works Director and/or City Manager will advise the City Council of the emergency at the first viable opportunity.
 During routine annual flushing of the distribution system to reduce brown water issues and provide clean water to the residents and business owners of Willits.  During maintenance activities related to the reservoirs, the surface water treatment plant, the distribution infrastructure, or other water system maintenance where the Public Works Director or Chief Plant Operator determines that the water supply for the community must be supplemented by groundwater.
111 E. Commercial Street
Willits, California 95490
Tel | 707.459.4601
Fax | 707.459.1562
www.cityofwillits.org
Gateway to the Redwoods

ATTACHMENT

GROUNDWATER OPERATIONAL USE PLAN
2  Regular operation of the groundwater plant to exercise the equipment, ensure operational integrity, and to ensure that groundwater is available should an emergency arise. The City Council has the discretion to use groundwater to prevent emergencies, address specific events, or when the Council determines the use of groundwater is necessary to support needs of the community.  To supplement the use of surface water for any major fires that could affect the community and surrounding areas.
 USE GUIDELINES
 Average monthly use will be 10.9 million gallons unless an emergency situation occurs, or regular operations and maintenance of the City’s water system requires the City to use in excess of that amount. Annual groundwater usage would not exceed 400 acre-feet for domestic purposes, consistent with the current permitted and approved operations threshold. Council would be apprised of the circumstances causing the increased usage and provided with a plan for groundwater usage should the need continue.
 GROUNDWATER LEVEL MONITORING
 The City will continue groundwater level monitoring, with a focus on monitoring wells within close proximity to the Elias Replacement Well. This effort would be aimed at monitoring the effects of the City’s pumping activities to ensure the ongoing beneficial use of neighboring wells. As part of this effort shallow wells will be included to ensure that the City’s pumping activities are not drawing on surface water.
 The City will coordinate groundwater monitoring efforts with the Mendocino County Resource Conservation District (MCRCD) to collect additional information from the City’s closest neighboring wells.
 Monitoring data from the Long 20 monitoring well & a shallow well in close proximity to the Long 20 well will be published on CASGEM, a statewide groundwater monitoring program that is available for public viewing.  An annual groundwater report will be prepared for the City Council at the second meeting in May of each year and will include groundwater data from April 15-April 14th of the past year. The report will be focused on the City’s use and effects.  TESTING
 Quarterly: Iron, Manganese and Arsenic in raw and treated water. There is no detectable arsenic in the Elias Replacement Well or the Elias Well. However, as a responsible practice, the City has decided to test for arsenic on a quarterly basis rather than every three years as required by the Division of Drinking Water.  Annually: Nitrates.

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GROUNDWATER OPERATIONAL USE PLAN
3  The City will continue to conduct the testing regimen as required by the Division of Drinking Water under the City’s Domestic Water Supply Permit No. 02-03- 16P2310004.
 ANNUAL PLAN REVIEW
 Following the release of the annual groundwater report, the City will revisit this Plan to determine if any changes are warranted.

ATTACHMENT

GROUNDWATER OPERATIONAL USE PLAN
REVISED DRAFT INITIAL STUDY and ENVIRONMENTAL

CHECKLIST
FOR

CITY OF WILLITS GROUNDWATER RESILIENCY IMPROVEMENTS

PROJECT
December 2020 ~ Revised January 2022
Lead Agency:

City of Willits
Lead Agency Contact:

City of Willits
Engineering Department
111 E. Commercial Street, Willits, California 95490
[email protected]
Prepared by:

LACO Associates
1072 N. State Street
Ukiah, California 95482
(707) 462-0222
LACO Project No.: 8509.08
State Clearinghouse No.: 2020120527

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DRAFT ISMND

TABLE OF CONTENTS
I. PROJECT SUMMARY ................................................................................................................................. 1 II. PROJECT DESCRIPTION ............................................................................................................................ 4 III. PROJECT SETTING AND LOCATION ....................................................................................................... 6 IV. ENVIRONMENTAL EFFECTS ..................................................................................................................... 6 V. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ........................................................................... 7 VI. REFERENCES ..........................................................................................................................................67

FIGURES AND APPENDICES
Figure 1: Site Vicinity Map
Figure 2: Project Overview
Figure 3: City of Willits Land Use Map
Figure 4: City of Willits Zoning Map
Figure 5: County of Mendocino Land Use Map
Figure 6: County of Mendocino Zoning Map
Appendix A: Mitigation Monitoring and Reporting Program (MMRP) Appendix B: Cultural Resources Correspondence
Appendix C: Habitat Assessment, prepared by Wildlife Research Associates and Jane Valerius Environmental Consulting, December 3, 2020
Appendix D: Soils Report, prepared by LACO Associates, June 30, 2020

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
I. PROJECT SUMMARY
Date: December 2020 ~ Revised January 2022
Project Title: City of Willits Groundwater Resiliency Improvements Project Lead Agency: City of Willits
Contact: Rod Wilburn, Consulting City Engineer, LACO Associates City of Willits
Engineering Department
380 E. Commercial Street, Willits, California 95490
[email protected]
Location: The proposed project is located northeast of the City of Willits (City) center on Cityowned parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030- 06, and 108-020-05 (Site) (see Figure 1). The Site is currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant (see Figure 2).

Coastal Zone: No
Affected Parcel(s): Assessor’s Parcel Number(s) 007-010-01, 108-030-06, and 108-020-05 APN 007-010-01 City of Willits Land Use Designation: Industrial-General (M-G) (see Figure 3) APN 007-010-01 City of Willits Zoning Designation: Heavy Industrial (MH) (see Figure 4)

APNs 108-030-06 and 108-020-05 County of Mendocino Land Use Designation: Agricultural Lands (AG) (see Figure 5)
APNs 108-030-06 and 108-020-05 County of Mendocino Zoning Designation: Agricultural Lands (AG) (see Figure 6)
Anticipated Permits and Approvals:
1) Adoption of Mitigated Negative Declaration (MND) by the City of Willits 2) Section 401 Water Quality Certification (WQC) through the North Coast Regional Water Quality Control Board (NCRWQCB)
3) Section 404 Nationwide Permit (NWP) through the U.S. Army Corps of Engineers (USACE) Tribal Cultural Resources: Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.? On March 12, 2020, in compliance with Assembly Bill (AB) 52, the City of Willits (City), sent consultation letters to the Middletown Rancheria Band of Pomo Indians and the Torres Martinez Desert Cahuilla Indians, two (2) Native American tribes that are traditionally and culturally affiliated to the project area and whom had previously requested notification of projects in the tribes’ area of traditional and cultural affiliation pursuant to AB 52. No responses were received. On June 23, 2020, the City sent additional AB 52 consultation letters

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
to each of the 13 Tribal representatives provided to the City of Willits on the Native American Heritage Commission (NAHC) Native American Contacts List dated October 28, 2019, including the EPA Director and Chairperson of the Cahto Tribe; the Chairpersons of the Coyote Valley Band of Pomo Indians, Guidiville Band of Pomo Indians, Hopland Band of Pomo Indians, Kashia Band of Pomo Indians of the Stewards Point Rancheria, Manchester Band of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, Sherwood Valley Band of Pomo Indians; and the President of the Round Valley Reservation/Covelo Indian Community. No requests for consultation were received from any of the 18 Native American tribes that were sent formal notification of the project in compliance with AB 52, as noted above. As no requests for consultation were received within the 30 day deadline specified by Public Resources Code Section 21082.3 (d), the City, as Lead Agency, has deemed the Tribal consultation process complete. A copy of the NAHC Native American Contacts List is included in Appendix B.

CEQA Requirement:

The proposed project is subject to the requirements of the California Environmental Quality Act (CEQA). The Lead Agency is the City of Willits. The purpose of this Initial Study (IS) is to provide a basis for determining whether to prepare an Environmental Impact Report (EIR) or a Negative Declaration. This IS is intended to satisfy the requirements of the CEQA (Public Resources Code, Div. 13, Sec. 21000-21177) and the State CEQA Guidelines (California Code of Regulations, Title 14, Sec 15000-15387).

CEQA encourages lead agencies and applicants to modify their projects to avoid significant adverse impacts (CEQA Section 20180(c) (2) and State CEQA Guidelines Section 15070(b) (2)).

Section 15063(d) of the State CEQA Guidelines states that an IS shall contain the following information in brief form:
1) A description of the project including the project location 2) Identification of the environmental setting
3) Identification of environmental effects by use of a checklist, matrix, or other method, provided that entries on a checklist or other form are briefly explained to provide evidence to support the entries 4) Discussion of means to mitigate significant effects identified, if any 5) Examination of whether the project would be consistent with existing zoning, plans, and other applicable land use controls
6) The name of the person or persons who prepared and/or participated in the Initial Study CEQA Discussion:

In December 2020 the City of Willits (City) prepared and circulated a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) for the proposed project. The Draft IS/MND was submitted to the State Clearinghouse (SCH No. 2020120527) and circulated for public review and comment for a period of 30 days, beginning on December 29, 2020 and ending on January 28, 2021. Following circulation of the Draft IS/MND and the receipt of comments, the City revised the Draft IS/MND to include additional detail on the proposed improvements, the City’s water use, the City’s existing wells and monitoring practices, and the conditions of the Little Lake Valley groundwater basin. A Revised Draft IS/MND was submitted to the State Clearinghouse (SCH No. 2020120527) and circulated for public review and comment for a subsequent period of 30 days, beginning on September 10, 2021 and ending on October 11, 2021. Following circulation of the Revised Draft IS/MND and the receipt of comments, the City revised the project to remove the Long 20 well from the project and include an upgrade of the pump at the Elias replacement well. This Revised Draft IS/MND, dated January 2022, reflects the City’s decision to remove the Long 20 well from the project and upgrade the Elias replacement well pump.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
As the new project revisions, removal of the Long 20 well, were added in response to written comments on the project’s effects identified in the Draft IS/MND and are not new avoidable significant effects, in accordance with State CEQA Guidelines Section 15073.5(c)(2), recirculation of the Draft IS/MND is not required.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
II. PROJECT DESCRIPTION
The City of Willits (City) proposes improvements to the existing Willits Groundwater System in order to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes untenable. The proposed project would provide the City with the flexibility to manage water sources adaptively, considering factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health. The proposed project is located northeast of the City center on City-owned parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030-06, and 108-020-05 (Site). The Site is currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant.

Project Background
The majority of water utilized in the City water supply system is currently supplied from surface water reservoirs on the Davis Creek watershed: Morris Reservoir and the upstream Centennial Reservoir. Water from these sources is treated at the surface water treatment plant near Morris Reservoir and piped to the City and surrounding regions approximately 2.5 miles via a single 16-inch transmission line. The surface water treatment plant produced approximately 260.5 million gallons (799.5 acre-feet), for an average of 0.714 million gallons per day (MGD), in 2020, and approximately 269.4 million gallons (826.7 acre-feet), for an average of 0.738 MGD, in 2019. A 5-year average from 2016 to 2020 demonstrated that the surface water treatment plant produced approximately 19.8 gallons per month (or 781.4 gallons per minute) given an average operation time of 19.2 hours per day.

The City’s groundwater infrastructure includes the Elias replacement well, the groundwater treatment plant, and the Park well. The Elias replacement well is the only well connected to the City’s groundwater treatment plant and water supply system. The groundwater treatment plant produced 13 million gallons (41.7 acre-feet) in 2019, for an average of 0.036 MGD, primarily used during the flushing of the distribution system. The City did not treat and/or distribute any groundwater at the groundwater treatment plant in 2020. The Long 20 well currently serves as a monitoring well and is not currently connected to the groundwater treatment plant or water supply system. Water from the Park well is used by the City for irrigation, sold to private water truck owners, and used for construction, fire suppression and other miscellaneous uses. The Park well generated 8 million gallons (24.5 acre-feet), for an average of 0.022 MGD and 1.1 million gallons (3.4 acre-feet), for an average of 0.003 MGD, in 2020 and 2019, respectively.

Currently, the City does not have a policy nor the resources to monitor where and how the bulk, untreated water from the Park well is used. The City actively monitors groundwater levels in multiple locations and plans to create a more robust monitoring plan in coming years. In August 2021, the City installed two new monitoring wells near the Park well to gather data on the effects of Park well pumping on the surrounding groundwater levels. The City will continue to look for wells near its groundwater infrastructure that can be accessed and measured in order to gather important data as part of the aforementioned groundwater monitoring plan.

Project Need
The dependence of the City’s water supply system on a single surface source has made it vulnerable to water supply and/or water quality issues due to catastrophic failures and/or to severe or protracted drought. In 2014, the continuing drought led to a severe water shortage during which the City was forced to call for mandatory restrictions on water use and the need for alternative water supplies became evident. The drought not only placed a strain on the quantity of water available, but also impacted the

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
water quality as well. Reduced levels in the reservoirs led to increased temperatures and biological growth, including algae blooms. Such organics overwhelmed the system, leading to violations for total trihalomethanes (TTHM) over two periods in 2015. In response to the extreme drought conditions in 2014, the City developed the Willits Groundwater System as an emergency project to supply and treat supplementary groundwater during the drought. The Willits Groundwater System included construction of a new groundwater treatment plant and the installation of over 8,000 feet of new water line to connect the Elias replacement well to the distribution system. In 2017, non-emergency use of this groundwater supply was approved by the State Water Resources Control Board (SWRCB) Division of Drinking Water, providing the City with the ability to supplement the surface water supply with groundwater and increase water supply reliability throughout the year.

Peak water demand in the City occurs in summer months. Water use exceeds 1.0 MGD on the days with highest use, which typically occurs for approximately two weeks during the month of August. Thus, the water system must be able to deliver peak summer flows of 1.0 MGD to be considered minimally reliable, given current population and demand. Currently, the Willits Groundwater System can produce an absolute maximum of 0.49 MGD, a fraction of the peak demand in summer, during which time of year the effects of a drought would most impact the City’s water supply system (LACO, 2019). In the event that the surface water supply is compromised as it was in 2014, the City does not currently have the infrastructure necessary to fulfill the demand with groundwater.

In 2019, the City applied for and was awarded Department of Water Resources (DWR) funds through the North Coast Resource Partnership (NCRP) Proposition 1 Integrated Regional Water Management (IRWM) grant program for Phase 1 of this project, described below.

Proposed Improvements
Improvements would include the replacement of 3,600 feet of water line within the Willits Groundwater System, upgrading the existing 30 horsepower (hp) pump to a 40 hp pump at the Elias replacement well, and the installation of a 250,000-gallon clear well (chlorine contact tank) adjacent to the west of the groundwater treatment plant. The proposed improvements would be completed in two (2) phases, as described below. Once installed, these improvements would be maintained by existing City staff as part of ongoing maintenance and operation of the Willits Groundwater System.

Phase 1 – Water Line and Well Pump Replacement and Installation In Phase 1 of the project, a 3,600-foot section of 6-inch Schedule 40 PVC pipe connecting the Elias replacement well to the Willits Groundwater System would be upgraded to a 10-inch high density polyethylene (HDPE) pipe and the existing 30 hp pump at the Elias replacement well would be upgraded to a 40 hp pump to accommodate increased flows and increase transfer capacity from the well to the groundwater treatment plant.

The new water line would be placed within, or in close proximity to, the footprint of the existing water line, to be abandoned-in-place, which is located within the driveway utilized by City staff for ongoing maintenance and operation of the Willits Groundwater System. The new pipe would be installed in three stages using horizontal directional drilling technology. The first stage would require the excavation of access holes approximately 400 square feet in area. The drill rig would be positioned at each of the access holes and pivoted at an angle to drill down to approximately 7 feet deep. During the first stage, a small diameter pilot hole would be drilled along the designed drill path or pipeline alignment. The second stage would enlarge the pilot hole to accommodate the 10-inch pipe installation. The third and last stage would pull the 10-inch pipe back through the hole. Fittings would then be fused onto the pipe and connections

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
would be established between sections of new pipe and between sections of new pipe and the existing 8- inch C900 pipe on either end of the project. Up to eight (8) access holes would be excavated approximately 500 feet apart, with the potential for a slight deviation in spacing of the access holes anticipated during construction.

Phase 2 – Clear Well Installation
In Phase 2, a 250,000-gallon bolted or welded steel clear well (chlorine contact tank) would be installed to enhance the treatment and operability of the groundwater treatment system. The clear well is proposed to be installed adjacent to the west of the groundwater treatment plant on a compacted dirt surface within the footprint of existing development.

The clear well would store the treated and potable water prior to sending it to the water supply system. The existing groundwater treatment system is limited in its ability to pump water to the highest storage tank and customers in the water supply system because the pressure filters have a maximum pressure of 80 pounds per square inch (psi) (186 feet). As such, additional pumping would be necessary in the event that the groundwater treatment system would need to function as an alternative to the surface water treatment system. Adding a clear well tank after filtration will allow for installation of additional system pumps that can overcome the system head and not carry the risk of cavitation from inline booster pump installation.

Additionally, installation of a clear well tank will allow operators to make adjustments to chemical dosages and treatment, as needed, and better monitor the water quality of finished water prior to its delivery to the water supply system.

III. PROJECT SETTING AND LOCATION
The City of Willits (City) is a rural incorporated community of 5,128 people, according to the City of Willits 2019 Housing Element (City of Willits, 2019a), located near the center of Mendocino County, California, along Highway 101 (see Figure 1). The City owns and operates the public water system, which supplies potable water to an estimated 5,500 to 6,500 people in the City and surrounding communities. The project is located northeast of the City center on City-owned parcels, identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030-06, and 108-020-05 (Site). The Site is currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant (see Figure 2). While the Site is entirely owned by the City of Willits, the parcel identified by APN 007-010-01 is located within the City limits, and the parcels identified by APN 108-030-06 and 108-020-05 are located within the unincorporated area surrounding the City. Uses surrounding the project area described in Phase 1 of the project include vacant fields utilized for cattle grazing during the dry season, typically May to October. Uses surrounding the area proposed for improvements in Phase 2 include the City groundwater treatment system and sewer plant.

A Habitat Assessment was prepared by Wildlife Research Associates (WRA) and Jane Valerius Environmental Consulting (Jane Valerius) on December 3, 2020 (see Appendix C). The survey encompassed the northern portion of the Site, with a focus on the alignment of the water line replacement and installation proposed in Phase I. A broad biological review and wetland delineation survey were conducted within an approximately 2.6-acre limit of disturbance area and a 15.34-acre study area, with focused plant surveys conducted within the limit of disturbance area. Protocol level surveys for all special status plants with the potential to occur within the study area were conducted by Jane Valerius and Geri Hulse-Stephens from April to June 2020. On May 12, 2020, Trish Tatarian of WRA conducted a reconnaissance-level site visit intended as an evaluation of on-site and adjacent habitat types and included an evaluation of the Site for small mammal burrows and suitable potential habitat for nesting birds and roosting bats. In addition, on May 12, 2020, Jane Valerius conducted a formal wetland delineation in

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
accordance with the 1987 Wetlands Delineation Manual and the 2010 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coastal Region of the U.S. Army Corps of Engineers (USACE).

The assessment found that two vegetation communities (upland non-native grassland and seasonal wetlands) and three wildlife habitats (annual grasslands, valley foothill riparian, and fresh emergent wetland) occur within the study area. The majority of the Site, 14.02 acres, qualifies as a seasonal wetland, with approximately 1.32-acres of upland non-native grassland on the Site. Oregon ash trees occur along the fence lines and in small groves within the larger grassland areas, and are considered to provide a continuation of the valley foothill riparian habitat that exists along Outlet Creek.

Of the 21 special status plant species that have been reported in the Willits and Burbeck 7.5-minute topographic quadrangles, two special status plants, Baker’s meadowfoam, a California Rare (CR) and California Native Plant Society (CNPS) Rank 1B (rare, threatened, or endangered in California and elsewhere) plant, and Davy’s semaphore grass, a CNPS Rank 4 (plants of limited distribution) species, were observed in a portion of the seasonal wetlands. A total of 0.59 acres of Baker’s meadowfoam was mapped on-site, primarily in areas where vehicles or other disturbance have created ruts or depressions in the grasslands. Based on the habitats present, a total of ten (10) sensitive wildlife species were assessed for potential occurrence at the Site. The assessment determined that nesting passerines and raptors with nonsensitive status, but protected under the Migratory Bird Treaty Act (MBTA), and roosting bats, including the Western red bat (a CDFW Species of Special Concern), have the potential to occur within various habitats on-site. Several passerine species may nest in the grasslands, blackberry bushes, or trees on-site, depending on the species, while nesting raptors and roosting bats may occur in the trees.

Elevations at the Site range between approximately 1,323 feet and 1,353 feet above mean sea level. The majority of the Site is located within the 100-year flood zone (Zone A) of Outlet Creek, as shown on Federal Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) panel number 06045C1112F, effective June 2, 2011, with the clear well proposed to be located in an area designated as Zone AE, an area inundated by the one-percent annual chance flooding, for which Base Flood Elevations (BFEs) have been determined. The clear well will be located adjacent to the existing groundwater treatment plant which is currently located in the Regulatory Floodway, as shown on FIRM panel number 06045C1112F, effective June 2, 2011. The Site is located east of Outlet Creek and west of Davis Creek, both of which flow from south to north. Soils are mapped by Natural Resources Conservation Services (NRCS) as Fluvaquents soils, very deep, very poorly drained soils on flood plains, originating from recent alluvium derived from sedimentary rock (NRCS, 1997).

IV. ENVIRONMENTAL EFFECTS
An environmental checklist follows this section, and addresses all potential adverse effects resulting from the proposed project. No significant adverse effects are expected from any of the proposed activities.

V. 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” or "Potentially Significant Unless Mitigation Incorporated" as indicated by the checklists on the following pages.

Aesthetics Agriculture and Forestry
Resources Air Quality
X Biological Resources X Cultural Resources Energy

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
X Geology and Soils Greenhouse Gas Emissions Hazards and Hazardous Materials
X Hydrology and Water
Quality Land Use and Planning Mineral Resources
Noise Population and Housing Public Services
Recreation Transportation X Tribal Cultural Resources
Utilities and Service Systems Wildfire X
Mandatory Findings of
Significance
An explanation for all checklist responses is included, and all answers take into account the whole action involved and the following types of impacts: off-site and on-site; cumulative and project-level; indirect and direct; and construction and operational. The explanation of each issue identifies (a) the threshold of significance, if any, used to evaluate each question; and (b) the mitigation measure identified, if any, to reduce the impact to less than significance. The mitigation measures recommended for the project are included in Appendix A.

In the checklist the following definitions are used:
"Potentially Significant Impact" means there is substantial evidence that an effect may be significant.
"Less than Significant Impact with Mitigation Incorporated" means the incorporation of one or more mitigation measures can reduce the effect from potentially significant to a less than significant level.
“Less Than Significant Impact” means that the effect is less than significant and no mitigation is necessary to reduce the impact to a lesser level.
“No Impact” means that the effect does not apply to the proposed project, or clearly will not impact nor be impacted by the proposed project.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
I. AESTHETICS. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning
and other regulations governing scenic quality?
d) Create a new source of substantial light or glare,
which would adversely affect day or nighttime views
in the area?
Thresholds of Significance: The project would have a significant effect on aesthetics if it would have a substantial adverse effect on a scenic vista; substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway; substantially degrade the existing visual character or quality of public views of the site and its surroundings (if the project is in a non-urbanized area) or conflict with applicable zoning and other regulations governing scenic quality (if the project is in an urbanized area); or create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area.

