Agenda — Willits City Council, October 23, 2024 (part 1 of 3)

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

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WILLITS CITY COUNCIL
AGENDA
OCTOBER 23, 2024 | 6:30 PM | CITY COUNCIL CHAMBERS

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

2. PUBLIC COMMUNICATIONS
The City Council welcomes input from the audience. If there is a matter of business on the agenda that you are interested in, you may address the Council when this matter is considered. If you wish to speak on a matter that is not on the agenda, you may do so at this time. In order for everyone to be heard, please limit your comments to three (3) minutes per person. The Brown Act regulations do not allow action to be taken on audience comments in which the subject is not listed on the agenda.

Members of the public are asked to observe the rules of decorum. While the City Council welcomes public criticism of policies, procedures, programs, or services of the agency; behavior that disrupts, disturbs, impedes, or renders infeasible the orderly conduct of the meeting and that includes, but is not limited to use of profanity, slurs, yelling from the audience, threatening remarks, physically threatening conduct, or physical or verbal displays of disrespect, will not be tolerated and the individual will be removed immediately.

3. PUBLIC MATTERS
a. PUBLIC HEARING: Discussion and Possible Adoption of the East Commercial Street Corridor Master Plan.

Presenting staff member: Leiloni Shine, Contract Planner. b. PUBLIC HEARING: To Adopt the 2024 Emergency Operations Plan Part 2: Flood Response Annex as an addition to the Emergency Operations Plan Part 1: Base Plan.

Presenting staff member: Logan Shine, Contract Planner
c. PUBLIC HEARING: Discussion and Possible Action Approving a Resolution to Certify the Final Environmental Impact Report and Adopt the Mitigation and Monitoring and Reporting Program for the City of Willits General Plan Land Use Element Update and Approve Said Project.

Presenting staff member: Dusty Duley, Community Development Director.

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. City Council Minutes:

Willits City Council Agenda – October 23, 2024

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i. October 9, 2024

6. MONTHLY ACTIVITY REPORTS
Matters that do not require action by the City Council but are of public interest. a. Accounts Payable Activity Report: August 2024.
b. Accounts Payable Activity Report: September 2024.
c. Business License Activity Report: September 2024.
d. Building Permit Activity Report: September 2024.

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. To Approve a Scope of Work to compose a Part 3: Fire and a Part 4: Earthquake Response Annexes for inclusion to the Local Emergency Operations Plan Part 1; Base Plan and amend the American Recuse Plan Act (ARPA) Project’s Budget Table to include these items at an expense of $66,000.
b. Verbal Reports – No Action.
i. 2024 Cal Cities Conference and Redwood Empire Division Business Meeting. ii. Project Updates:
• 2024 Pavement Preservation.
• Underground Utilities.
• Main Street Fiber Optic.
• Baechtel Road / PG&E Sidewalk.

9. DEPARTMENT RECOMMENDATIONS (ACTION ITEMS)
a. Adopt Resolution Approving the Resurfacing of State Street at a cost of $160,170 due to its Accelerated Deterioration from Construction Activity Associated with the 2024 Underground Utilities Project (Project #2023-08) with Monies from Transportation 202 and Wastewater 510 Funds and a Subsequent Reimbursement from the Surface Transportation Block Grant.

Presenting staff member: Walter Kolon, Services & Facilities Director. b. Adopt Resolution Approving Repairs to the South Clarifier at the Wastewater Treatment Plant due to Potential Mechanical Failure in an Amount not to Exceed $156,508.66.

Presenting staff member: Walter Kolon, Services & Facilities Director.

10. DEPARTMENT MONTHLY REPORTS – (presented at the second meeting of each month) a. Airport. b. Community Development. c. Finance. d. Police e. Services & Facilities. f. Utilities.

11. CITY COUNCIL ANNOUNCEMENTS, COMMUNICATIONS AND REPORTS

12. GOOD & WELFARE

13. CLOSED SESSION NOTICE
a. Conference with Labor Negotiator Pursuant to Government Code §54957.6 – Agency Negotiator: Brian Bender, City Manager. Employee Organization: Assistant City Manager.

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.

Willits City Council Agenda – October 23, 2024

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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 19th day of October 2024.

Delores Pedersen, City Clerk
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) 459-7113 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.

Item No. 3a
Meeting Date: October 23, 2024

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Dusty Duley - Community Development Director
Agenda Title: PUBLIC HEARING – DISCUSSION AND POSSIBLE ACTION APPROVING A RESOLUTION TO

CERTIFY THE FINAL ENVIRONMENTAL IMPACT REPORT AND ADOPT THE MITIGATION AND MONITORING

AND REPORTING PROGRAM FOR THE CITY OF WILLITS GENERAL PLAN LAND USE ELEMENT UPDATE AND APPROVE SAID PROJECT.

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

Summary of Request: Receive a presentation from staff and project consultants, Planwest Partners, conduct a public hearing, and consider adoption of the City of Willits General Plan Land Use Element Update and certification of the Final Environmental Impact Report (SCH #2023030321). Staff identified several new Land Use Element Policies and Implementation Measures that are recommended to be added to the Land Use Element Update as well as revisions to the Land Use Map and proposed Sphere of Influence boundary based on Council, agency, and public input. Modifications to the Draft Land Use Element Update are discussed in the staff report.

Background: Over the last few years, staff along with our project consultants, have been conducting public outreach and working with the project advisory committee and City Council to prepare a comprehensive update to the Land Use Element of the City’s General Plan. The Land Use Element is a planning document with text and diagrams that express the goals, objectives, and policies, intended to guide the community over a long-term planning period (typically around 20 years) towards achieving its vision for development. This element has not been updated by the City since 1994.

A Public review draft of the Land Use Element was published on June 26, 2024, and a Draft EIR (SCH No. 2023030321) was published on July 25, 2024. Both documents are available on the City of Willits Land Use Element Update project website at https://willitslanduseupdate.com and copies of both documents are also available at the Community Development Department. Nine comments were received during the Draft EIR public comment period, which began on July 25, 2024, and concluded on September 13, 2024. EIR comments provided by the public and other agencies along with staff responses are included in the Final EIR.

Recommended Action:

1. Adopt Resolution certifying the Final Environmental Impact Report Prepared for the Land Use Element and Sphere of Influence, making the Findings of Fact and adopting a Statement of Overriding Considerations and adopting the Mitigation Monitoring and Reporting Program;

2. Adopt Resolution adopting the Land Use Element, an Element of the City of Willits General Plan;

3. Direct Community Development Department to file a Notice of Determination with the Mendocino County Clerk within five days after the Final Environmental Impact Report is certified to be on file for a period of at least 30 days, after which the Notice will be returned to the Planning Division where it will be retained for not less than 12 months.

4. Direct the Community Development Department to correct any typographical or formatting errors and publish the Land Use Element to the City of Willits website with the goals, policies, implementation measures, and mitigation measures of the Circulation, Conservation and Open Space, Noise, Public Services and Facilities, Parks and Recreation General Plan, and Economic Development Elements formatted as appropriate to match the Land Use Element.

5. Direct Community Development Department staff to bring the updated Safety Element forward for adoption by the City Council within six months.

Alternative(s): Direct staff to make modifications the Land Use Element and bring matter back at the November 13th City Council meeting.

Fiscal Impact: Grant funds are available to support the remaining costs to adopt the Land Use Element and the Environmental Impact Report.

Personnel Impact: Significant staff time will be required to implement the various Land Use Element policies.

Identified City Council Conflict of Interest: The City Attorney and City Manager have identified two potential disqualifying conflicts of interest items regarding the adoption of the Land Use Designations within the Land Use Element.

First, is the proposed inclusion of a new “Mixed Use” designation applicable to the 82 contiguous downtown Main Street corridor parcels. Adoption of this new designated use, which is expected to allow for residential usage along with the existing commercial use on downtown Main Street parcels, would likely result in a material financial effect upon the Main Street commercial properties of council members Larry Stranske and Greta Kanne. It is therefore recommended that council members Stranske and Kanne be recused from this limited discussion and action item, that this matter be segmented from the other LUE items before the council, and that a separate resolution be adopted by the remaining members of the Council concerning this proposed Main Street use designation change.

Second, the proposed land use designation “Clean Up” action to the Land Use Element to reclassify approximately 212 non-conforming existing residential properties within the city that are presently designated as C-1 commercial, would likely result in a material financial effect upon the non-conforming residential property of Mayor Saprina Rodriquez. It is therefore recommended that Mayor Rodriquez be recused from this limited discussion and action item, that this matter be segmented from the other LUE items before the council, and that a separate resolution be adopted by the remaining members of the Council concerning this proposed “Clean Up” land use designation change.”
2021 Adopted Goals: Community Development Goal 1…Complete an update to the City’s General Plan to be used to guide future development within the City including encouragement of housing opportunities and sustainable economic development.

California Environmental Quality Act: A Draft Programmatic EIR (Draft EIR) for the City of Willits General Plan Land Use Element Update was prepared in accordance with CEQA.

This Item Relates to the following General Plan Element: N/A Land Use Circulation Conservation and Open Space Noise Housing Public Services and Facilities, Parks and Recreation Economic Development
Reviewed by: City Manager City Attorney Assistant City Manager City Clerk Finance Director Human Resources
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________ STAFF REPORT: LAND USE ELEMENT UPDATE
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CITY COUNCIL AGENDA STAFF REPORT
MEETING DATE: October 23, 2024 AGENDA ITEM NO:

TO: Honorable Mayor and Members of the City Council
PREPARED BY: Planwest Partners, Inc.

ITEM: THE CITY OF WILLITS GENERAL PLAN LAND USE ELEMENT

UPDATE AND ENVIRONMENTAL IMPACT REPORT
REQUEST: Consider adoption of the City of Willits General Plan Land Use Element Update and certification of the Final Environmental Impact Report (SCH #2023030321).

SUMMARY
The Land Use Element is one of seven required General Plan Elements and serves as a framework that uses maps, goals, and policies to guide how land should be developed and conserved. On September 11th and August 28th your Council and the public heard presentations from staff regarding proposed amendments to Land Use Element (LUE) policy, the Land Use Map, and the proposed expansion to the City Sphere of Influence. During these hearings, your Council heard public comments, in particular regarding a portion of the proposed SOI area in the Exley Road/Mill Creek area and relating to the State Route 20 area, and comments on LUE policy regarding environmental protections, protecting character of the downtown area, and coordination with local communities, in particular the Sherwood Valley Rancheria. During the September 11th hearing your Council also received input on the Draft Programmatic Environment Impact Report (EIR).

During tonight’s public hearing, your Council will also be considering and certifying the Final EIR prepared for the Land Use Element Update including an amendment to the Sphere of Influence boundary. There are several actions your Council is required to take to certify the Final EIR and adopt the Land Use Element Update, as described in this staff report.

STAFF REPORT: LAND USE ELEMENT UPDATE
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BACKGROUND
California state law requires that each city adopt a general plan “for the physical development of the city and any land outside its boundaries which bears relation to its planning” (California Government Code, Section 65300). In a larger sense a county general plan is a “constitution for future development,” which is how the California Supreme Court has described it. The general plan establishes the types, locations, and intensities of land uses as well as applicable resource protection and development policies. Land use maps are used to show land use plan designations, constraints, and public facilities.

The Willits General Plan Vision 2020, the current City of Willits General Plan, contains text and diagrams that express the goals, objectives, and policies intended to guide the community toward achieving its vision for development. City decision makers rely on the General Plan as the basis for making decisions on matters such as land use, transportation, open space and conservation, the provision of public services, and environmental quality and safety. It is also a policy document that guides decisions related to protecting and enhancing what the community values most, such as protecting and enhancing the character of the community. Since 1992, there have been no comprehensive updates to the General Plan or its Elements, except for the Housing Element which was updated in 2019. A draft Safety Element Update was prepared following the adoption of the Mendocino County Multi-Jurisdictional Hazard Mitigation Plan and the City’s Jurisdictional Annex (Local Hazard Mitigation Plan) is in draft form and should revised for consistency with state laws approved after its preparation and adopted within six months of the adoption of the Land Use Element Update.

LAND USE ELEMENT AND SPHERE OF INFLUENCE UPDATE:

The proposed amendments to the City of Willits Land Use Element and Land Use Map are comprehensive and include proposed changes to the City Zoning Map and Regulations, which will follow the approval of the Land Use Element. The changes to the Zoning Map will implement the Land Use Element and also involves changes to regulations, such as the addition of mixeduse zones. A draft Zoning Map has been prepared and the anticipated mixed-use zone is being developed. Additional amendments will also be required to fully implement the Land Use Element.

The Land Use Element Update includes a new comprehensive narrative section that contains background information, describes applicable laws, local and regional context, and other relevant information. The Land Use Element Update includes nine new policy groups, each related to a clear goal statement and that contain implementation measures. The tenth policy group contains the land use designations, including new mixed-use land use designations, and detailed criteria including the range of allowable uses, the allowable density or intensity, and consistent zones.

The General Plan Land Use Map included in the Land Use Element Update makes a series of land use changes (totaling approximately 435 acres) to apply the new mixed use land use designations and other changes that can be divided into three groups:

1. Proposed changes to the Land Use Map create potential opportunities for new residential or mixed-use development.

2. Potential changes that are prompted by property owner land use requests.

3. Land use “clean ups” where the long-time, established, land uses are inconsistent with the Land Use Designation applied in 1992 or earlier.

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The Land Use Element also includes a proposed expansion to the City’s Sphere of Influence (SOI), with the application of appropriate City Land Use Designations or “prezoning”, to support a potential Sphere of Influence Amendment application to the Mendocino Local Agency Formation Commission (LAFCo). The SOI was last approved by LAFCo in 2019 and is comprised of approximately twelve acres in area, divided into 61 Assessor’s parcels that are largely developed with single family homes and three vacant parcels. The proposed SOI considers Disadvantaged Unincorporated Community (DUC), as required by LAFCo law. To update the SOI, the City would prepare and submit to LAFCo an application, also including a Municipal Service Review, following the adoption of the Land Use Element.

The August 28th City Council staff report describes in detail the proposed goals, policies, and implementation measures and the proposed SOI area, and the September 11th staff report includes maps and tables that enumerate the proposed changes to the Land Use Designations and the proposed changes to the Land Use Map. Representatives of the Sherwood Valley Band of Pomo Indians made a comment requesting government-to-government consultation and members of the public and made comments during these hearings, in particular relating to the proposed SOI area. This staff report describes the requirements and process to certify the EIR and the recommended changes to the Draft EIR and the Land Use Element and Land Use Map resulting from the government-to-government consultation and public comments.

LAND USE MAP AND LAND USE MAP ADOPTION

COMPLIANCE WITH THE CALIFORNIA ENVIRONMENTAL QUALITY ACT The Land Use Element Update requires discretionary approval by the City of Willits and as such is subject to the California Environmental Quality Act (CEQA). The City, as the lead agency, must identify and document the potential environmental impacts of the project in accordance with CEQA. The City of Willits circulated a Notice of Preparation (NOP) for a 30-day public review period on March 10, 2023, which was received by the State Clearinghouse on the same day and assigned SCH# 2023030321. The NOP review period ended on April 10, 2023. The NOP Scoping Comments received are included as Appendix A in the Draft EIR.

A Draft Programmatic EIR (Draft EIR) for the City of Willits General Plan Land Use Element Update was prepared in accordance with CEQA, which is a full‐disclosure informational document that informs public agency decision‐makers and the public of the significant environmental effects of the project. Mitigation measures intended to minimize significant effects are identified in the Draft EIR and reasonable alternatives to the project are evaluated. The Draft EIR was submitted to the State Clearinghouse on July 25, 2024, for distribution to State agencies. The Draft EIR was uploaded to the State Clearinghouse and available for download at https://ceqanet.opr.ca.gov/Project/2023030321.

A Notice of Availability of the Draft EIR was emailed on July 25, 2024, to parties who requested to receive project updates via https://willitslanduseupdate.com (104 recipients), as well as direct emailing to trustee agencies, responsible agencies, area schools, and regional planning agencies, and was also posted at the County Clerk by law, and through a posting in a local newspaper, the Willits Weekly, on August 1, 2024. The public review period of the Draft EIR lasted over the 45 days as required by Section 15205 of the CEQA Guidelines and ended at 5:00 pm on September 13, 2024. The document was made available for review at City of Willits Community Development STAFF REPORT: LAND USE ELEMENT UPDATE
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department at 111 E. Commercial Street, Willits, CA and online at:
https://willitslanduseupdate.com. A public hearing was held before the City Council on September 11, 2024, to receive input on the Draft EIR.

Significant Unavoidable Impacts. The Draft EIR concludes there are two significant, unavoidable impacts from the Land Use Element and Sphere of Influence Update that cannot be mitigated to less than significant levels, both relating to greenhouse gas emissions. • Impact GHG-01: Would the Project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
• Impact GHG-02: Would the Project be consistent with statewide GHG emission reduction goals?
The proposed project will result in development that may generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment even with the mitigation measures described below, resulting in a significant, unavoidable impact. AB 32 establishes by law that GHG emissions cause significant adverse impacts to the environment, so this impact is conservatively determined to be significant. Ensuring that the Project’s GHG emissions will be mitigated through programs reducing emissions is not feasible at this time. Therefore, this impact is considered significant and unavoidable.

Several proposed Policies in the proposed Land Use Element are intended to reduce GHG emissions from the Project:
• Policy LU-3.8 Energy Conservation and Reduction encourages the installation of renewable energy systems and community-wide reductions in energy consumption, which will reduce GHG emissions associated with energy use.
• Policy LU-3.9, Plan for Climate Change, directs the City to develop and implement programs to achieve City-wide reductions in greenhouse gas emissions, • Policy LU-3.10 Greenhouse Gas Emission Reductions, directs the City to evaluate new larger-scale residential, commercial, and industrial projects for compliance with state regulations and require feasible mitigation measures to reduce GHG emissions.

The Draft EIR analysis found that Policy LU-3.10 Greenhouse Gas Emission Reductions, did not specify the requirement that GHG reductions be “consistent with state targets” and required the addition of this text to that policy. In spite of the required mitigation, the Draft EIR analysis conservatively concludes that future City-wide GHG emission reductions to meet state targets through the implementation of policies and programs identified in the Land Use Element Update cannot be assured. Therefore, this impact is considered significant and unavoidable.

Potential Impacts that would be Mitigated to Less Than Significant. The Draft EIR found that a total of 28 impact topics, or thresholds, from the CEQA Appendix G checklist could be potentially significant but would be less than significant after the implementation of mitigation measures. The analysis of these potentially significant impacts resulted in the requirement for sixteen (16) mitigation measures, two (2) of which are modifications to proposed policies of the Land Use Element Update, twelve (12) represent new policies or implementation measures that must be added to the Land Use Element Update, and two (2) relate to the Draft Safety Element, where one policy requires the adoption of the Safety Element be adopted prior to or within six months of the adoption of the Land Use Element Update and the other requires that the Safety Element be reviewed and updated as necessary to be consistent with applicable state legislation that has been passed since the draft’s preparation in 2019. Pursuant to Public Resources Code Section STAFF REPORT: LAND USE ELEMENT UPDATE
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21081.6, the Land Use Element Update must incorporate the approved mitigation measures identified in the Draft EIR into its policies and programs. The Revised Land Use Element Update, Attachment A, incorporates the mitigations specified in the Draft EIR.

Comments Received During the Public Comment Period. During the public comment period for the Draft EIR, the City of Willits received eight comment letters/emails, which included numerous comments on the Draft EIR. Responses to comments received on the Draft EIR have been prepared to be incorporated in a Final EIR (Attachment B) and were distributed to the maker of the comment at least ten days prior to the October 23, 2024, hearing.

Many comments did not address the Draft EIR and were instead comments on some aspect of the proposed Land Use Element Update, the proposed SOI, or some other aspect of land use planning. The review by the EIR preparers of the comments received did not identify new information not already disclosed as part of this Draft EIR, or issues of EIR adequacy. In preparing the Final EIR each of the individual comments within the comment letter were identified and summarized and a full response provided. In some instances, comments prompted a revision to the Draft EIR Environmental Setting or Regulatory Setting, which were made as part of the Final EIR to clarify existing conditions or requirements. The review of the comment letters by City staff prompted the preparation of two new policies or implementations in order for the Land Use Element to provide greater transparency, strengthen local procedures and further ensure that the health and safety of the public is protected.

Responses to comments received during the EIR comment period that related to the proposed Land Use Element are contained in the Final EIR and are briefly summarized in the following:

Willits Environmental Center
• The proposed expanded SOI defined in the Draft Land Use Element is very large and that only a small portion of the SOI area is developed, only a portion of the land within the City planned for development is currently developed, and that there is “ample room” within the City to accommodate infill development.
• The proposed expanded SOI should be reduced or eliminated due to potential open space, agricultural, watershed, riparian, and wetlands impacts. • The Baechtel Road land use change area should be designated as open space to protect the riparian area and to provide land for a park. The purpose of the secondary roadway that is a component of the planning for this land use change area is now unnecessary.

The comment letter also encourages the creation of parks throughout the City. • The Land Use Element implementations, such as the riparian protection overlay zone or changes to the Zoning Regulation relating to oak tree protections, be approved prior to the adoption of the Land Use Element.
• The comment letter states that the City of Willits is out of compliance with its State water right and that the City should be operating under a State-approved water right prior to approval of the Land Use Element Update.

Ruth Ford
• Housing units are not appropriate uses within the East Hill land use change area and would be incompatible and could create conflicts with the surrounding area and with neighboring agricultural uses. Agriculture is the appropriate use for the East Hill land use change area. The Willits Geneal Plan emphasizes infill before annexation of new areas, STAFF REPORT: LAND USE ELEMENT UPDATE
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limiting incompatible uses, and other aspects of open space and resource protection. This land use change would not be consistent with these aspects of the General Plan.

Mendocino County Farm Bureau
• The letter states concerns about potential impact to agriculture, particularly within the neighboring unincorporated areas, from the application of new General Plan Land Use Designations and Zoning Classifications within the SOI and the potential conflict between City land use and zoning and County land use and zone.

In addition, the review of the Draft EIR prompted by the comments identified the need to make corrections to address typographical errors and incomplete references, as well as to add specific clarifications or additional detail regarding information in the Draft EIR. The additions made as part of the Final EIR do not constitute “significant new information” requiring recirculation pursuant to Public Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5. The Final EIR merely clarifies, amplifies, and makes insignificant modifications to an adequate EIR, per CEQA Guidelines Section 15088.5(b).