DISCUSSION
The project involves improvements to the existing Willits Groundwater System in order to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes untenable. Improvements would include the replacement of 3,600 feet of water line within the Willits Groundwater System, and the installation of a 250,000-gallon clear well (chlorine contact tank) adjacent to the west of the groundwater treatment plant on a compacted dirt surface. Upon project completion, the only above-ground improvement that would remain visible would be the clear well. Access to the proposed improvements would be limited to normal business hours (7:00 am to 7:00 pm Monday through Saturday), or as required for the ongoing maintenance of the City sewer plant and Willits Groundwater System. No lighting is proposed.

I.a-b) The Site is comprised of vacant agricultural land utilized for cattle grazing during the dry season in the north and the groundwater treatment plant in the south and there are no designated scenic vistas in the vicinity of the Site. Furthermore, upon project completion, the only above-ground improvements that would remain visible would be the clear well. As noted above, the clear well would be located west of the existing groundwater treatment plant in close proximity to the City sewer plant. Per Chapter 4 of the 2009 Mendocino County General Plan (pg. 4-31), there are no officially designated State Scenic Highways in Mendocino County, although there are two designated State Scenic Byways through forests, which include the North Central Coast Heritage Corridor on State Route 1 and the Tahoe-Pacific Heritage Corridor encompassing sections of State Route 20 and Highway 101. While not officially designated as State Scenic Highways, Highway 20 through Mendocino County is eligible for designation and Highway 128, which passes through Yolo, Napa, Sonoma, and Mendocino Counties and is 140 miles long, was recently made eligible for designation under Assembly Bill (998) signed by Governor Gavin Newsom in July 2019. However, Highways 20 and 128 are not in the vicinity of the Site.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Since the Site is not a designated scenic vista, is not located in the vicinity of a designated scenic visit or state scenic highway, and visual changes would only be anticipated in the area of the existing groundwater treatment plant and sewer plant, the project would not impact a scenic vista, nor damage scenic resources or views along a state scenic highway. No impact would occur.

I.c) The proposed project has no physical elements that would block or impact views or substantially degrade the existing visual character or quality of public views of the Site and its surroundings as the project would be constructed within the footprint of existing development and would not modify views of the Site or surrounding area. The northern portion of the Site, which is currently surrounded by vacant agricultural land utilized for cattle grazing during the dry season, is not visible from public vantage points and the installation proposed improvements would not modify the existing visual character of the Site and its surroundings. The clear well structure, proposed in the southern portion of the Site, may be visible from a public vantage point; however, it would be located in an urbanized area that is developed with similar uses, including the City’s groundwater treatment plant and sewer plant. A less than significant impact would occur.

I.d) No new lighting is proposed as part of this project and no aspects of the project involve materials that would produce glare. Access to the site would be limited to normal business hours (7:00 am to 7:00 pm Monday through Saturday), or as required for the ongoing maintenance of the City sewer plant and Willits Groundwater System. Therefore, the project would have no impact on day or nighttime views due to light and glare. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less than Significant Impact on Aesthetics.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
II. AGRICULTURE AND FORESTRY RESOURCES. Would
the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g), timberland (as defined by PRC
section 4526), or timberland zoned Timberland
Production (as defined by Government Code section
51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use?
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forestland to non-forest use?
Thresholds of Significance: The project would have a significant effect on agriculture and forestry resources if it would convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (hereafter “farmland”), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural uses; conflict with existing zoning for agricultural use or a Williamson Act contract; conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g), timberland (as defined by PRC section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)); Result in the loss of forest land or conversion of forest land to non-forest use; or involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forestland to non-forest use.

DISCUSSION
The Site is located northeast of the City center on City-owned parcels currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant. While the Site is entirely owned by the City of Willits, the parcel identified by APN 007-010-01 is located within the City limits, while the parcels identified by APN 108-030-06 and 108-020-05 are located within the unincorporated area surrounding the City. Uses surrounding the project area described in Phase 1 of the project include vacant fields utilized for cattle grazing during the dry season, typically May to October. Uses surrounding the area proposed for improvements in Phase 2 include the groundwater treatment plant and sewer plant.

The parcels identified by APNs 108-030-06 and 108-020-05 have a Mendocino County General Plan (2009) land use designation of Agricultural Lands (AG) and are zoned as Agricultural Lands (AG) under the Mendocino County Inland Zoning Code (County Zoning Code), adopted in 1987 (see Figures 5 and 6, respectively). These parcels are designated as “Grazing Land” under the Farmland Mapping and Monitoring Program (FMMP) of the California Department of Conservation (DOC), Division of Land Resource Protection (2016) and are not currently under a Williamson Act Agricultural Preserve contract

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
(Mendocino County Maps - Timber Production & Williamson Act Lands, 2014). These parcels would be impacted by Phase 1 of the project, which includes the replacement of 3,600 feet of water line within the Willits Groundwater System and replacement of the existing 30 hp pump to a 40 hp pump at the Elias replacement well.

The parcel identified by APN 007-010-01 has a City of Willits General Plan (1992) land use designation of Industrial-General (M-G) and is zoned as Heavy Industrial (MH) under the City of Willits Zoning Code (2018) (see Figures 3 and 4, respectively). This parcel is designated as “Urban and Built-Up Land” under the FMMP of the DOC, Division of Land Resource Protection (2016). This parcel would be impacted by Phase 2 of the project which proposes to install a 250,000-gallon clear well adjacent to the west of the existing groundwater treatment plant.

II.a) The proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use. As noted above, the parcels identified by APNs 108-030-06 and 108- 020-05 are designated as “Grazing Land” and the parcel identified by APN 007-010-01 is designated as “Urban and Built-Up Land” under the FMMP of the DOC. No impact would occur.

II.b) The northern portion of the Site (proposed for improvements during Phase 1) is currently zoned as Agricultural Lands (AG) under the Mendocino County Zoning Code (see Figure 6) and is not currently under a Williamson Act contract. The City maintains and operates the Willits Groundwater System, including the Elias replacement well and underground water lines, in this portion of the Site and proposes no improvements that would conflict with the existing zoning designation. The southern portion of the Site (proposed for improvements during Phase 2) is currently zoned as Heavy Industrial (MH) under the City of Willits Zoning Code (see Figure 4) and proposes no changes to this zoning designation. Therefore, the proposed project would not conflict with existing zoning for agricultural use or a Williamson Act contract. A less than significant impact would occur.

II.c) The Site is neither designated nor zoned as forest land or timberland. No impact would occur.

II.d) The affected parcels do not include forest land and the project would not result in the loss of forest land or the conversion of forest land to non-forest use. Therefore, no impact would occur.

II.e) There are no components of the project that would involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland, to non-agricultural use or conversion of forest land to non-forest use. As described above, Phase 1 of the project would include improvements to the existing groundwater well and distribution system and would have no impact on the existing agricultural use and Phase 2 of the project would be implemented on an industrial-zoned parcel.

No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less than Significant Impact on Agricultural and Forestry Resources.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
III. AIR QUALITY. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state
ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
Thresholds of Significance: The project would have a significant effect on air quality if it would conflict with or obstruct implementation of applicable air quality plans; result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard; expose sensitive receptors to substantial pollutant concentrations; or result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

DISCUSSION: Air pollution control in the State of California is based on federal, state, and local laws and regulations. According to the 2005 Mendocino County Air Quality Management District (MCAQMD) Particulate Matter Attainment Plan (PM Attainment Plan) (pg. 5), the United States Environmental Protection Agency (EPA), California Air Resources Board (CARB), and regional clean air agencies all regulate air quality. The EPA and the CARB have set thresholds for each of the criteria pollutants, which include: ozone (O3), carbon monoxide (CO), oxides of nitrogen (NOx), lead (Lb), sulfur dioxide (SO2), particulate matter less than 10 microns in size (PM10), and particulate matter less than 2.5 microns in size (PM2.5). The standards set by the CARB are generally more stringent than those set by the EPA and the CARB has set additional standards for visibility-reducing particles (of any size), sulfates, and hydrogen sulfide (H2S). These standards are based on observable short-term (acute) health effects (MCAQMD, 2005).

The Site is located within the North Coast Air Basin (NCAB) and is subject to the requirements of the MCAQMD. The MCAQMD is responsible for monitoring and enforcing the state and federal Clean Air Acts as well as local air quality protection regulations in Mendocino County. The entire NCAB is currently designated as “non-attainment,” or in excess of allowable limits, for the state 24-hour allowable limits for breathable particulate matter of 10 microns or less (PM10), and as “attainment,” or within allowable limits, with respect to the balance of the criteria pollutants. The MCAQMD has been determined to be in “attainment”, or within allowable limits, for all federal and state ambient air quality standards, except for the state annual average PM10 standard and the 24-hour PM10 standard. The California Clean Air Act does not require attainment plans or transportation conformity for Districts that exceed the PM10 standard, but only requires that the Districts make reasonable efforts toward coming into attainment, defined as a five percent reduction in emissions per year, until the standard is attained. Although not required for coming into attainment for the state standard, the MCAQMD adopted the PM Attainment Plan in 2005. The PM Attainment Plan includes a description of local air quality, the sources of local particulate matter (PM) emissions, and recommended control measures to reduce future PM10 levels. While PM10 levels have dropped over the last 20 years, due to changing industrial base, enhanced regulations, and increased enforcement by the MCAQMD, the MCAQMD still exceeds the state PM10 level several times a year. The

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
majority of these exceedances result from wildfires, residential wood burning, unpaved roads, and construction activities (MCAQMD, 2005).

Improvements proposed during Phase 1 of the project include replacing a 3,600-foot section of 6-inch Schedule 40 PVC pipe connecting the Elias replacement well to the Willits Groundwater System with a 10- inch high density polyethylene (HDPE) pipe and upgrading the existing 30 hp pump to a 40 hp pump at the Elias replacement well to accommodate increased flows and increase transfer capacity from the well to the groundwater treatment plant. The water line replacement construction activities would be completed using horizontal directional drilling technology. In Phase 2, a 250,000-gallon clear well would be installed adjacent to the west of the existing groundwater treatment plant, within the footprint of existing development. The improvements proposed would require the use of construction equipment such as an excavator, drill rig, dump truck, vibratory plate/jumping jack, water truck, backhoe, and roller. Construction equipment would be maintained in good condition throughout project construction.

Emissions from the project would be comprised of temporary and permanent direct and indirect emissions, with the majority of potential emissions anticipated to be temporary, during construction. Direct emissions during construction, including exhaust and fugitive dust, would result from operation of construction equipment and would be temporary in nature. On-site operational emission sources at the Site would include stationary, mobile, and fugitive sources, the majority of which currently exist as part of the ongoing operation of the Willits Groundwater System. The proposed improvements would largely serve to enhance treatment and operability of the groundwater treatment system and would lead to negligible changes in existing direct emissions from the Site. As no additional employees would be required to operate the Willits Groundwater System after construction of the proposed project, no increase in indirect emissions from the Site would be anticipated.

III.a-b) The project would not conflict with or obstruct implementation of any air quality plan or result in a cumulatively considerable net increase of PM10, the only criteria pollutant for which the project region is in non-attainment. As noted above, the MCAQMD is in “non-attainment” for PM10 (MCAQMD, 2005).

Therefore, any use or activity that generates unnecessary airborne particulate matter may be of concern to MCAQMD and has the potential to create significant project-specific and cumulative effects to air quality. MCAQMD has advised that generally an activity that individually complies with the state and local standards for air quality emissions will not result in a cumulatively considerable net increase in the countywide PM10 emissions. While project construction would generate temporary emissions from use of construction equipment, the project would not include any source of visible emissions, including intentional fire/burning or manufacturing and would control exhaust emissions from construction equipment by minimizing idling, in accordance with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the California Air Resources Board (ARB). In addition, the contractor would suppress fugitive dust during construction and operation, pursuant to Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), and would maintain all construction equipment in good working order such that exhaust and fugitive dust emissions are minimized.

The project would be subject to current and future regulations adopted by MCAQMD, including the PM Attainment Plan (2005), and compliance with these regulations would ensure the project would not result in a substantial increase of PM10 within the vicinity of the Site. A less than significant impact would occur.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
III.c-d) The project would not expose sensitive receptors to substantial pollutant concentrations, nor create objectionable odors affecting a substantial number of people. Sensitive receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants, and include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and residential dwelling unit(s). The nearest location of potential sensitive receptors to the Site is the Community Ball Fields, located approximately 0.28 miles south of the Site. The project component nearest to the Community Ball Fields would be the clear well. Uses surrounding the project area described in Phase 1 of the project, to be implemented in the northern portion of the Site, include vacant fields utilized for cattle grazing during the dry season, typically May to October. Uses surrounding the area proposed for improvements in Phase 2, to be implemented in the southern portion of the Site, include the groundwater treatment plant and sewer plant.

The proposed project would be anticipated to create exhaust and fugitive dust during construction of the project. However, given the distance to the nearest sensitive receptors and with suppression of fugitive dust during construction and operation, pursuant to Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), and maintaining all equipment in good working condition, fugitive dust and exhaust emissions would be minimized. Additionally, there is no proposed use that would be anticipated to result in a significant increase in pollutant concentrations or other emissions, as the only significant above-ground component of the project includes the installation of a clear well that will have a negligible impact on operational emissions from the groundwater treatment system. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Air Quality.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
IV. BIOLOGICAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies, and
regulations or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or
other means?
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state
habitat conservation plan?
Thresholds of Significance: The project would have a significant effect on biological resources if it would have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service; have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service; have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means; interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

DISCUSSION
The Site is located northeast of the City center on City-owned parcels currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant (see Figure 2). While the Site is entirely owned by the City of Willits, the parcel identified by APN 007-010-01 is located within the City limits, while the parcels identified by APNs 108-030-06 and 108-020-05 are located within the unincorporated area to the north of the City. Uses

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
surrounding the project area described in Phase 1 of the project include vacant fields utilized for cattle grazing during the dry season, typically May to October. Uses surrounding the area proposed for improvements in Phase 2 include the groundwater treatment plant and sewer plant. The Site is located within the Mill Creek-Outlet Creek Hydrologic Unit of the Little Lake Valley. The Site is located east of Outlet Creek and west of Davis Creek, both of which flow from south to north. Outlet Creek receives flows from drainages on the west side of Little Lake Valley and Davis Creek receives flows from drainages on the east side of the valley.

A Habitat Assessment was prepared by Wildlife Research Associates (WRA) and Jane Valerius Environmental Consulting (Jane Valerius) on December 3, 2020 (see Appendix C). The survey encompassed the northern portion of the Site, with a focus on the alignment of the water line replacement and installation proposed in Phase 1. Information on special status plant and wildlife species was compiled through a review of the California Natural Diversity Database (CNDDB, 2020) for the Willits and Burbeck 7.5- minute topographic quadrangles, California Department of Fish and Wildlife (CDFW) Special Animals List (CDFW, 2020), State and Federally Listed Endangered and Threatened Animals of California (CDFW, 2020), the California Native Plant Society (CNPS) Electronic Inventory records (CNPS, 2020), and the U.S. Fish and Wildlife Service (USFWS) Information on Planning and Conservation (IPaC) list (USFWS, 2020).

A broad biological review and wetland delineation survey were conducted within an approximately 2.6- acre limit of disturbance area and a 15.34-acre study area, with focused plant surveys conducted within the limit of disturbance area. Protocol level surveys for all special status plants with the potential to occur within the study area based on the USFWS, CNDDB, and CNPS database searches noted above, were conducted by Jane Valerius and Geri Hulse-Stephens from April to June 2020. On May 12, 2020, Trish Tatarian of WRA conducted a reconnaissance-level site visit intended as an evaluation of on-site and adjacent habitat types and included an evaluation of the Site for small mammal burrows and suitable potential habitat for nesting birds and roosting bats. In addition, on May 12, 2020, Jane Valerius conducted a formal wetland delineation in accordance with the 1987 Wetlands Delineation Manual and the 2010 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coastal Region of the U.S. Army Corps of Engineers (USACE). The 2020 delineation updated the original 2003 verified delineation that was conducted for the wastewater treatment plant. The USACE approved the delineation in a letter dated September 24, 2020. The majority of the project area described in Phase 1 of the project is located within seasonal wetlands based on the delineations conducted in 2003 and updated in 2020. It should be noted that Phase 2 of the project is proposed adjacent to the west of the groundwater treatment plant on a compacted dirt surface within the footprint of existing development.

The assessment included an evaluation of the potential for occurrence of 21 special status plant species and 27 special status wildlife species, including bats, California red-legged frog, and western pond turtle, on the Site; however, no focused surveys for any special status wildlife species were conducted. The Habitat Assessment (WRA & Jane Valerius, 2020) notes that two vegetation communities (upland nonnative grassland and seasonal wetlands) and three wildlife habitats (annual grasslands, valley foothill riparian, and fresh emergent wetland) occur within the study area. The majority of the 15.34-acre study area (14.02 acres) qualifies as a seasonal wetland, with approximately 1.32-acres of upland non-native grassland on the Site. Oregon ash trees occur along the fence lines and in small groves within the larger grassland areas, and are considered to provide a continuation of the valley foothill riparian habitat that exists along Outlet Creek. Of the 21 special status plant species that have been reported in the Willits and Burbeck 7.5-minute topographic quadrangles, two special status plants, Baker’s meadowfoam, a California Rare (CR) and CNPS Rank 1B (rare, threatened, or endangered in California and elsewhere) plant, and Davy’s semaphore grass, a CNPS Rank 4 (plants of limited distribution) species, were observed in

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
a portion of the seasonal wetlands. A total of 0.59 acres of Baker’s meadowfoam was mapped on-site, primarily in areas where vehicles or other disturbance have created ruts or depressions in the grasslands.

Based on the habitats present, a total of ten (10) sensitive wildlife species were assessed for potential occurrence at the Site. The assessment determined that nesting passerines and raptors with non-sensitive status, but protected under the Migratory Bird Treaty Act (MBTA), and roosting bats, including the Western red bat (a CDFW Species of Special Concern), have the potential to occur within various habitats on-site.

Several passerine species may nest in the grasslands, blackberry bushes, or trees on-site, depending on the species, while nesting raptors and roosting bats may occur in the trees.

The Habitat Assessment (WRA & Jane Valerius, 2020) provides several avoidance, minimization, and mitigation measures for minimizing potential impacts to the sensitive biotic resources observed on-site.

These recommendations are described in detail below, in the applicable sections.

IV.a) Although 0.59 acres of Baker’s meadowfoam and populations of Davy’s semaphore grass were observed on-site, as shown on the project impact maps (see Project Impact maps provided in Appendix C) and as noted in the Habitat Assessment (WRA & Jane Valerius, 2020), all areas occupied by Baker’s meadowfoam and Davy’s semaphore grass are outside the proposed construction area. Furthermore, horizontal drilling technology would facilitate the installation of the new water line without impacts to the surface area outside the noted access holes. To ensure potential impacts to Baker’s meadowfoam are avoided, the Habitat Assessment provides several recommendations, including designating Environmentally Sensitive Areas (ESAs) and installing temporary fencing around areas of known Baker’s meadowfoam during construction to prevent disturbance from construction equipment and to prevent the placement of side cast soil material on the Baker’s meadowfoam during excavation of the access holes. These measures would be implemented as Mitigation Measures BIO-1 and BIO-2, respectively.

Implementation of Mitigation Measure BIO-1 would ensure areas to be avoided by construction activities would be designated as ESAs and fenced, or otherwise marked, in the field, while Mitigation Measure BIO-2 would ensure Baker’s meadowfoam areas would be avoided when constructing access holes and placing side cast soil material from excavation activities.

As discussed above, based on the habitats observed on-site, there is the potential for nesting passerines and raptors and roosting bats to be present on-site. The MBTA generally prohibits the take of migratory birds and their nests and roosting bats are protected under CDFW regulations. To reduce the potential for the take of nesting passerines and raptors and roosting bats, the Habitat Assessment recommends that noise and ground disturbance associated with construction occur September 1 through October 15, outside the nesting season for passerines and raptors and the maternity roosting season for bats. If the seasonal work restrictions are infeasible, pre-construction surveys shall be conducted in accordance with Mitigation Measure BIO-3. In addition, as the Oregon ash trees located along the west side of the Site are considered to be part of the Valley Foothill Riparian wildlife habitat and potentially present habitat for nesting passerines and raptors and roosting bats, potential disturbance to the trees and/or their root systems shall be limited through the placement of ground protection in accordance with Mitigation Measure BIO-4, below.

To ensure the aforementioned avoidance, minimization, and mitigation measures are implemented prior to, during, and upon completion of construction, an education program for all construction personnel shall be conducted by a qualified biologist before construction begins, in accordance with Mitigation Measure BIO-5. With the incorporation of Mitigation Measures BIO-1 through BIO-5, a less than significant impact would occur.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
IV.b) As discussed above and as presented in the Habitat Assessment, no special status vegetation communities have been reported in the CNDDB for the two topographic quadrangles, Willits and Burbeck, which contain the project area (CNDDB, 2020). However, the seasonal wetlands are considered to be sensitive natural communities because of their wetland status, and because they support Baker’s meadowfoam, a California Rare (CR) and CNPS Rank 1B plant, and Davy’s semaphore grass, a CNPS Rank 4 species.

Additionally, as described in Section X (Hydrology and Water Quality), below, construction projects that would disturb more than one acre of land, such as the proposed project, would be subject to the requirements of General Construction Activity Stormwater Permit (Construction General Permit Order 2009- 0009-DWQ, also known as the CGP), Mendocino County Code Chapter 16.30, and the City of Willits Design and Construction Standards, which require the preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) that specifies erosion and sediment control construction Best Management Practices (BMPs) to reduce or eliminate construction-related impacts to the water quality of receiving water bodies and nearby habitats. Implementation of the SWPPP would ensure proper stormwater controls are developed for the minimization of erosion resulting from construction and to avoid runoff into sensitive habitat areas (including Baker’s meadowfoam populations and the on-site tress), limit ground disturbance to the minimum necessary, and stabilize disturbed soil areas as soon as feasible after construction is completed. In addition, as discussed below under Impact IV.c, implementation of Mitigation Measure BIO6 would minimize impacts to the existing wetlands.

Implementation of Mitigation Measures BIO-1 through BIO-6 would facilitate the protection of the existing sensitive natural communities identified on-site. With mitigation incorporated, a less than significant impact would occur.

IV.c) As discussed above, the majority of the area studied in the Habitat Assessment is designated as seasonal wetlands, with only 1.32 acres of the 15.34-acre study area designated as upland non-native grassland. As the water line would be installed within and/or adjacent to the footprint of the existing water line and access road, the limits of disturbance for construction of the project and related vehicle access would be limited to designated areas of the Site. The proposed project would temporarily impact less than 3,200 square feet (0.07 acres) of seasonal wetlands. It should be noted that the Habitat Assessment evaluates a larger project area than the area proposed for improvements as part of this project. The water line installation to connect the Long 20 well to the Willits Groundwater System, as shown on the project impact maps (see Project Impact maps provided in Appendix C), is not proposed and is not part of this project. To minimize potential impacts to the seasonal wetlands identified on-site, a Section 404 permit through the USACE and a Section 401 Water Quality Certification through the North Coast Regional Water Quality Control Board (NCRWQCB) shall be obtained prior to implementation of the project, if required.

Additionally, the project shall be designed to result in no net loss of functions and values of the existing wetlands by incorporating the impact minimization measures detailed in Mitigation Measure BIO-6. With the incorporation of mitigation, a less than significant impact would occur.