EIR Certification. Prior to adopting the Land Use Element Update, your Council must certify, in accordance with Section 15090 of the CEQA Guidelines, that the Final EIR has been completed in compliance with CEQA and reflects the City‘s independent judgment and analysis, and that the Final EIR was presented to your Council and that your Council reviewed and considered the information contained in the Final EIR prior to approving the project. Your Council must also make the required findings pursuant to Section 15091 of the CEQA Guidelines with respect to each of the significant environmental effects identified in the Final EIR; adopt the mitigation measures in the EIR, adopt a Mitigation Monitoring and Reporting Program; and adopt a Statement of Overriding Considerations explaining why the project may be approved even though it will have significant unavoidable impacts on the environment. These actions are all included in the attached resolutions.

SENATE BILL 18 AND ASSEMBLY BILL 52 TRIBAL CONSULTATION The comment letter from the Sherwood Valley Band of Pomo Indians requested government to government consultation per Senate Bill 18 and Assembly Bill 52 requirements relating to Tribal Consultation. The Draft EIR states on page on page 3.5-10 and 11 states that in “February 2023, the City of Willits sent a letter to the NAHC requesting a current SB 18 and AB 52 Native American Contact List for the Project vicinity and a Sacred Lands File (SFL) search. On February 28, 2023, the NAHC provided a list of 13 tribal contacts with tribal connections to the Planning Area. In accordance with AB 52 and SB 18, on April 12, 2023, the City of Willits notified the following thirteen (13) tribes of the project and invited them to participate in consultation”. “No requests for consultation were received from the 13 Native American tribes that were sent formal notification of the project. As no requests for consultation were received within 30 days specified by PRC Section 21082.3 (d) for AB 52 nor within the 90 days specified by California Government Code Sections 65352.3 and 65352.4, the City of Willits, as Lead Agency, has deemed the tribal consultation process complete.”
However, City staff responded to a request from Sherwood Valley Rancheria of Pomo Indians to engage in discussions regarding the Draft Land Use Element and participated in government-togovernment consultation on October 2, 2024. During this meeting staff of the Sherwood Valley Rancheria of Pomo Indians provided detailed recommended edits to Draft EIR Section 3.5, 3.5 Cultural and Tribal Cultural Resources Environmental and Regulator Setting subsections and recommended edits to two mitigation measures: Mitigation Measure CUL-1, Cultural Resource STAFF REPORT: LAND USE ELEMENT UPDATE
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Discovery Protocols, and Mitigation Measure TCR-1, Avoid Impacts to Tribal Cultural Resources.

In addition, the comments requested that the definition of Tribal Cultural Resources in the Draft EIR, which references state law, be expanded to include “living cultural resources.” City staff is recommended that Implementation Measure LU-7A, Tribal Consultation, is to be modified to expand the reference to Tribal Cultural Resources to include “living cultural resources,” which will be part of future project specific Tribal consultations.

REVISIONS TO THE PUBLIC REVIEW DRAFT LAND USE ELEMENT UPDATE Staff has identified several new Land Use Element Policies and Implementation Measures that should be added to the Land Use Element Update based on Council, agency, and public input.

As described above, the Draft EIR, as modified in the Final EIR, identified potentially significant environmental impacts that could result from the implementation of the Land Use Element Update that require sixteen (16) mitigation measures, two (2) of which require modifications to proposed policies of the Land Use Element Update and twelve (12) require new policies or implementation measures that must be added to the Land Use Element Update. In addition, staff has identified several errors in tables that should be corrected prior to approval.

Based on public and landowner input, several revisions to the proposed SOI area are recommended, including the removal of the Mill Creek Area and the easternmost seven parcels of the East Valley Street Area. In addition, parcels in the Land Use Change Area 32 (north of West Commercial Street) is proposed to be General Mixed-Use rather than Main Street Mixed Use, and an additional parcel is proposed to be added to this area.

The following table lists recommended revisions to the Public Review Draft Land Use Element Update and the reason for each recommended or required change:

STAFF REPORT: LAND USE ELEMENT UPDATE
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#
Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications 1 • Remove “(units per acre)” from the Density Range column heading.
• Add an appropriate density ratio description to each land use designation, as applicable.
• Correct Residential-Suburban to be compatible with current General Plan (2 dwelling units per acres ~ one dwelling unit per 20,000 square feet from Table 3-1: General Plan Map Designations)
• Correct Agricultural - General density to be compatible with current General Plan (not specified in General Plan, fiveacre minimum lot size in Zoning Regulations 17.10.050 Lot regulations)
Table 2-1:

General Plan
Land Use
Designation
Summary on
page 19
No effect on draft EIR determinations. This is
an error in the table in the Public Review Draft
Land Use Element Update, the analysis in the
EIR does not identify a change in maximum
density for the Residential - Suburban
Agricultural - General Land Use Designations.
2 Add new policy or implementation:

LU-1.6 NEW FREEWAY COMMERCIAL USES WITHIN THE

PLANNING AREA
The City of Willits does not support the development of highway-oriented commercial development outside City
limits near the north and south Willits/U.S. 101 interchanges or other development which would impact the health of the business community within the City.

Staff recommended new policy to address Council and public concern relating to potential new commercial development adjacent to the U.S. Highway 101 interchanges.

Planning Area
Policy Group
page 26
No effect on draft EIR determinations. This
policy relates to areas within the Planning Area
and outside the City proposed SOI, not
proposed to be within City land use jurisdiction.

This policy informs the County, Caltrans, and
the public that the City does not support
freeway commercial development at
interchanges near the City.
3 Revise proposed policy or implementation:

LU-1B SEEK APPROVAL OF THE AN EXPANDED SPHERE
OF INFLUENCE.

Planning Area
Policy Group
page 26
No effect on draft EIR determinations. The
Draft EIR evaluated the entire proposed SOI
and to reduce the area that may be included in
the Land Use Element or that the City Council
may choose to include in an application to
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#
Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Submit an application to the Mendocino Local Agency
Formation Commission to expand the City of Willits Sphere of Influence to add some or all of the areas shown in Figure 3-1, as determined by the City Council, consistent with Mendocino Local Agency Formation Commission policy and
State law. Seek approval to add possible Areas of Interest for Mendocino Local Agency Formation Commission
designation so that notice is provided of other governmental actions that may impact the City of Willits.

This is a staff proposed clarification that the City Council is not obligated to seek LAFCo approval for the entire proposed SOI in the Land Use Element to the City’s SOI. The City Council could choose to submit application to only add a portion or to add portions over time.

LAFCo does not change the conclusion of the
analysis.
4 Add new policy or implementation:

LU-2.5 ANNEXATION PLANNING
Discourage urban development within the City’s Sphere of Influence until such lands are annexed by the City and
support County land use regulations that protect the viability of local agriculture in the Little Lake Valley. When
considering proposals for annexation, protect designated open space.

Required as mitigation to reduce potential impacts to "prime agricultural land", pursuant to LAFCo law, in future annexation planning.

Planning Area
Policy Group
page 26
None, This revision is a mitigation measure
required by the Draft EIR.
5 Revise proposed policy or implementation:

LU-3.10 PLAN FOR CLIMATE CHANGE
Willits
Character,
Vitality, and
Sustainability
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 10
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Plan for the public health implications of climate change, including potential disease and temperature effects, and work with state and county public health agencies to identify necessary programs to reduce, adapt to, and increase
resiliency to potential impacts and implement programs to achieve City-wide reductions in greenhouse gas emissions consistent with state targets.

Required as mitigation to reduce potential future greenhouse gas emissions.

Policy Group
page 33
6 Add new policy or implementation:

LU-4.8 FORMULA-BASED BUSINESSES
In order to maintain the character of the Willits Downtown and a business environment which is intended to support locally owned and managed businesses, prepare and
implement zoning regulations to restrict the location of large franchise, or formula-based, businesses within Downtown, as shown on Figure 3-2 Willits Focus Area.

This change is the result of public input
Downtown
Policy Group
page 38
No effect on draft EIR determinations. The
Draft EIR evaluated impacts related to the
proposed land use change areas and projected
population buildout. The nature of the business
owner would not change the level of
environmental effects or the conclusions in
applicable impact topics.
7 Revise proposed policy or implementation:

LU-7.1 ENVIRONMENTAL JUSTICE
Consider environmental justice issues as they are related to potential health impacts associated with of land use
decisions on residents regardless of all ages, cultures, ethnicityies, genders, racess, socioeconomic statuses, and geographic locations.

This is a change requested by the Sherwood Valley Band of Pomo Indians to use positive phrasing regarding persons.

Coordinate with
Local
Communities
Policy Group
page 46
None, This revision is does not change the
intent or effect of a policy considered as part of
the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 11
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications 8 Add new policy or implementation:

LU-7B TRIBAL CULTURAL RESOURCES AVOIDANCE
When feasible, development facilitated by the project shall be designed to avoid known tribal cultural resources. Known tribal cultural resources within 60 feet of planned
construction activities shall be protected by establishing an Environmentally Sensitive Area (ESA) that would be fenced, or otherwise protected, to ensure avoidance. The feasibility of avoidance of tribal cultural resources shall be determined by the City of Willits and applicants in consultation with local California Native American tribe(s).

Required as mitigation to reduce potential future impacts to Tribal Cultural Resources.

Coordinate with
Local
Communities
Policy Group
page 47
None, This revision is a mitigation measure
required by the Draft EIR.
9 Add new policy or implementation:

LU-7C INADVERTENT ENCOUNTER WITH TRIBAL

CULTURAL RESOURCES
If previously unidentified tribal cultural resources are encountered during project implementation, altering the materials and their stratigraphic context shall be avoided and work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural
resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

Required as mitigation to reduce potential future impacts to Tribal Cultural Resources as modified during the governmentCoordinate with Local
Communities
Policy Group
page 47
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 12
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications to-government consultation with the Sherwood Valley Band of Pomo Indians.
10 Add new policy or implementation:

LU-7D INADVERTENT ENCOUNTER WITH

ARCHAEOLOGICAL OR CULTURAL RESOURCES
In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or uncovered 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 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.

Required as mitigation to reduce potential future impacts to cultural resources as modified during the government-toCoordinate with Local
Communities
Policy Group
page 47
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 13
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications government consultation with the Sherwood Valley Band of Pomo Indians.
11 Add new policy or implementation:

LU-7E INADVERTENT DISCOVERY OF

PALEONTOLOGICAL RESOURCES
If fossils are encountered during construction (i.e., bones, teeth, or unusually abundant and wellpreserved
invertebrates or plants), the City and its contractor shall divert construction activities away from the discovery within 50 feet of the find, and a professional paleontologist shall be contracted to document the discovery as needed, to
evaluate the potential resource, and to assess the nature and importance of the find. Based on the scientific value or uniqueness of the find, the paleontologist may record the find and allow work to continue, or recommend salvage and recovery of the material, if it is determined that the find cannot be avoided. The paleontologist shall make
recommendations for any necessary treatment that is
consistent with currently accepted scientific practices. Any fossils collected from the area shall then be deposited in an accredited and permanent scientific institution where they would be properly curated and preserved.

Required as mitigation to reduce potential future impacts to paleontological resources.

Coordinate with
Local
Communities
Policy Group
page 48
None, This revision is a mitigation measure
required by the Draft EIR.
12 Revise proposed policy or implementation:

LU-8.3, RIPARIAN AREA LAND USE OVERLAY.

Apply an overlay to the Land Use Map, consistent with
Conservation and Open Space Element Implementation
Protect Natural
Resources
Within Areas
Planned for
Development
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 14
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Measure 3.320 identifying streams and wetlands within the City to be protected from development. Prohibit
development within a buffer area on both sides of streams subject to the following criteria:
(a) A combining zone for stream and riparian areas shall also be established and applied to parcels adjacent to
streams and subject to the Riparian Area Land Use
Overlay that specifies protective criteria consistent with this policy.
(b) Riparian Buffer Areas associated with streams shall be established on both sides of streams and shall be
measured from either the outer drip-line of riparian
vegetation or the top-of-bank, whichever is furthest
from the stream centerline, and shall extend
horizontally for a distance of:
 100 feet for perennial streams, or
 50 feet for intermittent streams.

Riparian Buffer Areas associated with wetlands shall
extend horizontally from the delineated wetland
boundary for a distance of:
 150 feet for perennial wetlands, or
 50 feet for seasonal wetlands.
(bc) Buffers may be reduced or eliminated where the
City determines, based on factual findings and in
consultation with CDFW, that the reduction will not result in significant adverse effects to the water quality,
dependent biological resources, or ecological functional capacity of the aquatic resource of interest.
(cd) For ministerial projects that are located on land
planned R-L, C-G, GM-U, DM-U containing occupied
Policy Group
page 50
STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 15
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications structures or on vacant parcels that are substantially
surrounded by developed parcels where improvements
are located within the buffer area, exceptions to these standards may be allowed after a site evaluation has
been conducted by City staff and factual findings are
made that development is sited to minimize potential
impacts to streams, wetlands, and associated riparian
resources; does not involve the removal of native
riparian vegetation; and the incorporation of performance standards relating to the revegetation of locallyappropriate riparian species and the implementation of best management practices for erosion control.
(de) When the prescribed buffer prohibits
development of the site for the primary use for which it is designated, measures shall be applied that allow
development that results in the least environmentally
damaging feasible project.
(ef) Road, bridge, and trail construction or replacement may be permitted that would not result in significant adverse effects to water quality, dependent biological resources, or ecological functional capacity of the aquatic resource of interest, where vegetative clearing is kept to a
minimum, and where revegetated with locallyappropriate native riparian species. (g) The installation or replacement of new or existing
fencing contiguous with Riparian Buffer Areas shall
require the use of wildlife-permeable materials and
designs to reduce the likelihood of wildlife
entrapment and otherwise facilitate wildlife
movement.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 16
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications (h) All projects shall implement stormwater
requirements from the Mendocino County Low
Impact Development Standards Manual to protect
water quality and associated aquatic habitats, avoid
the use of noxious weeds or other invasive plants
identified by the California Invasive Plant Council
(Cal-IPC) in associated revegetation and
landscaping efforts, and prioritize use of locallyappropriate native vegetation during any such revegetation.
(fi) The removal of vegetation for disease control or public safety purposes may be approved, in consultation with
CDFW.)
(gj) An exception to the implementation of regulations for this policy shall be included for “minor additions” to buildings or structures provided the aggregated total increase in square footage for all changes does not exceed thee
hundred (300) square feet of floor area.

Required as mitigation to reduce potential future impacts on biological resources.

Add new policy or implementation:

LU-8.6 UTILIZE BIOLOGICAL RESOURCE INVENTORY

ASSESSMENT TOOLS DURING PROJECT REVIEW
The City shall ensure that the best available biological resource mapping data is used during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to Protect Natural
Resources
Within Areas
Planned for
Development
Policy Group
page 52
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 17
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications insignificant levels consistent with CEQA. At a minimum, the following biological resource mapping data sources shall be used for project evaluation: California Department of Fish and Wildlife’s California Natural Diversity Database
(CNDDB) and their Biogeographic Information and
Observation System (BIOS), EcoAtlas and the California
Aquatic Resource Inventory (CARI), and U.S Fish and
Wildlife Service’s National Wetland Inventory (NWI).

Required as mitigation to reduce potential future impacts on biological resources.
13 Add new policy or implementation:

LU-8.7 REQUIRE PRE-PROJECT BIOLOGICAL RESOURCE

ASSESSMENTS AND SURVEYS
The City shall require site- and/or project-specific biological resource assessments: 1) prior to annexing any properties into the City from the Proposed Sphere of Influence
additions, and 2) prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area.

Biological resource assessments shall address potential impacts to special status and/or otherwise protected fish, wildlife, and botanical taxa (including potential interferences with their movement, migration, and/or dispersal); sensitive natural communities; and wetland habitats. Biological
resource assessments shall also identify mitigation
measures to avoid and/or reduce impacts to protected
biological resources to less than significant levels from all new development allowed within the study area by the
General Plan.

Protect Natural
Resources
Within Areas
Planned for
Development
Policy Group
page 52
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 18
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Where biological resource assessments identify potentially suitable habitat for special status fish, wildlife, and/or botanical taxa; nesting bird or roosting bat habitat; sensitive natural communities; and/or wetlands or other state- or federally regulated waters within respective study areas, appropriate pre-project biological surveys or habitat
delineations shall also be required. All biological resource assessments, surveys, and delineations shall be performed in coordination with CDFW by qualified professionals with demonstrated familiarity and experience within the region and consistent with respective current field survey
protocols.

Required as mitigation to reduce potential future impacts on biological resources.
14 Add new policy or implementation:

LU-8.8 LOW IMPACT DEVELOPMENT STANDARDS NEAR

STREAMS
To reduce stormwater impacts to streams and wetlands and improve water quality associated with discretionary
development and all development within 250 feet of Willits, Broaddus or Baechtel Creeks and their tributaries, the City shall implement stormwater requirements from the
Mendocino County Low Impact Development Standards
Manual to attenuate runoff, reduce scouring and erosion, promote on-site infiltration, and to protect water quality and associated aquatic habitats.

Protect Natural
Resources
Within Areas
Planned for
Development
Policy Group
page 53
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 19
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Required as mitigation to reduce potential future impacts on biological resources.
15 Add new policy or implementation:

LU-8.9 LANDSCAPING AND VEGETATION
The City shall develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for development-related landscaping and revegetation. The City shall encourage the use of locally appropriate and locally sourced native
vegetation for use in revegetation and landscaping efforts as well as encourage the planting of native milkweed
(Asclepias spp.) species (i.e., the sole plant group within the Planning Area region suitable for egg laying and larval development for the federal candidate species, Western
Monarch butterfly [Danaus plexippus plexippus]). Where
rapid plant establishment and development is required for purposes of soil stabilization and to minimize erosion
potential, the City shall encourage the use of sterile hybrid “wheatgrass” x ”wheat” (Elymus x Triticum) or other similar non-reproductive seed material in conjunction with
otherwise appropriately-selected revegetation seed
applications or blends.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 20
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications based on a known potential for preventing the
establishment of the intended vegetation assemblage within respective revegetation areas.

Required as mitigation to reduce potential future impacts on biological resources.
16 Add new policy or implementation:

LU-8.10 OUTDOOR LIGHTING NEAR STREAMS
The design and location of all outdoor lighting fixtures shall prevent direct illumination of streams, wetlands, and
Riparian Buffer Areas.

Required as mitigation to reduce potential future impacts on biological resources.

Protect Natural
Resources
Within Areas
Planned for
Development
Policy Group
page 53
None, This revision is a mitigation measure
required by the Draft EIR.
17 Add new policy or implementation:

LU-8.11 SUPPORT LOCAL AGENCIES IN WILDLIFE

PROTECTION
Partner with local organizations to educate applicants and residents about the impacts to special status and otherwise protected wildlife from toxic pest control methods, and to discourage their use within the City; as well as to educate the community about the impacts of free-ranging house
cats on special status and otherwise protected wildlife.

Required as mitigation to reduce potential future impacts on biological resources.

Protect Natural
Resources
Within Areas
Planned for
Development
Policy Group
page 53
None, This revision is a mitigation measure
required by the Draft EIR.
18 Add new policy or implementation:

LU-8.12 DEVELOPMENT IN HILLSIDE AREAS
Protect Natural
Resources
Within Areas
None, This revision is a mitigation measure
required by the Draft EIR.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 21
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Require new development in hillside areas be sited and
designed to retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas. The City shall encourage clustered dwelling units in hillside areas to preserve the scenic character of the
hillsides.

Required as mitigation to reduce potential future impacts on biological resources.

Planned for
Development
Policy Group
page 54
19 Add new policy or implementation:

LU-9E LIST OF HAZARDOUS WASTE SITES
City staff shall maintain a listing of state or County of Mendocino regulated hazardous waste sites that are on the Cortese Listing, including Envirostor and Geotracker, that is provided by the state of California in a manner that is readily available to applicants for development projects and the public. The City shall consult this list during the review discretionary and ministerial projects, and consistent with state law, require that applicants for development disclose, as part of their applications, whether the project site is within a hazardous waste site. Appropriate mitigations or site cleanup and closure, under permit and approval of the applicable agency, must occur prior to approval of a
development permit to ensure that a project site within a hazardous waste site will not result in an adverse human health or environmental effect.

Recommended by staff based on discussion with the Regional Water Quality Control Board staff.

General Plan
Implementation
and
Maintenance
Policy Group
page 59
No effect on draft EIR determinations. The
Draft EIR evaluated impacts related to
hazardous waste sites and disclosed all known
locations based on state lists and referenced
the role of state and federal regulations in
reducing potential environmental impacts. This
implementation measure is intended to provide
greater transparency, strengthen local
procedures and further ensure that the health
and safety of the public is protected.
20 Delete Overlay Land Use Designation Land Use
Destination
This overlay is proposed to be applied for
informational purposes and does not have
STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 22
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications LU-10.6 GENERAL PLAN LAND USE MAP OVERLAY

DESIGNATIONS
Conservation - Floodway (-FW). This General Plan overlay designation is intended for information purposes and is applied to waterways and primary drainage channels to
indicate the need to protect channels for the free flow of storm waters and to indicate the presence of adjacent
floodplains for the protection of persons and property.

Recommended by staff given that it is redundant because “waterways and primary drainage channels” would be subject to this overlay designation are either covered by the Natural Hazard Area (-G) or Riparian Areas (-R) designations.

Policy Group
page 62
regulatory effect and would therefore not
contribute to the reduction in environmental
impacts. Information notifications or regulatory
requirements relating to waterways and primary
drainage channels are fully addressed in the
Natural Hazard Area (-G) or Riparian Areas (-
R) designations.
21 Table 3-1: General Plan Land Use Designations
• Edits are consistent within those specifies for Table 2-1:

General Plan Land Use Designation Summary on page

19. • The minimum residential density for the Main Street Mixed Use, General Mixed Use , and CommercialGeneral is set to zero (0) because these designations allow mixed uses but do not require residential units as part of a property.

This table is revised to be consistent with the corrections in Table 2-1: General Plan Land Use Designation Summary on page 19, and to reflect the commercial and mixed-use land use designations allow single or mixed uses and do not require residential units with all development, so the minimum density is set to zero (0)
Land Use
Designation
Policy Group
page 64
No effect on Draft EIR determinations. This is
an error in the table in the Public Review Draft
Land Use Element Update, the analysis in the
EIR is not affected by changes in minimum
land use density.
22 Revise Land Use Map Land Use Map No effect on Draft EIR determinations. This is a small, developed parcel that could be
STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 23
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications APN 005-150-94: Revise prior recommended change from
Residential Low-Density to General Mixed Use (current Land Use Designation is Commercial-General)
The parcel contains a home consistent with the recommended land use change and the surrounding parcels to the south and east were recommended to be changed to mixed use and the property owner requested also to be included in the change to mixed use
redeveloped with more intensive mixed uses,
which is consistent with the conclusions of the
Draft EIR that impacts of growth are reduced
through infill development in existing developed
areas.
23 Revise Land Use Map
APNs 005-150-91, 005-150-92, and 005-150-93: Revise prior recommended change from Main Street Mixed Use to General Mixed Use (current Land Use Designation is CommercialGeneral) These parcels are improved with homes or office uses,
consistent with the recommended land use change
Land Use Map No effect on Draft EIR determinations. These are small, developed parcels that could be
redeveloped with more intensive mixed uses,
which is consistent with the conclusions of the
Draft EIR that impacts of growth are reduced
through infill development in existing developed
areas.
24 Revise Land Use Map
Remove the Mill Creek Area from the proposed SOI and City of Willits Land Use Map, approximately 148 acres.

This area consists of 23 APNs, 2 vacant parcels, one less than two acres and the other approximately 40 acres. Improved parcels range from less than two acres to 40 acres and an average of 20 acres with City water service through private laterals that is planned Rural Residential, 5 acres by Mendocino County. Residents of this area requested not to be included in the proposed SOI
Land Use Map No effect on Draft EIR determinations. If
annexed, this area would expand the City and
contains natural resources that proposed
policies and required mitigations are intended
to protect. Land use policies encourage infill
first and expanding the City when the supply of
land is constrained. Removing this area from
the proposed SOI could lessen potential
impacts that are otherwise reduced to less than
significant levels through mitigation.
25 Revise Land Use Map Land Use Map No effect on Draft EIR determinations. If annexed, this area would expand the City and
STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 24
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Land Use Element Update /
Revision and Reason for Revision Location CEQA Implications Remove from the proposed SOI and City of Willits Land Use Map that portion of the East Valley Street Area east of the parcels zoned by Mendocino County for multi-family
development, approximately 17.2 acres, and is a
Disadvantaged Unincorporated Community, according to
LAFCo law.

This area to be excluded consists of eight parcels averaging approximately three acres in size, served by City fire hydrants and most developed parcels have water service, planned and zoned for agricultural use and developed with single family homes, small pastures and barns, industrial buildings, and corporation yards. A property owner requested to be excluded from the proposed SOI and to remove this owner’s property would create an illogical boundary so all parcels east of this property owner are also recommended to be removed from the proposed SOI.
contains prime agricultural soils and some
agricultural uses on small parcels and
proposed policies and required mitigations are
intended to protect agricultural uses as defined
by LAFCo. Land use policies encourage infill
first and expanding the City when the supply of
land is constrained. Removing this area from
the proposed SOI could lessen potential
impacts that are otherwise reduced to less than
significant levels through mitigation.

STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 25

RECOMMENDATION

2. Adopt Resolution adopting the Land Use Element, an Element of the City of Willits General Plan;

5. Direct Community Development Department staff to bring the updated Safety Element forward for adoption by the City Council within six months.

FINDINGS

1. CEQA findings are contained in the attached Findings of Fact and Statement of Overriding Considerations in Attachment C.

2. The Land Use Element Update to the City of Willits General Plan is in the public interest because it furthers social, economic, housing and other goals of the City.

3. The Land Use Element Update will replace the Land Use Element contained in the Willits General Plan, Vision 2020.

4. The adoption of the Land Use Element Update will not cause the General Plan to become internally inconsistent:
a. The proposed changes to the Land Use Map are consistent with the current land uses and compatible with surrounding uses.
b. The Land Use Element Update maintains the current, ultimate build-out population of approximately 7,500 residents, which is an important consistency metric for the Circulation Element and Public Services and Facilities, Parks and Recreation Elements and the Land Use Element Update Policies and Implementation Measures in the Planning Area, Planning for Growth, Willits Character, Vitality, and Sustainability, Downtown, South Main Street, Coordinate with Local Communities, were developed to be consistent with these critical General Plan Elements. c. The Policies and Implementation Measures contained in the Protect Natural Resources Within Areas Planned for Development Policy Group were developed STAFF REPORT: LAND USE ELEMENT UPDATE
PAGE 26
to be consistent with and strengthen the Policies, Implementation Measures, and Mitigation Measures in the Conservation and Open Space Element. d. The Policies and Implementation Measures contained in the General Plan Implementation and Maintenance Policy Group were developed to be consistent with and strengthen the Policies, Implementation Measures contained in the Draft Safety Element.
e. The Land Use Element Update was prepared in consideration with and to further the objectives of related adopted City plans including the Willits Downtown Specific Plan and the Willits Bicycle and Pedestrian Specific Plan, and the Urban Forest Management Plan.

5. The Land Use Element Update will not limit the number of housing units which may be constructed on an annual basis in the City of Willits consistent with the certified City of Willits Housing Element.

ATTACHMENTS
A. City of Willits Land Use Element Update (Adoption Version Incorporating Changes noted in Staff Report)
B. City of Willits Land Use Element Update Final Programmatic Environmental Impact Report which incorporates that Draft Programmatic Environmental Impact Report C. City of Willits Land Use Element Update CEQA Findings of Fact and Statement of Overriding Considerations
D. Resolution certifying the Final Environmental Impact Report Prepared for the Land Use Element and Sphere of Influence, making the Findings of Fact and adopting a Statement of Overriding Considerations and adopting the Mitigation Monitoring and Reporting Program.

E. Resolution adopting the Land Use Element, an Element of the City of Willits General Plan
General Plan Land Use
Element
2 CITY OF WILLITS

LAND USE ELEMENT

CITY OF WILLITS

LAND USE ELEMENT
Final Draft
October 2024
Prepared for
City of Willits
111 E Commercial Street
Willits, California 95490
www.cityofwillits.org
Prepared by
Planwest Partners, Inc.
670 9th Street, Suite 201
Arcata, CA 95521

CITY OF WILLITS

LAND USE ELEMENT
The City of Willits extends gratitude to the members of the community that participated in this important process.

Saprina Rodriguez, Mayor
Gerardo Gonzalez, Vice Mayor
Greta Kanne, Councilmember
Larry Stranske, Councilmember
Madge Strong, Councilmember
Brian Bender, City Manager
Dusty Duley, Community Development Director
Taylor Perry, Senior City Planner
Davey Bowles, Building Official
Amber Ojeda, Office Assistant III
Walter Kolon, Services & Facilities Director
Scott Herman, Utilities Superintendent
Kenan O’Shea, Streets Superintendent
Fabian Lizarraga, Former Police Chief
Susan Mahoney, Willits Chamber of Commerce
Josh Gravier, Sherwood Valley Band of Pomo Indians
Jessica Johnson, RCHDC
Henry Moss, METALfx
Emily Heitman, LEEF Organics
Jay Fraser, Fraser Construction
Linda Givens, Adventist Health Howard Memorial Hospital Alan Falleri, Retired Willits Community Development Director Eric Alvarez, LLFPD Fire Chief
Tony Madrigal, LLFPD Board Chairman
Planwest Partners, Inc
George Williamson AICP, Senior Advisor
Colette Santsche AICP, Principal Planner
John Miller, Project Manager
Krystle Heaney AICP, Senior Planner
Jason Barnes, GIS Analyst
LACO Associates
Michael Nelson AICP, Principal Planner
Becky Clark, AICP Project Manager
Rodney Wilburn, Principal Engineer
Fehr & Peers
Ronald Milam AICP, Principal
J.B Lovelace and Associates
J. Brett Lovelace, Principal Environmental
Scientist

ACKNOWLEDGEMENTS
ii

CITY OF WILLITS

LAND USE ELEMENT
INTRODUCTION ........................................................................................................................ 1 A. PURPOSE AND USE OF THE GENERAL PLAN........................................................................... 1 WHAT IS A LAND USE ELEMENT?............................................................................................................................................ 1 RELATIONSHIP TO ZONING..................................................................................................................................................... 1 B. USING THE LAND USE ELEMENT ............................................................................................ 2 CITY COUNCIL ..................................................................................................................................................................... 2 PLANNING COMMISSION....................................................................................................................................................... 2 CITY DEPARTMENTS ............................................................................................................................................................. 2 C. MAINTAINING THE LAND USE ELEMENT................................................................................ 3 D. COMMUNITY ENGAGEMENT ................................................................................................ 4 A DVISORY C OMMITTEE M EETINGS ......................................................................................................................... 5 ONLINE C OMMUNITY S URVEY .................................................................................................................................. 5 COMMUNITY OPEN HOUSE EVENT ............................................................................................................................... 5 LAND USE ELEMENT UPDATE WEBSITE .................................................................................................................................... 6 CITY COUNCIL MEETINGS ...................................................................................................................................................... 6 E. ANALYSES INFORMING THE LAND USE ELEMENT .................................................................. 7 E XISTING C ONDITIONS ............................................................................................................................................. 7 LAND USE CHANGES AND SPHERE OF INFLUENCE ADDITIONS SCREENING ............................................................... 7 P ROGRAM E NVIRONMENTAL I MPACT R EPORT ................................................................................................... 7 F. RELATED CITY PLANS ............................................................................................................. 8 WILLITS DOWNTOWN SPECIFIC PLAN (2000) ............................................................................................................ 8 WILLITS CIRCULATION AND PARKING IMPROVEMENT S TUDY (2002)...................................................................... 8 BAECHTEL ROAD-RAILROAD AVENUE CORRIDOR COMMUNITY DESIGN STUDY (2003) ............................................................ 8 WILLITS BICYCLE AND PEDESTRIAN SPECIFIC PLAN (2009)...................................................................................... 9 WILLITS MAIN STREET CORRIDOR ENHANCEMENT PLAN (2016)............................................................................. 9 WILLITS DRAFT SAFETY ELEMENT (2019)........................................................................................................................... 9 G. LAND USE ELEMENT OBJECTIVES ........................................................................................ 10 H. THE WILLITS COMMUNITY .................................................................................................. 11 REGIONAL S ETTING ......................................................................................................................................................12 POPULATION ................................................................................................................................................................. 12 WILLITS PLANNING BOUNDARIES .....................................................................................................................................13 H. ORGANIZATION OF THE LAND USE ELEMENT...................................................................... 17 GOALS AND POLICIES .......................................................................................................................................................17 IMPLEMENTATION PROGRAMS .........................................................................................................................................17 LAND USE MAP & DESIGNATIONS........................................................................................... 18 LAND USE DESIGNATIONS ...........................................................................................................................................19 RESIDENTIAL DENSITY......................................................................................................................................................20 NON-RESIDENTIAL BUILDING INTENSITY (FAR) ................................................................................................................20 OVERLAY DESIGNATIONS .................................................................................................................................................20

TABLE OF CONTENTS
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GOALS AND POLICIES .............................................................................................................. 23 P LANNING A REA .....................................................................................................................................................23 P LANNING FOR G ROWTH .....................................................................................................................................27 W ILLITS C HARACTER , V ITALITY , AND S USTAINABILITY .......................................................................31 D OWNTOWN ..............................................................................................................................................................35 S OUTH M AIN S TREET ...........................................................................................................................................40 L AND U SE C OMPATIBILITY AND F LEXIBILITY ............................................................................................42 C OORDINATE WITH L OCAL C OMMUNITIES ..................................................................................................45 PROTECT NATURAL RESOURCES WITHIN AREAS PLANNED FOR DEVELOPMENT ..............................................................49 GENERAL PLAN IMPLEMENTATION AND MAINTENANCE..................................................................................................55 LAND USE DESIGNATIONS ..............................................................................................................................................59 IMPLEMENTATION ACTION PLAN............................................................................................ 66

LIST OF FIGURES AND TABLES
FIGURE 1-1 PLANNING AREA................................................................................................................................ 14 FIGURE 1-2 PROPOSED SPHERE OF INFLUENCE..................................................................................................... 15 FIGURE 1-3 LITTLE LAKE GROUNDWATER BASIN................................................................................................... 16 FIGURE 2-1 LAND USE MAP.................................................................................................................................. 21 FIGURE 2-2 LAND USE MAP - SOI AREAS............................................................................................................... 22 FIGURE 10-1 NATURAL HAZARD AREA (-G) MAP..................................................................................................... 62 FIGURE 10-2 RIPARIAN AREAS (-R) MAP................................................................................................................. 63 TABLE 2-1 GENERAL PLAN LAND USE DESIGNATION SUMMARY TABLE ............................................................... 19 TABLE 10-1 GENERAL PLAN LAND USE DESIGNATIONS.......................................................................................... 64

1 CITY OF WILLITS

LAND USE ELEMENT

INTRODUCTION
A. PURPOSE AND USE OF THE GENERAL PLAN
What is a Land Use Element?
A General Plan is made up of “elements” that cover mandatory topics as well as topics important to the community.

Eight elements are required to be included in the General Plan by the State. These are: land use, circulation, housing, conservation, open space, noise, safety, and environmental justice. Though the required topics must be addressed in the General Plan, communities can organize their General Plan anyway they choose. Typically, a General Plan is designed to address the issues facing the jurisdiction for the next 20 years. The City of Willits’ General Plan was last comprehensively updated and adopted in 1992 and the planning timeframe was identified as 30 years. Since then, the City's land use needs have changed to some degree due to demographic and economic conditions and updates to the Land Use Element are also required to comply with state law.

Relationship to Zoning
The General Plan Land Use Element is not to be confused with zoning. Although both the Land Use Element and the zoning code control how land may be developed, they do so in different ways. The General Plan has a long-term outlook. It identifies the types of land uses that will be allowed and the density and intensity of uses, the spatial relationships among land uses, and the general pattern of future development. Zoning regulates development, consistent with the General Plan, through specific development standards such as lot size, building setbacks, and permitted uses. Land uses shown on the General Plan Map must be reflected on the local zoning maps to assure consistency per State law. Development must not only meet the specific requirements of the zoning code, but also the broader policies set forth in the General Plan. Put simply, the General Plan guides the zoning code, but the zoning code does not guide the General Plan.
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CITY OF WILLITS

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B. USING THE LAND USE ELEMENT
The Land Use Element is used by decision makers and City staff to make recommendations and decisions with direct or indirect land use implications. It also provides a framework for inter-jurisdictional coordination of planning efforts among officials and staff of the City and other Federal, State, and local agencies. City residents, property owners, and businesses use the General Plan for guidance on City policies for particular geographic areas or for particular subjects of interest.

The General Plan, in particular the Land Use Element, is the basis for a variety of regulatory measures and administrative procedures. California planning law requires consistency between the General Plan and its implementing programs, such as zoning and subdivision regulations, capital improvement programs, specific plans, environmental impact procedures, and building and residential codes. The specific roles of the City Council, Planning Commission, and City Departments with respect to the approval and use of the General Plan are described below.

City Council
The City Council is the political body which formulates and implements policies in Willits. It is the City Council, through its decision-making authority, that affirms the policy direction and priorities contained within this
General Plan. The City Council is responsible for adoption of the General Plan, as well as the regulations, capital improvement programs, and financing mechanisms that
implement the General Plan.

Planning Commission
State law provides for the establishment of a planning
agency, typically referred to as a Planning Commission, which is appointed by a city council to review and act on certain matters related to planning and development.

Planning Commissions are responsible for conducting public hearings on matters relating to planning and development, such as amendments to the General Plan and Zoning Code, considering the public input, and taking action on matters within its authority and making recommendations to the City Council. The City of Willits has created a Planning
Commission in its municipal code, but at the time of the adoption of this Land Use Element the City Council has
chosen to carry out all duties of the Planning Commission.

City Departments
All City Departments use the General Plan for policy
guidance as it pertains to their operations, service
delivery, and planning for future capital improvement
projects and potential service level changes. The City’s Community Development Department, responsible for
building permit review, code enforcement, and land
use planning, and Services and Facilities Department,
responsible for roads, utilities, and parks, are the two departments that interact most with the General Plan
and Land Use Element. The Community Development
Department is responsible to ensure that that the
General Plan Land Use Element is implemented on a
day-to-day basis so that appropriate land uses are
proposed in the proper locations, appropriate levels of service are provided, proposed land uses conform to
development regulations, and the environment has
been adequately protected.
3 CITY OF WILLITS

LAND USE ELEMENT
C. MAINTAINING THE LAND USE ELEMENT
Over time, the City’s population will fluctuate, its goals will evolve, and the physical environment in which its residents live and work will change. For the General Plan and Land Use Element to be useful, it must be monitored and periodically revised to respond to and reflect changing conditions and needs over time. State law permits the General Plan to be amended up to four times in any calendar year unless special conditions apply as defined by Government Code Sections 65358(c) and (d). Each amendment may contain more than one change to the General Plan. General Plan Amendments can be initiated by the City or at the request of a property owner. Each General Plan Amendment goes through a public review process, including hearings with the City Council acting as the Planning Commission.

Each Amendment is also subject to review under the California Environmental Quality Act (CEQA).

Housing Safety Land Use
Economic
Development
Conservation &
Noise Open Space
Public Services & Facilities,
Circulation Parks & Recreation
Existing Willits General Plan Elements
4 CITY OF WILLITS

LAND USE ELEMENT
D. COMMUNITY ENGAGEMENT
The Land Use Element was shaped through a robust public engagement program that provided an opportunity for all community members to be involved in the update process. The City gathered community input through the following methods:

1. Advisory Committee Meetings

2. Online Community Survey

3. Community Open House Event

4. Land Use Element Update Website

5. City Council Meetings, Study Sessions, And Public Hearings 5 CITY OF WILLITS

LAND USE ELEMENT
Advisory Committee Meetings
An advisory committee was established to help guide the process of updating the Land Use Element. The advisory committee was made up of technical experts from City departments and partner agencies that provided feedback on the project to ensure the plan concepts could be achieved. The advisory committee met a total of four times during the update process and provided feedback on the public engagement program, possible land use revisions, sphere amendment options, and draft policy.

Online Community Survey
A community survey was released to gather feedback from residents of all ages on key land use and development issues in the City. The web-based survey was available in English and Spanish and was used to provide essential guidance on policy and mapping recommendations.

Community Open House Event
The City hosted a community open house for residents and stakeholders to share their ideas on how to shape the future of Willits. The open house was held at the Willits Community Center and included afternoon and evening sessions.

Members of the public were encouraged to write comments on post-it notes and place them on various posters that displayed maps and land use concepts. Staff and consultants were on hand to answer questions.
6 CITY OF WILLITS

LAND USE ELEMENT
Land Use Element Update Website
To help expand outreach efforts, a dedicated
project website (www.willitslanduseupdate.com)
provided information on the Land Use Element
update process, meeting dates and locations, and
related documents. There people could sign up
for project updates by email, take the online
community survey, submit a property owner
zone change request, and learn more about
Willits land use and zoning.

City Council Meetings
The City held multiple City Council study sessions
throughout the update process to inform decisionmakers and the public, discuss key milestones, and provide policy direction for the Land Use Element.
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LAND USE ELEMENT
E. ANALYSES INFORMING THE LAND USE ELEMENT
As part of the City of Willits Land Use Element update process, the City prepared the following supporting documents:

Existing Conditions
To ensure that the Land Use Element update considered the availability of current and the identified need for additional infrastructure and services, an Existing Conditions Report was prepared by LACO Associates in April 2023. This report provides a comprehensive review of the current water, wastewater, stormwater, recycling, and solid waste services provided by the City of Willits and serves to guide the Land Use Element Update and any potential future City Sphere of Influence (SOI) amendment. Drawing from readily accessible public data, reports, and conversations with City staff, the report establishes a foundation of reliable information for these purposes.

Land Use Changes and Sphere of Influence
Additions Screening
The Advisory Committee devoted considerable time to the evaluation of land use changes within the City and potential areas for the City to consider expanding outside the current boundary. The City Council received a screening level review of land use designation changes and sphere of influence amendments on June 21, 2023. This included proposed changes to the Land Use Map to create opportunities for new residential or mixed-use development, make changes prompted by property owner land use requests, and incorporate land use “clean ups” where the long-established land uses are inconsistent with the Land Use Designation applied in 1992 or earlier.

In addition, the screening included potential additions to the City’s Sphere of Influence to be submitted to the Local Agency Formation Commission (LAFCo) for consideration of approval.

Program Environmental Impact Report
The Program Environmental Impact Report (PEIR) responds to the requirements of the California Environmental Quality Act (CEQA) as set forth in Sections 15126, 15175, and 15176 of the CEQA Guidelines. The City Council will use the PEIR during the Land Use Element update process to consider potential environmental implications associated with implementing the Land Use Element and to identify feasible mitigation measures for significant impacts. The PEIR may also be used in the environmental evaluation of future projects. Future projects may be able to build (or tier) their environmental review on the General Plan Land Use Element PEIR if they are consistent with the Element.

Did You
Know?
The City’s wastewater
collection system
consists of 22 miles of
gravity-fed sewer
mains ranging in
diameter
from 4 to 24 inches,
one (1) lift station,
and 450 manholes.

The WWTP was
constructed in 1975
as a secondary
aeration treatment
plant and has since
gone through several
upgrades. Currently,
the WWTP
utilizes grit removal,
two (2) extended
aeration basins, a
circular clarifier,
ultraviolet (UV)
disinfection, and an
enhanced effluent
polishing in a 30-acre
treatment wetland.
8 CITY OF WILLITS

LAND USE ELEMENT
F. RELATED CITY PLANS
There are a number of documents other than the City of Willits General Plan that bear a relationship to the Land Use Element and were closely considered during its preparation. For the most part these plans were developed to address transportation and mobility issues, economic growth and regional development, and placemaking along the Main Street corridor and the surrounding area. In addition, the City of Willits has prepared a draft Safety Element Update which was developed to reflect the Mendocino County Multi-Jurisdiction Hazard Mitigation Plan and is likely to be adopted prior to or shortly after the Land Use Element Update. A brief description of related City planning documents are as follows:

Willits Downtown Specific Plan (2000)
The Willits Downtown Specific Plan provides an overall strategy for expansion, reuse, and revitalization of Downtown Willits. The plan comprehensively tackles challenges pertaining to downtown Main Street by encompassing vital elements such as parking strategies, placemaking endeavors, and innovative design concepts. Concerning parking strategies, the plan advocates for the enhancement of parking lot signage visibility and explores the prospect of repurposing parking areas situated alongside Main Street. Moreover, the plan underscores the imperative need for public gathering spaces within the downtown Main Street area, identifying them as potential sites for future development. In terms of design innovation, the plan introduces ideas such as bulb-outs and intersection enhancements, gateway improvements, and the refinement of crosswalk infrastructure to further enhance the vibrancy and functionality of Main Street.