IV.d) The proposed project has no elements that would interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors. As noted in the Habitat Assessment (WRA & Jane Valerius, 2020), the open grasslands at the Site allow for unimpeded movement, which would be maintained following construction of the proposed project. Phase 1 of the proposed project, replacement and installation of the water line and upgrades to an existing pump, includes no noticeable above-ground improvements in the northern portion of the Site, which is currently surrounded by open grasslands utilized during the dry season for cattle grazing. The clear

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
well structure proposed in the southern portion of the Site during Phase 2 of the project would be located in an urbanized area that is developed with similar uses, including the City’s groundwater treatment system and sewer plant. However, as discussed previously, construction activities proposed during Phase 1 of the proposed project include horizontal directional drilling for the installation of new water line from up to eight (8) access holes. To ensure wildlife passing through the Site is not negatively impacted during project construction, Mitigation Measure BIO-7 would be implemented to avoid the entrapment of wildlife.

In addition, as noted above, based on the habitat present on-site, there is a potential for nesting passerines and raptors and roosting bats to be present on-site. Construction during the nesting season for passerines and raptors (February 1 through August 31) and/or the maternity roosting season for bats (April 15 through August 31) may impede the use of native wildlife nursery sites. To avoid potential impacts to nesting passerines and raptors and roosting bats, construction would be limited to September 1 through October

15. If seasonal work restrictions cannot be adhered to, Mitigation Measure BIO-3 would be implemented to mitigate for potential impacts to nesting passerines and raptors and roosting bats. With mitigation incorporated, a less than significant impact would occur.

IV.e) The proposed project would not conflict with any local policies or ordinances protecting biological resources. As discussed above, vegetation removal associated with the proposed project would be limited to the temporary removal of soil during excavation, which would be replaced, recompacted, and reseeded upon completion of construction. All potential impacts to the sensitive species and natural communities on-site would be temporary in nature and would be avoided and minimized to the extent feasible. A less than significant impact would occur.

IV.f) There are no adopted Habitat Conservation Plans, Natural Community Conservation Plans, or other approved local, regional, or state habitat conservation plans that apply to the Site. No impact would occur.

MITIGATION MEASURES
BIO-1: Prior to the start of construction, specific project locations that are associated with listed species and sensitive habitats will be identified and designated as Environmentally Sensitive Areas (ESAs) using highvisibility orange fencing, flagging and signage, or silt fencing. This applies specifically to areas with Baker’s meadowfoam and to the Oregon ash, valley oak, and other native trees within the project study area.

ESAs shall be shown on project design plans or maps to be provided to construction personnel. The ESA fencing shall remain in place throughout the duration of the project related construction activities to prevent the encroachment of construction equipment/personnel into sensitive areas. Only the minimum area needed for vehicle access and the placement of side cast material shall be allowed; areas that are to be avoided shall be identified as ESAs. To the extent feasible, construction access, staging, storage, and parking areas shall be located in upland areas and outside of any designated ESA.

The bid package special provisions shall clearly describe acceptable fencing material and prohibited construction-related activities, vehicle operation, material and equipment storage, and other surfacedisturbing activities within ESAs. The final project plans shall depict all locations where ESA fencing or flagging and signage would be installed and how it would be installed.

BIO-2: Areas containing Baker's meadowfoam shall be protected with temporary fencing during construction, and these areas shall be avoided during construction. There shall be no side cast soil material placed in areas fenced for Baker’s meadowfoam protection.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
BIO-3: To reduce the potential for the take of migratory birds, including passerines and raptors, and roosting bats, ground and noise disturbance within 100 feet of the on-site trees shall be timed to occur during the non-nesting/roosting season, from September 1 to October 15. If these seasonal work restrictions cannot be adhered to, the following measures shall be performed in order to avoid or minimize impacts to passerines and raptors that may potentially nest, and bats that may potentially roost, in the project area:
 A pre-construction nesting bird (both passerine and raptor) survey of the grasslands and adjacent trees shall be performed by a qualified biologist within seven (7) days of ground breaking. If no nesting birds are observed, no further action is required and grading shall occur within one (1) week of the survey to prevent “take” of individual birds that could begin nesting after the survey.

Inactive bird nests, other than those of eagles and threatened or endangered species, may be removed.
 A bat habitat assessment of the adjacent trees for both foliage and cavity roosting bats shall be conducted by a qualified bat biologist within 14 days of the start of construction.  If active bird nests (either passerine and/or raptor) or bat roosts are observed during the preconstruction survey, a disturbance-free buffer zone shall be established around the nest/roost tree(s) until the young have fledged or the roosting has ceased, as determined by a qualified biologist.
 The radius of the required buffer zone can vary depending on the species (i.e., 75-100 feet for passerines and bats, and 200-300 feet for raptors), with the dimensions of any required buffer zones to be determined by a qualified biologist in consultation with CDFW.  To delineate the buffer zone around a nesting tree, orange construction fencing shall be placed at the specified radius from the base of the tree within which no machinery or workers shall intrude.

After the fencing is in place, there will be no restrictions on grading or construction activities outside the prescribed buffer zones.
 Work buffers or construction delays shall be implemented until all birds have fledged.

BIO-4: Prior to the start of construction, specific project locations where native trees and/or their root systems cannot be avoided by vehicle traffic and construction equipment, and/or would be utilized for the placement of side cast material shall have rubber mats or other ground protection placed to minimize soil and root disturbance by vehicle traffic and construction equipment. The bid package special provisions shall clearly describe acceptable ground protection material and the final project plans shall clearly depict how and where the ground protection measures shall be installed. After construction is complete, the ground protection measures shall be removed and the areas reseeded, as needed.

BIO-5: Before construction activities begin, a qualified biologist shall conduct an education program for all construction personnel. The training shall include a description of special status species, including state listed species and associated habitats with potential to occur in the project study area; an explanation of the status of these species and their protection under the California Endangered Species Act (CESA); the measures to conserve listed species and their habitats as they relate to the work being done; proper soil excavation and replacement techniques; and boundaries within which construction may occur. A fact sheet conveying this information will be prepared and distributed to all construction crews. Upon completion of the program, personnel shall sign a form stating that they attended the program and understand all of the project mitigation measures and implications of subject regulations.

BIO-6: A Section 404 permit from the U.S. Army Corps of Engineers (USACE) and a Section 401 Water Quality Certification from the North Coast Regional Water Quality Control Board (NCRWQCB) shall be obtained for impacts to wetlands, if required by the respective agencies. If required, these permits shall be obtained

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
prior to implementation of the project. The project shall be designed to result in no net loss of functions and values of the existing wetlands by incorporating the following impact minimization measures:
 Vehicles and construction equipment shall be rubber tired, to the extent feasible.  Ground-protection measures, as described in Mitigation Measure BIO-4, shall be placed in turnaround areas for vehicles and construction equipment to prevent the removal of vegetation and soil disturbance.
 Where excavation occurs, soil shall be removed in lifts with the top 8 to 12 inches of topsoil removed and cast to one side and the remaining subsoil placed separately such that when the access hole is refilled the topsoil, along with all the seeds, will be in the same position in the soil profile, thus allowing for quick reestablishment of existing species and reestablishment of the wetland functions and values.
 Following construction, the approximate and original contours of the disturbed areas shall be restored to pre-project conditions, to the extent feasible, and any areas of bare soil shall be seeded with a native grass seed mixture comprised of species known to occur in the area.

BIO-7: To prevent the inadvertent entrapment of animals during construction, all excavated, steep-walled access holes more than 1-foot deep shall be covered at the close of each working day with plywood or other suitable material(s) or provided with one or more escape ramps constructed of earth fill or wooden planks. Before such holes are filled, they must be thoroughly inspected for trapped animals. All replacement pipes, culverts, or similar structures stored overnight will be inspected before they are subsequently moved, capped, and/or buried. If at any time a listed species is discovered, the contractor and qualified biologist shall be immediately informed. The animal shall be allowed to move out of the area on its own volition or until the qualified biologist notifies the contractor to resume work in the area.

FINDINGS
The proposed project would have a Less Than Significant Impact with Mitigation Incorporated on Biological Resources.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
V. CULTURAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to §15064.5?
c) Disturb any human remains, including those interred
outside of formal cemeteries?
Thresholds of Significance: The project would have a significant effect on cultural resources if it would cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5; cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5; or disturb any human remains, including those interred outside of formal cemeteries.

DISCUSSION
According to Chapter 3 (Development Element) of the Mendocino County General Plan (2009), ten (10) Native American tribes historically had territory in what is now Mendocino County. Native American tribes known to inhabit Mendocino County concentrated mainly along the coast and along major rivers and streams, while mountainous areas and redwood groves were occupied seasonally by some tribes. The first permanent non-native settlers came to Mendocino County in the middle of the 16th century, exploring and establishing small outposts. It was almost 300 years before the first permanent non-Spanish settlements in Mendocino County were established in April of 1852 on the coast north of Big River. As European-American settlement expanded in Mendocino County, most of the tribes known to inhabit the land were restricted to reservations and rancherias. During the 19th century, other tribes from the interior of California were forced to settle on the Round Valley Reservation in the northeastern portion of Mendocino County (County of Mendocino, 2009). Settlement in the vicinity of the City began in the mid-1880s (City of Willits, 1992, pg. III27).

Various County and City policies exist related to the protection and preservation of cultural and historical resources, including but not limited to: Chapter 3 of the Mendocino County General Plan (2009), pages 3- 94 through 3-95; Chapter 22.12 of the Mendocino County Code (1987); the City of Willits General Plan Revision EIR (1992), page III-27; and Chapter 17.48 of the City Code (1982). In an effort to protect archaeological and cultural resources, in particular Native American sites, from potential development impacts, the County has adopted an Archaeological Ordinance, Chapter 22.12 of the Mendocino County Code (1987). The ordinance establishes a County Archaeological Commission that evaluates the potential impacts of proposed projects on archaeological resources and recommends measures to reduce or eliminate impacts on these resources. Both Policy DE-115 of Chapter 3 of the Mendocino County General Plan (2009) and Mendocino County Code Sections 22.12.050 through 22.12.100 (1987) include provisions for archaeological sensitivity review, field evaluations, impact mitigations, archaeological discovery, and human remain discovery protocols. In addition, mitigation measures 4.931 and 4.932 of the City of Willits General Plan Revision EIR (1992) and Chapter 17.48 (Historical Resources) of the City of Willits Code (1982) include provisions for the protection, enhancement, perpetuation or use of places, buildings, structures, and other objects having a special character or special historical or aesthetic interest or value to the City.

Several historical resources have been identified in the County and within, or in close proximity to, the City, many of which have been placed on various federal and state historic registries; however, no historical sites or buildings have been designated by the County or the City and none are within the vicinity of the Site.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
On June 22, 2020, LACO Associates (LACO), on behalf of the City, contacted the Northwest Information Center (NWIC) located on the Sonoma State University campus to request a Records Search. On July 23, 2020, LACO received a letter response from the NWIC (File No. 19-2317), which presented the results of the records search conducted by NWIC that entailed reviewing pertinent NWIC base maps that reference cultural resource records and reports, historic-period maps, and literature for Mendocino County. As described in the letter from NWIC, there have been two (2) cultural resource studies covering portions of the Site and no archaeological resources have been recorded at the Site. Study 23633 (Bass 2000) included the entire project area within its study area and included field survey for approximately 90 percent of the southern portion of the Site, while Study 14121 (Rondeau 1992) may have included approximately 10 percent of the northern portion of the Site.

According to the NWIC letter, ethnographic literature references Native American villages in the Little Lake Valley area in or adjacent to the Site. Based on an evaluation of the environmental setting and features associated within known sites, Native American resources in the part of Mendocino County that includes the Site have been found in valleys, at the hill to valley interface, near creeks and near ecotones. Given the similarity of one or more of the Site-specific environmental factors to the environmental setting and feature associated with known Native American sites and the ethnographic sensitivity of the area, the NWIC deems that there is a moderate to high potential for unrecorded Native American resources at the Site. In addition, the NWIC letter indicates that there is a moderate to high potential for unrecorded historicperiod archaeological resources to be at the Site, based on review of historical literature and maps that indicated several lumber mills within the immediate or surrounding area of the Site. Due to the passage of time since the previous surveys, and the lack of coverage of the entire Site, the NWIC recommends a qualified archaeologist conduct further archival and field study for the entire Site to identify archaeological and cultural resources and that the local Native American tribes be contacted regarding traditional, cultural, and religious heritage values.

On March 12, 2020, in compliance with Assembly Bill (AB) 52, the City of Willits (City), sent consultation letters to the Middletown Rancheria Band of Pomo Indians and the Torres Martinez Desert Cahuilla Indians, two (2) Native American tribes that are traditionally and culturally affiliated to the project area and that had previously requested notification of projects in the tribes’ area of traditional and cultural affiliation pursuant to AB 52. No responses were received within the 30 day deadline specified by Public Resources Code section 21082.3 (d). On June 23, 2020, the City sent additional AB 52 consultation letters to each of the 13 Tribal representatives listed on the Native American Heritage Commission (NAHC) Native American Contacts List dated October 28, 2019, which the City had previously requested from the NAHC, including the EPA Director and Chairperson of the Cahto Tribe; the Chairpersons of the Coyote Valley Band of Pomo Indians, Guidiville Band of Pomo Indians, Hopland Band of Pomo Indians, Kashia Band of Pomo Indians of the Stewards Point Rancheria, Manchester Band of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, and Sherwood Valley Band of Pomo Indians; and the President of the Round Valley Reservation/Covelo Indian Community. No requests for consultation were received from any of the 18 Native American tribes that were sent formal notification of the project in compliance with AB 52, as noted above. As no requests for consultation were received within the 30 day deadline specified by Public Resources Code section 21082.3 (d), the City, as Lead Agency, has deemed the Tribal consultation process complete. Copies of the NWIC response letter and the NAHC Native American Contacts List are included in Appendix B.

V.a) The project, as presently designed, is not anticipated to have an adverse effect on historical resources. No structures are being demolished or altered as a result of the project and no historical

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
resources are identified at or near the Site, per Figure 10-1 of the City of Willits General Plan Revision (City of Willits, 1992). As a result, no impact would occur.

V.b-c) The project is not anticipated to cause a substantial adverse change in the significance of an archaeological resource or disturb any human remains. No further field study was initiated because the Site is proposed within the general footprint of historic ground disturbance for construction of the exiting Willits Groundwater System, is not identified as an area of high archaeological sensitivity in the City of Willits General Plan Revision EIR (1992), and further study was not requested by the Native American tribes contacted. However, there is the possibility that an archaeological resource or human remains could be inadvertently discovered due to the ground-disturbing activities required during project construction. In addition, as noted in the letter from the NWIC, there is a moderate to high potential for unrecorded Native American resources and historic-period archaeological resources to be at the Site. The incorporation of Mitigation Measure CUL-1, which requires that the contractor implement standard protocol similar to Mendocino County’s “Discovery Clause” during project construction, and Mitigation Measure CUL-2, which requires that the City inform a cultural monitor prior to beginning excavation for the purposes of installing the proposed water line and invite the monitor to oversee excavation activities, would ensure that archaeological and cultural resources, including human remains, are not adversely impacted by the project, and that implementation of the proposed project will be consistent with Mendocino County policies for protection of archaeological and cultural resources, including human remains. With mitigation incorporated, a less than significant impact would occur.

MITIGATION MEASURES
CUL-1: In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or discovered during construction, the contractor shall immediately halt all grading/land-clearing activities and contact the City of Willits Community Development Department (CDD). All activity in the vicinity of the resources shall cease until it can be evaluated by a qualified archaeologist and a Native American representative. If the archaeologist and Native American representative determine that the resources may be significant, they shall notify the CDD and develop an appropriate treatment plan for the resources. The archaeologist shall consult with Native American representatives in determining appropriate treatment for prehistoric or Native American cultural resources.

In considering any suggested mitigation proposed by the archaeologist and Native American representative, the CDD will determine whether avoidance is necessary and feasible in light of factors such as the nature of the find, project design, costs, and other considerations. If avoidance is infeasible, other appropriate measures (e.g., data recovery) will be instituted. Work may proceed in other parts of the project area while mitigation for cultural resources is being carried out.

CUL-2: A note shall be placed on all grading plans that the project contractor and/or the City shall notify a qualified cultural monitor with general knowledge of the project area prior to any excavation for the purposes of installing the proposed water line, and agree to open the Site to the cultural monitor to oversee the subsurface construction activities in order to ensure appropriate treatment of any artifacts uncovered.

FINDINGS
The proposed project would have a Less Than Significant Impact with Mitigation Incorporated on Cultural Resources.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
VI. ENERGY. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy, or wasteful use of energy
resources, during project construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
Thresholds of Significance: The project would have a significant effect on energy if it would result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy, or wasteful use of energy resources, during project construction or operation.

DISCUSSION
On October 7, 2015, Governor Edmund G. Brown, Jr. signed into law Senate Bill (SB) 350, known as the Clean Energy and Pollution Reduction Act of 2015, which sets ambitious annual targets for energy efficiency and renewable electricity aimed at reducing greenhouse gas (GHG) emissions. According to the Final Commission Report of the California Energy Commission (CEC), dated October 2017, SB 350 requires the CEC to establish annual energy efficiency targets that will achieve a cumulative doubling of statewide energy efficiency savings and demand reductions in electricity and natural gas final end uses by January 1, 2030. This mandate is one of the primary measures to help the state achieve its long-term climate goal of reducing GHG emissions to 40 percent below 1990 levels by 2030. The proposed SB 350 doubling target for electricity increases from 7,286 gigawatt hours (GWh) in 2015 up to 82,870 GWh in 2029.

For natural gas, the proposed SB 350 doubling target increases from 42 million of therms (MM) in 2015 up to 1,174 MM in 2029 (CEC, 2017).

Site improvements proposed under the project include the replacement of 3,600 feet of water line within the Willits Groundwater System, and the installation of a 250,000-gallon clear well. The 250,000-gallon clear well is the only permanent structure proposed to be installed as part of the project and this tank would not be subject to Part 6 (California Energy Code) of Title 24 of the California Code of Regulations, which contains energy conservation standards applicable to residential and non-residential buildings throughout California (CEC, 2020).

VI.a) The proposed project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy, or wasteful use of energy resources, during project construction or operation. The consumption of energy would occur during construction through the use of fossil fuels and electricity for construction equipment and vehicles. Construction would occur during normal business hours, typically 7:00 am to 7:00 pm, Monday through Saturday, or as approved by the City, and would be temporary in nature. Equipment will include an excavator, drill rig, dump truck, vibratory plate/jumping jack, water truck, backhoe, and roller. The contractor would keep all construction equipment in good working order and would limit idling of vehicles and equipment during construction, in accordance with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the California Air Resources Board (ARB).

Therefore, it is anticipated that the construction phase of the project would not result in wasteful, inefficient, and unnecessary consumption of energy.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Operation of the project would require a minimal increase in energy above the current usage for operation of the Willits Groundwater System. Although the upgraded 40 hp pump proposed at the Elias replacement well would require a slight increase in energy above existing conditions, the upgraded pump would facilitate an increase in the pumping capacity of the Elias replacement well, allowing for more efficient use of the well when it is needed. Additionally, compared to the surface water treatment plant, the groundwater treatment plant requires less energy to operate, as less treatment is required for the groundwater and less energy is consumed by the transport of groundwater, since the groundwater treatment system is in close proximity to the water supply distribution system. Implementation of the project would allow the City to efficiently supplement the surface water supply with groundwater, when needed, and use less energy system-wide in the process. A less than significant impact would occur.

VI.b) The proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Part 6 (California Energy Code) of Title 24 of the California Code of Regulations (Title 24) contains energy conservation standards applicable to residential and non-residential buildings throughout California and are regarded as the most advanced energy efficiency standards (CEC, 2020). As noted above, the 250,000-gallon clear well is the only structure proposed to be installed as part of the project; however, Title 24 is not be applicable to operation of the clear well. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Energy.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
VII. GEOLOGY AND SOILS. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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 wastewater 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?
Thresholds of Significance: The project would have a significant effect on geology and soils if it would directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: 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, strong seismic ground shaking, seismic-related ground failure, including liquefaction, or landslides; result in substantial soil erosion or the loss of topsoil; 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; 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; have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater; or directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

DISCUSSION
A Soils Report was prepared by LACO on June 30, 2020 (see Appendix D), in order to explore the surface and subsurface conditions and develop recommendations at the site of the proposed clear well (clear well site) regarding the following: recommended foundation type(s) for the proposed clear well and design criteria for the recommended foundation type(s), consistent with the current edition of the California

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Building Code (CBC); estimates of foundation settlement; assessment of potential earthquake-related hazards in accordance with CBC requirements including surface fault rupture, quantitative liquefaction analysis, quantitative statis and dynamic differential settlement analysis, and slope instability; recommendations regarding earthwork including site and subgrade preparation, fill material quality, placement and compaction requirements, and subdrains; and construction considerations.

As noted in the Public Review Draft 2019 Safety Element of the City of Willits General Plan (2019), seismic and geologic hazards in and around the City include surface fault rupture, seismic shaking, seismically induced landslides, liquefaction, and landslides (pp. 7 through 11). The City is located within a seismically active region and in close proximity to numerous active faults. According to the Public Review Draft Safety Element (2019), these faults include the Maacama fault, considered an active fault by the California Geological Survey (CGS), which runs through the center of the City, and the San Andreas Fault Zone and the Bartlett Springs Fault, which run through the surrounding Mendocino County region to the east of the City. As shown on the Faulting and Seismicity map, Figure S-1, there are no fault lines or zones located at the Site; however, the Site is located within an area of very high earthquake shaking potential (City of Willits, 2019b). According to the Soils Report (LACO, 2020), the Site is located in the California Coast Ranges Geomorphic Province, a seismically active and geologically complex province due to historic and ongoing tectonic deformation that is characterized by northwest trending faults and topographic and geologic features. The seismicity of the area is dominated by the presence of the San Andreas Fault system, with the nearest potentially active faults within the northern section of Maacama fault zone, located approximately

0.75 miles west of the Site. However, the Site is not mapped as a special study zone per the Alquist-Priolo Earthquake Fault Zoning Act and the likelihood of surface rupture at the Site from a potentially active fault is considered to be low (LACO, 2020).

The Site is relatively flat, with elevations from north to south ranging from approximately 1,323 feet to 1,353 feet above mean sea level, respectively. According to the Natural Resources Conservation Service (NRCS, 1997), the specific soil type underlying the Site is Fluvaquents soils, which are very deep, very poorly drained soils on flood plains, originating from recent alluvium derived from sedimentary rock. This soil type is primarily found on flood plains and supports native vegetation such as annual and perennial grasses and forbs.

Fluvaquents have a moderately slow to moderately rapid permeability with a generally high available water capacity, very slow to ponded runoff, and a slight hazard of water erosion. These soils are generally found where a seasonal high water table fluctuates between the surface and a depth of 18 inches from November to March (NRCS, 1997). As noted in the Soils Report, on April 15, 2020, LACO explored subsurface conditions at the clear well site by drilling three (3) borings (B1 through B3) to depths of 41.5 feet, 2.5 feet, and 16.5 feet below ground surface (bgs), respectively. Laboratory tests were performed on select soil samples by LACO’s materials testing laboratory to evaluate and characterize the soils. The clear well site is underlain by approximately 7 feet of undocumented fill overlying alluvial deposits to the maximum depth explored of 41.5 feet bgs. Undocumented fill consists of heterogeneous deposits of brown clayey sand with gravel and grayish brown clay. Alluvial deposits consist of approximately 3 to 8 feet of brown sandy lean clay, overlying approximately 27 feet of lean clay with sand interbedded with 6-inch thick beds of sandy lean clay. Groundwater was encountered in boring B1 at a depth of 8.5 bgs (LACO, 2020).