Willits Circulation and Parking Improvement Study (2002) The Willits Circulation and Parking Improvement Study focuses on several specific issues concerning Main Street and outlines safety issues south of Highway 20 including pedestrian access near the railroad tracks at the Willits arch and bicycle, pedestrian and vehicular coordination at the Main/Baechtel Road Intersection. The plan suggests a roundabout at Highway 20. North of Highway 20, the study outlines pedestrian safety issues at Main/Mendocino and Main/Valley. The study concluded that occupancy tends to be higher during the week, however there is no demonstrated need for added parking spaces.

Baechtel Road-Railroad Avenue Corridor
Community Design Study (2003)
While this study focused on Baechtel Road, it also described interventions that create a stronger relationship to South Main Street entry points. This project shows how a bicycle and pedestrian trail system connects through Main Street at intersections including Baechtel Road and Commercial Street.

At North Baechtel Road, the plan shows a new crossing at Main Street including a pedestrian crosswalk and planted median. At South Baechtel Road, this plan proposes a
“Gateway to Willits Roundabout,” in order to mitigate
circulation issues at this intersection and provide a gateway for the city.
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LAND USE ELEMENT
Willits Bicycle and Pedestrian Specific Plan (2009)
The Willits Bicycle and Pedestrian Specific Plan offers detailed insights into the conditions prevailing on Main Street. It highlights a significant trend wherein less experienced bicyclists tend to navigate away from Main Street due to its fractured grid and various safety hazards. The plan effectively demonstrates that an overwhelming majority—ranging from 80% to 90%—of incidents involving bicycles and pedestrians in collision with vehicles occur on Main Street. As a remedy, the plan proposes a set of recommendations, notably advocating for the construction of wider 8-foot sidewalks along Main Street, a proposal supported by the reduced necessity for on-street parking.

Willits Main Street Corridor
Enhancement Plan (2016)
The Willits Main Street Corridor Enhancement Plan provides a framework of plan concepts for both short and long-term changes to the Main Street corridor. The plan encompasses motorized and non-motorized safety improvements,
pedestrian and bicycle enhancements, landscaping, and other hardscaping recommendations. Further, the plan prescribes phases in which the recommendations can be implemented, identifies alternatives based upon level of cost, and provides resources for possible funding.

Willits Draft Safety Element (2019)
The City of Willits prepared a draft Safety Element Update in October 2019 to address changes in California planning law and to incorporate the Mendocino County Multi-Jurisdiction Hazard Mitigation Plan into the City’s General Plan. The City anticipates adopting the Safety Element prior to or shortly after the adoption of the Land Use Element Update. The
Safety Element directly relates to the Land Use Element and the City will take care to ensure that proposed land uses are planned in a manner that minimizes the impacts of known hazards and reflects the climate adaptation and resiliency strategies contained in the Local Hazard Mitigation Plan. 10 CITY OF WILLITS

LAND USE ELEMENT
G. LAND USE ELEMENT OBJECTIVES
Following community discussions, which were facilitated through a community survey, an open house event, and advisory committee meetings, the Willits City Council assessed various potential land use policy focus areas for the Land Use Element on May 10, 2023. These policy focus areas were intended to guide the City’s planning to update the General Plan Land Use Element to accommodate desired growth, address community needs, protect natural resources, and meet changes in State law – especially relating to housing – and to update the City’s Sphere of Influence to provide new housing opportunities, streamline the approval process, and accelerate housing development. The policy focus areas contributed to the development of the City’s objectives for the Land Use Element, listed as follows:

1. Plan for a range of potential population growth levels within the City.

2. Facilitate infill development and commercial vitality.

3. Define an expanded Sphere of Influence that includes appropriate areas around the City for potential future residential development to help ensure an adequate City supply of developable land.

4. Ensure adequate public utilities, services, infrastructure, and a street network that supports all users and plan for phased improvements to support existing, and new land planned for residential and commercial development.

5. Plan new and sustain existing parks and recreation facilities for the entire community, especially underserved areas.

6. Facilitate the vitality of Downtown and South Main Street by improving important City gateways and by defining flexible land use regulations to encourage adaptive re-use of existing structures and design standards that improve the streetscape and create a comfortable atmosphere for walking, biking, outdoor seating and gathering.

7. Define a Land Use Map and policy that minimizes the number of non-conforming uses and protects existing communities from incompatible uses, reduces energy consumption, and vehicle miles travelled.

8. Streamline the permitting process and maximize opportunities for housing development to address the local, regional and statewide housing shortage, especially infill development within current city limits.

9. Protect and conserve natural resources and avoid hazards. 11 CITY OF WILLITS

LAND USE ELEMENT
H. THE WILLITS COMMUNITY
Before arrival of the Europeans, the Little Lake Valley was home to a rich history of Native American heritage. Originally inhabited by the Pomo tribe of Native Americans, the Valley was settled in the 1850’s by pioneering ranchers who found prosperity through ranching and timber harvesting. In 1888, as the tanbark industry flourished, the town embraced the name "Willits" in honor of its visionary founder, Hiram Willits. The year 1914 marked a pivotal juncture with the establishment of the Northwestern Railroad, positioning Willits as the strategic midpoint between San Francisco and Eureka. As the 20th century dawned, the town burgeoned from a modest population of 153 in 1880 to an impressive 3,000 by 1970. Throughout this evolution, Main Street witnessed the blossoming of numerous businesses, epitomizing the town's spirit of entrepreneurship. Notably, the Willits Frontier Days celebration, inaugurated in 1927, continues to capture the community's vibrant essence, inviting thousands to partake in the annual 4th of July festivities, complete with a cherished rodeo and parade. With its timeless traditions, Frontier Days stands resolute as "California's Oldest Continuous Rodeo," emblematic of Willits' enduring legacy of unity and celebration. 12 CITY OF WILLITS

LAND USE ELEMENT
Regional Setting
The City of Willits is located in the heart of Mendocino County at the intersection of the county’s main north-south transportation corridor, US Highway 101, and east-west corridor, State Route 20. The City lies within the Little Lake Valley and is known as the Gateway to the Redwoods. The core city boundary area is approximately 2.65-square miles (1,696 acres) in size and has two incorporated islands comprised of city-owned property, including the Ells Field/Willits Municipal Airport (73-acres) located in Brooktrails northwest of the city and the Morris Reservoir/Willits Municipal Water Treatment Plant (34-acres) located southeast of the city. The Morris and Centennial Reservoir and their watersheds comprise approximately 3,136-acres.

Population
The City of Willits has not experienced substantial population or housing growth over the last 20 years. Between Census 2000 and 2010, Willits total population fell by 3.7 percent, resulting in a loss of 185 persons from 5,073 to 4,888. Between 2010 and 2020, City population increased from 4,888 to 4,947, an increase of 59 persons or a total change of

1.2 percent and the average annual growth rate was approximately 0.13 percent, or about six additional persons per year. While the City of Willits population declined between Census 2000 and 2010, the total number of housing units increased by 60 units or a total change of three percent, increasing from 2,013 to 2,073 units. The average annual housing growth rate during this period was 0.29 percent per year. Between 2010 and 2020, housing units within the city increased from 2,073 to 2,147 units, an increase of 74 units or a total change of 3.6 percent. The average annual housing growth rate during this period was 0.35 percent per year. Between 2020 and 2022, an additional ten housing units were added at an annual average rate of 0.23 percent, or a total change of about ½ of a percent. Although past growth in the City and surrounding area has been limited and future projections for Mendocino County indicate a population decline, various emerging local and regional factors indicate a need to identify land that can support a range of housing types in Willits and that can be readily developed. This Land Use Element will continue to plan for a buildout population of approximately 7,500 residents and establish programs that can effectively respond to a range of potential growth rates that could occur during the General Plan planning period.

Planning
for Growth
This Land Use
Element will
continue to plan
for a buildout
population of
approximately
7,500 residents
and establish
programs that
can effectively
respond to a
range of potential
growth rates that
could occur
during the
General Plan
planning period.
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LAND USE ELEMENT
Willits Planning Boundaries
California planning law requires the City to adopt a General Plan for lands within its limits and any land outside of its boundaries which bears relation to its planning.

Defining a Planning Area that includes land outside of its boundaries is a means by which a City can communicate its desires to annex land to the City or its objectives and concerns for the future of surrounding lands under the jurisdiction of the County.  Planning Area. A General Plan, pursuant to State law, must address all areas within the jurisdiction’s Planning Area. The Planning Area (See Figure 1-1) encompasses all incorporated and unincorporated territory that bears a physical relationship to the long-term planning of the city. For Willits, the Planning Area is defined as the area that includes both the city limits and SOI, as well as the watersheds and groundwater recharge areas that are so essential to the City’s water supply (See Figure 1-3, Little Lake Groundwater Basin).
 City Limits. The City has land use authority over all land within its limits, which encompasses approximately 2.82-square miles (1,804-acres), including two island areas away from the main City boundary that include the Ells Field-Willits Municipal Airport and the city water treatment plant adjacent to the Morris Reservoir.  Sphere of Influence. The Mendocino Local Agency Formation Commission (LAFCo) establishes Spheres of Influence (SOI), which are intended to define the probable physical boundary and service area of a local agency. The City’s existing SOI includes approximately twelve acres, as adopted by LAFCo in May 2019. As part of the Land Use Element update, the City intends to update its SOI to the proposed SOI shown on Figure 1-2.
 Areas of Interest. An Area of Interest is a LAFCo policy relating to geographic areas beyond the sphere of influence in which land use or development actions of the County or a special district could impact directly or indirectly upon the City. The City’ proposed Area of Interest includes areas beyond the City’s proposed SOI containing the Little Lake Valley groundwater basin (See Figure 1-3, Little Lake Groundwater Basin) and City watershed, the City’s Airport Influence Area, and other areas where the City provides water service.

Willits City boundary is
about 2.8 square miles
in area in total and
includes Ells Field
Airport near Brooktrails
Township and the
Morris Dam south of
the City.

The City provides
water service outside
the city boundaries to
over 400 homes and
businesses.
14 CITY OF WILLITS

LAND USE ELEMENT
Figure 1-1 Planning Area
15 CITY OF WILLITS

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Figure 1-2 Proposed Sphere of Influence
16 CITY OF WILLITS

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Figure 1-3 Little Lake Groundwater Basin
17 CITY OF WILLITS

LAND USE ELEMENT
H. ORGANIZATION OF THE LAND USE ELEMENT
The Land Use Element provides a framework to guide and shape the future physical development of Willits. The element includes policies establishing land use designations that identify the type and intensity of uses permissible in the Planning Area. This element includes goals and policies identifying the City’s philosophy for future change and development. This element addresses a broad range of topics related to the physical structure and appearance of the City’s built environment and to establish the image and character of the city. This serves as the primary policy guidance for ensuring that new land uses are logically organized and developed in a way that is sustainable and enhances Willits’s unique identity.

Goals and Policies
The Land Use Element contains goals and policies that will guide future decisions within the City. Implementation programs are also identified to ensure that the goals and policies in the General Plan are carried out. The goals and policies in the General Plan are presented in a standard format. • Goal. A goal is a statement that describes, in general terms, a desired future condition or “end” state. Goals describe ideal future conditions for a topic and are intentionally general and broad. • Policy. A policy is a statement that guides a specific course of action for decision-makers to achieve a desired goal.

Implementation Programs
While many policies can be implemented as part of standard City operations, some policies require specific implementation programs to ensure they are carried out. The last section of the element includes a table of implementation programs. While the City intends to pursue the implementation programs included in the Land Use Element, the City will need to evaluate each program in light of City resources. This includes resources such as financial, staffing, and technology. Over the 20+ year planning period, the City Council and staff will need to prioritize various implementation programs based on the resources available, and some implementation programs may not be completed as planned.
18 CITY OF WILLITS

LAND USE ELEMENT

LAND USE MAP & DESIGNATIONS
This section provides an overview of the General Plan Land Use Designations and Land Use Map. The Land Use Element defines the location and extent of future development in Willits and identifies standards for that development. The geographic locations of land uses are presented in the Land Use Map, or Map, which is a part of this Element. The Land Use Element, through the Land Use Map, is focused on the following specific characteristics of the City: the longterm maintenance and preservation of existing development; the revitalization or redevelopment of areas within the City where rehabilitation is necessary and/or desired; and vacant parcels available for new development.

Through the use of policies and Maps, the Land Use Element establishes clear and logical patterns of land use as well as standards for future development. An important feature of this Element is the Land Use Map (see Figure 2-1 and 2-2). This map indicates the location, density, and intensity of development for all land uses Citywide. The goals and policies of the Land Use Element combined with the Land Use Map establish a constitutional framework for future land use planning and decision making in Willits.
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CITY OF WILLITS

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Land Use Designations
The Land Use Element in Goal LU-10 defines the residential, mixed-use, commercial, industrial, and other Land Use Designations of the City of Willits General Plan and the Land Use Map applies the Land Use Designations to achieve the focus characteristics described above.

Table 2-1 identifies each designation with their corresponding density/intensity standards using the following columns:

Designation. This column provides the name of each
designation and the acronym used when referring to
the designation.

Color. To the right of each designation name is the
color that is assigned to this designation on the Land
Use Map (Figure 2-1).

Density (Dwelling Units Per Acre). This column
describes allowable development density or intensity.

Designations allowing residential uses include a
minimum and maximum density, expressed as dwelling
units per acre (du/ac). Residential designations also
include maximum lot coverage.

Intensity Standards (Floor Area Ratio). Nonresidential uses include maximum building intensity standards, expressed as Floor Area Ratio (FAR), which
is defined below. Most non-residential land use
designations also allow residential uses and include
density standards as well.

Table 2 - 1: General Plan Land Use Designation Summary Table Land Use Designation Density Range Floor Area Ratio (FAR) R-S Residential-Suburban 0 – 2 units/acre N/A
R-L Residential-low Density 0 - 15 units/acre N/A
R-M Residential-Medium Density 15 - 30 units/acre N/A
DM-U Main Street Mixed Use 0 - 30 units/acre 3.0
GM-U General Mixed Use 0 - 30 units/acre 2.0
C-G Commercial-General N/A 2.0
M-G Industrial-General N/A 1.0
A-G Agricultural - General 0 – 1 unit/five acres N/A
0-S Open Space - Recreation N/A N/A
P-S Public Service N/A N/A
20 CITY OF WILLITS

LAND USE ELEMENT
Residential Density
Residential development is typically categorized by allowed density ranges (minimum and maximum) measured in dwelling units per acre (du/ac). Residential density is calculated by dividing the number of dwelling units allowed on a site by the gross acreage of the site. Consistent with the housing type and density standards in the Land Use Element, the Zoning Code establishes building height and lot regulations, parking requirements, allowed uses, and other standards.

Accessory Dwelling Units (ADUs) are allowed in addition to densities otherwise permitted, in accordance with State regulations. Density bonuses may be approved for projects with affordable housing and housing for elderly residents with specific amenities designated for residents, provided the design and development standards are in conformance with those specified in the Zoning Code. The City also encourages the development of Missing Middle Housing per California Senate Bill 9, which generally allows any residential lot larger than 2,400 square feet to be divided into two lots if both can meet City standards. In Willits, Missing Middle Housing is compatible within areas appropriately zoned for single family residential uses and located within an Urban Cluster as defined by the U.S. Census.

Non-Residential Building Intensity (FAR)
The intensity of non-residential development, which can be regulated by total building size and lot coverage, is measured by Floor Area Ratio (FAR). FAR means the gross floor area of a building or buildings on a parcel divided by the area of the parcel. The maximum FAR standard limits the overall size of development on a parcel. As an example, a maximum FAR of 0.75 would allow 75,000 square feet of building floor area on a 100,000-square foot lot. The 75,000 square feet could be developed in one building, or more buildings, and include one of more stories. Maximum building size based on FAR can be used in combination with estimates of typical employees per square foot of building area based on industry type to determine the potential future number of employees.

Overlay Designations
Land Use Element Overlay Designations are used, in combination with the primary land use designation, to notify landowners of the presence of important resources or hazards, including streamside and historic areas, and hazards, such as floodways and floodplains. There are five overlay land use designations that may be applied on the Land Use Map:

Natural Hazard Area (-G); Conservation - Floodway (-FW); Historical Resources (-H); Riparian Areas (-R); and Urban Reserve (-UR).

Missing Middle
Missing Middle Housing
refers to housing types that
fall somewhere in between
a single-family home and
mid-rise apartment
buildings such as
townhomes, duplexes,
triplexes, and courtyard
clusters. Missing middle
housing can help localities
increase the availability of
less expensive housing
types and support vibrant,
walkable neighborhoods,
while gently increasing
density. These housing
types are an important
component of a diverse
housing stock that can be
used to expand the
affordability of housing in
neighborhoods dominated
by single-family homes.
21 CITY OF WILLITS

LAND USE ELEMENT
Figure 2-1 Land Use Map
22 CITY OF WILLITS

LAND USE ELEMENT
Figure 2-2 Land Use Map - SOI Areas
23 CITY OF WILLITS

LAND USE ELEMENT
Goals and Policies
Planning Area
California planning law requires Cities to adopt a general plan for lands within its limits and any land outside of its boundaries which bears relation to its planning. Defining a Planning Area that includes land outside of its boundaries is a means by which a City can communicate its desires to annex land to the City or its objectives and concerns for the future of surrounding lands under the jurisdiction of the County.

The City of Willits Planning Area (Figure 3-1) includes lands to which the City provides utility services, such as water service (a substantial number of housing units in the Planning Area receive City water service) and to a lesser degree wastewater service; areas where the City has utility infrastructure, such as the City’s wastewater treatment plant or that its infrastructure is dependent upon, such as the watersheds for the City’s reservoirs or the hazard areas around the City’s airport; and areas where development could have an impact on the City, such as the Little Lake Groundwater Basin that is so essential to the City’s water supply. Within the Planning Area, the City may apply Land Use Designations and pre-zoning and adopt specific policies that relate to the City’s future interest and that could be used to guide County planning but would not apply unless such lands were within the City. 3 24

CITY OF WILLITS

LAND USE ELEMENT
Designating lands as part
of the SOI allows the City
to plan for the eventual
annexation and extension
of services as part of
community growth; and
allows the City to
designate uses
compatible with
adjacent City lands.

State law sets forth procedures under which the City of Willits may apply to the Mendocino Local Agency Formation Commission (LAFCo) to annex land into its City boundary and requires that any annexation area must be within the LAFCo approved Sphere of Influence (SOI). The intention is to encourage orderly growth and development and the protection of agricultural and open space land. An SOI defines the City’s probable physical boundaries and service area as determined by LAFCo. State law also requires that the Land Use Element identify Disadvantaged Unincorporated Communities, which are communities with an annual median household income that is less than 80 percent of the statewide annual household income, which must also be considered when defining SOIs. An analysis of Disadvantaged Unincorporated Communities within the Planning Area has been prepared and is included as an Appendix to this Element.

Designating lands as part of the SOI allows the City to plan for the eventual annexation and extension of services as part of community growth; and allows the City to designate uses compatible with adjacent City lands. The City’s SOI is adopted, as required by State law, by the Mendocino LAFCo. The Sphere of Influence (SOI) shown in Figure 3-1 represents the potential boundaries of the City and its service areas, defines land eligible for annexation to the City in the future, and includes adequate land to accommodate potential future growth.

Within the Planning Area, Areas of Interest may be designated consistent with Mendocino LAFCo policy contained in Resolution No. 2018-19-01. An Area of Interest is a geographic area beyond the sphere of influence in which land use decisions or other governmental actions of the County or a special district, defined as the “Acting Agency,” impact directly or indirectly upon the City, defined as the “Interested Agency”. For example, approval of a housing project developed to city-like densities on septic tanks outside the city limits may result in the city being forced subsequently to extend sewer services to the area to deal with septic failures. The city in such a situation would be the Interested Agency with appropriate reason to request special consideration from the Acting Agency in considering projects adjacent to the city.

An Area of Interest may include areas beyond the City’s SOI that are important to the City and contain characteristics such as entrances to the City along important travel routes, areas where highway related commercial development could impact
business vitality within the City, or areas where the City of Willits provides out of area water or wastewater services. 25 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-1 To ensure logical and appropriate annexations that maintain a compact City boundary as well as surrounding open space, working lands and natural resources and support disadvantaged communities.

LU-1.1 PLANNING AREA
Request that applications for development or changes in organization within the Planning Area boundary received by Mendocino County and the Local Agency Formation Commission be referred to the City for review and comment and encourage the County to implement measures to protect areas within the Planning Area not planned for development, including the City watersheds and groundwater recharge areas.

LU-1.2 SPHERE OF INFLUENCE
Annexations to the City may only be approved when such lands are within the approved Sphere of Influence and the annexation is consistent with the goals and policies of this plan.

LU-1.3 COUNTY GENERAL PLAN LAND USE WITHIN SPHERE OF INFLUENCE Seek agreement with Mendocino County on appropriate interim land use designations and zoning classifications for Sphere of Influence areas, including development standards, that may include the application of an urban reserve designation to ensure that any development prior to annexation is consistent with the City of Willits General Plan and does not prevent attainment of planned densities.

LU-1.4 AREAS OF INTEREST
The City of Willits defines its Area of Interest to be the portions of the Planning Area outside the SOI, where existing land use and future development within Areas of Interest could have a direct impact on health, safety, and welfare of City residents, and the City shall request that responsible agencies, including Mendocino County, the Mendocino Local Agency Formation Commission, and Caltrans give special consideration to the recommendations and comments of the City of Willits.