Based on the exploration program, the Soils Report (LACO, 2020) concludes that from a geotechnical standpoint, the proposed clear well installation is feasible. LACO found a low potential for slope instability, surface rupture from a potentially active fault, and lurching. The primary geotechnical concerns at the clear well site are the presence of up to 7 feet of potentially liquefiable undocumented fill and the potential for flooding, as the clear well site is located in an area designated as Zone AE, an area inundated by the one-percent annual chance flooding, for which Base Flood Elevations (BFEs) have been

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
determined, and adjacent to the west of the existing groundwater treatment plant, which is currently located in the Regulatory Floodway, as shown on FIRM panel number 06045C1112F, effective June 2, 2011.

VII.a.i) The Site is situated within a seismically active area proximal to multiple seismic sources capable of generating moderate to large ground motions. Given the proximity of the proposed project to active seismic sources (the Maacama Fault Zone and San Andreas Fault), there is a high probability that the Site will experience strong ground shaking during the economic lifespan (50 years) of the project. However, as the Site is not mapped as a special studies zone per the Alquist-Priolo Earthquake Fault Zoning Act and based on the distance between the Site and the closest active fault, the Maacama fault zone, the potential for surface rupture at the Site is considered low. Therefore, the proposed project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to the rupture of a known earthquake fault and a less than significant impact would occur.

VII.a.ii) As noted above, there are no mapped faults or Alquist-Priolo special studies zones traversing the Site. However, since the project area is situated within a seismically active region and given the proximity of significant active faults to the Site, the Site will likely experience strong ground shaking during the economic life span of any development on the Site and the risk of ground shaking at the Site is high. However, the only above-ground improvement proposed includes the 250,000-gallon clear well to be installed adjacent to the west of the existing groundwater treatment system. The proposed clear well and associated infrastructure would be subject to the recommendations contained in the Soils Report (LACO, 2020) and the American Water Works Association (AWWA) tank standards for steel tanks and to the American Society of Civil Engineers (ASCE) standards for seismic anchoring of tanks. Furthermore, the Soils Report (LACO, 2020) provides several recommendations pertaining to Site development, including site preparation and grading, foundation, seismic design parameters, construction considerations, and future geotechnical services. These recommendations are included as Mitigation Measure GEO-1, below, in order to reduce potential seismic risks.

In addition, prior to construction of Phase 2, the tank manufacturer would design the tank and foundation and would conduct seismic analysis of the proposed design. The clear well would additionally include a tank volume monitoring device which would provide an indication of if leakage is occurring and if maintenance is needed. With incorporation of Mitigation Measure GEO-1, which requires compliance with the design recommendations provided in the Soils Report (LACO, 2020) and adherence to the requirements of the AWWA and ASCE standards for seismic anchoring of tanks, the proposed project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking, and a less than impact would occur.

VII.a.iii) According to the City of Willits Public Review Draft 2019 Safety Element, liquefaction occurs when intense vibrations from an earthquake cause saturated soil to lose stability and act more like a liquid than a solid. Areas near the City where groundwater is shallower than 50 feet may be prone to liquefaction; however, no historic impacts associated with liquefaction have occurred within the City (City of Willits, 2019b). According to the Soils Report (LACO, 2020), liquefaction has three potential consequences:
liquefaction-induced settlement, bearing capacity failure, and lateral spreading toward a free face.

As noted in the Soils Report (LACO, 2020), the underlying soil layers encountered during the exploration are not susceptible to liquefaction; however, the clear well site is blanketed by up to 7 feet of potential liquefiable undocumented fill. Recommendations related to site grading and preparation were provided in the Soils Report and included as Mitigation Measure GEO-1, below, in order to reduce the potential for liquefaction of the near surface undocumented fill material. In addition, the proposed clear well and

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
associated infrastructure would be designed to the AWWA tank standards for steel tanks and to the ASCE standards for seismic anchoring of tanks. As such, the project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to seismic-related ground failure, including liquefaction. With mitigation incorporated, a less than significant impact would occur.

VII.a.iv) As shown on the Landslide Susceptibility Classes figure, Figure S-3a of the City of Willits Draft 2019 Safety Element, landslides present some risk to the City of Willits, mainly along the southern and western portion of the City. However, the Site is relatively flat and is located at an elevation between 1,323 and 1,353 feet above mean sea level in an area characterized as “Low Landslide Susceptibility Class.” Given the relatively low slopes, both on and adjacent to the Site, the project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to landslides and no impact would occur.

VII.b) The proposed project involves excavation of up to eight (8) access holes for horizontal directional drilling required to install the new water line and excavation for installation of the clear well. While the proposed excavation would have the potential to temporarily create erosion and loss of topsoil, the project is proposed in an area that has been previously disturbed for the construction and ongoing maintenance of the Willits Groundwater System and during project construction, standard Best Management Practices (BMPs), such as straw bales, fiber rolls, and/or silt fences, would be employed to limit the potential for erosion resulting from construction and to avoid runoff into sensitive habitat areas. In addition, construction would occur during the dry season (dry season is typically May 30 through October 15, and construction would be further limited to the non-nesting and roosting season from September 1 to October 15) when rainfall and runoff potential would be low. Upon completion of construction, all disturbed soils would be stabilized and bare soil vegetated, as needed, with native vegetation and/or native seed mixes for soil stabilization as soon as feasible. As a result, the proposed project would not result in substantial soil erosion or the loss of topsoil and a less than significant impact would occur.

VII.c) As discussed above, based on the exploration program provided in the Soils Report (LACO, 2020) the project is feasible from a geotechnical standpoint. LACO found a low potential for slope instability, surface rupture from a potentially active fault, and lurching. The primary geotechnical concerns at the clear well site are the presence of up to 7 feet of potentially liquefiable undocumented fill and the potential for flooding, as the clear well site is located in an area designated as Zone AE, an area inundated by the onepercent annual chance flooding, for which BFEs have been determined. The clear well will be located adjacent to the west of the existing groundwater treatment plant, which is currently located in the Regulatory Floodway, as shown on FIRM panel number 06045C1112F, effective June 2, 2011. As such, there is the potential for liquefaction, settlement, and soil swelling or shrinkage. Additionally, although the Site is not located within a mapped Alquist-Priolo special study zone, the Site is located within a seismically active region and would likely experience ground shaking during the economic lifespan of the project. Several recommendations were provided in the Soils Report (LACO, 2020) in order to minimize and reduce the potential for such risks, which have been included under Mitigation Measure GEO-1. With mitigation incorporated, potential geological risks would be minimized and a less than significant impact would occur.

VII.d) Expansive soils generally consist of cohesive fine-grained clay soils and represent a significant structural hazard to buildings founded on them as they have a tendency to undergo volume changes (shrink or swell) with changes in moisture content. As previously discussed, the clear well site contains approximately 7 feet of undocumented fill that consists of heterogeneous deposits of brown clayey sand with gravel and greyish brown clay, overlying alluvial deposits to the maximum depth explored of 41.5 feet

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Groundwater Resiliency Improvements Project
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bgs (LACO, 2020). Provided the undocumented fill is removed and replaced as a pad of engineered fill in accordance with the site preparation and grading recommendations provided in the Soils Report (LACO, 2020) and included under Mitigation Measure GEO-1, a less than significant impact would occur.

VII.e) The proposed project would not require the use of septic systems or other alternative wastewater disposal system, as the project proposed improvements to the existing Willits Groundwater System, including the replacement of existing water line, upgrading an existing well pump, and the installation of a clear well.

As such, no impact would occur.

VII.f) The potential exists for unique paleontological resources or site or unique geological features to be encountered within the project area during ground-disturbing construction activities, including excavation for installation of the water lines and clear well; however, the potential is low as the Site was previously disturbed for installation of the existing water line and the groundwater treatment plant. In the event that any archaeological or paleontological resources are discovered during site preparation or other earthdisturbing construction activities, the contractor would immediately halt all work and contact the City of Willits Community Development Department, in accordance with City policies. As such, a less than significant impact would occur.

MITIGATION MEASURES
GEO-1: The proposed clear well installation shall comply with the recommendations pertaining to site preparation and grading, foundation, seismic design parameters, construction considerations, and future geotechnical services provided in the Soils Report, prepared by LACO Associates and dated June 30, 2020 (see Appendix D). Prior to construction of the project, the City of Willits Engineering Department shall review and approve of the site development plans, which must demonstrate project compliance with the recommendations of the Soils Report (LACO, 2020), in addition to any seismic requirements of the latest adopted edition of the CBC. All on‐site geotechnical engineering activities shall be conducted under the supervision of a licensed Geotechnical Engineer or Certified Engineering Geologist.

FINDINGS
The proposed project would have a Less Than Significant Impact with Mitigation Incorporated on Geology and Soils.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
VIII.GREENHOUSE GAS EMISSIONS. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Generate greenhouse gas emissions (GHG), 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?
Thresholds of Significance: 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 greenhouse gases.

DISCUSSION
The Global Warming Solutions Act of 2006, also known as Assembly Bill (AB) 32, is a State law that establishes a comprehensive program to reduce greenhouse gas (GHG) emissions from all sources throughout the State. AB 32 requires the State to reduce its total GHG emissions to 1990 levels by 2020, a reduction of approximately 15 percent below emissions expected under a “business as usual” scenario. Pursuant to the AB 32 Scoping Plan (last reviewed in 2018), the California Air Resources Board (ARB) must adopt regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. The following major GHGs and groups of GHGs being emitted into the atmosphere are included under AB 32:
carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3). The 2020 GHG emissions statewide limit set by AB 32, equal to the 1990 level, is 431 million metric tonnes of carbon dioxide equivalent (MMTCO2e). In addition, in 2016, Senate Bill (SB) 32 was signed into law to codify the reduction target to reduce GHG emissions to 40 percent below the 1990 levels by 2030 (ARB, 2018).

The California Air Resources Board (ARB), in its California Greenhouse Gas Emissions for 2000 to 2017 (California GHG Emission Inventory), 2019 edition, states that GHG emissions within the State of California have followed a declining trend since 2007. In 2017, statewide GHG emissions were 424 million metric tons of CO2 equivalent (MMTCO2e), 5 MMTCO2e lower than 2016 levels and lower than the 2020 statewide GHG limit of 431 MMTCO2e. The transportation sector remains the largest source of GHG emissions in the State, accounting for 41 percent of the State’s GHG emissions in 2017 (ARB, 2019).

The Site is located within the North Coast Air Basin (NCAB) and is subject to the requirements of the Mendocino County Air Quality Management District (MCAQMD). The MCAQMD is responsible for monitoring and enforcing federal, state, and local air quality standards in the Mendocino County. As noted in Chapter 4 (Resource Management Element) of the Mendocino County General Plan (2009), page 4-19, due to the rural nature of Mendocino County, the amount of GHG generated by human activities (primarily the burning of fossil fuels for vehicles, heating, and other uses) is small as compared to other, more urban counties and miniscule in statewide or global terms. However, GHG emissions in Mendocino County are higher per capita due to the distances involved in traveling around the county.

VIII.a) The project would not generate GHG emissions either directly or indirectly, that may have a significant impact on the environment, as neither construction nor operation of the project would generate significant amounts of GHG emissions above the baseline conditions. A limited amount of GHG emissions would be anticipated to occur during construction activities; however, it is anticipated that the

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
construction phase of the project would not result in wasteful, inefficient, and unnecessary consumption of energy. To reduce the potential for GHG emissions, the contractor would keep all construction equipment in good working order and would limit idling of vehicles and equipment during construction, in accordance with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit DieselFueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the California Air Resources Board (ARB). In addition, the clear well would be constructed by off-site water tank builders. Therefore, the construction of the clear well would not be considered in the impacts to GHG emissions at the Site.

Once construction is complete, the project would generate a negligible increase in operational GHG emissions from the Site, beyond the current emissions from operation of the groundwater treatment system.

Vehicle trips to the Site would not be anticipated to increase, as current City staff would maintain the project components as part of general ongoing maintenance and operation of the Willits Groundwater System. Given the relatively small scale of the project, neither construction nor operation of the proposed project would have a measurable or considerable contribution to the cumulative GHG impact at the local, regional, or state level. A less than significant impact would occur.

VIII.b) The proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Action Item RM-50.2 in Chapter 4 of the Mendocino County General Plan (2009) requires the County to “create a greenhouse gas reduction plan for the unincorporated areas of the county that sets specific reduction strategies and targets to meet.” Although the County has not yet prepared and adopted this plan, a significant amount of GHG emissions is not anticipated under the project, as described above. In addition, the proposed project would not conflict with local, MCAQMD, State, or federal regulations pertaining to GHG emissions, since the proposed project would have a negligible impact on the current GHG emissions from the Site. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Greenhouse Gas Emissions.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
IX. HAZARDS AND HAZARDOUS MATERIALS. Would
the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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?
Thresholds of Significance: The project would have a significant effect on hazards and hazardous materials if it were to 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; emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school; be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment; result in a safety hazard or excessive noise for people residing or working in the project area if 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; or impair the implementation of, or physically interfere with an adopted emergency response plan or emergency evacuation plan; or expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

DISCUSSION
A material is considered hazardous if it appears on a list of hazardous materials prepared by a federal, state, or local agency, or has characteristics defined as hazardous by a federal, state, or local agency.

Chemical and physical properties such as toxicity, ignitability, corrosiveness, and reactivity cause a substance to be considered hazardous. These properties are defined in the California Code of Regulations, Title 22, Article 3: Characteristics of Hazardous Waste (effective July 1, 1991). A “hazardous waste” includes any hazardous material that is discarded, abandoned, or will be recycled. The criteria that render a

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Groundwater Resiliency Improvements Project
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material hazardous also cause a waste to be classified as hazardous, per California Health and Safety Code, Chapter 6.5, Section 25117 (effective January 1, 1997).

Mendocino County has adopted numerous plans related to hazard management and mitigation including, but not limited to: Community Wildfire Protection Plan, Hazardous Waste Management Plan, Operational Area Emergency Plan, and Multi-Jurisdictional Hazard Mitigation Plan, in which the City of Willits (City) is a participant. In addition, in October 2019, the City released a Public Review Draft of the 2019 Safety Element of the City of Willits General Plan to identify safety risks the City faces and develop goals, policies, and implementation programs to better address the issues.

The Site does not include any known hazardous waste sites, as mapped by the State Water Resources Control Board (SWRCB) or the California Department of Toxic Substances Control (DTSC) on the GeoTracker (2020) and EnviroStor (2020) databases, respectively, nor are there any listed sites within the vicinity of the Site. The project would require the transport, use, storage, and disposal of small quantities of hazardous materials common for equipment and site maintenance and operation, such as gasoline, diesel fuel, hydraulic fluids, oils, lubricants, and cleaning solvents and supplies. However, all hazardous materials would be utilized and disposed of in accordance with all applicable federal and state regulations.

IX.a-b) The proposed project would not transport, use, emit, or dispose of significant amounts of hazardous materials, or 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. During the construction phase, small quantities of hazardous materials common to equipment maintenance and operation, such as gasoline, diesel fuel, hydraulic fluids, oils, and lubricants may be required. Once constructed, the project would be anticipated to utilize fuels, lubricants, solvents, and chemicals used for routine groundwater treatment operations. However, the types and quantities of materials to be used are not expected to pose a significant risk to the public and/or environment and would be managed in accordance with federal, state, and local regulations. Since the transport, use, and storage of any hazardous materials at the Site would be required to be conducted in accordance with all federal, state, and local regulations, a less than significant impact would occur.

IX.c) No existing or proposed schools are located within one-quarter mile of the Site. The Site is located within the Willits Unified School District (Mendocino County Maps - School Districts, 2014), with the nearest school, Willits High School, located approximately 0.47 miles west of the Site at its closest point. It is not anticipated that hazardous materials would be used at the Site in any quantity or application that could impact any schools in the area. Therefore, no impact would occur.

IX.d) Review of the SWRCB’s GeoTracker (2020) and DTSC’s EnviroStor (2020) databases indicates the Site is not included on a list of sites that impact or have the potential to impact water quality in California (GeoTracker), or hazardous waste facilities and sites with known or suspected contamination issues (EnviroStor). As discussed above, any hazardous materials to be used on-site would be utilized, stored, transported, and disposed of in accordance with federal, state, and local regulations. No impact would occur.

IX.e) The Site is not located within an airport land use plan and the nearest airport, Ells Field (Willits Municipal Airport), is located approximately 1.68 miles northwest of the Site in Brooktrails, at its closest point.

As project implementation would be temporary in nature and any ongoing maintenance of the project would be infrequent, workers in the project area would not be exposed to a safety hazard or excessive noise levels. A less than significant impact would occur.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
IX.f) There are no components of the project that would impair or interfere with emergency response or evacuation. The proposed clear well, the only project component located within a developed area, would be required to be constructed and installed in accordance with state and local standards, including safety and emergency access requirements. The remaining project improvements would occur within a vacant agricultural area that is utilized for cattle grazing and would have no impact on emergency response or evaluation plans. As such, the clear well would have no impact on emergency response or evacuation in the project area and there are no components of the project that would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. A less than significant impact would occur.

IX.g) The proposed project would not expose people or structures, either directly or indirectly to a significant risk of loss, injury, or death involving wildland fires. As described above, the Site is located northeast of the City center on City-owned parcels currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant. The Site is located within the Local Responsibility Area (LRA) and is served by the Little Lake Fire District (Mendocino County Maps – Little Lake Valley – Fire Responsibility Areas, 2019). The Site is mapped as located within a “Moderate” fire hazard severity zone per Figure S-7a of the Public Review Draft 2019 Safety Element of the City of Willits General Plan. The parcels identified by APNs 108-030-06 and 108-020-05 are vacant agricultural field utilized for cattle grazing during the dry season, while the parcel identified by APN 007-010-01 is comprised of the groundwater treatment plant and sewer plant.

Replacement of the existing water line and upgrading the existing well pump would improve existing infrastructure and the clear well installation within a developed area would not increase the risk of wildfires.

The proposed project components would not cause increased exposure of people or structures to a significant risk of loss, injury or death involving wildland fires. As such, a less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Hazards or Hazardous Materials.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
X. HYDROLOGY AND WATER QUALITY. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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 substantial erosion or siltation on- or
off-site?
ii) Substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or off-site?
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?
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?
Thresholds of Significance: The project would have a significant effect on hydrology and water quality if it would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner, which would result in substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, or impede or redirect flows; in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation; or conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

DISCUSSION
The National Pollutant Discharge Elimination System (NPDES) permit program of the U.S. Environmental Protection Agency (EPA) addresses water pollution by regulating point sources that discharge pollutants to waters of the United States. Created in 1972 by the Clean Water Act, the NPDES permit program grants authority to state governments to perform many permitting, administrative, and enforcement aspects of the program. Within California, the NPDES permit program is administered by the State Water Resources Control Board (SWRCB) and the Regional Water Quality Control Boards. Construction projects that would disturb more than one acre of land, such as the proposed project, would be subject to the requirements of

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
General Construction Activity Stormwater Permit (Construction General Permit Order 2009-0009-DWQ, also known as the CGP), which requires operators of such construction sites to implement stormwater controls and develop a SWPPP identifying specific Best Management Practices (BMPs) to be implemented to minimize the amount of sediment and other pollutants associated with construction sites from being discharged in stormwater runoff.

According to Section 4-3 of the Resource Management Element (Chapter 4) of the Mendocino County General Plan (2009), the most critical surface water quality problem in Mendocino County is sedimentation.

Major sources of sediment include erosion from barren or poorly vegetated soils, erosion from the toes of slides along stream channels, and sediments from roads. Policies RM-1 through RM-23 of the Resource Management Element (Chapter 4) of the Mendocino County General Plan (2009) are related to protection of environmentally sensitive habitat areas and maintaining water quality by minimizing adverse effects of wastewater dischargers, controlling runoff, preventing depletion of groundwater supplies and substantial interference with surface water flow, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams. Mendocino County Ordinance No. 4313, Stormwater Runoff Pollution Prevent Procedure (Mendocino County Code Chapter 16.30 et.seq.), requires any person performing construction and grading work anywhere in the unincorporated areas of the County to implement appropriate BMPs to prevent the discharge of construction waste, debris or contaminants from construction materials, tools, and equipment from entering the storm drainage system (off-site). BMPs that must be implemented during construction activities are listed in Section 16.30.070 of the County Code.

Construction within the City is subject to the 100% Draft City of Willits Design and Construction Standards (City Standards), updated November 12, 2011. The City Standards requires that contractors prepare and implement a program to control water pollution on construction projects that result in 1 acre (ac) or more of soil disturbance, in accordance with the CGP of the SWRCB, as described above. The City requires that construction projects that submit a Notice of Intent (NOI) provide a copy of the SWPPP to the City, as part of the application for an Erosion Control Permit through the City. Section IV of Part A.2 (Erosion Control Specifications) of the City Standards (2011) details BMPs that must be implemented whenever construction is occurring.

The Site is located within the Mill Creek-Outlet Creek Hydrologic Unit of the Little Lake Valley. The Site is located east of Outlet Creek and west of Davis Creek, both of which flow from south to north. Baechtel Creek splits the northern and southern portions of the Site, with an existing crossing of Baechtel Creek utilized to access to the northern portion of the Site and for the ongoing maintenance and operation of the Willits Groundwater System and wastewater treatment ponds (see Figure 2). Per Section 4.600 (Hydrology) of Volume 3 (Environmental Impact Report) of the Willits General Plan Revision: Vision 2020 (City of Willits, 1992), the confluence of Baechtel Creek and Outlet Creek, a tributary of the Eel River, is located approximately four (4) miles north of the City and receives and controls storm runoff throughout the Little Lake Valley. Due to the localized geologic formations at the confluence, backwaters can occur, leading to flooding in the Little Lake Valley during moderate to heavy storm conditions (City of Willits, 1992).

Additionally, the reduced velocities of the runoff at the Baechtel-Outlet confluence encourages stream siltation in the valley’s drainage network, aggravating flooding problems. The majority of the Site is located within the 100-year flood zone (Zone A) of Outlet Creek, as shown on Federal Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) panel number 06045C1112F, effective June 2, 2011, with the clear well proposed to be located in an area designated as Zone AE, an area inundated by the one-percent annual chance flooding, for which Base Flood Elevations (BFEs) have been determined. The clear well will be located adjacent to the west of the existing groundwater treatment plant, which is currently located in the Regulatory Floodway, as shown on FIRM panel number 06045C1112F, effective June 2, 2011. As previously discussed, the Site is currently utilized for the Willits Groundwater System, including the Elias

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant.

Uses surrounding the northern portion of the Site include vacant fields utilized for cattle grazing during the dry season, typically May to October. Uses surrounding the southern portion of the Site include the groundwater treatment plant and sewer plant. As a result, drainage primarily occurs through sheet flow and percolation, with the potential for concentrated flow across the impervious surfaces located in the southern portion of the Site.