LU-1.5 DISADVANTAGED UNINCORPORATED COMMUNITIES
Consider Disadvantaged Unincorporated Communities (DUCs) within the City’s SOI during infrastructure and services planning and, as appropriate, ensure that identified DUCs are included in annexation proposals.
26 CITY OF WILLITS

LAND USE ELEMENT
LU-1.6 NEW FREEWAY COMMERCIAL USES WITHIN THE PLANNING AREA The City of Willits does not support the development of highway-oriented commercial development outside City limits near the north and south Willits/U.S. 101 interchanges or other development which would impact the health of the business community within the City.

Implementation Measures
LU-1A NOTIFY AGENCIES OF PLANNING AREA BOUNDARY.

Provide copies of the City of Willits Planning Area showing City Land Use Designations to the Mendocino County Planning and Building Services and Transportation Departments, the Mendocino County Local Agency Formation Commission, and Caltrans, and request that proposals to intensify land uses, such as general plan and zoning amendments or subdivisions and roadway improvements or water service extensions that would expand capacity or that could affect the Planning Area’s resources be referred to the City of Willits for review and communicate the City’s position on these matters to the applicable decision-making body.

LU-1B SEEK APPROVAL OF AN EXPANDED SPHERE OF INFLUENCE.

Submit an application to the Mendocino Local Agency Formation Commission to expand the City of Willits Sphere of Influence to add some or all of the areas shown in Figure 3-1, as determined by the City Council, consistent with Mendocino Local Agency Formation Commission policy and State law. Seek approval to add possible Areas of Interest for Mendocino Local Agency Formation Commission designation so that notice is provided of other governmental actions that may impact the City of Willits. 27 CITY OF WILLITS

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Planning for Growth
The City of Willits population is estimated by the California Department of Finance (DOF) to be 4,830 in 2024 and has not changed appreciably since the adoption of the prior City of Willits General Plan, Vision 2020, in 1992 (the population of Willits was 5,027 in 1990 based on the U.S. Census). Although the City population was generally stable between 1990 and 2024, over 200 new units were added to the City housing stock.

In 1992, the prior General Plan, City of Willits Vision 2020, projected a future City population of 7,500 residents based on countywide growth rates at that time. City infrastructure, most notably the wastewater treatment system, and planning for the City’s street network were based on this population projection. The City and the local business community have identified that the lack of available housing is directly related to lack of population growth. The business community has indicated a need to hire more workers and feel that the lack of new housing is the primary issue limiting recruitment efforts.

The high Mendocino County growth rates that were anticipated in the 1990’s and early 2000’s did not occur. Between 1990 and 2020, the total county-wide population grew by about seven percent, rather than the projected 50 percent.

The DOF estimates that the population of Mendocino County has been declining over the last few years and projects further decline for the next five or so years and then slow growth back to approximately the County’s 2020 population level over the next 20 to 30 years.
28 CITY OF WILLITS

LAND USE ELEMENT
The City’s intent is to
plan this additional
land for residential,
industrial, and public
facility development,
increasing the
available supply of
residential lands in
particular, to increase
the likelihood that
interested developers
can find willing
landowners to build
housing units to
accommodate
growth.

State population growth projections rely on trends and relationships observed in the past (previous population + births - deaths + net migration) and may not accurately project the future population of the county when future events do not follow past trends. The current regional and statewide demographic factors suggest that the future population growth rate for the City may be very low or zero. However, future demographic factors, such as global climate conditions and losses and recovery from disaster, such as from wildfire, or the COVID19 global pandemic, may contribute to increased rates of in-migration.

These factors suggest that using the past conservative buildout population projection, 7,500 persons, may be prudent for the current General Plan planning period.

As a result, the City is seeking to create a supply of land that is responsive to the levels of demand that may occur during the planning period. The City is adding a mixed-use land use designation to accommodate demand for housing and commercial development and to accommodate growth in areas served by existing infrastructure and services. Because City General Plan Land Use Designations alone cannot determine the preferences of individual property owners or their desired timing to develop their land, the City is proposing to expand its Sphere of Influence to plan additional land for potential future annexation. The City’s intent is to plan this additional land for residential, industrial, and public facility development, increasing the available supply of residential lands in particular to increase the likelihood that interested developers can find willing landowners to build housing units to accommodate growth. The General Plan includes programs to limit the potential for leapfrog development and to ensure that growth occurs in a logical manner.
29 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-2 To promote growth within infill and redevelopment sites near neighborhood commercial areas.

LU-2.1 PLANNED GROWTH
Continue to plan for a buildout population of approximately 7,500 residents and establish programs that can effectively respond to a range of potential growth rates that could occur during the General Plan planning period. (Source: Existing Policy 1.210, modified) LU-2.2 INFILL DEVELOPMENT
Land within areas of the City served by utilities, transportation infrastructure, and municipal services represent the best opportunity to support affordable housing and employment development, and to reduce greenhouse emissions. Encourage incremental development of vacant and underutilized infill areas that are appropriately scaled and enhance existing neighborhoods within the City. (Source: Existing Policy 1.230, modified) LU-2.3 LAND USE CHANGES
During the consideration of proposals for changes in land use, priority shall be given to projects that result in the greatest public benefit, which may include opportunities for employment growth, providing for the community’s housing needs, or addressing unmet needs for parks and recreation facilities. (Source: Existing Policy 1.260, modified)
LU-2.4 ANNEXATIONS
Monitor the supply of land within the City that is planned for residential, commercial, industrial, and public service uses and, as appropriate, encourage annexations of land adjacent to the City that support the preservation of open space lands, promote orderly development in a manner consistent with the General Plan and contribute to the City’s fiscal stability, and that create a logical City boundary; result in the efficient use of City services and utilities; and support a transportation network that, in combination with an appropriate mix of land uses, minimizes vehicle trips by promoting walking, bicycling, and transit. (Source: Existing Policy 1.240, modified) LU-2.5 ANNEXATION PLANNING
Discourage urban development within the City’s Sphere of Influence until such lands are annexed by the City and support County land use regulations that protect the viability of local agriculture in the Little Lake Valley. When considering proposals for annexation, protect designated open space. 30 CITY OF WILLITS

LAND USE ELEMENT
Implementation Measures
LU-2A POPULATION AND GROWTH.

As part of the annual General Plan progress report, provide the City Council with a report on the estimated City population in comparison to the buildout population contained in this General Plan using data such as City estimates based on approved permits, the Department of Finance annual population estimates, the Census Bureau decennial census counts and American Community Survey estimates. Where the Director of Community Development determines that actual rates of growth could result in a total City population level that exceeds that included in this General Plan during the planning period, the City Council shall be informed of the need to update the Land Use Element.

LU-2B RESIDENTIAL LAND SUPPLY.

Maintain an inventory of vacant and underutilized land planned and zoned for residential use within the City and apply priority weighting based on the proximity of the land to utilities, services, schools, streets, and transit, and relative ease of development (topography and constraints relating to hazards and natural resources). For higher priority infill lands, periodically reach out to landowners and seek their:
(1) level of interest in development,
(2) concerns regarding development; and
(3) potential constraints affecting development or landowner needs to proceed with development.

As needed, during the annual General Plan progress report, provide the City Council with a report on the inventory of vacant and underutilized land planned and zoned for residential use and the potential need for changes to General Plan policy or Zoning standards, annexations, or other City programs that may be needed to facilitate development consistent with the General Plan.
31 CITY OF WILLITS

LAND USE ELEMENT
Willits Character, Vitality, and Sustainability
The City of Willits is located at the intersection of U.S. 101, State Route 20, the Great Redwood Trail Agency right of way (formerly the North Coast Railroad Authority), and the Mendocino Railway or Skunk Train. City residents and businesses rely on these transportation routes for employment and commerce, and many current and future travelers along these routes stop in Willits, the “Gateway to the Redwoods,” to visit or for an overnight stay. Gateway monuments and signage can reflect the history of Willits and inform travelers that they have arrived at an important place that is valued by its residents; welcome and encourage travelers to visit notable locations or commercial areas; and can identify and acknowledge connectivity to the larger City street and trail network. The Willits Main Street Corridor Enhancement Plan contains strategies for gateway improvements to welcome travelers from the north and south that are closely coordinated with other relevant City planning documents.

To foster a healthier community, the City has placed a strong emphasis on providing accessible parks and top-notch
recreational facilities and services. These Willits parks cater not only to city residents but also extend their benefits to the neighboring areas, underscoring the City's aspiration to amplify its influence as a provider of regional park services.

Furthermore, as a part of its endeavors, the City is actively engaged in the development of a segment of the Great
Redwood Trail, a project that assumes vital significance as a pivotal north-south route for pedestrians and cyclists, seamlessly threading its way through the City. The City’s General Plan has always prioritized public health and energy conservation by encouraging infill development within the City and employing policy and programs to reduce singleoccupancy vehicle trips. The City seeks to enhance the connection between public health, land use planning, and community development by expanding access to public
gathering areas, encouraging local production of and access to healthy foods.
32 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-3 To achieve a community design that promotes neighborhood vitality, health, energy efficiency, and conservation.

LU-3.1 COMPLETE STREETS
Consistent with Circulation Element Policies 2.230 and 2.260 that seek to enhance the street network for walking and biking and reduce single occupancy vehicle trips, the design, construction, reconstruction, repair and maintenance efforts on the City’s streets, bridges, pathways, and sidewalks, shall create a comprehensive, integrated transportation network that is safe, accessible, comfortable Complete streets accommodate and welcome users of all ages, races, ethnicities, incomes, and physical abilities, and all modes of transportation, particularly those walking, biking, and using transit. The City shall apply a Complete Streets framework in all applicable and feasible transportation projects to allow the safe, comfortable, convenient and accessible use of streets for all street users.

LU-3.2 CITY GATEWAYS AND CORRIDORS
Highway 101, State Route 20, and County streets serve as important gateways and welcome travelers to the City and its downtown. Designate, construct, and maintain well-designed and landscaped City Gateways as identified in the Willits Main Street Corridor Enhancement Plan.

The City should partner with businesses and the residents in the gateway neighborhoods and Caltrans and the County to establish attractive and welcoming entries to the City that encourage visitors to Willits, support the neighborhoods in which they are located, and can be efficiently and practically maintained. (Source: Existing Policy 1.250, modified) LU-3.3 MIXED USE AREAS
Encourage development that creates vibrant and walkable areas, reduces greenhouse gas emissions, and promotes economic development within downtown and neighborhood areas by implementing mixed use land use designations that support a range of commercial, office and residential uses; enable the flexible use of existing structures and vacant land; and ensure compatibility with adjacent land uses, particularly residential uses, through site, landscape, and building design features.

LU-3.4 IMPROVE NORTH-SOUTH CONNECTIVITY
Encourage the establishment of new north-south transportation connections between central and southern Willits, such as the conceptual Baechtel Road – Railroad avenue corridor. New north-south transportation corridors should be planned to support all modes of transportation, enhance City utilities and infrastructure, improve emergency evacuation, and accommodate future residential, commercial, and industrial development. 33 CITY OF WILLITS

LAND USE ELEMENT
LU-3.5 SPECIFIC PLANNING
Consider using specific plans, as defined in California Planning and Land Use Law, as a tool in implementing the objectives of the General Plan and to refine the City’s vision for specific areas, as well as to serve as a policy and regulatory document that may either provide greater flexibility in development or enforce stricter regulations, and for providing certainty to property owners and the residents of the City.

LU-3.6 PROMOTE A HEALTHY COMMUNITY
Ensure that all residents have access to spaces, events, and programs that support physical activity, and encourage businesses and service providers to create a healthy food system, including local organic food production and community gardens, which supports all residents.

LU-3.7 CONSIDER PUBLIC HEALTH IN LAND USE
When reviewing proposals for changes in land use and development, public health, welfare, and safety must be considered.

LU-3.8 FARMERS MARKET
Support the expansion of the Willits Farmers Market and facilitate its location at Bud Snider Park or other appropriate locations in close proximity to downtown and neighborhood areas.

LU-3.9 ENERGY CONSERVATION AND REDUCTION
Encourage the installation of renewable energy systems and community-wide reductions in energy consumption.

LU-3.10 PLAN FOR CLIMATE CHANGE
Plan for the public health implications of climate change, including potential disease and temperature effects, and work with state and county public health agencies to identify necessary programs to reduce, adapt to, and increase resiliency to potential impacts and implement programs to achieve City-wide reductions in greenhouse gas emissions consistent with state targets.

LU-3.11 GREENHOUSE GAS EMISSION REDUCTIONS
Evaluate new larger-scale residential, commercial, and industrial projects for compliance with state regulations and require feasible mitigation measures to reduce greenhouse gas (GHG) emissions.

LU-3.12 PARKS AND RECREATION
Consistent with the Public Services and Facilities, Parks and Recreation Element Policies 6.230 and 6.350, equitably expand opportunities for trails, parks, and recreational facilities throughout Willits and support the role of the City of Willits as a regional parks provider and consider evaluating the feasibility of establishing a recreation and parks district that extends beyond City boundaries to finance facilities that support the region that may be provided by the City. 34 CITY OF WILLITS

LAND USE ELEMENT
Implementation Measures
LU-3A WILLITS GATEWAY ENHANCEMENT PROGRAM.

Review and revise the gateway strategies identified in the Willits Main Street Corridor Enhancement Plan and seek grant funding and local public-private partnerships to implement a comprehensive program of gateways to celebrate Willits history and character, welcome visitors, and highlight local businesses and attractions.

LU-3B ENERGY CONSERVATION AND GREENHOUSE GAS REDUCTIONS.

Modify the Zoning, Subdivision, and Building regulations and other land use policy to implement:
• An assessment of GHG emissions for large scale discretionary residential, commercial and industrial projects, and require feasible mitigation; • A GHG Emissions threshold of significance for discretionary projects for use in future GHG emissions analyses;
• Programs to facilitate the installation of renewable energy systems, such as solar arrays, and the development of battery storage and micro grid capacity for storing renewable power through amendments to the Zoning Regulations; and • A city-wide program such as a greenhouse gas reduction plan that will meet the State’s 2030 objective of 40 percent below 1990 emissions levels and 2045 goal of carbon neutrality.

LU-3C PARK ENHANCEMENT.

Prepare and implement a public spaces, parks, and recreation strategic plan that:
• Addresses gaps in the geographic distribution of pocket, neighborhood, in community parks in the City, especially within disadvantaged communities; • Identifies and implements needed public gathering areas within the downtown area and commercial areas;
• Includes master planning for important park properties; • Defines and sets forth a program to implement a complete, convenient, and safe network of walking and biking pathways throughout the City; and • Incorporates a funding strategy that may include approaches for public-private partnerships; priorities and linkages for state and federal grants; City development and use fees; and the creation of a regional district with an ongoing revenue source that includes all users who benefit from City parks.
35 CITY OF WILLITS

LAND USE ELEMENT
Downtown
The Willits Downtown area is shown in Figure 3-2 and centers around Main Street, the City’s primary north-south arterial, and is the historic focal point of the City. Main Street is a traditional mixed-use area located within Downtown Willits and contains two distinct design character areas: the commercial area between Commercial Street and California Street that is defined by single and multi-story shop-front buildings, the most prominent of which is the Van Hotel; and the area between California and Oak Streets that contains single-family homes and businesses in former residential structures. The close proximity of employment, services, and residences within the Downtown area, in particular to the Main Street corridor, reduces the need to travel by car and can serve the needs of the economy, community, public health, and the environment by transit, foot, or by bike.

The City has undertaken a number of planning efforts relating to the Downtown area including the Willits Downtown Specific Plan, Downtown Willits Streets and Alleys Connectivity Study, Willits Circulation and Parking Improvement Study, Willits Main Street Corridor Enhancement Plan, and Willits Bicycle and Pedestrian Specific Plan. Each of these plans contributes to identifying benefits, needs, and strategies upon which to revitalize and renew a vital city downtown. The Land Use Element identifies the need for a Main Street Land Use Designation to be applied within a portion of Downtown, that incorporates elements of each of these planning efforts and adds policies that will build flexibility in the Zoning standards to allow the adaptive reuse and revitalization of existing buildings and encourage creative Main Street redevelopment.

Effective management of vehicle parking remains a significant consideration within Willits' Downtown area, mirroring its importance in numerous commercial districts. The architectural layout of traditional downtowns, characterized by shopfront buildings, was purposefully designed to allure and engage pedestrians, inviting them to explore each store as they stroll by. The need for each business to satisfy its off-street parking requirements makes the adaptive reuse and revitalization of existing commercial structures challenging. With the objective of activating and energizing the Willits Main Street area, the Land Use Element seeks to reduce or eliminate the requirement to satisfy peak parking demand onsite and replace it with a park-once program that incorporates provisions for best utilizing available on-street space for parking, strategically allocates space in City-owned lots, encourages the shared use of existing private lots, and provides for ongoing monitoring and management to balance the interests of all users. 36 CITY OF WILLITS

LAND USE ELEMENT
Figure 3-2 Willits Focus Areas
37 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-4 To activate Main Street as the vibrant commercial and cultural core of the City.

LU-4.1 CITY OF WILLITS MAIN STREET
Maintain the traditional downtown core of the City of Willits that is located along Main Street between Commercial and Oak Street as a place for employment, goods and services, gathering, and community events.

LU-4.2 MAIN STREET MIXED USE LAND USE DESIGNATION
Apply the Main Street Mixed Use Land Use Designation to property that generally fronts along the Main Street core between Commercial Street and Oak Street and allow for a range of commercial, office and residential uses; enable the flexible use of existing commercial structures; encourage building design, sidewalk, plaza area, and street designs to slow traffic to provide a comfortable atmosphere for walking, biking, outdoor seating and gathering.

LU-4.3 ADAPTIVE REUSE OF COMMERCIAL STRUCTURES
Enable the adaptive reuse and revitalization of existing commercial structures on Main Street by establishing flexible and appropriate lot standards, including reducing or eliminating on-site parking requirements.

LU-4.4 OFF-STREET PARKING
Consider implementing a “park once” program for Downtown, that includes provisions within the Main Street Mixed-Use area to reduce or eliminate parking mandates to lessen regulatory barriers to the reuse and revitalization of downtown buildings, and that implements the recommendations of the Downtown Specific Plan and the Willits Circulation and Parking Improvement Plan and provides for ongoing monitoring and management to balance the interests of all users.
38 CITY OF WILLITS

LAND USE ELEMENT
LU-4.5 DOWNTOWN GATHERING AND STREET ACTIVITIES
Implement the recommendation of the Downtown Specific Plan relating to public spaces and identify appropriate sites for downtown plaza areas and gathering spaces that enable street fairs and other outdoor activities within the downtown and consider encouraging seasonal markets and festivals to locate in a central downtown area or on a side street and implement a feasible program to establish such areas.

LU-4.6 SLOWING TRAFFIC
Continue to evaluate modifications to Main Street design to slow traffic and provide a comfortable atmosphere for outdoor seating and gathering, walking, and biking, while considering the needs for parking.

LU-4.7 MAIN STREET SHOP FRONTS
Protect and enhance the commercial frontages along Main Street between Commercial Street and Oak Street and encourage mixed-uses where commercial uses are typically located along the sidewalk and create a comfortable environment for shopping, gathering, and walking.

LU-4.8 FORMULA-BASED BUSINESSES
In order to maintain the character of the Willits Downtown and a business environment which is intended to support locally owned and managed businesses, prepare and implement zoning regulations to restrict the location of large franchise, or formulabased, businesses within Downtown, as shown on Figure 3-2 Willits Focus Area. 39 CITY OF WILLITS

LAND USE ELEMENT
Implementation Measures
LU-4A MAIN STREET MIXED-USE ZONE.

Prepare and implement a Main Street Mixed-Use Zone that includes:
• A range of allowable uses, including commercial, office, service, and residential; • Review, update, and implement as appropriate the Willits Downtown Design Guidelines, for the Main Street Mixed Use Zone, which generally include requirements for commercial uses along building frontages that allow residential and commercial uses behind and above within the area north of California Street and allow residential uses on the ground floors between California and Oak Streets;
• Simple and clear design standards for ministerial projects that can be implemented using a checklist format; and,
• A “park once” parking monitoring and management program for vehicles that reduces or eliminates on-street parking requirements and encourages gathering, walking, and biking, and may include sidewalk and streetscape improvements; incentives for the shared use of existing private off-street parking areas; maximizing the efficiency of on-street parking; improved signage and parking information; the evaluation of a shuttle system, parking permits, restrictions, and pricing; and planning for new public parking lots.

LU-4B DOWNTOWN ACTION PROGRAM.

Implement a program that prioritizes actions and recommendations from prior City of Willits planning documents for the Downtown Area, identifies and secures needed funding, and develops a schedule for implementation, and includes:
• Identifying and forming an ad-hoc Downtown working group including City staff, business and property owners, and the Willits Chamber of Commerce. • Reviewing identified actions and recommendations that have not been fully implemented from prior City of Willits planning documents for the Downtown Area and adjacent areas, including:
• Refining and prioritizing identified actions and recommendations. • Identifying the likely cost of actions, if any, and the most feasible funding sources, including local and regional private sources, public-private partnerships, regional/state/federal grant programs.
• Preparing a schedule for implementation that includes timing, responsibility, and necessary steps.
- Willits Downtown Design Guidelines
- Willits Bicycle & Pedestrian Specific Plan
- Willits Downtown Streets & Alleys Connectivity Study
- Willits Main Street Corridor Enhancement Plan
- Downtown Specific Plan
- Willits Circulation & Parking Improvement Plan
40 CITY OF WILLITS

LAND USE ELEMENT
South Main Street
The South Main Street area (Figure 3-2) between South Street and Muir Mill Road serves as the City’s southern gateway, contains important businesses and residential areas, and represents substantial infill development and employment potential. South Main Street buildings have been erected around a state highway, CA-Hwy 20. This region could be strengthened by improving the connectivity between businesses and the surrounding residential areas and by evaluating and implementing a range of design options for the street and streetscape for South Main Street to improve visual quality and to ensure the comfort, safety, and experience of people walking and biking to shops and services.
41 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-5 To maintain South Main Street as the City’s southern gateway and important employment center for the City.

LU-5.1 FOCUSED SOUTH MAIN STREET PLANNING
Consider conducting focused planning for the South Main Street area, in partnership with businesses, property owners, Caltrans and other appropriate organizations, to identify programs to facilitate ongoing commercial vitality and as a means of implementing desired improvements and Land Use policy specific to this area.

LU-5.2 SOUTH MAIN STREET IMPROVEMENTS
In cooperation with property owners and Caltrans, develop and implement street design standards, including lane configuration, coordinated landscaping, signage, street lighting, benches, wider sidewalks, safe crossings, and bike lanes, to enhance and beautify the streetscape and building frontages to support businesses and to provide a safer, and more enjoyable atmosphere for shopping, walking, biking, outdoor seating and gathering, consistent with any City Complete Streets policies.

Implementation
LU-5A SOUTH MAIN STREET STRATEGIC PLAN.

In close cooperation with South Main Street businesses, property owners, neighborhoods, and Caltrans, prepare a South Main Street Strategic Plan that is sensitive to the varying contexts that exist along the street (such as heavy commercial areas, shopping centers, visitor serving uses, and residential neighborhoods), and serves as an ongoing, cooperative, and inclusive planning strategy.

Form an ad-hoc working group to develop a South Main Street Strategic Plan that addresses in particular:
• Complete streets planning and network connectivity.
• Convenient access to businesses and homes.
• City gateway planning and improvements.
• Signage and streetscape improvements.
42 CITY OF WILLITS

LAND USE ELEMENT
Land Use Compatibility and Flexibility
Residential and commercial development, especially in older portions of Willits, has occurred over time, and in many instances was constructed before the adoption of City Zoning Regulations resulting in non-conforming structures and uses that are part of the neighborhood fabric. Community input has highlighted the need to include flexibility in the Zoning Regulations to allow long-standing uses to continue, allow for the establishment of needed nearby limited neighborhood commercial uses within residential areas as well as the need to incorporate standards to protect vulnerable uses from excessive noise and other nuisances, while protecting businesses from the encroachment of sensitive uses that could limit their potential growth. 43 CITY OF WILLITS

LAND USE ELEMENT
GOAL LU-6 To provide for compatibility between uses and greater zoning flexibility to respond to changing conditions and opportunities.

LU-6.1 LIMIT INCOMPATIBLE AND CONFLICTING USES
Minimize potential land use conflicts by applying appropriate land use designations and implementing appropriate development standards and buffers through modifications to the Zoning Regulations to limit adverse impacts from future development on surrounding properties. (Source: Existing Policy 1.220, modified)
LU-6.2 COMPATIBLE DEVELOPMENT
On lands designated for industrial or commercial uses, buildings and accessory structures should be sited and designed to limit potential conflicts with adjacent residential land uses. (Source:

Existing Policy 1.280, modified)
LU-6.3 PROTECT LONG-STANDING COMPATIBLE USES IN OLDER NEIGHBORHOODS To minimize the number of non-conforming uses and to protect the ability of owners of integral long-standing uses in older neighborhoods to finance improvements or the sale of property using conventional financing, apply appropriate Land Use Designations and Zoning Classifications and provide additional flexibility to the range of allowable uses.

LU-6.4 INTERIM AGRICULTURAL USES
Encourage agricultural activities on lands designated for industrial use as well as other large vacant properties until such time as the lands are utilized for their intended purposes. (Source:

Existing Policy 1.290, modified)
LU-6.5 MISSING MIDDLE HOUSING
Facilitate new “Missing Middle Housing” construction, defined as a mix of housing types including duplexes, triplexes, and fourplexes, in a manner consistent with Senate Bill 9 within areas appropriately zoned for single family residential uses and located within an Urban Cluster as defined by the U.S. Census.
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LAND USE ELEMENT
LU-6.6 ZONING FLEXIBILITY
Provide greater flexibility in the range of permitted and conditionally permitted uses in commercial and residential areas to allow residences on upper floors and behind shop fronts or consider establishing limited neighborhood commercial combining zone that may be applied to residential zones and includes a specific range of allowable uses, clear performance standards, and a variety of permitting pathways to allow needed commercial uses in close proximity within residential areas.

LU-6.7 SUPPORT HOME-BASED BUSINESSES
Review and update standards for home-based businesses, or home occupations to allow greater flexibility where such uses are compatible. Allow home-based businesses as principally permitted uses where all performance standards specified in the Zoning Regulations are met and a business license is secured. Allow for an increase in the scale and range of allowable home-based business types in residential zones where potential nuisances are addressed through the permit approval process.

Implementation Measures
LU-6A ZONING REGULATIONS.

Update the Zoning Regulations to:
• Add performance standards for industrial and heavy commercial development adjacent to residential areas to provide buffers, landscaping, and screening that minimize noise, light, glare, and other impacts;
• Increase the range of allowable uses and the incorporation of performance standards to limit potential impacts; and
• Update the standards for home-based businesses to increase the range of allowable home-based business types in residential zones where potential nuisances are addressed through the permit approval process.
45 CITY OF WILLITS

LAND USE ELEMENT
Coordinate with Local Communities
The ongoing relationship between the City of Willits, the County, and its neighbors, in particular the Sherwood Valley Rancheria and the Brooktrails Township Community Services District, is important for long range land use and service planning. The three entities share utility systems, transportation networks, and recreation facilities, and rely on the health of Willits’ businesses and services. Ongoing partnerships should seek to leverage resources to achieve the broadest outcomes. The City also recognizes Tribal Sovereignty and takes seriously its obligation to carry out meaningful Tribal consultation to identify and protect tribal cultural resources.
46 CITY OF WILLITS

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GOAL LU-7 To establish enduring partnerships and consider the needs of all communities in City decision making.

LU-7.1 SHERWOOD VALLEY RANCHERIA
The Sherwood Valley Band of Pomo Indians is a valuable partner and important neighbor to the City of Willits. Regularly coordinate with representatives of the Sherwood Valley Rancheria on land use, municipal, infrastructure, and services planning and seek partnerships, where appropriate, to achieve mutually beneficial outcomes on projects that promote the welfare of the City and the Sherwood Valley Rancheria.

LU-7.2 TRIBAL CONSULTATION
Coordinate with local Native American tribes in City land use and service planning and ensure that consultation occurs during discretionary project review for the identification, protection, and mitigation of adverse impacts to significant cultural resources.

LU-7.3 BROOKTRAILS TOWNSHIP COMMUNITY SERVICES DISTRICT The City of Willits and the Brooktrails Township Community Services District (CSD) partner to provide wastewater services, and City businesses, streets, and other services support Brooktrails Township residents. The City should continue to coordinate closely with the Brooktrails Township CSD on infrastructure and services planning and work together on mutually beneficial projects such as regional trails and parks and recreation.

LU-7.4 ENVIRONMENTAL JUSTICE
Consider environmental justice issues as they relate to potential health impacts of land use decisions on residents of all ages, cultures, ethnicities, genders, races, socioeconomic statuses, and geographic locations.

LU-7.5 NEIGHBORHOOD INVOLVEMENT IN DECISION-MAKING
The City shall provide for the fair treatment and meaningful involvement in land use decisions and policies for people of all incomes, genders, ages, races, colors, and national origins and shall evaluate and avoid, reduce, or mitigate disproportionate adverse health and safety impacts of land use decisions on disadvantaged communities. 47 CITY OF WILLITS

LAND USE ELEMENT
Implementation Measures
LU-7A TRIBAL CONSULTATION.

Consistent with State law, Native American Tribes shall be consulted during amendments to the General Plan and CEQA review for the identification, protection and mitigation of adverse impacts to significant cultural resources, including living cultural resources. Consultation on ministerial permits shall be initiated if it has been determined the project may create a substantial adverse change to a significant cultural resource.

LU-7B TRIBAL CULTURAL RESOURCES AVOIDANCE
When feasible, development facilitated by the project shall be designed to avoid known tribal cultural resources. Known tribal cultural resources within 60 feet of planned construction activities shall be protected by establishing an Environmentally Sensitive Area (ESA) that would be fenced, or otherwise protected, to ensure avoidance. The feasibility of avoidance of tribal cultural resources shall be determined by the City of Willits and applicants in consultation with local California Native American tribe(s).

LU-7C INADVERTENT ENCOUNTER WITH TRIBAL CULTURAL RESOURCES If previously unidentified tribal cultural resources are encountered during project implementation, altering the materials and their stratigraphic context shall be avoided and work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

LU-7D INADVERTENT ENCOUNTER WITH ARCHAEOLOGICAL OR CULTURAL

RESOURCES
In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or uncovered 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 suggested mitigation proposed 48 CITY OF WILLITS

LAND USE ELEMENT
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.

LU-7E INADVERTENT DISCOVERY OF PALEONTOLOGICAL RESOURCES If fossils are encountered during construction (i.e., bones, teeth, or unusually abundant and wellpreserved invertebrates or plants), the City and its contractor shall divert construction activities away from the discovery within 50 feet of the find, and a professional paleontologist shall be contracted to document the discovery as needed, to evaluate the potential resource, and to assess the nature and importance of the find. Based on the scientific value or uniqueness of the find, the paleontologist may record the find and allow work to continue, or recommend salvage and recovery of the material, if it is determined that the find cannot be avoided. The paleontologist shall make recommendations for any necessary treatment that is consistent with currently accepted scientific practices. Any fossils collected from the area shall then be deposited in an accredited and permanent scientific institution where they would be properly curated and preserved.
49 CITY OF WILLITS

LAND USE ELEMENT
Protect Natural Resources Within Areas Planned
for Development
The City’s oak trees and urban forests, streams, riparian areas, and wetlands are important to the City, and provide for a healthy and attractive environment, as well as valuable habitat and ecological function. These natural areas are interspersed throughout the developed and undeveloped portions of the City and require additional protection to ensure that the design of new development sustains these resources.

The General Plan includes overlay land use designations and general policies to protect natural resources in the review of proposed development projects by identifying and mitigating potential adverse impacts prior to project approval to assure no net loss of wetlands and their associated habitats. However, the City seeks to streamline future development by establishing objective standards that will assure resource protection and disclose the presence of habitat constraints to property owners. To support the Conservation and Open Space Element, the Land Use Element includes definitive General Plan policies and programs that seek to demonstrate that future ministerial projects within the City and annexations will not result in significant environmental impacts.
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GOAL LU-8 To ensure that land use decisions protect and sustain important natural resources and limit exposure to hazards.

LU-8.1 RIPARIAN BUFFER AREAS
Streams, wetlands, and their associated riparian habitats should be conserved in areas planned for development. Require project applicants located adjacent to streams to include appropriate measures for natural occurring stream channel and native riparian vegetation preservation, appropriate measures to stabilize stream banks, and prevent erosion and the discharge of sediment. (Source: New Policy and relates to Conservation and Open Space Policies in Section

3.200 and Mitigation Measures 4.731 and 4.733)
LU-8.2 NOT NET LOSS OF WETLANDS RESULTING FROM DEVELOPMENT To ensure that no net loss of wetlands result from development consistent with Conservation and Open Space Mitigation 4.736, the presence of potential wetlands in the vicinity of a proposed project shall be determined during the review process for discretionary projects and for ministerial building and grading permit applications, when the proposed building development activity involves new construction or expansion of existing structures or grading activities. Wetland delineation by a qualified professional shall be required when wetland characterization and limits cannot be easily determined based on available information or identified during a pre-site inspection.

LU-8.3 RIPARIAN AREA LAND USE OVERLAY
Apply an overlay to the Land Use Map, consistent with Conservation and Open Space Element Implementation Measure 3.320 identifying streams, known wetlands, and their associated riparian habitats within the City to be protected during development. Prohibit development within a buffer area sufficient to protect resources that is established on either side of the stream and subject to the following criteria:
(a) A combining zone for stream and riparian areas shall also be established and applied to parcels adjacent to streams and subject to the Riparian Area Land Use Overlay that specifies protective criteria consistent with this policy.
(b) Riparian Buffer Areas associated with streams shall be established on both sides of streams and shall be measured from either the outer drip-line of riparian vegetation or the top-ofbank, whichever is furthest from the stream centerline, and shall extend horizontally for a distance of:
(i) 100 feet for perennial streams, or
(ii) 50 feet for intermittent streams.
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Riparian Buffer Areas associated with wetlands shall extend horizontally from the delineated wetland boundary for a distance of:
(iii) 150 feet for perennial wetlands, or
(iv) 50 feet for seasonal wetlands.
(c) Buffers may be reduced or eliminated where the City determines, based on factual findings and in consultation with CDFW, that the reduction will not result in significant adverse effects to the water quality, dependent biological resources, or ecological functional capacity of the aquatic resource of interest.
(d) For ministerial projects that are located on land planned R-L, C-G, GM-U, DM-U containing occupied structures or on vacant parcels that are substantially surrounded by developed parcels where improvements are located within the buffer area, exceptions to these standards may be allowed after a site evaluation has been conducted by City staff and factual findings are made that development is sited to minimize potential impacts to streams, wetlands, and associated riparian resources; does not involve the removal of native riparian vegetation; and the incorporation of performance standards relating to the revegetation of locally-appropriate riparian species and the implementation of best management practices for erosion control.
(e) When the prescribed buffer prohibits development of the site for the primary use for which it is designated, measures shall be applied that allow development that results in the least environmentally damaging feasible project.
(f) Road, bridge, and trail construction or replacement may be permitted that would not result in significant adverse effects to water quality, dependent biological resources, or ecological functional capacity of the aquatic resource of interest, and where vegetative clearing is kept to a minimum and where revegetated with locally-appropriate native riparian species.
(g) The installation or replacement of new or existing fencing contiguous with Riparian Buffer Areas shall require the use of wildlife-permeable materials and designs to reduce the likelihood of wildlife entrapment and otherwise facilitate wildlife movement. (h) All projects shall implement stormwater requirements from the Mendocino County Low Impact Development Standards Manual to protect water quality and associated aquatic habitats, avoid the use of noxious weeds or other invasive plants identified by the California Invasive Plant Council (Cal-IPC) in associated revegetation and landscaping efforts, and prioritize use of locally-appropriate native vegetation during any such revegetation.
(i) The removal of vegetation for disease control or public safety purposes may be approved, in consultation with CDFW.
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(j) An exception to the implementing regulations for this policy shall be included for “minor additions” to buildings or structures provided the aggregated total increase in square footage for all changes does not exceed three hundred (300) square feet of floor area.

LU-8.4 PROTECT OAK TREES AND WOODLANDS
Integrate important tree protections from the Urban Forest Management Plan into the Zoning Regulations and establish an oak tree and oak woodland retention and protection program for new development that emphasizes the avoidance, minimization, or mitigation of oak tree and oak woodlands removal.

LU-8.5 PRESERVE AGRICULTURAL LANDS
The City shall discourage urban development on unincorporated land within its Sphere of Influence until annexed by the City. The City shall support County land use regulations that protect the viability of local agriculture in the Little Lake Valley.

LU-8.6 UTILIZE BIOLOGICAL RESOURCE INVENTORY ASSESSMENT TOOLS DURING

PROJECT REVIEW
The City shall ensure that the best available biological resource mapping data is used during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to insignificant levels consistent with CEQA. At a minimum, the following biological resource mapping data sources shall be used for project evaluation: California Department of Fish and Wildlife’s California Natural Diversity Database (CNDDB) and their Biogeographic Information and Observation System (BIOS), EcoAtlas and the California Aquatic Resource Inventory (CARI), and U.S Fish and Wildlife Service’s National Wetland Inventory (NWI).

LU-8.7 REQUIRE PRE-PROJECT BIOLOGICAL RESOURCE ASSESSMENTS AND SURVEYS The City shall require site- and/or project-specific biological resource assessments: 1) prior to annexing any properties into the City from the Proposed Sphere of Influence additions, and 2) prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area. Biological resource assessments shall address potential impacts to special status and/or otherwise protected fish, wildlife, and botanical taxa (including potential interferences with their movement, migration, and/or dispersal); sensitive natural communities; and wetland habitats. Biological resource assessments shall also identify mitigation measures to avoid and/or reduce impacts to protected biological resources to less than significant levels from all new development allowed within the study area by the General Plan.

LAND USE ELEMENT
LU-8.8 LOW IMPACT DEVELOPMENT STANDARDS NEAR STREAMS
To reduce stormwater impacts to streams and wetlands and improve water quality associated with discretionary development and all development within 250 feet of Willits, Broaddus or Baechtel Creeks and their tributaries, the City shall implement stormwater requirements from the Mendocino County Low Impact Development Standards Manual to attenuate runoff, reduce scouring and erosion, promote on-site infiltration, and to protect water quality and associated aquatic habitats.

LU-8.9 LANDSCAPING AND VEGETATION
The City shall develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for development-related landscaping and revegetation. The City shall encourage the use of locally appropriate and locally sourced native vegetation for use in revegetation and landscaping efforts as well as encourage the planting of native milkweed (Asclepias spp.) species (i.e., the sole plant group within the Planning Area region suitable for egg laying and larval development for the federal candidate species, Western Monarch butterfly [Danaus plexippus plexippus]). Where rapid plant establishment and development is required for purposes of soil stabilization and to minimize erosion potential, the City shall encourage the use of sterile hybrid “wheatgrass” x ”wheat” (Elymus x Triticum) or other similar non-reproductive seed material in conjunction with otherwise appropriately-selected revegetation seed applications or blends.

LU-8.10 OUTDOOR LIGHTING NEAR STREAMS
The design and location of all outdoor lighting fixtures shall prevent direct illumination of streams, wetlands, and Riparian Buffer Areas.

LU-8.11 SUPPORT LOCAL AGENCIES IN WILDLIFE PROTECTION
Partner with local organizations to educate applicants and residents about the impacts to special status and otherwise protected wildlife from toxic pest control methods, and to discourage their use within the City; as well as to educate the community about the impacts of free-ranging house cats on special status and otherwise protected wildlife.

LU-8.12 DEVELOPMENT IN HILLSIDE AREAS
Require new development in hillside areas be sited and designed to retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas. The City shall encourage clustered dwelling units in hillside areas to preserve the scenic character of the hillsides. 54 CITY OF WILLITS

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Implementation Measures
LU-8A STREAM AND RIPARIAN COMBINING ZONE.

Amend the Zoning Regulations to establish a Stream and Riparian Combining Zone with standards consistent with the Conservation and Open Space Element and the Land Use Element to protect all streams, riparian areas, and wetlands from new ministerial and discretionary development. Amend the Zoning Map to apply the Stream and Riparian Combining Zone to notify the public that specific standards apply for all development within such areas.

LU-8B OAK TREE PROTECTIONS.

Consistent with Urban Forest Management Plan, adopt Zoning Standards to protect oak trees as part of new ministerial and discretionary development. 55 CITY OF WILLITS

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General Plan Implementation and Maintenance
A General Plan is a long-term policy document that should have at least a 20-year planning vision and provide the needed flexibility to allow for policy modifications to respond to unique situations while maintaining a consistent and predictable framework to achieve the City’s long-term vision. To achieve this there should be regular and comprehensive reviews of the entire Plan that are scheduled to coincide with state mandated review of the Housing Element or other regular intervals. In addition, the Zoning Code should be regularly reviewed to ensure that development regulations are consistent with the General Plan and are clear and understandable to decision makers, developers, and the general public.
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GOAL LU-9 Ensure the effective use and implementation of Land Use Element Policy and the Land Use Map.

LU-9.1 LAND USE MAP
Maintain and implement the General Plan Land Use Map, Figure 2-1, which applies the approved Land Use Designations and specifies the allowed land uses by geographic location and the density of allowed uses within each designation to all land within the City of Willits.

LU-9.2 ZONING MAP AND REGULATIONS
Ensure that the Zoning Regulations are consistent with the policies of the General Plan and the Zoning Map is consistent with the General Plan Land Use Map.

LU-9.3 PERIODIC GENERAL PLAN REVIEW
Periodically review and update the General Plan for consistency with State law and comprehensively review and update the General Plan or specific Element(s) to coincide with the state-mandated Housing Element periodic update cycle or every seven years.

LU-9.4 WEB-BASED LAND USE MAPPING
Consider developing and maintaining a web-based land use mapping system to display General Plan, Zoning, administrative, service, environmental resource, and hazard maps and to enable the public to access vital land use and service information.

LU-9.5 PLANNING COMMISSION
Consider appointing and maintaining a Planning Commission to actively involve Willits residents in the City planning process, to relieve City Council members from the review of more mundane planning applications, and to streamline the process of planning approval.

LU-9.6 STREAMLINING DEVELOPMENT APPROVAL
Consider modifying the Zoning Regulations to add additional permit types that can be approved by the Community Development Director to streamline the process for approving minor exceptions to development standards.
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LU-9.7 EMERGENCY EVACUATION
Prohibit subdivisions in neighborhoods having only one access or that are vulnerable to isolation if access roads are impacted, until alternative evacuation routes are established or where the Fire Marshal has determined that access and egress are adequate.

LU-9.8 MILITARY OPERATING AREAS
Provide notification to the appropriate military departments for discretionary development projects that may have the potential to affect military special use airspace areas, as required by California law.

Implementation Measures
LU-9A COMPREHENSIVE GENERAL PLAN UPDATE.

The City shall actively pursue funding for the preparation of a comprehensive General Plan Update to ensure that all General Plan Elements are revised to reflect the priorities and needs of the City and are consistent with State law.

LU-9B ZONING CONSISTENCY.

Following the adoption of the Land Use Element, revise the Zoning Regulations to implement the changes to allowable uses and development standards and to re-establish consistency with the policies of the General Plan and amend the Zoning Map to achieve consistency with the General Plan Land Use Map.

LU-9C GENERAL PLAN ANNUAL REPORT.

A General Plan Annual Report shall be prepared by the Community Development Department by April 1 of each year pursuant to State law and shall be presented to the City Council in a public meeting.

LU-9D GENERAL PLAN CONFORMANCE.

The City shall review public works projects for conformity with the General plan and shall not acquire, dedicate, dispose, vacate or abandon real property unless in conformance with this Plan pursuant to State law.
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LU-9E LIST OF HAZARDOUS WASTE SITES
City staff shall maintain a listing of state or County of Mendocino regulated hazardous waste sites that are on the Cortese Listing, including Envirostor and Geotracker, that is provided by the state of California in a manner that is readily available to applicants for development projects and the public. The City shall consult this list during the review discretionary and ministerial projects, and consistent with state law, require that applicants for development disclose, as part of their applications, whether the project site is within a hazardous waste site.