The proposed project includes the replacement of 3,600 feet of water line within the Willits Groundwater System and upgrading of the existing 30 hp pump to a 40 hp pump at the Elias replacement well in order to increase transfer capacity from the Elias replacement well and the installation of a 250,000-gallon clear well to enhance treatment and operability of the Willits Groundwater System. The project provides benefits to water resource management in the City, including increasing the resiliency and conjunctive use capabilities and improving the quality of the City water system.

X.a) As described above, construction of the project would be subject to the CGP, Mendocino County Code Chapter 16.30, and the City of Willits Design and Construction Standards, which require the preparation and implementation of a SWPPP that specifies erosion and sediment control construction BMPs to reduce or eliminate construction-related impacts to the water quality of receiving water bodies. Areas of disturbance would be regraded to mimic existing conditions, to the extent feasible. Post-construction, any disturbed areas would be revegetated and the majority of the Site would remain undeveloped such that the majority of stormwater runoff from the Site would continue to follow natural drainage patterns and infiltrate into the soil.

The Soils Report prepared by LACO on June 30, 2020, notes that shallow groundwater levels were encountered between 8.5 and 14 feet below ground surface (bgs) during on-site exploration and that the local minimum depth to groundwater level of 1.07 feet bgs was recorded approximately 2,400 feet southeast of the Site, but provided construction is performed during the dry months of summer or early fall, it may not be a concern. Should groundwater be encountered during foundation excavation, construction shall be performed in accordance with Mitigation Measure HYDRO-1, below, in order to reduce potential impacts to groundwater quality.

Per the Technical Memorandum dated May 30, 2019 prepared by LACO, in support of the NCRP’s Outreach and Involvement: Economic Opportunity for Disadvantaged Communities Program, until recently, all water for the City water supply system was supplied from surface water reservoirs on the Davis Creek watershed: Morris Reservoir and the upstream Centennial Reservoir. Water from these sources is treated at the surface water treatment plant near Morris Reservoir and piped to the City and surrounding regions approximately 2.5 miles via a single 16-inch transmission line. The dependence of the City water supply system on a single surface source has made it vulnerable to water supply and/or water quality issues due to catastrophic failures and/or to severe or protracted drought, as was demonstrated during the water crisis the City experienced in 2014. The drought not only placed a strain on the quantity of water available, reduced levels in the reservoirs led to increased temperatures and biological growth, including algae blooms (LACO, 2019). The proposed project would provide the City with increased conjunctive use capabilities, allowing the City flexibility to manage water sources adaptively, considering factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health, and would help to ensure a reliable water supply in the City, sufficient to meet community needs if surface water again becomes untenable.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
The proposed project will comply with the relevant water quality standards and waste discharge requirements during construction and would also allow the City the flexibility to improve the quality of its water supply system and prevent future water quality violations in its surface water supply since the construction of the clear well tank would allow operators to make adjustments to chemical dosages and treatment of the water, as needed, prior to its delivery to the water supply system. Through proper implementation of appropriate BMPs, compliance with the aforementioned regulations, and the incorporation of Mitigation Measure HYDRO-1 to limit the potential for impacts to groundwater during foundation excavation, the proposed project would not violate any water quality standards or waste discharge requirements, and a less than significant impact would occur.

X.b) Data indicate that groundwater levels in the Little Lake Valley groundwater basin (Basin) fluctuate principally in response to pumping and precipitation, with seasonal fluctuations resulting from seasonal variations in rainfall and pumping (Farrar, 1986; DWR, 2004). According to hydrographs presented by Farrar (1986) that include water-level records for four (4) wells spanning 10 years or more prior to 1986, groundwater levels in the Basin fluctuate approximately 10 to 15 feet seasonally. Johnson (2008) found that first encountered groundwater in the Basin in the spring fluctuates approximately between ground surface (0 feet bgs) and 5 feet bgs, while during the fall, groundwater fluctuates at approximately 15 to 30 feet bgs.

Long-term groundwater-level trends in the Basin have been observed to be relatively flat to slowly recovering from heavy well pumpage and drought (Farrar, 1986; North Coast Hydrologic Region, 2004; Johnson, 2008). Groundwater levels observed in 2008 were as high as or higher than the earliest recorded data (Johnson, 2008). Additional data show that groundwater levels in the Basin recover relatively quickly from declines in groundwater levels due to heavy pumping and years of drought. Johnson (2008) observed that groundwater levels quickly recovered in a well east of the City following declines in groundwater levels attributed to heavy pumping followed by an extended drought. These groundwater levels were recorded between 1966 and 1978 with the drought occurring between 1975 and 1977.

As noted previously, the City’s groundwater infrastructure includes the Elias replacement well, the groundwater treatment plant, and the Park well. The City actively monitors groundwater levels in multiple locations and plans to create a more robust monitoring plan in coming years. The City will continue to look for wells near its groundwater infrastructure that can be accessed and measured in order to gather important data as part of the aforementioned groundwater monitoring plan.

The Elias replacement well is currently the only well connected to the City’s groundwater treatment plant and water supply system. An aquifer test conducted by GHD on the Ellias replacement well in 2015 recommended a production rate of 600 to 800 gallons per minute (gpm), considering a 20-to-40-percent safety factor. The aquifer test on which this recommendation was based was performed by continuously pumping the Elias replacement well at 400 gpm and monitoring surrounding wells. The wells connected to the same confined aquifer as the Elias replacement well experienced drawdown during the aquifer test.

The wells accessing groundwater from the confined aquifer are generally described as those developed with screening deeper than 60 feet bgs. However, the test determined that shallow wells were not affected by the pumping of the Elias replacement well at a rate of 400 gpm.

Water from the Park well is used by the City for irrigation, sold to private water truck owners, and used for construction, fire suppression and other miscellaneous uses. In 1988, DWR conducted an aquifer test on the Park well. The test found that wells tapping into the same aquifer and within one-half mile of the Park well

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
experienced a drawdown of approximately 10 feet after 30 days of continuous pumping at a rate of 450 gpm. The test report noted that changes in water level can be mitigated by pumping part-time since water levels were observed to immediately increase when pumping stopped. Data collected from four (4) shallow monitoring wells indicated that that there was no response to the pumping of the Park well. In August 2021, the City installed two new monitoring wells near the Park well to gather additional data on the effects of Park well pumping on the surrounding groundwater levels.

In 1965, Cardwell estimated the groundwater storage capacity for the Basin to be 50,000 acre-feet between 10 and 100 feet bgs. In 1986, Farrar estimated the quantity for the same range of depth to be 35,000 acre-feet. In 1965, DWR estimated the groundwater storage capacity for the Basin to be between 10 and 200 feet bgs to be 91,600 acre-feet. One (1) acre-foot is equal to 325,851 gallons and the City used approximately 799.5 acre-feet of treated surface water and no treated groundwater in 2020; and approximately 826.7 acre-feet of treated surface water and 41.7 acre-feet of treated groundwater in 2019. Additionally, approximately 24.5 acre-feet and 3.4 acre-feet of untreated groundwater was drawn from the Park well for bulk water sales in 2020 and 2019, respectively. The total water usage by the City (from surface water and groundwater sources) was 824 acre-feet in 2020 and 871.8 acre-feet in 2019. This calculation does not account for the water used to irrigate the Recreation Grove or the little league and soccer fields. Currently, there are no meters in place to measure this quantity and the amount is considered to be nominal and not necessary to this evaluation. To provide further context, the City’s total water usage is shown as a percentage of the storage capacity estimates in the following table, which demonstrates that the total water usage by the City is a small percentage of the estimated groundwater storage capacity in the Basin:

Table 1. City water usage as a percentage of estimated storage capacity.

Year
City Usage
(acre-feet)
Estimated Storage
Capacity
35,000 acre-feet
(Farrar 1986)
Estimated Storage
Capacity
50,000 acre-feet
(Cardwell 1965)
Estimated Storage
Capacity
91,600 acre-feet
(DWR 1965)
2020 824 2.4% 1.6% 0.9%
2019 871.8 2.5% 1.7% 1.0%
Given historical groundwater level data and the purpose of the proposed project to increase the City’s ability for conjunctive use, the proposed project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge. Although the project would result in increased functionality and capacity of the Willits Groundwater System, the project is intended to improve the City’s ability to use groundwater to supplement surface water and, at the same time, provide a reliable secondary source in the case of an emergency. Increased conjunctive use capabilities would provide the City with the ability to manage both surface water and groundwater sources adaptively, in consideration of factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health. In addition, the City would operate and maintain the improved Willits Groundwater System in accordance with the goals and policies of the groundwater management plan currently adopted by the City.

Additionally, as the proposed clear well is the only proposed impervious improvement and would be installed adjacent to the west of the existing groundwater treatment plant, in an existing disturbed area, the majority of the Site would remain undeveloped and stormwater would continue to infiltrate and recharge the groundwater basin. As a result, a less than significant impact would occur.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
X.c.i) The project would not alter the existing drainage pattern of the Site in a manner which would result in substantial erosion or siltation on- or off-site. The proposed clear well is the only proposed impervious improvement and would be installed adjacent to the west of the existing groundwater treatment system, on an existing fill pad. Through implementation of the project, existing drainage patterns of the Site would remain largely unaltered. In addition, as described above, the project would be subject to the CGP, which requires the preparation and implementation of a SWPPP that specifies erosion and sediment control construction BMPs to reduce or eliminate construction-related impacts on receiving water quality. BMPs to be employed during construction may include fiber rolls, silt fencing structures, gravel bag barriers, a stabilized construction entrance, and concrete waste management. Upon completion of constructionrelated activities, all disturbed areas would be stabilized to limit the exposed surfaces and prevent the potential for erosion. As a result, implementation of the proposed project would not result in substantial erosion or siltation, and a less than significant would occur.

X.c.ii-iii) The project would not substantially increase the rate or amount of surface runoff in a matter which would result in flooding on- or off-site, create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems, or provide substantial additional sources of polluted runoff. The clear well installation would be installed on an existing fill pad located between the groundwater treatment plant and an agricultural field owned by the City. The majority of the Site would remain undeveloped such that the majority of stormwater runoff from the Site would continue to follow natural drainage patterns and infiltrate into the soil. Through implementation of the project, existing drainage patterns of the Site would remain largely unaltered and a less than significant impact would occur.

X.c.iv) As discussed above, the majority of the project site is located within the 100-year flood zone (Zone A) of Outlet Creek, as shown on FEMA’s FIRM panel number 06045C1112F, effective June 2, 2011, with the clear well proposed to be located in an area designated as Zone AE, an area inundated by the onepercent annual chance flooding, for which BFEs have been determined. The clear well would be located adjacent to the west of the existing groundwater treatment plant, which is currently located in the Regulatory Floodway, as shown on FIRM panel number 06045C1112F, effective June 2, 2011.

Recommendations related to the consideration of surface drainage during construction were provided in the Soils Report and included as Mitigation Measure GEO-1, above, in order to reduce the potential for impacts related to flooding of the proposed clear well. In addition, the proposed clear well and associated infrastructure would be designed to the AWWA tank standards for steel tanks and to the ASCE standards for flood resistant design and the clear well would not be anticipated to significantly alter the drainage patterns of the Site. As a result, with mitigation incorporated, the project would not substantially alter the existing drainage pattern of the Site in a manner which would impede or redirect flood flows and a less than significant impact would occur.

X.d) While the Site is located in a flood hazard zone, as described above, it is not located in a tsunami or seiche zone, as it is not located near any large inland bodies of water and is more than 25 miles east of the Pacific Ocean, and does not risk the release of pollutants due to project inundation. The project improvement proposed to be located within the 100-year flood zone (Zone A), as defined by FEMA, includes the replacement of the existing water line and upgrading the existing well pump. In addition, the clear well is proposed to be located in an area inundated by the one-percent annual chance flooding, for which Base Flood Elevations (BFEs) have been determined (Zone AE); however, the clear well would be a bolted or welded steel tank and would not release pollutants in the event of inundation. A less than significant impact would occur.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
X.e) As discussed above, the project would be required to comply with the Statewide CGP, Mendocino County Code Chapter 16.30, and the City of Willits Design and Construction Standards (City Standards), updated November 12, 2011, which would require preparation of a SWPPP, including identification and implementation of BMPs to be utilized to minimize the amount of sediments and other pollutants from being discharged in stormwater runoff. Compliance with these regulations would facilitate the implementation of water quality control efforts at the local and state levels. There is currently no sustainable groundwater management plan for the Little Lake Valley groundwater basin; however, the Little Lake Valley Groundwater Management Plan (GWMP) was adopted by the City of Willits on August 26, 2020. The proposed project aligns with a goal of the GWMP to “optimize conjunctive use of surface water and groundwater.” As implementation of the proposed project would provide the City with increased conjunctive use capabilities, allowing the City flexibility to manage water sources adaptively, considering factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health, the project would not be anticipated to conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. A less than significant impact would occur.

MITIGATION MEASURES
HYDRO-1: In the event groundwater is encountered during foundation excavation activities, the contractor shall dewater the excavation area prior to placing concrete. Extracted groundwater shall be discharged in a manner that does not cause erosion at the discharge point. Any dewatering activities on-site shall be conducted under the supervision of a Qualified Stormwater Practitioner (QSP).

FINDINGS
The proposed project would have a Less Than Significant Impact with Mitigation Incorporated on Hydrology and Water Quality.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XI. LAND USE AND PLANNING. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on land use and planning if it would physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

DISCUSSION
The Site, identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030-06, and 108-020-05, is located northeast of City center on City-owned properties currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant. While the Site is entirely owned by the City of Willits, the parcel identified by APN 007-010- 01 is located within the City limits and has a City of Willits land use designation of Industrial-General (M-G) (1992) and zoning designation of Heavy Industrial (MH) (2010), while the parcels identified by APN 108-030- 06 and 108-020-05 are located within the unincorporated area surrounding the City and have County of Mendocino land use (2009) and zoning designations (2013) of Agricultural Lands (AG). See Figures 3 through 6, respectively for a visual depiction of the land use and zoning designations of the Site. No changes to the Site’s current land use or zoning designations are proposed.

Improvements would include the replacement of 3,600 feet of water line within the Willits Groundwater System, upgrading the existing 30 hp pump to a 40 hp pump at the Elias replacement well, and the installation of a 250,000-gallon clear well. The project proposes improvements to an existing public facility, with no changes proposed to the existing and principally permitted uses.

XI.a) The proposed project would not physically divide an established community as all project improvements are proposed within the existing Willits Groundwater System. The only noticeable aboveground improvement would include the clear well. This improvement would not physically divide an established community as the clear well would be sited adjacent to the west of existing City infrastructure, between the groundwater treatment plant and an existing agricultural field owned and utilized by the City.

As a result, no impact would occur.

XI.b) The project would not 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. As the project proposes modifications to the existing Willits Groundwater System, a permitted use on the Site, the proposed project would be consistent and compatible with surrounding and existing on-site uses. While implementation of the project may lead to an increased use of groundwater through improvements to treatment and operability of the system, as noted above, the project is intended to increase the City’s conjunctive use capabilities by improving the existing groundwater treatment system. Increased conjunctive use capabilities would provide the City with the ability to manage both surface water and groundwater sources adaptively, in consideration of factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health. In addition, the City would operate and maintain the improved Willits Groundwater System in accordance with the goals and policies of the Little Lake

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Valley Groundwater Management Plan (GWMP) adopted by the City of Willits on August 26, 2020, and any other future sustainable groundwater management plans applicable to the City. As such, a less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Land Use and Planning.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XII. MINERAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on mineral resources if it would 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 or result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

DISCUSSION
The proposed project is not located in an area of known rock, aggregate, sand, or other mineral resource deposits of local, regional, or state residents. There are no known mineral resources of significance on the Site that would be made unavailable by the proposed project. Furthermore, the project Site is not utilized for Surface Mining and Reclamation Act (SMARA) activities.

XII.a-b) The proposed project area does not contain mineral resources that are of value locally, to the region, or to residents of the City, County, or state. According to the Mineral Land Classification Studies Index of the California Department of Conservation (DOC, 2015), the proposed project is not located in an area with known mineral resources. The proposed project area is not identified as a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

Therefore, the proposed project would not interfere with materials extraction or otherwise cause a shortterm or long-term decrease in the availability of mineral resources. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have No Impact on Mineral Resources.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XIII.NOISE. Would the project result in:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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 groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of 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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on noise if it would result in the 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; or generation of excessive groundborne vibration or groundborne noise levels; or expose people residing or working in the project area to excessive noise levels (for a project located within the vicinity of a private airstrip or an airport or an airport land use plan, or where such as plan has not been adopted, within two miles of a public airport or public use airport).

DISCUSSION
Noise is typically defined as unwanted sound. In any one location, the noise level will vary over time, from the lowest background or ambient noise level to temporary increases caused by traffic or other sources.

State and federal standards have been established as guidelines for determining the compatibility of a particular use with its noise environment. The City of Willits relies principally on standards in its Noise Element of the City of Willits General Plan (1992), its Zoning Ordinance (1982), the County of Mendocino Noise Element of the County of Mendocino General Plan (2009), the County of Mendocino Zoning Ordinance (1987), other County ordinances, and the Mendocino County Airport Comprehensive Land Use Plan (ACLUP) to evaluate noise-related impacts of development, depending on the location of proposed development.

Acceptable levels of noise vary depending on the land use. Generally speaking, land uses considered noise-sensitive are those in which noise can adversely affect what people are doing on the land. For example, a residential land use where people live, sleep, and study is generally considered sensitive to noise because noise can disrupt these activities. Churches, schools, and certain kinds of outdoor recreation are also usually considered noise-sensitive. The Site is currently utilized for the Willits Groundwater System, including the Elias replacement well and the groundwater treatment plant, and is located adjacent to the City’s sewer plant (see Figure 2). Surrounding uses include vacant fields utilized for cattle grazing during the dry season to the north and the groundwater treatment plant and sewer plant to the south, with no noisesensitive uses within close vicinity of the Site. The proposed improvements would include the replacement of 3,600 feet of water line within the Willits Groundwater System, upgrading the existing 30 hp pump to a 40 hp pump at the Elias replacement well, and the installation of a 250,000-gallon clear well; improvements to and uses that are similar to, and compatible with, the uses that exist in the area.

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Construction of the proposed project would generate short-term noise corresponding to the phase of construction and the noise generating equipment used during those phases. Construction activities would involve excavation, horizontal directional drilling, grading, drilling, earth movement, and vehicle travel to and from the Site. Throughout all phases of construction, work would be limited to normal business hours, typically 7:00 am to 7:00 pm, Monday through Saturday, or as approved by the City. In addition, the equipment used during construction would include an excavator, drill rig, dump truck, vibratory plate/jumping jack, water truck, a backhoe, and roller, and would not be of such a scale that it would create a significant amount of noise or vibration. Upon completion of construction, the proposed improvements would be located within the area of the existing groundwater treatment system and operation of the proposed improvements would not require any additional equipment that would increase permanent noise levels at the Site.

XIII.a-b) Implementation of the proposed project would not be expected to generate noise in excess of what is common for such improvements, nor result would the project result in excessive ground borne vibration or ground borne noise levels. The Site is located within the area currently utilized for the Willits Groundwater System, including the Elias replacement well and the groundwater treatment plant, and is located adjacent to the City’s sewer plant (see Figure 2). In addition, aside from the clear well installation, all proposed improvements would be located within a vacant agricultural area utilized for cattle grazing during the dry season and the clear well would be sited west of the existing groundwater treatment plant, between the groundwater treatment plant and an existing agricultural field owned by the City.

During construction, temporary noise would be anticipated as a result of utilizing standard heavy equipment, which may include, but is not limited to the following: excavator, drill rig, dump truck, vibratory plate/jumping jack, water truck, backhoe, and roller. However, these noise impacts would be temporary in nature and standard conditions would be incorporated on the proposed development plans and implemented throughout construction, such as limiting construction hours to the hours of 7:00 a.m. and 7:00 p.m. Monday through Saturday, or as approved by the City, using quiet models of air compressors and other stationary noise sources where technology exists, and use of mufflers on all internal combustion engine-driven equipment. In addition, with the exception of minor nearby vibrations created from standard heavy equipment, there are no elements of the proposed project that would create either temporary or permanent ground borne vibrations or noise levels.

Once construction is complete, operational noise would be associated with the general operational noises of the existing Willits Groundwater System and nearby City sewer plant. No periodic or permanent increase in ambient or ground borne noise levels nor ground borne vibrations would be anticipated. Therefore, a less than significant impact would occur.

XIII.c) As previously discussed, the Site is not located within an airport land use plan and the nearest airport, Ells Field (Willits Municipal Airport), is located approximately 1.68 miles northwest of the Site in Brooktrails, at its closest point. As project implementation would be temporary in nature and any ongoing maintenance of the project would be infrequent, workers in the project area would not be exposed to excessive noise levels. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Noise.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XIV. POPULATION AND HOUSING. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Induce substantial unplanned population growth in
an area, either directly (e.g., by proposing new
homes and/or businesses) or indirectly (e.g., through
extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on population and housing if it would induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and/or businesses) or indirectly (e.g., through extension of roads or other infrastructure); or displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

DISCUSSION
According to the City of Willits 2019 Housing Element (City of Willits, 2019a), the population of Willits increased by more than 4 percent from 2010 to 2018, from 4,888 to 5,128 persons; however, the population growth is expected to slow over the next five years, decreasing to 2 percent county-wide. In 2016, Willits had 2,120 total housing units, 2,028 of which were occupied, with an average household size of approximately 2.52 persons in 2018 (City of Willits, 2019a). The General Plan Revision: Vision 2020 (City of Willits, 1992) forecasted an ultimate build-out population in Willits of approximately 7,500 residents by 2020, which would result in an estimated 33 percent increase in water consumption and would require careful monitoring of the available water services due to the limited capacity of and impact of drought on the City’s surface water supply.

XIV.a) The project would not induce substantial population growth in Willits, as substantial population growth, which has not yet been realized, was projected in the General Plan Revision (City of Willits, 1992), and the project entails improvements to the treatment and transfer capabilities of the existing Willits Groundwater System. As described previously, the proposed project is intended to expand the City’s conjunctive use capabilities to ensure a reliable water supply sufficient to meet community needs if surface water again becomes untenable. Although the replacement of the existing water line, upgrade of an existing well pump, and clear well installation would facilitate an increase in the transfer capacity of the Willits Groundwater System, these improvements would largely serve to enhance treatment and operability of the Willits Groundwater System and provide the City with a resilient water supply. In addition, as the proposed project would improve the existing Willits Groundwater System treatment and transfer capabilities, it would be operated by existing City staff as part of the ongoing maintenance and operation of the Willits Groundwater System, with no additional staff needed. Therefore, a less than significant impact would occur.

XIX.b) The northern section of the Site is currently vacant and utilized for cattle grazing during the dry season and the southern section contains the existing City’s groundwater treatment plant and sewer plant; as a result, no existing housing units would be removed under the project. Since the project would not displace any existing housing or residents, no impact would occur.

MITIGATION MEASURES
No mitigation required.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

FINDINGS
The proposed project would have a Less Than Significant Impact on Population and Housing.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XV. PUBLIC SERVICES. Would the project 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:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on public services if it would result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or result in the 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 (a) fire protection, (b) police protection, (c) schools, (d) parks, or (e) other public facilities.

DISCUSSION
There are no elements of the proposed project that would impact the ability of the City, County, or other local services providers to provide public services to the Site or local community. As previously discussed, the project includes the replacement of 3,600 feet of water line within the Willits Groundwater System, upgrading the 30 hp pump to a 40 hp pump at the Elias replacement well, and the installation of a 250,000-gallon clear well. Upon project completion, no new employees would be required to manage the proposed improvements as City staff would maintain the project components as part of general ongoing maintenance and operations of the Willits Groundwater System.