Appropriate mitigations or site cleanup and closure, under permit and approval of the applicable agency, must occur prior to approval of a development permit to ensure that a project site within a hazardous waste site will not result in an adverse human health or environmental effect.
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Land Use Designations
GOAL LU-10 Apply appropriate Land Use Designations to areas within the City to protect resources, foster a sense of community, and to facilitate economic development.

LU-10.1 RESIDENTIAL LAND USE DESIGNATIONS
The following land use designations are applicable to land planned primarily for residential uses.

Table 3-1 lists the allowable uses, densities, and other standards that may be applied within each designation.

Residential-Suburban (R-S). This designation is intended to provide a transition from rural to urban areas where soils, topography, and site conditions are more appropriate for large lot residential uses.

Residential-Low Density (R-L). This designation is for application in areas where City services are available or planned and single family residential is the dominant use.

Residential-Medium Density (R-M). This designation is used where all urban services are available and close to services, recreation, schools, and employment and is suitable for mixed density residential uses allowing a variety of housing types.

LU-10.2 MIXED USE LAND USE DESIGNATIONS
The following land use designations are applicable to land planned for a range of allowable uses, including commercial and residential. Table 3-1 lists the allowable uses, densities, floor area ratios, and other standards that may be applied within each designation.

Main Street Mixed Use (DM-U). This designation is intended to be applied to Willits’ core downtown area to stimulate the adaptive reuse of existing buildings and the development of new pedestrian-oriented, mixed-use buildings.

General Mixed Use (GM-U). This designation is intended to be applied to specific areas within neighborhood and commercial centers where the existing or planned transportation alternatives, utilities, and services allow for mixed-use development that encourages walking, biking, and transit use. Allowable uses include retail, administrative office, general commercial, and a variety of housing types.
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LU-10.3 COMMERCIAL LAND USE DESIGNATIONS
The following land use designations are applicable to land planned primarily for commercial uses. Table 3-1 lists the allowable uses, densities (where applicable), floor area ratios, and other standards that may be applied within each designation.

Commercial-General (C-G). This designation is intended to be applied to areas that may serve as central business districts or address the needs of the travelers and visitors as a result of the location, access, site characteristics, or proximity to neighborhoods or travel routes.

LU-10.4 INDUSTRIAL LAND USE DESIGNATIONS
The following land use designations are applicable to land planned for industrial uses. Table 3- 1 lists the allowable uses, floor area ratios, and other standards that may be applied within each designation.

Industrial-General (M-G). This designation is for application to sites that are best suited for a variety of industrial operations because of access, location, availability of power, water, sewer services and transportation facilities, and where their operations will be compatible with adjacent uses. Allowable uses may include office; research and development; heavy commercial; shipping, storage, and warehousing; a range of compatible industrial and manufacturing uses; and general agriculture.

LU-10.5 RESOURCE AND PUBLIC LAND USE DESIGNATIONS
The following land use designations are applicable to land planned for agricultural, open space, and public uses. Table 3-1 lists the allowable uses, densities, floor area ratios, and other standards that may be applied within each designation.

Agricultural - General (A-G). This designation is for application to areas which are suitable for agricultural production because of historical use or future potential based on soil capability. Allowable uses include general agriculture, agriculture-related visitor serving activities, and rural residential uses that support agricultural operations.

Public - Service (P-S). This designation is for application to public sites of schools, parks, civic centers, fairgrounds, airports, museums, libraries, auditoriums, utilities and infrastructure, corporation yards, hospitals, social service centers, and similar uses, and may be applied to investor-owned utility and quasi-public sites.

Open Space - Recreation (O-S). This designation is for unimproved land in its natural state which is to be conserved for open space and/or recreation purposes. Allowable uses include natural resource protection and restoration, outdoor recreation, and general agriculture.
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LU-10.6 GENERAL PLAN LAND USE MAP OVERLAY DESIGNATIONS
The following overlay land use designations are applicable, in addition to the primary land use designation, to ensure protection for important resources, including streamside and historic areas, and hazards, such as floodways and floodplains.

Natural Hazard Area (-G). This overlay designation is intended for information purposes and is applied to lands subject to hazards that may include to excessive slopes, erosion, soil stability, seismic hazards, wildfire, periodic inundation and other similar natural hazards to life, property, and the natural environment. for the protection of persons and property.

Historical Resources (-H). This General Plan overlay designation is applied, for information purposes, to historical resources within the community. The intent of the Historical Resources classification is to encourage the preservation and enhancement of unique historical resources in the City of Willits.

Riparian Areas (-R). The purpose of this designation is intended to identify important stream and riparian areas where reasonable buffers should be applied to indicate the need to protect, as part of development review, sensitive fish and wildlife habitats and to minimize the potential for erosion, runoff, and interference with surface water flows and that balance to the greatest extent feasible resource protection and property rights. (Source: New Overlay) Urban Reserve (-UR). The purpose of this designation is to protect from premature subdivision and development, urban lands or land within the Sphere of Influence not now developed to urban densities or adequately provided with urban services but expected to develop to urban uses and densities when services are available. This designation is used where annexation is required for urban services and full build-out. (Source: New Overlay) 62 CITY OF WILLITS

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Figure 10-1 Natural Hazard Area (-G) Map
63 CITY OF WILLITS

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Figure 10-2 Riparian Areas (-R) Map
64 CITY OF WILLITS

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Table 10-1: General Plan Land Use Designations
Land Use R-S R-L R-M GM-U DM-U C-G M-G A-G O-S P-S
Residential
Single Residence ✔ ✔ ✔ ✔ ✔ ✔
Attached Residences, up to Four ✔ ✔ ✔ ✔ ✔
Multiple Residences ✔ ✔ ✔ ✔
Manufactured Home Parks ✔
Live/Work ✔ ✔ ✔ ✔ ✔
Commercial
Neighborhood Commercial ✔ ✔ ✔ ✔ ✔ ✔
Office and Professional Offices ✔ ✔ ✔
Retail Services ✔ ✔ ✔ ✔
Retail Sales ✔ ✔ ✔
Wholesaling, Storage and Distribution ✔ ✔
Heavy Commercial ✔ ✔
Visitor Accommodation
Hotels, Motels, Inns ✔ ✔ ✔
Campgrounds and RV Parks ✔ ✔
Community Assembly ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔
Industrial
Research and Development ✔ ✔
Light Industrial ✔
Heavy Industrial ✔
Other
Agriculture ✔ ✔ ✔ ✔ ✔
Health Care Services and Hospital ✔ ✔
Private Institutions ✔ ✔ ✔ ✔ ✔ ✔ ✔
Public Facilities and Essential Services ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ ✔ Resource-Related Recreation ✔ ✔ ✔
Habitat Restoration and Management ✔ ✔ ✔
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Land Use R-S R-L R-M GM-U DM-U C-G M-G A-G O-S P-S
Development Density/Intensity Standards
Maximum Density
(dwelling units per acre) 2 15 30 30 30 30 N/A 0.2 N/A N/A Minimum Density
(dwelling units per acre) 0 0 15 0 0 0 N/A 0 N/A N/A
Maximum Floor Area Ratio
(building area ÷ lot area) N/A N/A N/A 2.0 3.0 2.0 1.0 N/A N/A N/A Consistent Zones
Agricultural (A) ✔ ✔ ✔ ✔
Residential Estates (RE) ✔
Single-Family Residence (R1) ✔
Residential Medium-Density (R2) ✔ ✔
Multiple-Residence (R3) ✔ ✔ ✔
General Mixed-Use (GU) ✔ ✔
Main Street Mixed-Use (DU) ✔
Community Commercial (C1) ✔ ✔ ✔
Heavy Commercial (C2) ✔
Limited Industrial (ML) ✔
Heavy Industrial (MH) ✔
Industrial Park (I-P) ✔ ✔
Open Space (OS)
Public Facility (PF) ✔ ✔
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Implementation Action Plan
4 67

CITY OF WILLITS

Provide copies of the City of Willits
Planning Area showing City Land Use
Designations to the Mendocino County
Planning and Building Services and
Transportation Departments, the
Mendocino County Local Agency
Formation Commission, and Caltrans, and
request that proposals to intensify land
uses, such as general plan and zoning
amendments or subdivisions and roadway
improvements or water service extensions
that would expand capacity or that could
affect the Planning Area’s resources be
referred to the City of Willits for review
and communicate the City’s position on
these matters to the applicable decisionmaking body.

LU-1.1 PLANNING
AREA
LU-1.3 COUNTY

GENERAL PLAN LAND

USE WITHIN SPHERE

OF INFLUENCE
Government to
government
communication
City Manager ~ $100s Within 6
Months
LU-1B SEEK APPROVAL OF AN
EXPANDED SPHERE OF INFLUENCE.

Submit an application to the Mendocino
Local Agency Formation Commission to
expand the City of Willits Sphere of
Influence to add some or all of the areas
shown in Figure 3-1, as determined by the
City Council, consistent with Mendocino
Local Agency Formation Commission
policy and State law. Seek approval to add
possible Areas of Interest for Mendocino
Local Agency Formation Commission
LU-1.4 AREAS OF

INTEREST
LU-1.5

DISADVANTAGED

UNINCORPORATED

COMMUNITIES
Submit
application to
the Local
Agency
Formation
Commission
(LAFCO)
Community
Development
Department
< $10,000 Within 6
Months
68 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
designation so that notice is provided of
other governmental actions that may
impact the City of Willits.

LU-2A POPULATION AND GROWTH.

As part of the annual General Plan
progress report, provide the City Council
with a report on the estimated City
population in comparison to the buildout
population contained in this General Plan
using data such as City estimates based on
approved permits, the Department of
Finance annual population estimates, the
Census Bureau decennial census counts
and American Community Survey
estimates. Where the Director of
Community Development determines that
actual rates of growth could result in a
total City population level that exceeds
that included in this General Plan during
the planning period, the City Council shall
be informed of the need to update the
Land Use Element.

LU-2.1 PLANNED
GROWTH
Core City
Service
Community
Development
Department
Covered by the
City’s normal
operations
budget
Annually
LU-2B RESIDENTIAL LAND SUPPLY.

LU-2.1, LAND USE

CHANGES
LU-2.2,

ANNEXATIONS
LU-2.3, ANNEXATION

PLANNING
Preparation of
an additional
Plan or Study
Community
Development
Department
~ $1,000s Within 6
Months;
Ongoing;
Annually
69 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
For higher priority infill lands, periodically
reach out to landowners and seek their:
(1) level of interest in development,
(2) concerns regarding development;
and
(3) potential constraints affecting
development or landowner needs to
proceed with development.

As needed, during the annual General Plan
progress report, provide the City Council
with a report on the inventory of vacant
and underutilized land planned and zoned
for residential use and the potential need
for changes to General Plan policy or
Zoning standards, annexations, or other
City programs that may be needed to
facilitate development consistent with the
General Plan
LU-3A WILLITS GATEWAY
ENHANCEMENT PROGRAM.

Review and revise the gateway strategies
identified in the Willits Main Street
Corridor Enhancement Plan and seek grant
funding and local public-private
partnerships to implement a
comprehensive program of gateways to
celebrate Willits history and character,
welcome visitors, and highlight local
businesses and attractions.

LU-3.2, CITY

GATEWAYS AND

CORRIDORS
Core City
Service
Legislative
Advocacy /
Seeking Grants
Community
Development
Department
~ $10,000 Within 2 to
5 Years
LU-3B ENERGY CONSERVATION AND
GREENHOUSE GAS REDUCTIONS.

LU-3.1, ENERGY

CONSERVATION AND
Amendment to
the Zoning
Community
Development
$50,000 -
$100,000
Within 2 to
5 Years
70 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
Modify the Zoning, Subdivision, and
Building regulations and other land use
policy to implement:
• An assessment of GHG emissions for
large scale discretionary residential,
commercial and industrial projects,
and require feasible mitigation;
• A GHG Emissions threshold of
significance for discretionary projects
for use in future GHG emissions
analyses;
• Programs to facilitate the installation
of renewable energy systems, such as
solar arrays, and the development of
battery storage and micro grid
capacity for storing renewable power
through amendments to the Zoning
Regulations; and
• A city-wide program such as a
greenhouse gas reduction plan that
will meet the State’s 2030 objective of
40 percent below 1990 emissions
levels and 2045 goal of carbon
neutrality.

REDUCTION
LU-3.2, PLAN FOR

CLIMATE CHANGE
LU-3.3,

GREENHOUSE GAS

EMISSION

REDUCTIONS
Regulations
Amendment to
other City Codes
that govern
development
(Subdivision,
Building, Water
& Sewage
Regulations
etc.)
Preparation of
an additional
Plan or Study
Department and
Services and Facilities
Department
LU-3C PARK ENHANCEMENT.

Prepare and implement a public spaces,
parks, and recreation strategic plan that:
• Addresses gaps in the geographic
distribution of pocket, neighborhood,
and community parks in the City,
especially within disadvantaged
LU-3.12, PARKS AND

RECREATION
Preparation of
an additional
Plan or Study
Community
Development
Department & Public
Works
$50,000 -
$100,000
Within 5
Years
71 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
communities;
• Identifies and implements needed
public gathering areas within the
downtown area and commercial areas;
• Includes master planning for
important park properties;
• Defines and sets forth a program to
implement a complete, convenient,
and safe network of walking and biking
pathways throughout the City; and
• Incorporates a funding strategy that
may include approaches for publicprivate partnerships; priorities and linkages for state and federal grants;
City development and use fees; and
the creation of a regional district with
an ongoing revenue source that
includes all users who benefit from
City parks.

LU-4A MAIN STREET MIXED-USE ZONE.

MIXED USE LAND

USE DESIGNATION
LU-4.3, ADAPTIVE

REUSE OF

COMMERCIAL

STRUCTURES
LU-4.4, OFF-STREET

PARKING
Amendment to
the Zoning
Regulations
Community
Development
Department
< $10,000 Within 1
Year
72 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
allow residential and commercial uses
behind and above within the area
north of California Street and allow
residential uses on the ground floors
between California and Oak Streets;
• Simple and clear design standards for
ministerial projects that can be
implemented using a checklist format;
and,
• A “park once” parking monitoring and
management program for vehicles
that reduces or eliminates on-street
parking requirements and encourages
gathering, walking, and biking, and
may include sidewalk and streetscape
improvements; incentives for the
shared use of existing private offstreet parking areas; maximizing the efficiency of on-street parking;
improved signage and parking
information; the evaluation of a
shuttle system, parking permits,
restrictions, and pricing; and planning
for new public parking lots.

LU-4.7, MAIN STREET

SHOP FRONTS
LU-4B DOWNTOWN ACTION PROGRAM
Implement a program that prioritizes
actions and recommendations from prior
City of Willits planning documents for the
Downtown Area, identifies and secures
needed funding, and develops a schedule
for implementation, and includes:

LU-4.1, CITY OF

WILLITS MAIN
STREET
LU-4.5, DOWNTOWN

GATHERING AND

STREET ACTIVITIES
Preparation of
an additional
Plan or Study
Legislative
Advocacy /
Seeking Grants
Community
Development
Department &
Services and Facilities
Department
$50,000 -
$100,000
Within 5
Years
73 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
• Identifying and forming an ad-hoc
Downtown working group including
City staff, business and property
owners, and the Willits Chamber of
Commerce.
• Reviewing identified actions and
recommendations that have not been
fully implemented from prior City of
Willits planning documents for the
Downtown Area and adjacent areas,
including:
o Willits Main Street Corridor
Enhancement Plan
o Downtown Specific Plan
o Willits Circulation & Parking
Improvement Plan
o Willits Downtown Design
Guidelines
o Willits Bicycle & Pedestrian
Specific Plan
o Willits Downtown Streets & Alleys
Connectivity Study
• Refining and prioritizing identified
actions and recommendations.
• Identifying the likely cost of actions, if
any, and the most feasible funding
sources, including local and regional
private sources, public-private
partnerships, regional/state/federal
grant programs.
• Preparing a schedule for
LU-4.6, SLOWING

TRAFFIC
74 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
implementation that includes timing,
responsibility, and necessary steps.

LU-5A SOUTH MAIN STREET STRATEGIC
PLAN.

In close cooperation with South Main
Street businesses, property owners,
neighborhoods, Chamber of Commerce,
and Caltrans, prepare a South Main Street
Strategic Plan that is sensitive to the
varying contexts that exist along the street
(such as heavy commercial areas,
shopping centers, visitor serving uses, and
residential neighborhoods), and serves as
an ongoing, cooperative, and inclusive
planning strategy. Form an ad-hoc
working group to develop a South Main
Street Strategic Plan that addresses in
particular:
• Complete streets planning and
network connectivity.
• Convenient access to businesses and
homes.
• City gateway planning and
improvements.
• Signage and streetscape
improvements.

LU-5.1, FOCUSED

SOUTH MAIN STREET

PLANNING
LU-5.2, SOUTH MAIN
STREET

IMPROVEMENTS
Preparation of
an additional
Plan or Study
Legislative
Advocacy /
Seeking Grants
Community
Development
Department & Public
Works
$50,000 -
$100,000
Within 5
Years
LU-6A ZONING REGULATIONS.

Update the Zoning Regulations to:
• Add performance standards for
industrial and heavy commercial
development adjacent to residential
LU-6.1, LIMIT

INCOMPATIBLE AND

CONFLICTING USES
LU-6.2, COMPATIBLE
Amendment to
the Zoning
Regulations
Community
Development
Department
< $50,000 Within 5
Years
75 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
areas to provide buffers, landscaping,
and screening that minimize noise,
light, glare, and other impacts;
• Increase the range of allowable uses
and the incorporation of performance
standards to limit potential impacts;
and
• Update the standards for home-based
businesses to increase the range of
allowable home-based business types
in residential zones where potential
nuisances are addressed through the
permit approval process.

DEVELOPMENT
LU-6.3, PROTECT

LONG-STANDING

COMPATIBLE USES IN
OLDER

NEIGHBORHOODS
LU-6.4, INTERIM

AGRICULTURAL USES
LU-7A TRIBAL CONSULTATION.

Consultation on ministerial permits shall
be initiated if it has been determined the
project may create a substantial adverse
change to a significant cultural resource.

LU-7.2, TRIBAL

CONSULTATION
Project Review Community
Development
Department
Covered by the
City’s normal
operations
budget
Ongoing
LU-7B TRIBAL CULTURAL RESOURCES

AVOIDANCE
When feasible, development facilitated by
the project shall be designed to avoid
known tribal cultural resources. Known
tribal cultural resources within 60 feet of
LU-7.2, TRIBAL

CONSULTATION
CEQA Mitigation
Project Review Community
Development
Department &
Services and Facilities
Department
Covered by the
City’s normal
operations
budget
Ongoing
76 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
planned construction activities shall be
protected by establishing an
Environmentally Sensitive Area (ESA) that
would be fenced, or otherwise protected,
to ensure avoidance. The feasibility of
avoidance of tribal cultural resources shall
be determined by the City of Willits and
applicants in consultation with local
California Native American tribe(s).

LU-7C INADVERTENT ENCOUNTER WITH

TRIBAL CULTURAL RESOURCES
If previously unidentified tribal cultural
resources are encountered during project
implementation, altering the materials
and their stratigraphic context shall be
avoided and work shall halt immediately.

Project personnel shall not collect, move,
photograph, post on social media, or
disturb cultural resources. A
representative from a locally-affiliated
Native American Tribe shall be contacted
in a timely manner to evaluate the
resource and prepare a tribal cultural
resources plan identifying methods
necessary to protect the resource, in
consultation with the City of Willits.

LU-7.2, TRIBAL

CONSULTATION
CEQA Mitigation
Project Review Community
Development
Department &
Services and Facilities
Department
Covered by the
City’s normal
operations
budget
Ongoing
LU-7D INADVERTENT ENCOUNTER WITH

ARCHAEOLOGICAL OR CULTURAL

RESOURCES
In the event archaeological resources or
cultural resources, including human
LU-7.2, TRIBAL

CONSULTATION
CEQA Mitigation
Project Review Community
Development
Department &
Services and Facilities
Department
Covered by the
City’s normal
operations
budget
Ongoing
77 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
remains, are inadvertently unearthed or
uncovered 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 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.
78 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
LU-7E INADVERTENT DISCOVERY OF

PALEONTOLOGICAL RESOURCES
If fossils are encountered during
construction (i.e., bones, teeth, or
unusually abundant and well-preserved
invertebrates or plants), the City and its
contractor shall divert construction
activities away from the discovery within
50 feet of the find, and a professional
paleontologist shall be contracted to
document the discovery as needed, to
evaluate the potential resource, and to
assess the nature and importance of the
find. Based on the scientific value or
uniqueness of the find, the paleontologist
may record the find and allow work to
continue, or recommend salvage and
recovery of the material, if it is
determined that the find cannot be
avoided. The paleontologist shall make
recommendations for any necessary
treatment that is consistent with currently
accepted scientific practices. Any fossils
collected from the area shall then be
deposited in an accredited and permanent
scientific institution where they would be
properly curated and preserved.

CEQA Mitigation Project Review Community
Development
Department &
Services and Facilities
Department
Covered by the
City’s normal
operations
budget
Ongoing
LU-8A STREAM AND RIPARIAN
COMBINING ZONE.

Amend the Zoning Regulations to establish
a Stream and Riparian Combining Zone
LU-8.1, RIPARIAN

BUFFER AREAS
LU-8.2, NOT NET
Amendment to
the Zoning
Regulations
Community
Development
Department &
Services and Facilities
< $50,000 Within 1 to
2 Years
79 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
with standards consistent with the
Conservation and Open Space Element
and the Land Use Element to protect all
streams, riparian areas, and wetlands from
new ministerial and discretionary
development. Amend the Zoning Map to
apply the Stream and Riparian Combining
Zone to notify the public that specific
standards apply for all development within
such areas.

LOSS OF WETLANDS

RESULTING FROM

DEVELOPMENT
LU-8.3, RIPARIAN

AREA LAND USE

OVERLAY
LU-8.8, LOW IMPACT

DEVELOPMENT

STANDARDS NEAR

STREAMS
LU-8.9,

LANDSCAPING AND

VEGETATION
LU-8.10, OUTDOOR

LIGHTING NEAR

STREAMS
Department
LU-8B OAK TREE PROTECTIONS.

Consistent with Urban Forest
Management Plan, adopt Zoning
Standards to protect oak trees as part of
new ministerial and discretionary
development.