XV.a) The project would not create additional facilities that would require increased fire protection above current levels. None of the proposed improvements would require fire protection and all development would be sited within the footprint of existing development that is currently served by the Little Lake Fire District (Mendocino County Maps – Little Lake Valley – Fire Responsibility Areas, 2019). No impact would occur.

XV.b-c) There are no portions of the proposed project that would require additional police protection or the construction of a new school. The project includes no impact on the population of Willits as existing City staff will maintain the project as part of ongoing maintenance of the Willits Groundwater System, and no new staff would be needed. Therefore, there would be no impact on police protection or schools as a result of the proposed project.

XV.d-e) As previously discussed, no residential units would be constructed, nor is the population expected to increase, as a result of the proposed project. Because the proposed project would not create a need for new or physically altered park facilities or other public facilities, it will not result in adverse physical impacts associated with the construction of such facilities. No impact would occur.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have No Impact on Public Services.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XVI. RECREATION. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) 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) Include recreational facilities or require the
construction or expansion of recreational facilities
which might have an adverse physical effect on the
environment?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on recreation if it would 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, or include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

DISCUSSION
The Site is located in the vicinity (within 5 miles) of the following neighborhood and regional parks and recreational facilities:
 Community Ball Fields, located approximately 0.28 miles south of the Site;  Frank Grasse Dog Park and Willits Skate Park, located approximately 0.38 miles south of the Site;  Willits Rodeo Grounds, located approximately 0.45 miles south of the Site;  Recreation Grove, located approximately 0.46 miles southwest of the Site;  Willits Municipal Swimming Pool, located approximately 0.59 miles west of the Site;  Bud Snider City Park, located approximately 0.63 miles southwest of the Site;  Highway 20 Park, located approximately 1.14 miles southwest of the Site;  Babcock Park, located approximately 1.31 miles southwest of the Site;  Ohl Redwood Grove Park, located approximately 2.2 miles west of the Site; and  Little Darby Environmental Education Area and Nature Trail, located approximately 4.49 miles east of the Site.

XVI.a-b) No residential units would be constructed, nor is the population expected to increase, as a result of the proposed project. The proposed project would not increase the usage of or demand for neighborhood and regional parks or other recreational facilities. Therefore, the proposed project would not result in the physical deterioration of parks or facilities, nor would it require the construction of new park or recreational facilities. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have No Impact on Recreation.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XVII. TRANSPORTATION. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
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
section 15064.3, subdivision (b)?
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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on transportation if it would conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b); substantially increase hazards due to a geometric design features (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or result in inadequate emergency access.

DISCUSSION
On September 27, 2013, Governor Jerry Brown signed Senate Bill (SB) 743 into law, initiating an update to the CEQA Guidelines to change how lead agencies evaluate transportation impacts under CEQA, with the goal to better measure the actual transportation-related environmental impacts of a given project.

Traditionally, transportation impacts had been evaluated by using Level of Service (LOS) analysis. Starting July 1, 2020, lead agencies are required to analyze the transportation impacts of new projects using vehicle miles traveled (VMT), instead of LOS. According to the SB 743 Frequently Asked Questions provided by the Governor’s Office of Planning and Research (OPR), VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto the roads, the project may cause a significant transportation impact. VMT analysis is intended to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations (OPR, 2020).

The proposed project includes improvements to the existing Willits Groundwater System that would increase the resiliency and conjunctive use capabilities and improve the quality of the City water system.

The Site is comprised of three (3) parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108- 030-06, and 108-020-05. While the Site is entirely owned by the City of Willits, the parcel identified by APN 007-010-01 is located within the City limits, while the parcels identified by APN 108-030-06 and 108-020-05 are located within the unincorporated area surrounding the City. The Site will be accessed through the driveways and access roads currently utilized by City staff for ongoing maintenance and operation of the Willits Groundwater System and nearby City sewer plant.

XVII.a) The proposed project would not conflict with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian paths. It is expected that construction of the project would result in a slight increase in traffic to and from the Site, as construction workers arrive and leave the Site at the beginning and end of the day, in addition to minor interruption of traffic on adjacent streets, when heavy equipment necessary for project construction is brought to and removed from the Site.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
However, once construction is complete, these temporary workers would no longer be required at the Site.

Upon project completion, no increase in travel to the Site would be anticipated, as City staff would maintain the project components as part of general ongoing maintenance and operations of the Willits Groundwater System. The development proposed on-site is not be expected to significantly impact the capacity of the street system, level of service standards established by the City, or the overall effectiveness of the circulation system, nor substantially impact alternative transportation facilities, such as transit, bicycle, or pedestrian facilities, as a substantial increase in traffic trips or use of alternative transportation facilities is not anticipated and all increased trips to the Site would be temporary. A less than significant impact would occur.

XVII.b) The proposed project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), which states:
“(1) Land Use Projects. Vehicle miles traveled 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. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be considered to have a less than significant transportation impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, a lead agency may tier from that analysis as provided in Section 15152.” The proposed project is considered a linear infrastructure project, with no impact to operational trips to the Site. All project-generated trips would be temporary in nature, ceasing upon completion of construction. In addition, as of the date of this Initial Study, the County of Mendocino and City of Willits have not established a threshold with regard to VMT impact significance consistent with CEQA Guidelines Section 15064.3, subdivision (b). As a result, a less than significant impact would occur.

XVII.c-d) The proposed project is not anticipated to substantially increase hazards due to design features or incompatible uses and would not result in inadequate emergency access as the project proposes no improvements to or that would interfere with existing transportation facilities or access corridors. As previously discussed, the project includes replacement of existing water line, upgrade of an existing well pump, and installation of a clear well. Proposed project improvements would be constructed and accessed during operation from existing access roads utilized by City staff for operation of the Elias replacement well, groundwater treatment plant, and sewer plant, with no changes to the existing access roads required to serve the proposed project. As such, no impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Transportation.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XVIII. TRIBAL CULTURAL RESOURCES. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code §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:
i) 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 §5020.1(k)?
ii) 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 §5024.1? In applying the
criteria set forth in subdivision (c) of Public
Resources Code §5024.1, the lead agency
shall consider the significance of the
resource to a California Native American
tribe.

Thresholds of Significance: The project would have a significant effect on Tribal Cultural Resources if it would cause a substantial adverse change in the significance of a cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code §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 listed or eligible for listing in the California Register of Historical Places or in a local register of historical resources as defined in Public Resources Code §5020.1(k), or is 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 §5024.1.

DISCUSSION
According to Chapter 3 (Development Element) of the Mendocino County General Plan (2009), ten (10) Native American tribes historically had territory in what is now Mendocino County. Native American tribes known to inhabit Mendocino County concentrated mainly along the coast and along major rivers and streams, while mountainous areas and redwood groves were occupied seasonally by some tribes. The entire southern third of Mendocino County was the home of groups of Central Pomo. To the north of the Central Pomo groups were the Northern Pomo, who controlled a strip of land extending from the coast to Clear Lake. The Coast Yuki claimed a portion of the coast from Fort Bragg north to an area slightly north of Rockport. They were linguistically related to a small group, called the Huchnom, living along the South Eel River north of Potter Valley. Both of these smaller groups were related to the Yuki, who were centered in Round Valley. At the far northern end of the county, several groups extended south from Humboldt County. The territory of the Cahto was bounded by Branscomb, Laytonville, and Cummings. The North Fork Wailaki was almost entirely in Mendocino County, along the North Fork of the Eel River. Other groups in this area included the Shelter Cove Sinkyone, the Eel River, and the Pitch Wailaki (County of Mendocino, 2009).

The first permanent non-native settlers came to Mendocino County in the middle of the 16th century, exploring and establishing small outposts. It was almost 300 years before the first permanent non-Spanish

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
settlements in Mendocino County were established in April of 1852 on the coast north of Big River.

Settlement in the vicinity of the City began in the mid-1880s (City of Willits, 1992, pg. III-27). As EuropeanAmerican settlement expanded in Mendocino County, most of the tribes known to inhabit the land were restricted to reservations and rancherias. During the 19th century, other tribes from the interior of California were forced to settle on the Round Valley Reservation in the northeastern portion of Mendocino County (County of Mendocino, 2009).

On March 12, 2020, in compliance with Assembly Bill (AB) 52, the City of Willits (City), sent consultation letters to the Middletown Rancheria Band of Pomo Indians and the Torres Martinez Desert Cahuilla Indians, two (2) Native American tribes that are traditionally and culturally affiliated to the project area and whom had previously requested notification of projects in the tribes’ area of traditional and cultural affiliation pursuant to AB 52. No responses were received. On June 23, 2020, the City sent additional AB 52 consultation letters to each of the 13 Tribal representatives provided to the City of Willits on the Native American Heritage Commission (NAHC) Native American Contacts List dated October 28, 2019, including the EPA Director and Chairperson of the Cahto Tribe; the Chairpersons of the Coyote Valley Band of Pomo Indians, Guidiville Band of Pomo Indians, Hopland Band of Pomo Indians, Kashia Band of Pomo Indians of the Stewards Point Rancheria, Manchester Band of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, and Sherwood Valley Band of Pomo Indians; and the President of the Round Valley Reservation/ Covelo Indian Community. No requests for consultation were received from any of the 18 Native American tribes that were sent formal notification of the project in compliance with AB 52, as noted above. As no requests for consultation were received within the 30 day deadline specified by Public Resources Code section 21082.3 (d), the City, as Lead Agency, has deemed the Tribal consultation process complete. A copy of the NAHC Native American Contacts List is included in Appendix B.
a.i-ii) As discussed in Section V (Cultural Resources), above, no historical resources are identified at or near the Site, per Figure 10-1 of the Willits General Plan Revision: Vision 2020 (City of Willits, 1992), no responses were received from the Tribal consultation effort, and there are no known Tribal cultural resources in the project area. However, there is the possibility that a tribal cultural resource could be inadvertently discovered due to the ground-disturbing activities required during project construction. The incorporation of Mitigation Measure CUL-1, which requires that the contractor implement standard protocol similar to Mendocino County’s “Discovery Clause” during project construction, and Mitigation Measure CUL-2, which requires that the City inform a cultural monitor prior to beginning excavation for the purposes of the water line replacement, and invite the monitor to oversee excavation activities, would ensure that any currently unknown tribal cultural resources that are discovered during project construction are not adversely impacted by the project. With mitigation incorporated, a less than significant impact would occur.

MITIGATION MEASURES
Refer to Mitigation Measures CUL-1 and CUL-2 under Section V (Cultural Resources), above.

FINDINGS
The proposed project would have Less Than Significant Impact with Mitigation Incorporated on Tribal Cultural Resources.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XVIX. UTILITIES AND SERVICE SYSTEMS. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or
stormwater 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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on utilities and service systems if it would require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects; not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years; result in a determination by the wastewater treatment provider, which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments; 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; or not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

DISCUSSION
The Site is comprised of three (3) parcels identified by Assessor’s Parcel Numbers (APNs) 007-010-01, 108-030- 06, and 108-020-05. While the Site is entirely owned by the City of Willits, the parcel identified by APN 007- 010-01 is located within the City limits, while the parcels identified by APN 108-030-06 and 108-020-05 are located within the unincorporated area surrounding the City. The proposed project includes improvements to the Willits Groundwater System that would increase the resiliency and conjunctive use capabilities, and improve the quality of the City water system. The project would not require or result in the construction or expansion of new or existing wastewater treatment facilities and proposes no changes to existing electricity facilities, storm drainage infrastructure, nor solid waste services.

XVIX.a) The proposed project is limited to the replacement of 3,600 feet of water line within the Willits Groundwater System and upgrading of the existing 30 hp pump to a 40 hp pump at the Elias replacement

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
well to increase transfer capacity from the Elias replacement well, and the installation of a 250,000-gallon clear well to enhance treatment and operability of the Willits Groundwater System. The project would not require or result in the construction or expansion of new or existing wastewater treatment or stormwater drainage facilities. Electricity at the Site is currently provided by the Pacific Gas & Electric Company (PG&E). Although the upgraded 40 hp pump proposed at the Elias replacement well would require a slight increase in energy above existing conditions, the upgraded pump would facilitate an increase in the pumping capacity of the Elias replacement well, allowing for more efficient use of the well when it is needed. Operation of the groundwater treatment plant requires less energy than the surface water treatment plant, due to the limited treatment required for the groundwater supply, as compared to the surface water supply. In addition, due to the proximity of the groundwater treatment plant to the City water distribution system, energy costs to transport the water from source to distribution would be decreased.

The project provides benefits to water resource management in the City, including increasing the resiliency and conjunctive use capabilities and improving the quality of the City water system. Although the project would result in the expansion of the City’s water supply system to allow for increased use of groundwater, when necessary, as described throughout this Initial Study, the proposed improvements to the Willits Groundwater System would not cause significant environmental effects. Therefore, a less than significant impact would occur.

XVIX.b) As described above, the proposed project would increase the resiliency and conjunctive use capabilities and improve the quality of the City water system, allowing the City to have sufficient water supplies during normal, dry, and multiple dry years. Until recently, all water for the City water supply system was supplied from surface water reservoirs on the Davis Creek watershed: Morris Reservoir and the upstream Centennial Reservoir. Water from these sources is treated at the surface water treatment plant near Morris Reservoir and piped to the City and surrounding regions approximately 2.5 miles via a single 16- inch transmission line.

The dependence of the City water supply system on a single surface source has made it vulnerable to water supply and/or water quality issues due to catastrophic failures and/or to severe or protracted drought, as was demonstrated during the water crisis the City experienced in 2014. The drought not only placed a strain on the quantity of water available, reduced levels in the reservoirs led to increased temperatures and biological growth, including algae blooms. In response to the extreme drought conditions in 2014, the City developed the Willits Groundwater System as an emergency project to supply and treat supplementary groundwater during the drought. The Willits Groundwater System included construction of a new groundwater treatment plant and the installation of over 8,000 feet of new water line to connect the Elias replacement well to the distribution system. In 2017, non-emergency use of this groundwater supply was approved by the State Water Resources Control Board (SWRCB) Division of Drinking Water, providing the City with the ability to supplement the surface water supply with groundwater and increase water supply reliability throughout the year. In the event that the surface water supply is compromised as it was in 2014, the City does not currently have the infrastructure necessary to fulfill the demand with groundwater.

The proposed project would provide the City with increased conjunctive use capabilities, allowing the City flexibility to manage water sources adaptively, considering factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health, and would help to ensure a reliable water supply in the City, sufficient to meet community needs if surface water again becomes untenable.

Therefore, a less than significant impact would occur.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XVIX.c) The capacity of the local wastewater treatment plant is not affected by the proposed project.

Therefore, the proposed project would have no impact.

XVIX.d-e) A significant amount of solid waste is not anticipated under the project and all solid waste generated under the project would be disposed of in accordance to all federal, state, and local statutes and regulations related to solid waste including state and local waste diversion requirements. The majority of solid waste generated by the proposed project would be anticipated during project construction and, as noted, above, project construction would be temporary in nature. Once constructed, the project would be anticipated to dispose of solid waste in accordance with the standards and practices currently in place for routine groundwater treatment operations. As such, the proposed would not negatively impact the provision of solid waste services or impair the attainment of solid waste reduction goals. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less Than Significant Impact on Utilities and Service Systems.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XX. WILDFIRE. If located in or near state
responsibility areas or lands classified as
very high fire hazard severity zones, would
the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Impair an adopted emergency response plan or
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 challenges?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on wildfire if it would impair an adopted emergency response plan or emergency evacuation plan; 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; 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; or 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 challenges.

DISCUSSION
The Site is located within the Local Responsibility Area (LRA) and is served by the Little Lake Fire District (Mendocino County Maps – Little Lake Valley – Fire Responsibility Areas, 2019). The Site is mapped as located within a “Moderate” fire hazard severity zone per Figure S-7a of the Public Review Draft 2019 Safety Element of the City of Willits General Plan. The nearest fire station to the Site is the Little Lake Fire Protection District located approximately 0.7 miles southwest of the Site. Replacement of the water line and upgrading the well pump would improve existing infrastructure and the clear well installation would not increase the risk of wildfires.

XX.a) The County of Mendocino County adopted a Mendocino County Operational Area Emergency Operations Plan (County EOP) on September 13, 2016, under Resolution Number 16-119. As noted on the Plans and Publications webpage of the Mendocino County Office of Emergency Services (MCOES), the County EOP, which complies with local ordinances, state law, and stated and federal emergency planning guidance, serves as the primary guide for coordinating and responding to all emergencies and disasters within the County. The purpose of the County EOP is to “facilitate multi-agency and multijurisdictional coordination during emergency operations, particularly between Mendocino County, local and tribal governments, special districts as well as state and Federal agencies” (MCOES – Plans and Publications, 2019).

As discussed under Section IX, Hazards and Hazardous Materials, above, there are no components of the project that would impair an adopted emergency response plan or emergency evaluation plan, including

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
the adopted County EOP. The Site is located with the LRA and within a “Moderate” fire hazard severity zone per Figure S-7a of the Public Review Draft 2019 Safety Element of the City of Willits General Plan.

Except for the clear well installation, the project primarily includes underground and/or nominal aboveground improvements which would have no impact on emergency response or evacuation in the project area. In addition, the clear well would be required to be constructed and installed in accordance with state and local standards, including safety and emergency access requirements. As such, there are no components of the project that would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. A less than significant impact would occur.

XX.b) Under the proposed project, it is not anticipated that wildfire risks would be exacerbated due to slope, prevailing winds, and other factors. The Site is primarily flat, with elevations at the Site ranging between approximately 1,323 feet and 1,353 feet above mean sea level, Phase 1 would be implemented in a vacant agricultural area, and Phase 2 would be implanted in an area currently developed with the City’s groundwater treatment plant and sewer plant. There are no factors of the Site that would cause an exacerbated risk of wildfire due to implementation of the project. In addition, the project would not require increased occupancy of the project area, as project implementation would be temporary in nature and any ongoing maintenance of the project would be infrequent. No impact would occur.

XX.c) The project would not require the installation or maintenance of associated infrastructure that would exacerbate fire risk or result in temporary or ongoing impacts to the environment. The Site is currently utilized for the Willits Groundwater System, including the Elias replacement well and groundwater treatment plant, and is located adjacent to the City’s sewer plant, with improvements proposed to be located within the general vicinity of these existing features. Phase 1 would include replacement of the existing water line and upgrading the 30 hp to a 40 hp pump at the Elias replacement well, and Phase 2 would include the installation of a 250,000-gallon clear well west of the groundwater treatment plant. The proposed improvements would be accessed via existing roads. In addition, during project construction and associated maintenance, appropriate Best Management Practices (BMPs) would be implemented to limit impacts to the environment. No impact would occur.

XX.d) The proposed project would not 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 challenges, as the Site is comprised of flat agricultural land to the north and a developed groundwater treatment plant to the south, with elevations at the Site ranging between approximately 1,323 feet and 1,353 feet above mean sea level. As such, no impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed project would have a Less than Significant Impact on Wildfire.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
XXI. MANDATORY FINDINGS OF SIGNIFICANCE.

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Does the project have the potential to substantially 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 selfsustaining 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?
THRESHOLDS OF SIGNIFICANCE: The project would have a significant effect on mandatory findings of significance if it would have the potential to substantially 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; 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.); or have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly.

DISCUSSION
Certain mandatory findings of significance must be made to comply with CEQA Guidelines §15065. The proposed project has been analyzed and it has been determined that it would not:
• Substantially degrade environmental quality;
• Substantially reduce fish or wildlife habitat;
• Cause a fish or wildlife population to fall below self-sustaining levels; • Threaten to eliminate a plant or animal community;
• Reduce the numbers or range of a rare, threatened, or endangered species; • Eliminate important examples of the major periods of California history or pre-history; • Achieve short term goals to the disadvantage of long term goals; • Have environmental effects that will directly or indirectly cause substantial adverse effects on human
 beings; or
 Have possible environmental effects that are individually limited but cumulatively considerable when viewed in connection with past, current, and reasonably anticipated future projects.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Potential environmental impacts from the replacement of 3,600 feet of water line within the Willits Groundwater System, upgrading the 30 hp pump to a 40 hp pump at the Elias replacement well, and the installation of a 250,000-gallon clear well adjacent to the west of the groundwater treatment plant, have been analyzed in this document and mitigation measures have been included in the document to ensure impacts would be held to a less than significant level.

XXI.a) The project does not have the potential to substantially 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. There are no important examples of California Pre-history or history located on the Site. While the northern portion of the Site, where the replacement of existing water line is proposed, is largely mapped as a seasonal wetland and supports Baker’s meadowfoam populations, the Site does not provide habitat for any fish or wildlife species. Mitigation has been applied to reduce any potential environmental impacts to levels that are less than significant.

XXI.b) No cumulative impacts have been identified as a result of the proposed project. The project is intended to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes untenable and would provide the City with the flexibility to manage water sources adaptively, considering factors such as aquifer and watershed health, water quality, operational constraints, and ecosystem health. Individual impacts from the project would not significantly contribute to cumulative impacts in the area. A less than significant impact would occur.

XXI.c) The project will not have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly. Concerns related to the suitability of soils on-site for this type of construction are mitigated by Mitigation Measure GEO-1, which reduces the threat of failure of the clear well foundation to a level that is less than significant. A less than significant impact would occur.

Based on the findings in this Initial Study and as mitigated and conditioned, the proposed project would not have environmental effects that would cause substantial adverse effects on human beings either directly or indirectly. Potential environmental impacts associated with approval of the project have been analyzed and, as mitigated, all potential impacts can be reduced to a less-than-significant level.

MITIGATION MEASURES
Refer to Mitigation Measures BIO-1 and BIO-7 in Section IV (Biological Resources), CUL-1 and CUL-2 in Section V (Cultural Resources), GEO-1 in Section VII (Geology and Soils), and HYDRO-1 in Section X (Hydrology and Water Quality), above.

FINDINGS
The proposed project would have a Less Than Significant Impact with Mitigation Incorporated on Mandatory Findings of Significance.

ATTACHMENT

DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
VI. REFERENCES
California Air Resources Board (CARB). 2018. AB 32 Scoping Plan. Accessed March 6, 2020. Available at:
https://ww3.arb.ca.gov/cc/scopingplan/scopingplan.htm.

California Air Resources Board (CARB). 2019. GHG Current California Emission Inventory Data. California Greenhouse Gas Emissions for 2000 to 2017. Accessed March 6, 2020. Available at:
https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2017/ghg_inventory_trends_00-17.pdf.

California Department of Conservation (DOC). 2016. Farmland Mapping & Monitoring Program. California Important Farmland Finder. Accessed February 28, 2020. Available at:
https://maps.conservation.ca.gov/DLRP/CIFF/.

California Department of Conservation (DOC). 2019. California Geological Survey. California Earthquake Hazards Zone Application. Accessed March 6, 2020. Available at:
https://www.conservation.ca.gov/cgs/geohazards/eq-zapp.

California Department of Conservation (DOC). 2015. California Geological Survey. Mineral Land Classification Studies Index. Accessed June 8, 2020. Available at:
https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=mlc.

California Department of Toxic Substances Control (DTSC). 2020. EnviroStor. Accessed February 26, 2020.

Available at: https://www.envirostor.dtsc.ca.gov/public/.

California Department of Water Resources (DWR). 1988. Memo. Aquifer test at the Willits City Park well.

California Department of Water Resources (DWR). Last updated February 27, 2004. California’s Groundwater Bulletin 118. North Coast Hydrologic Region – Little Lake Valley Groundwater Basin.

California Energy Commission (CEC). 2020. 2019 Building Energy Efficiency Standards. Accessed February 28, 2020 Available at: https://www.energy.ca.gov/programs-and-topics/programs/building-energyefficiency-standards/2019-building-energy-efficiency.

California Energy Commission (CEC). October 2017. California Energy Commission Final Commission Report - Senate Bill 350: Doubling Energy Efficiency Savings by 2020. Accessed February 26, 2020. Available at: http://docketpublic.energy.ca.gov/PublicDocuments/17-IEPR06/TN221631_20171026T102305_Senate_Bill_350_Doubling_Energy_Efficiency_Savings_by_2030.pdf California Legislative Information. July 12, 2019. Assembly Bill No. 998. Accessed February 26, 2020. Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB998.

California Legislative Information. September 27, 2006. Assembly Bill No. 32. Accessed March 6, 2020.

Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200520060AB32.

California Legislative Information. Effective January 1, 1997. Health and Safety Code (HSC). Division 20, Chapter 6.5, Article 2, Section 25117. Accessed March 6, 2020. Available at:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=25 117.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
California Legislative Information. October 7, 2015. Senate Bill No. 350. Accessed February 26, 2020.

Available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB350.

City of Willits. August 2019a. City of Willits 2019 – 2027 Housing Element Update. Public Review Draft.

Prepared by PlaceWorks. Accessed June 18, 2020. Available at:
https://cityofwillits.org/DocumentCenter/View/522/Draft-Housing-Element-2019-2027.

City of Willits. October 21, 2019b. City of Willits General Plan 2019 Safety Element. Public Review Draft.

Accessed February 28, 2020. Available at: https://cityofwillits.org/DocumentCenter/View/584/2019- General-Plan-Safety-Element-Update---Public-Review-Draft-.

City of Willits. 1982. Code of Ordinances: Chapter 17.48 – Historical Resources. Accessed March 6, 2020.

Available at:
https://library.municode.com/ca/willits/codes/code_of_ordinances?nodeId=TIT17ZO_CH17.48HIRE.

City of Willits. 2020a. Maps. Accessed February 28, 2020. Available at: https://cityofwillits.org/242/Maps.

City of Willits. November 12, 2011. Public Works and Engineering Department. 100% DRAFT City of Willits Design and Construction Standards. Accessed April 17, 2020. Available at:
https://cityofwillits.org/DocumentCenter/View/227/Construction-Standards-COMPLETE-BOOK-.

City of Willits. 2020b. Regulations. Accessed February 28, 2020. Available at:
http://www.cityofwillits.org/238/Regulations.

City of Willits. August 12, 1992. Willits General Plan Revision: Vision 2020. Prepared by Neal Martin and Associates. Accessed March 6, 2020. Available at:
https://cityofwillits.org/DocumentCenter/View/262/City-of-Willits-General-Plan.

County of Mendocino. 1987. Code of Ordinances: Chapter 22.12 – Archaeological Resources. Accessed February 18, 2020. Available at:
https://library.municode.com/ca/mendocino_county/codes/code_of_ordinances?nodeId=MECOC O_TIT22LAUS_CH22.12ARRE.

County of Mendocino. 2009. Department of Planning & Building Services. Mendocino County General Plan.

Accessed February 28, 2020. Available at:
https://www.mendocinocounty.org/government/planning-building-services/plans/mendocinocounty-general-plan.

County of Mendocino. 2020. Department of Planning & Building Services. Mendocino County Maps (Various). Accessed February 28, 2020. Available at:
https://www.mendocinocounty.org/government/planning-building-services/county-maps.

County of Mendocino. 1991. Department of Planning & Building Services. Zoning Ordinance. Accessed February 28, 2020. Available at: https://www.mendocinocounty.org/government/planning-buildingservices/regulations/zoning-code/inland.

Farrar, C.D. July 1986. USGS Water-Resources Investigation Report 85-4258. Ground-Water Resources in Mendocino County, California.

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Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
Federal Emergency Management Agency (FEMA). No Date. FEMA Flood Map Service Center: Search by Address. Accessed February 26, 2020. Available at: https://msc.fema.gov/portal/search.

GHD. October 2015. Technical Report. Elias Replacement Well Installation and Aquifer Test.

Johnson, N.M. April 25, 2008. Water-supply reconnaissance (letter). Nicholas M. Johnson, PhD, RG, CHG, Water Resources Consultant.

LACO Associates (LACO). May 30, 2019. Technical Memorandum. Technical Assistance for City of Willits’ Project “Improving Willits Water Supply Reliability and Drought Resiliency with Groundwater and Conjunctive Use.”
Mendocino County Air Quality Management District (MCQAMD). January 2005. Particulate Matter Attainment Plan. Accessed February 26, 2020. Available at:
http://www.co.mendocino.ca.us/aqmd/pdf_files/Attainment%20Plan_DRAFT.pdf.

Mendocino County Air Quality Management District (MCAQMD). February 2011. Rules and Regulations.

Regulation 1 – Air Pollution Control Rules. Accessed February 26, 2020. Available at:
http://www.co.mendocino.ca.us/aqmd/district-regulation-4.html.

Mendocino County Office of Emergency Services (MCOES). 2020. Plans and Publications. Accessed February 28, 2020. Available at: https://www.mendocinocounty.org/government/executiveoffice/office-of-emergency-services/plans-and-publications.

North Coast Unified Air Quality Management District (NCUAQMD). Last modified July 9, 2015. District Rules & Regulations. Rule 110 – New Source Review & Prevention of Significant Deterioration. Accessed March 26, 2020. Available at: http://www.ncuaqmd.org/files/rules/reg%201/Rule%20110.pdf.

State Water Resources Control Board (SWRCB). 2020. GeoTracker. Accessed February 26, 2020. Available at: https://geotracker.waterboards.ca.gov/.

Thomson Reuters Westlaw. 2005. California Code of Regulations. Title 13, Division 3, Chapter 10, Article 1, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling.

Accessed February 26, 2020. Available at:
https://govt.westlaw.com/calregs/Document/I6DACC2EF0D6441DDA5B788DFEDCD1A22?viewType= FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Def ault)
Thomson Reuters Westlaw. 1991. California Code of Regulations. Title 22, Division 4.5, Chapter 11, Article 3:

Characteristics of Hazardous Waste. Accessed February 26, 2020. Available at:
https://govt.westlaw.com/calregs/Document/IA3C90780D4BA11DE8879F88E8B0DAAAE?viewType=Fu llText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Defa ult).

United States Census Bureau. Not Dated. Data Portal. Accessed February 26, 2020. Available at:
https://data.census.gov/cedsci/profile?g=1600000US0685600&q=Willits%20city,%20California.

United States Department of Agriculture (USDA). January 1991. Natural Resources Conservation Service (NRCS). Soil Survey of Mendocino County, Eastern Part, and Trinity County, Southwestern Part,

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City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08
California. Accessed February 28, 2020. Available at:
https://www.nrcs.usda.gov/Internet/FSE_MANUSCRIPTS/california/mendocinotrinityCA1991/mendoci notrinityCA1991.pdf
United States Department of Agriculture. 2019. Natural Resources Conservation Service (NRCS). Web Soil Survey. Accessed February 28, 2020. Available at:
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.

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DRAFT ISMND

City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

F I G U R E S
F i g u r e 1 S i t e V i c i n i t y M a p
F i g u r e 2 P r o j e c t O v e r v i e w
F i g u r e 3 C i t y o f W i l l i t s L a n d U s e M a p F i g u r e 4 C i t y o f W i l l i t s Z o n i n g M a p F i g u r e 5 C o u n t y o f M e n d o c i n o L a n d U s e M a p F i g u r e 6 C o u n t y o f M e n d o c i n o Z o n i n g M a p

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DRAFT ISMND
Draft CEQA Initial Study
City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

A P P E N D I X A
M i t i g a t i o n a n d M o n i t o r i n g P r o g r a m ( M M R P )

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Draft CEQA Initial Study
City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

A P P E N D I X B
C u l t u r a l R e s o u r c e s C o r r e s p o n d e n c e

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Draft CEQA Initial Study
City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

A P P E N D I X C
H a b i t a t A s s e s s m e n t

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Draft CEQA Initial Study
City of Willits
Groundwater Resiliency Improvements Project
LACO Project Number: 8509.08

A P P E N D I X D
S o i l s R e p o r t

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February 26th, 2022
From: Ellen Drell
6150 Hearst Rd.

Willits, CA 95490
To: Mayor Saprina Rodriguez and Council Members
111 East Commercial Street
Willits, CA 95490
Re: Notice of Intent to Adopt an Initial Study and Mitigated Negative Declaration for the City of Willits Groundwater Improvements Project, and Recommendations For Changes and Amendments to the IS/MND, Including the Project Description Dear Mayor Rodriguez and Council Members;
I am writing to you and the City staff to add my support for John Almida’s 2/10/22 letter addressed to you recommending that specific language protective of the quantity and quality of the groundwater from the Elias well be incorporated into the body of the IS/MND. I am in agreement with Mr. Almida that the best way to ensure that this and future Councils faithfully implement certain “conditions of use” designed to avoid the consequences of over-pumping the Elias well is to make those conditions Mitigations of the IS/MND. Incorporating specific limits on the use of the well as Mitigations in the IS/MND allows the Council to adopt the IS/MND with legally defensible “Mandatory Findings” that the project will not have a significant negative impact on the affected environment.

Specifically, I am recommending the following changes and added Mitigations to the IS/MND:

1. The INITIAL STUDY, at II, PROJECT DESCRIPTION, should clarify the project purpose by modifying the language to read:
“The City of Willits proposes improvements to the existing groundwater system in order to maintain adequate water quantity and quality to provide for the health and safety of the residents and businesses of City of Willits, its current water customers, and the current Little Lake Valley residents who are dependent on Little Lake Valley groundwater for residential and agricultural use. This project is not for the purpose of supplying water for city annexations, new waterintensive industry, or for the purpose of supplying water to other communities or locations, except on a short term emergency basis when all other options, including household and business water rationing, have been implemented.”
Currently the project description uses the terms “increase the City’s conjunctive use capabilities”, “community needs”, and “untenable” surface water conditions. These terms are too vague and consequently open to a wide range of interpretation. They leave the City and the aquifer vulnerable to over-use and the consequences of short-sighted planning.

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2. The PROJECT DESCRIPTION should define what is meant by “untenable” surface water conditions at the reservoirs in such a way that it will be clear what conditions would trigger the use of the Elias well. Those conditions should include water levels, water temperature, extent of algae bloom, etc. To further ensure that the Elias well is used conservatively, the Project Description should state that it is the City’s intent to implement staged, and where necessary, mandatory reduction in water use per person per household as a prerequisite for using the Elias well as a back-up water supply.

3. The IS/MND and CHECKLIST should be amended to more realistically acknowledge potential harm to the environment and eventually to the health and safety of the residents of Willits and Little Lake Valley that could result due to excessive groundwater pumping. Most importantly, the IS/MND should be amended to specifically include the additional Mitigation of a detailed operational use plan that specifies the limited situations, as suggested above, that would trigger the use of the project in order to avoid that harm. Although this critical additional Mitigation should be added to several of the IS/MND’s categories on the environmental “checklist”, as suggested below, the added Mitigation would be the same in each instance and therefore easily accomplished, I think.

I recommend the following changes and additions to the IS/MND’s checklist, Discussions and Mitigations starting with the most critical concern:

At X. HYDROLOGY AND WATER QUALITY, b) the question is asked, “Would the Project substantially decrease groundwater supplies such that the project may impede sustainable groundwater management of the basin?” The second box, “Less than significant with mitigation incorporated” should be checked.

The Discussion should include a description of the limited purposes of the project and all of the parameters regulating the use of the project that will ensure that use of the well does not go beyond those of back-up water supply in specifically defined drought conditions, emergency back-up, and use during maintenance of the current surface water system. To further support the need for this Mitigation, the discussion should include the current and possibly deepening drought conditions that have occurred since the publication of the 1986 Farrar report, and the absence of an updated aquifer study that takes into account recent rainfall and aquifer recharge data.

The Mitigations for potential hydrology and water quality impacts must include the addition of the following:

HYDRO 2. Implementation of the Use Plan (described in full here, or referenced as “See Appendix ___”), designed to ensure that the Project is only used for the limited purposes described in the above Discussion and as detailed in the Project Description (as amended/rewritten above).

At II. AGRICULTURE AND FOREST RESOURCES, e) the question is asked, “Would the Project involve other changes in the existing environment which, due to their location or nature,

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could result in the conversion of farmland to non-agricultural use”? The second box should be checked - “Less than significant with mitigation incorporated”.

The Discussion at II e) should include potential impacts of the project to the long term resiliency of the aquifer of Little Lake Valley, the health of the surrounding on-going wetlands creation and restoration, and the surrounding presence of residences and agricultural activities dependent on groundwater wells. The Discussion should describe the limitations on use of the Project to those uses described in the above re-written/amended Project Description and purpose.

The Mitigation for potential agriculture use impacts must include the following:

AG 1. Implementation of the Use Plan (described in full here, or referenced as “See Appendix___”), which is designed to ensure that the Project is used only for the limited purposes and under the conditions detailed in the Project Description and purpose (as amended/re-written above).

At IV. BIOLOGICAL RESOURCES, f) the question is asked, “Would the Project conflict with provisions of a regional or state habitat conservation plan?” The second box, “less than significant with mitigations”, should be checked.

The Discussion should include the fact that the Project is located in the midst of a State and federally mandated, and tax-payer funded, 2000 - acre wetland creation and enhancement mitigation project, legally required under several State and federal environmental laws, for the purpose of mitigating impacts of the Willits Bypass on the Little Lake Valley wetlands, and is to be managed for those purposes in perpetuity. To have ignored this “elephant in the living room” is inexplicable, unacceptable, legally risky, and readily remedied. The Discussion should reiterate the limited purposes of the Project, as recommended above, and include the restrictions that will be implemented in the detailed use plan. The use plan should be included as a mitigation.

The Mitigations for potential Biological impacts must include the following:

BIO 8. Implementation of the Use Plan (described in full here, or referenced as “See Appendix ___”), which plan is designed to ensure that the Project is used only for the limited purposes and under the conditions detailed in the Project Description and purpose (as amended/re-written above).

At VIII. GREENHOUSE GAS EMISSIONS, a) the question is asked, “Would the Project generate greenhouse gas emissions directly or indirectly that may have a significant effect on the environment?” The second box, “less than significant with mitigations” should be checked.

The Discussion should acknowledge the increase in energy needed to pump water up-grade to all City users, especially in the event that the Elias well is used extensively if water availability from the existing surface water system becomes less and less dependable. As with the above considerations, the Discussion should note that the limited project purposes, and the use plan

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ensuring that those limits are adhered to, will mitigate the impacts on the emission of greenhouse gases.

The Mitigation for potential significant greenhouse gas emissions increase should include the following:

GHG 1. Implementation of the Use Plan (described in full here, or references as “See Appendix ___”), which plan is designed to ensure that the Project is used only for the limited purposes, and under the conditions described in the Project Description and purpose (as amended/re-written above).

IN SUMMARY
We all agree that Willits is very lucky to have a back-up system to provide water when the reservoirs are too low to provide good quality water to the City and Willits water customers, and it is the right decision to develop the Elias well and treatment and delivery system for that contingency.

What we have no way of agreeing on is how much pumping (per minute, per day, or even over the course of several years) is possible without drawing down the groundwater level such that 1) groundwater levels are not able to recharge annually, and such that 2) water quality is threatened by arsenic, boron, or other heavy metal intrusion into the pumping radius of the Elias well.

To answer the above questions takes more than estimating the current acre feet of available groundwater, based on a 36 yr-old study. It will take a thorough study of the Little Lake Valley aquifer - probably a multi-year undertaking. We can probably agree that though such a study is necessary, and should begin as soon as possible, we shouldn't wait to complete such a study before getting a back-up system in place.

Therefore, since the City is moving forward with a groundwater delivery system without knowing the long term consequences, it is imperative for the welfare of the public, and the legal underpinnings of the project, that the Initial Study/Mitigated Negative Declaration include the above listed mitigations that enforce conservation.

January and February of the current year are the driest in the history of rainfall/snowfall records in California. Climatologists know that California has experienced multi-decade and multihundred year droughts over the millennia recorded in tree rings, land forms and sediment deposits and the presence or absence of fossil plants and pollen, and in the histories of indigenous peoples living in California for thousands of years. Though alarming as it may be, it is conceivable that we are moving into just such a circumstance. Willits is indeed fortunate to have access to a thus far lightly tapped water source. It could provide essential water needs for many years to come of extremely low rainfall, similar to the 1/3 to 1/2 of “normal” that we saw last year and may be seeing again this year, if we discipline ourselves to actively conserve.

We already know that pumping the Elias well this last year for three months to provide water to the City during a maintenance overhaul at the reservoirs lowered the groundwater level and

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caused the neighboring Long 20 well to fluctuate. We are told that with the rains last Fall, recharge was rapid. Though this is good news, it does not predict what recharge we can expect in the seasons or years to come. The Fall of 2021 was an unusually wet November and December, and as mentioned above, was followed by the driest January and February on record. Where would the groundwater levels be without those wet months? Where will it be in the Fall of 2022? No one knows.

One scenario is that we won’t have much rain in the rest of ’22, and that ’23, ’24’ 25, etc. may be similar. It would not take too many years of dependency on the Elias well, with only a fraction of what was once “normal” rainfall, to begin to have a significant and detrimental draw-down of the valley’s reputed 30,000 to 90,000 acre feet of water storage.

The Project’s Initial Study/Mitigated Negative Declaration needs to state clearly to City water users and to any other community which may be looking to the Little Lake Valley aquifer for back-up water supplies when its own supplies are overtaxed or gone, that this groundwater development is for the purpose of maintaining adequate water quantity and quality to support the health and safety of the community of Willits, its current water customers and the current Little Lake Valley residents who use groundwater for domestic and agricultural purposes.

These conditions, when built into the IS/MND, will calm the legitimate anxiety about overdrafting the valley’s precious groundwater supply, especially when the City lacks up-to-date data on long term groundwater recharge based on current climate conditions. We can’t assume a return to “normal” rainfall in our lifetimes. This is a most critical moment. We can take steps now that will commit us to conservation, or we can risk facing a worse crisis in the future.

As stated above, I think that the best way to put teeth into this commitment to conserve is to make these specific conditions Mitigations of the IS/MND. This way adherence to the conditions, by this and future City Councils, will be required under State CEQA law. Conditions of use can be changed, but only after this, or a future Council, makes official findings, after environmental review, that the change will not cause significant harm to the aquifer. Future generations deserve this commitment to restraint.

Finally, by clearly stating the limitations of the use of the Elias well, and making those limiting conditions actual Mitigations in the IS/MND, the Council can confidently make the determination that this project will not cause significant harm to the environment, human or natural, and the IS/MND will stand on firm legal ground.

Sincerely,
Ellen Drell, Board Member, Willits Environmental Center, and Willits area resident CC: Vice Mayor Greta Kanne
Council Member Gerardo Gonzales
Council Member Larry Stranske
Council Member Madge Strong
Willits City Manager Brian Bender
Project Manager Andrea Trincado

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1 March 1st, 2022
From: Rosamond Crowder
P.O. Box 1413
Willits, CA 95490
To: Mayor Saprina Rodriguez and Council Members
111 East Commercial Street
Willits, CA 95490
Re: Notice of Intent to Adopt an Initial Study and Mitigated Negative Declaration (IS/MND) for the City of Willits Groundwater Improvements Project, and Recommendations For Changes and Amendments to the Initial Study and Environmental Checklist (IS), Including the Project Description.

Dear Mayor Rodriguez and Council Members;
I am writing to you and the City staff to declare my support for specific language protective of the quantity and quality of groundwater both in and from use of the Elias replacement well being incorporated into the body of the Revised Initial Study (IS). At the 2/9/22 Council meeting, staff was directed to write an, “Operational Use Plan” before the IS/MND is approved. Unless the “Operational Use Plan” is part of the IS/MND it is effectively meaningless, as it could be changed at any time by this or any City Council in the future. Including the “Operational Use Plan” within the document is necessary because the current study does not adequately address the effects to the environment of a greatly increased rate of pumping and assure that CEQA has been followed. Referencing the Plan as mitigations in the IS/MND makes those conditions enforceable. Incorporating specific limits on the use of the well as Mitigations in the IS allows the Council to adopt the IS/MND with legally defensible “Mandatory Findings” that the project will not have a significant negative impact on the affected environment.

At the 2/9/22 meeting Attorney Ramos indicated that the environmental review was intended to be for the greatest use possible so that review would not have to be done again when the City desired to pump more water. Please understand that the current document calls for a 10” pipe (pipes are listed by inside diameter). A pipe like this can carry something over 63,000 gallons an hour or 1.5 million gallons a day or 1693 acre feet a year. The pump size was removed from the revised IS document, so conceivably a pump could be installed that could deliver this amount of water. This is enough for the city of Willits to more than double its population. Unless it is clear this is not the intention of the Project there is a potential for environmental impacts that have not been considered. This is why it is extremely important that until a thorough understanding of the aquifer characteristics can be determined the Elias replacement well should be considered a back-up system and that this is clear in the documents.

Recommendations for changes: The Project Description (p.3 II) needs to be amended or rewritten, both in the IS and the MND. The current project description states the purpose is: “ to increase the City’s conjunctive use capabilities and provide the City with a reliable water supply sufficient to meet community needs in the event surface water becomes untenable.” Several

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2 terms are vague and open to a wide range of interpretation. “Conjunctive use capabilities” is not a description of conditions or limits of pumping, only that the project is intended to be in conjunction with the current surface water system. “Community needs” can be viewed as needs of the entire county and even beyond. “Needs” can be viewed as what is needed for an increase in population or industry such as was projected in 2006 West –Yost study (quadrupling the population of Willits). “Untenable”, it is not clear what argument the city would have difficulty defending.

This vague description leaves the City and the aquifer vulnerable to over-use. It also shows that there are unexamined consequences that the environmental document fails to address. The Project’s IS/MND needs to state clearly to City water users and to any other community which may be looking to the Little Lake Valley aquifer for back-up water supplies that this groundwater development is for the purpose of maintaining adequate water quantity and quality to support the health and safety of the community of Willits, and its current water customers.

Therefore I recommend including a statement in the Project Description such as, “This project is intended for use as an emergency back-up system, for maintaining water quality and systems operation, as defined in the Operational Use Plan.” or, “The City of Willits proposes improvements to the existing groundwater system in order to maintain adequate water quantity and quality to provide for the health and safety of the residents and businesses of the City of Willits’ current water customers.”
I understand and support getting the back-up system on-line in the near future. The current environmental document will show that the project avoids growth inducement for instance only if the Project Description is clear and an Operational Use Plan is included and referenced in the “Population and Housing” section of the Initial Study and Environmental Checklist (IS).

If or when the City wants to grow, careful records of the effect of pumping from this well would go a long way toward understanding aquifer characteristics and assuring the public and the regulatory agencies that water quality, drawdown and environmental effects can be assessed using current data. I agree with Attorney Ramos that the geology of Little Lake Valley has not changed but it is very evident that the surface water and hence groundwater hydrology has changed. This is documented by US Geological Survey gauging station records described in the 2006 Outlet Creek Basin Assessment that are more recent than the 1965 and 1986 studies being referenced in the IS/MND. The changes in surface water are extremely significant; volumes dropping in the early 1990’s to roughly half of the average of four decades of records. Certainly rainfall quantity, patterns of precipitation, lessening of fog drip, increasingly incised creeks and increases in upland water use, new agricultural ponds and increased pumping of groundwater contribute to changes in valley hydrology and recharge.

The following is a template for an Operational Use Plan showing what I believe needs to be included, followed by a list of the places in the IS that should reference it.

Operational Use Plan: Intentions of the Use Plan need to be spelled out, such as: The Project is not intended for the purpose of supplying water for city annexations, new housing developments, new water-intensive industry, or for the purpose of supplying water to other communities or

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3 locations, except in emergencies as defined. The system is intended for mitigating drought conditions, maintaining water quality and systems operation as defined. The Project is also intended as a back-up system should the surface water system be severely compromised (such as an earthquake breaking the water line from the dams).

Emergencies: definition of emergency, such as: An emergency is defined as drought conditions and water use causing surface water levels in Centennial and Morris reservoirs to reach ____% of capacity and where projections for reservoir recharge are not likely, or when the surface water system has been damaged to the extent it cannot be used until repairs have been completed.
 When drought conditions have caused an emergency to be identified the city will first implement reductions in water use, then the Elias replacement well may be used to augment the supply of potable water.
 When the surface water system is damaged and cannot be used, the City will make all reasonable efforts to repair the surface water system while using the Elias replacement well as an emergency back-up system.
 The City will not supply water to other communities except on a short-term emergency basis when the other community has instituted all other options, including residential and business water rationing.

Water Quality:
 When surface water temperatures have reached _____ and algae blooms exceed ______ , water from the Elias replacement well may be used to augment surface water to maintain water quality.
 If water quality concerns require groundwater to be used for more than ______days, the reservoirs are below _____% capacity and where projections for reservoir recharge are not likely, the situation will be classed an emergency, water use reduction measures will be implemented and the Elias replacement well will be used on an emergency basis to augment water supplies.

Systems Operation:
 When from time to time the system needs to be flushed and surface water levels are below _____ % of capacity and projections for reservoir recharge are not likely, the Elias replacement well may be used to perform these functions.

Ongoing monitoring: The city will establish and fund, as part of this project a robust monitoring program before the new pump, water line and holding tank are put on line as follows:
 An agreement will be crafted with the Mendocino Resource Conservation District (MCRCD) to allow the City to monitor the wells on the Willits Bypass Mitigation Lands within ____mile(s) of the Elias replacement well. These wells will be monitored for baseline levels, drawdown levels, and water quality to establish aquifer characteristics and the effects of pumping on neighboring wells.
 The wells owned by the City (Long-20, Park well and _____) will be monitored for baseline levels, drawdown levels, and water quality to establish aquifer characteristics and the effects of pumping on neighboring wells.

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4  Owners of private wells within ____mile(s) of the Elias replacement well will be contacted to request agreements for monitoring for baseline levels, drawdown levels, and water quality to establish aquifer characteristics and the effects of pumping on neighboring wells. This should include agreements that neighboring well users agree to install systems that measure their use of their own wells.  A standard schedule of monitoring for drawdown and mineral content will be _________(i.e. quarterly).
 A temporary schedule of monitoring for drawdown and mineral content for when Elias replacement well is being used for more than ______ consecutive days will be ________ (i.e. every other week).
 In the event that significant drawdown (_______ how many feet is significant?) is recorded ___________ (a process to notify neighbors, reduce pumping at _______ of drawdown and/or stop pumping at _______ of drawdown or slow pumping to maintain a drawdown of _________).
 In the event that mineral contamination, particularly arsenic is discovered in the Elias replacement well or a change in arsenic levels in neighboring wells __________ (a process to notify neighbors, monitor changes in water quality, reduce pumping at ______mg of arsenic and/or stop pumping at _____mg of arsenic).

ENVIRONMENTAL CHECKLIST (IS p. 9 through 66) I know that my colleague Ellen Drell has written a similar list and I would like to build on her foundation with the following recommendations, The Revised Initial Study and Environmental Checklist should be amended to specifically include the additional Mitigation of the more detailed Operational Use Plan that identifies the limited situations that would trigger the use of the Project in order to avoid that harm. Although this critical additional Mitigation should be added to several of the IS categories of environmental impacts, as suggested below, it would be the same Mitigation in each instance and therefore easily accomplished. For example:
p.11 II. Agriculture and Forest Resources, e) The second box - “Less than significant with mitigation incorporated” should be checked, AND the Agriculture and Forest Resources box in the table on p.7 checked.

The Discussion should include potential impacts of the project to the long-term health of the aquifer due to the location (Little Lake Valley) and environmental context (on-going wetlands restoration and the surrounding presence of residences and agricultural activities dependent on groundwater wells). The Discussion should make reference to the limited nature of the Project described in the Project Description and purpose (as amended/rewritten), and the restrictions that will be implemented in the Operational Use Plan (OUP).

The OUP should be included as mitigation.

The Mitigation for potential agriculture use impacts must be included and reference the Operational Use Plan.

AG-1 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under specific conditions.

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5 p. 16 IV. Biological Resources, f) The second box, “less than significant with mitigations”, should be checked.

The Discussion should include the fact that the Project makes it possible for the City to pump a great deal of water from the Elias replacement well. The removal of as much as 1700 acre feet or more per year from the wetlands can cause drawdown and pull mineral concentrations into new areas. Furthermore, the Project is located in the midst of a wetland creation and enhancement mitigation project, legally required under several State and federal environmental laws, to mitigate the impacts of the Willits Bypass. The effects of drawdown from the long-term use or high volume pumping of Elias Replacement well and characteristics of the aquifer have not been established. It is not enough to say that the aquifer and groundwater levels recharge in winter when groundwater levels drop to the point of affecting surface water in the summer when the well is being used. The Department of Water Resources Bulletin 118 clearly states, “Scientific studies have identified the linkage between groundwater pumping and a decrease in streamflow in areas of the North Coast region (U.S. Geological Survey 1975). Groundwater managers in the region must consider stream depletion among other factors when extracting and managing groundwater”. As stated above the streamflow in Outlet Creek fell to about half of its historical flows in the early 1990’s after Centennial Dam was built. Streamflows are critical to numerous species including endangered anadramous fish. The effects of groundwater pumping in the dry season which continues to become longer is therefore a critical importance and needs to be discussed here. The Discussion should reiterate the limited purposes of the Project, as a back-up system only, and that restrictions will be implemented and monitoring will be ongoing as detailed in the Operational Use Plan.

The Mitigations for potential Biological impacts must be included and reference the Operational Use Plan.

BIO-8 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under specific conditions. p.23 V. Cultural Resources, a) The second box, “less than significant with mitigations” should be checked
The Discussion should include the fact that Little Lake Valley’s ecosystem as a whole is a cultural resource for all local tribes. The traditional basket making plants, foods, and especially the fish are cultural resources. The Willits Bypass Mitigation lands have preserved in perpetuity a large section of the ecosystem that supports these resources and the Elias replacement well is located pretty much in the very middle of them. Any drawdown that affects the streamflow and the dryness of the mitigation lands and consequently the plants that are being regenerated needs to be acknowledged as an effect. The Operational Use Plan is mitigation for these effects. As the Department of Water Resources notes in their 2020 publication, “The North Coast Hydrologic Region is historically home to some of the most prolific anadromous fisheries in the state. These fisheries, including the Smith, Klamath, Mad, and Russian rivers have supported many California Native American Tribes for millennia. Today, 42 California Native American Tribes are known to have tribal homelands,

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6 trust lands, rancherias, and reservations in the region. These fisheries are critical for the cultures and livelihoods of tribes in the region. These fisheries have been affected over the last century by dams, land use changes, and flow reductions, but efforts are underway to help restore them. In-stream flow requirements are now in place to help provide adequate flows to sensitive species.”
The Mitigations for potential Biological impacts must be included and reference the Operational Use Plan.

CIL-3 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under specific conditions. p. 33 VIII. Greenhouse Gas Emissions, a) The second box, “less than significant with mitigations” should be checked, AND the Greenhouse Gas Emissions box in the table on p.7 checked.

The Discussion should acknowledge the increase in energy needed to pump water up-grade to all City users, especially in the event that the Elias well is used extensively if water availability from the existing surface water system becomes less and less dependable. As with the above considerations, the Discussion should note that the limited project purposes, and the Operational use plan ensuring that those limits are adhered to, will mitigate the impacts on the emission of greenhouse gases.

The Mitigation for potential significant greenhouse gas emissions increase should include the following:

GHG-1 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under certain conditions. p. 37 X. Hydrology and Water Quality, b) The second box, “Less than significant with mitigation incorporated” should be checked.

The Discussion should acknowledge that the effect of extensive pumping of the Elias replacement well for extended periods of time has not been thoroughly examined. Records cited from 2008 are from a letter written by Johnson describing a series of tests (p. 43). These tests in fact show that during times of drought the groundwater is affected by pumping. Although we are lucky that so far it appears recharge is happening in the winter, effects of groundwater pumping can have major consequences in the summer months. As stated above (Biological Resources), the relationship of groundwater to surface water is clear and must be acknowledged in this section. The Department of Water Resources publication cited (2004) brings no new information about Little Lake Valley groundwater. It is the report that is updated, not the information about our basin. The discussion should include the current and possibly deepening drought conditions that have occurred since the publication of the 1986 Farrar report, and the absence of an updated aquifer study that takes into account recent rainfall and aquifer recharge data, and precipitous declines in surface water (streamflow). By applying the Operational Use Plan as mitigation the

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7 beginnings of a study would be part of the plan and the effects of pumping groundwater more realistic in today’s climate.

The Mitigations for potential hydrology and water quality impacts must be included and reference the Operational Use Plan.
p.45 HYDRO-2 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under certain conditions and that data will be collected to identify aquifer characteristics and possible effects of groundwater pumping.
p. 51 Population and Housing: a) The second box, “less than significant with mitigations” should be checked, AND the Population and Housing box in the table on p.7 checked.

The Discussion should include acknowledgement that an increase in water availability has the potential to increase the population of Willits substantially especially given the 10” pipe specified in the Project Description (p.4). The size of the pump is not specified in the current IS/MND but conceivably a large pump (70 horsepower or more) could pump over 800 gpm (1,152,000 gallons per day). The actual capacity of the system is determined by the speed at which the groundwater treatment facility at the 250,000 gallon tank can process this water.

This is also not described in the current IS/MND. The Operational Use Plan monitoring system can be used to establish characteristics of the aquifer using current data for future growth should the City wish to establish the environmental effects of using groundwater for increasing the population capacity of the City.

The Mitigations for potential population and housing impacts must be included and reference the Operational Use Plan.

POP-1 Implementation of the Operational Use Plan (see Appendix___), which is designed to ensure that the Project is used only for the limited purposes and under certain conditions.

Again, I am very supportive of the City having a back-up system to provide water when the reservoirs are too low and to provide good quality water to the City’s water customers. I am also supportive of the city planning for growth at a future time by initiating a robust monitoring system using numerous wells in order to collect data for evaluating the effect of groundwater pumping on the aquifer of Little Lake Valley. Without good data we have no way of being sure how much pumping (per minute, per day, or even over the course of several years) is possible without drawing down the groundwater level such that 1) groundwater levels are not able to recharge annually, and such that 2) water quality is threatened by arsenic, boron, or other heavy metal intrusion into the pumping radius of the Elias replacement well and possibly even into the Elias replacement well itself.

It is imperative for the welfare of the public, and the legal basis of the project, that the Mitigated Negative Declaration and its supporting Initial Study and Environmental Checklist include mitigations (the Operational Use Plan serves for numerous mitigations) that enforce conservation and a robust monitoring system is implemented.

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8 We already know that pumping the Elias well this last year for three months caused levels in the neighboring Long 20 well, about ½ mile away to fluctuate. Did the arsenic levels in any of the neighboring wells fluctuate as well? I understand recharge was rapid in the fall of 2021 with its unusually wet November and December. However this was followed by the driest January and February on record. It is just this sort of unpredictable and uneven weather that can lead to early drought conditions, the need for using groundwater more and more and eventually possible effects to the aquifer. Without data we cannot know what and how much the effects are. Effects to an aquifer can take a long time to be realized and also a long time to recover, and some possible effects cannot be recovered from.

Including a detailed Operational Use Plan in the IS/MND, will assure all parties that the City is being careful not to over draft the valley’s precious groundwater supply, especially when the City lacks up to date data on long term groundwater recharge based on current climate conditions. With such an Operational Use Plan as I suggest included in the IS/MND this and future City Councils will be required under State CEQA law to follow it. The Operational Use Plan can be changed, but only after this, or a future Council, makes official findings, after environmental review, that a change in pumping rates will not cause significant harm to the aquifer.

By clearly stating the limitations of the use of the Elias well, and making those limiting conditions actual Mitigations in the Initial Study and Environmental Checklist, the Council can make the determination that this Project will not cause significant harm to the environment, human or natural, and the IS/MND will stand on firm legal ground.

Sincerely,
Rosamond Crowder, Vice-President, Willits Environmental Center, and Willits area resident CC: Vice Mayor Greta Kanne
Council Member Gerardo Gonzales
Council Member Larry Stranske
Council Member Madge Strong
Willits City Manager Brian Bender
Project Manager Andrea Trincado

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Resolution No. 2022-____ Page 1 of 2 April 13, 2022
RESOLUTION NO. 2022-_______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS RATIFYING AND EXTENDING FOR AND ADDITIONAL 30-DAYS, UNTIL MAY 13, 2022 THE CONTINUANCE

OF VIRTUAL CITY COUNCIL, COMMISSION, AND COMMITTEE MEETINGS DURING DECLARED STATE OF EMERGENCY PURSUANT TO GOVERNMENT CODE 54953 (AB 361).

WHEREAS, on October 13, 2021, the City of Willits adopted Resolution No. 2021-37, authorizing virtual City Council, Commission and Committee meeting during the Declared State of Emergency, which is to be renewed every 30-days. FURTHERMORE, the Resolution was renewed on November 10, 2021, Resolution No. 2021-40; December 8, 2021, Resolution No. 2021-42; December 20, 2021, Resolution 2021-47; and January 12, 2022, Resolution No. 2022- 01; February 9, 2022, Resolution No. 2022-11, March 9, 2022, Resolution No. 2022-15; March 23, 2022, Resolution No. 2022-16; and
WHEREAS, AB 361 was recently signed by the Governor of the State of California, enacting certain changes to the Brown Act as set forth in Government Code section 54953; and WHEREAS, AB 361 authorizes local legislative bodies to continue having purely virtual meetings using teleconferencing and virtual meeting technology as long as there is a “proclaimed state of emergency” and either 1) State or local officials imposing or recommending measures that promote social distancing, or 2) The legislative body finding that meeting in person would present an imminent safety risk to attendees; and
WHEREAS, the state of emergency proclaimed by the Governor on March 4, 2020, related to the pandemic of coronavirus commonly known as COVID-19 has not been rescinded and remains in effect; and
WHEREAS, new variants of COVID-19 have developed, and risk of illness or death due to such variants remains significant to the general public; and WHEREAS, the City Council has determined virtual meetings have not limited participation of Council Members, City Staff and other potential attendees; and WHEREAS, staff advised the City Council that modifications to the Council Chambers and the Community Center to accommodate on-site and/or hybrid meetings are cost prohibitive.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Willits that:

1. The City Council determines that the pandemic of COVID-19 creates an imminent safety risk to councilmember, staff, and other potential attendees of City Council meetings.

2. In accordance with AB 361, the City Council shall re-consider the passage of this resolution not less than every 30 days to determine whether the state of emergency continues to directly impact the ability of the members to meet safely in person, or whether state or local officials continue to impose or recommend measures to promote social distancing, until this resolution is rescinded.

The above and foregoing Resolution was introduced by Councilmember ________ seconded by Councilmember _________, and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the 13th day of April, 2022, by the following vote:

AYES:

NOES:
5b
Resolution No. 2022-____ Page 2 of 2 April 13, 2022
ABSENT:

ATTEST:
____________________________________
__________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits

DELORES PEDERSEN
City Clerk
Item No. 5c
Meeting Date: April 13, 2022

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Karen Stevenson, HR Manager
Agenda Title: 1) RESOLUTION APPROVING REVISED 2021/2022 CLASSIFICATION AND COMPENSATION SCHEDULE; 2) RESOLUTION APPROVING WAGE ADJUSTMENTS FOR SWIMMING POOL STAFF.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: N/A Summary of Request: The purpose of this revision to the 2021/2022 Classification and Compensation Schedule is to include the City Clerk position that was approved at the March 23, 2022 City Council Meeting.

The second item acknowledges the January 1, 2022 California Minimum Wage Increase for employers with 25 or more employees and adjust the wages for the swimming pool staff.

Recommended Action: Approve the Resolution for the revision to the 2021/2022 Classification and Compensation Schedule and approve the Resolution authorizing wage adjustments for swimming pool staff.

Alternative(s): None recommended.

Fiscal Impact: For the current fiscal year there is no negligible impact due to savings within the budget from the closure of the pool during the pandemic. However, an annual increase moving forward of approximately $3,500 per year given an expectation of the same hours of service budgeted the year before.

Personnel Impact: None
Reviewed by: City Manager City Attorney Asst. City Manager City Clerk Finance Director Human Resources Risk
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________

Resolution No. 2022-__ Page 1 of 1 April 13, 2022
RESOLUTION NO. 2022-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS APPROVING A NEW

EMPLOYEE POSITION CLASSIFICATION AND CORRESPONDING SALARY RANGE WHEREAS, the City Council has adopted a Master Classification and Compensation Schedule; and
WHEREAS, the City Council desires to update the Master Classification and Compensation Schedule to include the position of City Clerk; and WHEREAS, the City Council desires to add job classification and accompanying salary/wage range to meet the needs of the organization.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Willits hereby approves the new position classification and salary/wage range as set forth on Attachment A, which is attached hereto.

The above and foregoing Resolution was introduced by Councilmember seconded by Councilmember , and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the 13th day of April 2022, by the following vote:

AYES:

NOES:

ABSENT:

ATTEST:
___________________________
__________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits

DELORES PEDERSEN
City Clerk
Resolution No. 2022-__ Page 1 of 1 April 13, 2022
RESOLUTION NO. 2022-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS ACKNOWLEDGING THE JANUARY 1, 2022 CALIFORNIA MINIMUM WAGE INCREASE FOR EMPLOYERS WITH 25

OR MORE EMPLOYEES AND APPROVES THE ADJUSTMENT OF THE WAGES FOR SWIMMING POOL STAFF.

WHEREAS, the City Council has adopted a Master Classification and Compensation Schedule; and
WHEREAS, the City Council desires to update the Master Classification and Compensation Schedule to acknowledge the January 1, 2022 California Minimum Wage Increase to adjust the wages for swimming pool staff; and
WHEREAS, the City Council desires the wage adjustments to meet the needs of the organization.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Willits hereby approves the wage adjustments for swimming pool staff as set forth on Attachment A, which is attached hereto.

The above and foregoing Resolution was introduced by Councilmember seconded by Councilmember , and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the 13th day of April, 2022, by the following vote:

AYES:

NOES:

ABSENT:

ATTEST:
__________________________
__________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits

DELORES PEDERSEN
City Clerk
Item No. 9a
Meeting Date: April 13, 2022

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Davey Bowles, Building Inspector
Agenda Title: RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS HEREBY

ANNOUNCES THE INTENT OF THE CITY COUNCIL TO ADOPT AN ORDINANCE TO ENFORCE PROVISIONS OF SENATE BILL 1383.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 15 min Summary of Request: SB 1383, California’s short-lived climate pollution reduction strategy became law on January 1, 2022. The City of Willits received a five-year waiver on January 2, 2022 for many of the requirements. The purpose of this Resolution is to notify CalRecycle of where the City of Willits is not in full compliance with SB 1383 potentially alleviating the City of violations or fines. The Resolution also announces the City’s intent to adopt an ordinance in the near future.

Recommended Action: Adopt the accompanying Resolution approving the notification of intent to comply.

Alternative(s): None
Fiscal Impact: Staff anticipates utilizing one of the on-call engineering consultants to draft a local ordinance. The project estimate is $5K to compose the necessary ordinance provisions and Community Development is working with the Finance Department to secure budget funds.

Personnel Impact: Minimal staff to coordinate with consultants and provide guidance and oversight.

Reviewed by: City Manager City Attorney Assistant City Manager City Clerk Finance Director Human Resources Risk
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________ Resolution No. 2022- Page 1 of 2 April 13, 2022
RESOLUTION NO. 2022-

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS HEREBY ANNOUNCES

THE INTENT OF THE CITY COUNCIL TO ADOPT AN ORDINANCE TO ENFORCE PROVISIONS OF SENATE BILL 1383.

WHEREAS, CalRecycle, in consultation with the California Air Resources Board, has adopted regulatory requirements (Regulations), consistent with the mandate of Senate Bill 1383 (Lara, 2016), that are designed to achieve the organic waste reduction goals established in Section 39730.6 of the Health and Safety Code through a 50 percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2020 and a 75 percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2025; and WHEREAS, City of Willits is a local jurisdiction required to comply with the Regulations; and
WHEREAS, City of Willits is or expects to be facing continuing violations of the Regulations commencing during the 2022 calendar year; and WHEREAS, Senate Bill 619 (Laird, 2021), through amendments to Section 42652.5 of the Public Resources Code (Statute), created a mechanism called a Notification of Intent to Comply through which a local jurisdiction may secure administrative civil penalty relief from any continuing violations of the Regulations for the 2022 calendar year and may be eligible for a broader and longer-term regulatory compliance path, including suspended administrative civil penalties, through a corrective action plan; and
WHEREAS, City of Willits is a local jurisdiction authorized by the Statute to submit a Notification of Intent to Comply for CalRecycle approval; and WHEREAS, CalRecycle shall approve a Notification of Intent to Comply that is duly adopted by the jurisdiction by formal written resolution and meets the requirements of the Statute.

NOW THEREFORE BE IT RESOLVED, that the City Council of Willits by hereby formally adopts the Notification of Intent to Comply attached as Exhibit “A.” The City Council of Willits hereby authorizes and directs the City Manager, on its behalf, to submit the Notification of Intent to Comply attached as Exhibit “A” to CalRecycle for approval pursuant to the Statute.

By submitting the Notification of Intent to Comply pursuant to and subject to the above referenced requirements, the City of Willits represents and certifies that it will implement the proposed actions to remedy the violations according to the proposed schedule as approved by CalRecycle and in accordance with the Statute and Regulations.

The City of Willits also acknowledges and agrees to comply with any maximum compliance deadline in any corrective action plan that CalRecycle, in its sole discretion, determines to be necessary and appropriate under the circumstances for the correction of any violation(s) of the Statute and Regulations identified in its Notification of Intent to Comply.

Resolution No. 2022- Page 2 of 2 April 13, 2022
The above and foregoing Resolution was introduced by Councilmember _____seconded by Councilmember____, and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the 13th day of April, 2022, by the following vote:

AYES:

NOES:

ABSENT:

ATTEST:
______________________
__________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits

DELORES PEDERSEN
City Clerk
Attachment: Exhibit A – Notification of Intent to Comply ATTACHMENT "A"