LU-8.4, PROTECT

OAK TREES AND

WOODLANDS
Amendment to
the Zoning
Regulations
Community
Development
Department & Public
Works
< $50,000 Within 5
Years
LU-9A COMPREHENSIVE GENERAL PLAN
UPDATE.

The City shall actively pursue funding for
the preparation of a comprehensive
General Plan Update to ensure that all
LU-9.3, PERIODIC

GENERAL PLAN
REVIEW
Preparation of
an additional
Plan or Study
Community
Development
Department
>$400,000 Within 5
Years
80 CITY OF WILLITS

LAND USE ELEMENT
Implementation Action Plan
Implementation
Policies
Implemented
Method of
Implementation Responsible Entity Scope of Cost Timing
General Plan Elements are revised to
reflect the priorities and needs of the City
and are consistent with State law.

LU-9B ZONING CONSISTENCY.

Following the adoption of the Land Use
Element, revise the Zoning Regulations to
implement the changes to allowable uses
and development standards and to reestablish consistency with the policies of the General Plan and amend the Zoning
Map to achieve consistency with the
General Plan Land Use Map.

LU-9.2, ZONING MAP

AND REGULATIONS
Amendment to
the Zoning
Regulations
Community
Development
Department
< $50,000 Within 1 to
2 Years
LU-9C GENERAL PLAN ANNUAL REPORT.

A General Plan Annual Report shall be
prepared by the Community Development
Department by April 1 of each year
pursuant to State law and shall be
presented to the City Council in a public
meeting.

Continues to
implement state
Planning and Zoning
Law
Core City
Service
Community
Development
Department
Covered by the
City’s normal
operations
budget
Annually
LU-9D GENERAL PLAN CONFORMANCE.

The City shall review public works projects
for conformity with the General plan and
shall not acquire, dedicate, dispose, vacate
or abandon real property unless in
conformance with this Plan pursuant to
State law.

Continues to
implement state
Planning and Zoning
Law
Core City
Service
Community
Development
Department and
Services and Facilities
Department
Covered by the
City’s normal
operations
budget
Ongoing

Final Programmatic Environmental Impact Report
SCH No. 2023030321
Prepared for:

City of Willits
111 E. Commercial Street
Willits, CA 95490
Prepared by:
670 9th St. Suite 200
Arcata, CA 95521
(707) 825-8260
October 10, 2024
City of Willits

GENERAL PLAN LAND USE

ELEMENT UPDATE
Table of Contents

1. Introduction ...................................................................................................................................... 1

1.1 Purpose of the Final Environmental Impact Report .........................................................................1

1.2 Environmental Review Process ....................................................................................................... 1

1.3 Document Organization of the Final EIR ......................................................................................... 2

2. Comments and Responses.............................................................................................................. 3

2.1 Comments Received During Circulation.......................................................................................... 3

2.2 Public Comments Received During Circulation ............................................................................... 4 Letter 1 - North Coast Regional Water Quality Control Board .................................................................. 4 Letter 1 – Response to Comments ....................................................................................................... 5 Letter 2 - Brooktrails Township Community Services District .................................................................. 9 Letter 2 – Response to Comments .....................................................................................................16 Letter 3 - Veronica Wilson ......................................................................................................................22 Letter 3 – Response to Comments .....................................................................................................23 Letter 4 - Sherwood Valley Band of Pomo Indians ................................................................................24 Letter 4 – Response to Comments .....................................................................................................30 Letter 5 - Mendocino LAFCo ..................................................................................................................37 Letter 5 – Response to Comments .....................................................................................................38 Letter 6 - Willits Environmental Center...................................................................................................39 Letter 6 – Response to Comments ......................................................................................................44 Letter 7 - Ruth Ford ................................................................................................................................55 Letter 7 – Response to Comments ......................................................................................................56 Letter 8 - Mendocino County Farm Bureau............................................................................................59 Letter 8 – Response to Comments ......................................................................................................61

3. Comments Received Following Circulation ...................................................................................66

3.1 Comments Received via Letter or Email.......................................................................................66

4. Errata, Revisions and Clarifications ...............................................................................................67

4.1 Text Revisions and Clarifications...................................................................................................67 Chapter 1.0 Introduction and Summary...............................................................................................67 Chapter 2.0 Project Description...........................................................................................................67 Chapter 3.0 Environmental Analysis – Global Change .......................................................................68 Chapter 3.0, Section 3.4 Biological Resources ...................................................................................69 Chapter 3.0, Section 3.5 Cultural and Tribal Cultural Resources........................................................70 Chapter 3.0, Section 3.8 Greenhouse Gas Emissions ........................................................................74 Chapter 3.0, Section 3.9 Hazards and Hazardous Materials, .............................................................75 Chapter 3.0, Section 3.15 Public Services ..........................................................................................76 Chapter 3.0, Section 3.18 Utilities and Service Systems ....................................................................76 Chapter 6.0 EIR Preparers ..................................................................................................................76

5. Mitigation Monitoring and Reporting ..............................................................................................78 Table 5a Mitigation Monitoring and Reporting Program..........................................................................79

6. Report of Preparers........................................................................................................................92 List of Acronyms
AB Assembly Bill
Caltrans California Department of Transportation
CARB California Air Resources Board
CEQA California Environmental Quality Act
City City of Willits
Draft EIR Draft Environmental Impact Report
EIR Environmental Impact Report
EPA Environmental Protection Agency
Final EIR Final Environmental Impact Report
FMMP Farmland Mapping and Monitoring Program
GHG Greenhouse Gas
MMRP Mitigation Monitoring and Reporting Program
NCUAQMD North Coast Unified Air Quality Management District NOP Notice of Preparation
NRCS National Resource Conservation Service
OPR California Governor’s Office of Planning and Research PG&E Pacific Gas and Electric Company
PM Particulate Matter
PRC Public Resources Code
ROG Reactive Organic Gases
SB Senate Bill
TAC Toxic Air Contaminant
VMT Vehicle Miles Traveled
City of Willits | Final PEIR Introduction
September 2024 [1]

1. INTRODUCTION

1.1 PURPOSE OF THE FINAL ENVIRONMENTAL IMPACT REPORT
This Final Environmental Impact Report (Final EIR) for the City of Willits Land Use Element Update (Land Use Element Update; Project) consists of the Draft Programmatic Environmental Impact Report (Draft EIR), comments received on the Draft EIR, the responses to comments, revisions to the Draft EIR, and a Mitigation, Monitoring and Reporting Program. To certify the Final EIR, the City Council must find that:
 The Final EIR has been completed in compliance with CEQA;  The Final EIR was presented to the decision-making body of the Lead Agency and the decision-making body reviewed and considered the information contained in the Final EIR prior to approval of a project;
 The Final EIR reflects the Lead Agency’s independent judgment and analysis (CEQA Guidelines Section 15090);
 The findings of the EIR are consistent with Section 15091 of the CEQA Guidelines, findings are supported by substantial evidence, the Final EIR includes a Mitigation, Monitoring, and Reporting Program, and a Statement of Overriding Considerations has been made for each significant effect pursuant to Section 15093 of the CEQA Guidelines;  When a Final EIR identifies one or more significant effects, the Lead Agency and each Responsible Agency shall make a finding under Section 15091 for each significant effect and may need to make a statement of overriding considerations under Section 15093 for the project;
 Approval of the EIR is consistent with Section 15092 of the CEQA Guidelines.

1.2 ENVIRONMENTAL REVIEW PROCESS
CEQA requires lead agencies to consult with public agencies having jurisdiction over a proposed project, and to provide the general public with an opportunity to comment on the Draft EIR. This FEIR has been prepared to respond to the written comments received on the Draft EIR.

The Notice of Preparation (NOP) was published on March 10, 2023, by the Office of Planning and Research (State Clearing House #2023030321). CEQA Guidelines Section 15082 (b) requires a 30-day response period for input on the scope and content of the EIR. The NOP review period ended on April 10, 2023. Sections 1.1 Project Background and Purpose summarizes the public scoping process.

The Draft EIR was made available for public review on July 25, 2024. The review period lasted over 45 days and ended at 5:00 pm on September 13, 2024. The document was made available for review at City of Willits Community Development department at 111 E. Commercial Street, Willits, CA and online at: https://willitslanduseupdate.com/. The Draft EIR was uploaded to the State Clearinghouse on July 25, 2024, and available for download at https://ceqanet.opr.ca.gov/Project/2023030321, and was distributed to local, state, and federal responsible and trustee agencies and tribal governments. The general public was advised of the Draft EIR through a Notice of Availability posted at the County Clerk as required by law, and through a posting in a local newspaper, the Willits Weekly, on August 1, 2024. The Notice of Availability of the Draft EIR was also sent to the listserv of parties who signed up for project updates on the City of Willits Land Use Element Update project webpage (103 recipients) as well City of Willits | Final PEIR Introduction
September 2024 [2]
as emails to Tribal organizations, trustee agencies, responsible agencies, service providers, area schools, and regional planning agencies. A public hearing before the City Council was held on September 11, 2024, where public input on the Draft EIR was received.

This Final EIR will be provided to the City Council for review and consideration on certification of the EIR as a full disclosure of potential impacts, mitigation measures and alternatives. The Final EIR will be sent to the public agencies who commented on the Draft EIR at least 10 days prior to certification of the EIR per CEQA Guidelines Section 15088.

If the Project is approved, recommended mitigation measures will be adopted and implemented as specified in the City Council’s resolution and an accompanying Mitigation Monitoring and Reporting Program (MMRP). The additions made in this Final EIR do not constitute “significant new information” requiring recirculation pursuant to Public Resources Code section 21092.1 and CEQA Guidelines Section 15088.5. The Final EIR merely clarifies, amplifies, and makes insignificant modifications to an adequate EIR, per CEQA Guidelines Section 15088.5(b).

1.3 DOCUMENT ORGANIZATION OF THE FINAL EIR
The Final EIR is organized into the following chapters:
 Chapter 1 – Introduction. This chapter discusses the use and organization of this Final EIR and the environmental review process.
 Chapter 2 – Comments and Responses. This chapter includes a list of persons, organizations, and public agencies who commented on the DEIR, reproductions of the letters received from the public on the DEIR, and responses of the Lead Agency to those comments.
 Chapter 3 – Comments Received Following the Close of Public Circulation. This chapter states that no comments were received by the City of Willits following the close of public circulation.
 Chapter 4 – Errata. This chapter includes text modifications to the Draft EIR. Proposed text additions are signified with underlined bold text (example), and stricken text is signified with strike through (example).
 Chapter 5 – A table containing the procedures to monitor and report take place through implementation of a Mitigation Monitoring and Reporting Program Mitigation Monitoring and Reporting. This chapter lists the .
 Chapter 6 – List of Preparers. This chapter includes the list of individuals who contributed to this document.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [3]

2. COMMENTS AND RESPONSES
This chapter includes responses to comments received during the comment period. Included are copies of the written comments received by the City of Willits through September 13, 2024.

When changes to the Draft EIR are necessitated, the change is indicated by indented text. Text that has been added to the Draft EIR is indicated in underline font, while text that has been deleted is indicated with strikethrough font. Where a change to the Draft EIR revises text that appears in multiple chapters of the Draft EIR, it can be assumed that the revision is changed in all locations.

For example, if a mitigation measure has been revised, and that mitigation measure is referenced in additional chapters other than the chapter in which it was modified herein, it can be assumed to be changed in all chapters including the Executive Summary which contains a summary table of all mitigation measures. Revisions herein typically reference the primary location of the text.

2.1 COMMENTS RECEIVED DURING CIRCULATION
During the public comment circulation period for the Draft EIR, the City of Willits received eight comment letters/emails, which included numerous comments on the Draft EIR. A list of the comments received via letters and comments received at a public hearing is shown below in Table 1 (either by agency/organization or name of the individual).

Table 1: Draft EIR Comments Received by Agency or Name

LETTER LAST NAME OR AGENCY FIRST NAME LETTER
DATE
PGS. CMT#
1 North Coast Regional Water
Quality Control Board
8/26/2024 1 1
2 Brooktrails Township Community
Services District
9/3/2024 7 7
3 Wilson Veronica 9/5/2024 1 2
4 Sherwood Valley Band of Pomo
Indians
9/11/2024 &
10/3/2024
6 9
5 Mendocino LAFCo 9/12/2024 1 1
6 Willits Environmental Center 9/12/2024 5 9
7 Ford Ruth 9/13/2024 1 2
8 Mendocino County Farm Bureau 9/13/2024 2 4
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [4]

2.2 PUBLIC COMMENTS RECEIVED DURING CIRCULATION
LETTER 1 - NORTH COAST REGIONAL WATER QUALITY CONTROL BOARD Comment received via email
Hi Dusty, we reviewed the CEQA documents for the General Plan Land Use Element Update and saw that within many of the areas zoned for a change in land use from a less sensitive use (i.e. commercial) to and more sensitive use (mixed use) there exists contaminated sites that are within our regulatory oversight program that would need significant mitigations and testing were they to be developed for any residential use. I would like to ensure that if you move forward with this that there are policies or guidelines in place to make sure that housing is not inadvertently built on top of contaminated sites which could have a significant impact on the occupants health. Would you be able to meet with Kelsey and I to discuss this? Thank you.

Best,
Heidi
Heidi M. Bauer, P.G.

Senior Engineering Geologist
Site Cleanups Unit Supervisor
North Coast Regional Water Quality Control Board
5550 Skylane Blvd. Suite A
Santa Rosa, CA. 95403
[email protected]
Office: (707) 570-3769
Comment
1-1
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [5]
LETTER 1 – RESPONSE TO COMMENTS
Response to Comment 1-1
The comment letter states that there are many “contaminated sites” within the North Coast Regional Water Quality Control Board regulatory oversight program where the land use is proposed to be changed from a less sensitive use to a more sensitive use that would need “significant mitigations and testing” if they are to be developed for any residential use and that there should be “policies or guidelines” in place to make sure that housing is not inadvertently built on top of contaminated sites which could have a significant impact on the occupants health.

This comment documents established agency procedures and does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Draft EIR Section

3.9 Hazards and Hazardous Materials, Environmental Setting, under the heading Cortese List, on page 3.9-2 lists ten locations with a Willits address that are listed in the EnviroStor database (listed in Table 3.9a: DTSC EnviroStor Sites with a Willits Address) and further states that the EnviroStor database “provides information on hazardous waste facilities (both permitted and corrective action) as well as available site cleanup information. This site cleanup information includes: Federal Superfund Sites on the National Priority List (NPL), State Response Sites, Voluntary Cleanup Sites, School Cleanup Sites, Corrective Action Sites, Tiered Permit Sites, and Evaluation / Investigation Sites. The hazardous waste facilities include Permitted–Operating, Post- Closure Permitted, and Historical Non-Operating.” Section 3.9 Hazards and Hazardous Materials further lists 55 locations in Table 3.9b: GeoTracker LUST Sites with a Willits Address with a Willits address that are listed in the GeoTracker database for Leaking Underground Storage Tanks as “Completed – Case Closed” or “Open - Site Assessment”; 11 locations with a Willits address that have Permitted Underground Storage Tanks in Table 3.9c: Permitted UST Sites with a Willits Address; and 18 locations with a Willits address that are listed in the GeoTracker database, which are either “Completed – Case Closed,” Open – Inactive,“ “Open – Remediation,” “Open – Assessment & Interim Remedial Action,” or “Open – Site Assessment.” Some sites are located within the Planning Area but outside of the City of Willits and the Proposed Sphere of Influence and some sites are on multiple lists.

Draft EIR Impact HAZ-04 on page 3.9-21 analyzed the potential for a development project to be located on a hazardous materials site and to create a significant hazard to the public or the environment. This analysis concluded that the Land Use Element Update “does not propose specific development projects”, but could “create a hazard to the public or the environment through a disturbance or release of contaminated materials if the development occurs on or adjacent to contaminated sites without appropriate measures to contain or mitigate the existing contamination”, but that “(f)ederal and state regulations ensure that existing hazards, including those associated with known hazardous materials sites, are addressed prior to development.

Compliance with federal and state regulations would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5 Cortese List would be less than significant.”
State law (Government Code Section 65962.5) requires that the state annually provide a consolidated list of hazardous waste sites to each City and that the list be consulted by applicant in applications for development projects and by the City. Various other components of California Planning and Zoning law, including the Housing Accountability Act and the Housing Crisis Act of City of Willits | Final PEIR Comments Received Following Circulation September 2024 [6]
2019, and CEQA, direct applicants for development projects that include housing to disclose, and for the City to identify, whether the project site is within a hazardous waste site.

The following list identifies sites either from the GeoTracker sites list or EnviroStor sites list above that are within the City of Willits and where there is a proposed change in the Land Use Designation shown on the Draft Land Use Element Update Land Use Map.

APN Site Name
Existing Use
of Land*
State List &
Information
Proposed General Plan
Land Use Change
005-211-16 Whitney Property Single Family
Residential
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
General Mixed-Use
005-147-06 Noyo Theater Recreational GeoTracker LUST Sites Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
006-044-21 Willits Automotive Service
Stations
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
005-216-43 SBC Facility Willits Utilities GeoTracker LUST Sites Completed ? Case Closed
Industrial-General to
Public Service
007-120-03 Blaze ChevroletPontiacSingle Family
Residential
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Residential-Medium
Density
007-130-06
(portion)
Berglund, Inc. Service Shops Envirostor GeoTracker
LUST Sites Completed ?
Case Closed
Commercial-General to
Residential-Medium
Density
005-150-61 Chevron #9-6188 Vacant
Commercial
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
005-150-06 Redwood Oil,
Willits
Service
Stations
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
005-141-01 Willits Service
Station (Former)
Light
Manufacturing
GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
005-146-21 Alliance Self
Service
Church GeoTracker LUST Sites
Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
006-075-37 Villanova, Remo Retail Store GeoTracker LUST Sites Completed ? Case Closed
Commercial-General to
Downtown Mixed-Use
006-170-35
(portion)
Abex Heavy
Manufacturing
Envirostor Residential-Low Density
to Industrial-General
* Existing use of land is based on the Mendocino County Assessor’s Use Code for the Assessor’s Parcel.

As stated in Impact HAZ-04 the Land Use Element does not include any specific development projects. The table above indicates that ten sites that contained leaking underground storage tanks for which the state GeoTracker website indicates that the associated cleanup case has been closed are proposed to be changed from a commercial land use designation to a mixed use or residential land use designation. It should be noted that two of these land use change sites City of Willits | Final PEIR Comments Received Following Circulation September 2024 [7]
currently contain residential uses and the Willits Housing Element allows residential uses above ground floor commercial uses.

The cleanup of contaminated sites consistent with state law, especially leaky underground storage tanks, is a normal part of land use development. The analysis in Draft EIR Impact HAZ04 concludes that the implementation of state and federal laws ensures that existing hazards, including those associated with known hazardous materials sites, are addressed prior to new development that could occur under the Land Use Element Update, and that compliance with such laws would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5 are less than significant. State law directs that housing development projects on hazardous materials sites be disclosed as part of the application process and the conclusion in this impact topic states that compliance with federal and state regulations would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5.

The review of Section 3.9 Hazards and Hazardous Materials Regulatory Setting as part of this Final EIR indicates that it does not fully enumerate the obligations of applicants for development within sites on the Cortese List or requirements of the City. In addition, in conflict with the 3.9 Hazards and Hazardous Materials Environmental Setting (described above) and the analysis in Draft EIR Impact HAZ-04, the Regulatory Setting states that there “are no hazardous materials release sites located in the Planning Area listed on the Cortese List (DTSC 2023).” This is clearly an error in the Draft EIR. However, given that the Environmental Setting clearly enumerates the Cortese List sites within the City and evaluates these sites in Draft EIR Impact HAZ-04, this error does not affect the adequacy of the Draft EIR.

The following modifications to the EIR will be made with newly proposed text underlined and bolded with single strikethrough, and unchanged text remaining in normal font and included in Final EIR Section 4, Errata, and further address these comments. Section 3.9, Hazards and Hazardous Materials, State, under the heading Cortese List,” on page 3.9-13 shall be revised in the following manner to clarify the responsibilities of future applicants for development and the City:

Cortese List
California Government Code Section 65962.5 established the (Cortese) List, which requires state agencies to compile a list of all properties affected by hazardous waste and develop a framework for how they will continue to be monitored and addressed by the state. A site’s presence on the list has bearing on the local permitting process as well as on compliance with the California Environmental Quality Act (CEQA). The DTSC is responsible for a portion of the information contained in the Cortese List. Other State and local government agencies are required to provide additional hazardous material release information for the Cortese List. There are no hazardous materials release sites located in the Planning Area listed on the Cortese List (DTSC 2023).

California Government Code Section 65962.5(e) requires that the Secretary for Environmental Protection “distribute (the Cortese List) in a timely fashion to each city and county in which sites on the lists are located.” Section 65962.5(f) requires that an applicant for any development project “consult the lists sent to the appropriate city or county and shall submit a signed statement to the local agency indicating whether the project and any alternatives are located on a site that is City of Willits | Final PEIR Comments Received Following Circulation September 2024 [8]
included” on the Cortese List, and if the site is within a site on the Cortese List not specified by the applicant “the lead agency shall notify the applicant” thereof.

The comment does not state that the conclusions in Draft EIR Impact HAZ-04 are incorrect, rather the comment recommends that there should be additional “policies or guidelines” in place if the City is to move forward with the Land Use Element Update. In response to this request and to provide greater transparency, strengthen local procedures and further ensure that the health and safety of the public is protected, City staff has informed the EIR preparers that a new implementation measure is recommended to be added to the “General Plan Implementation and Maintenance” implementation program group under Goal LU-9 of the Land Use Element relating to General Plan Implementation and maintenance:
“LU-9D List of Hazardous Waste Sites
City staff shall maintain a listing of state or County of Mendocino regulated hazardous waste sites that are on the Cortese Listing, including Envirostor and Geotracker, that is provided by the state of California in a manner that is readily available to applicants for development projects and the public. The City shall consult this list during the review discretionary and ministerial projects, and consistent with state law, require that applicants for development disclose, as part of their applications, whether the project site is within a hazardous waste site. Appropriate mitigations or site cleanup and closure, under permit and approval of the applicable agency, must occur prior to approval of a development permit to ensure that a project site within a hazardous waste site will not result in an adverse human health or environmental effect.”
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [9]
LETTER 2 - BROOKTRAILS TOWNSHIP COMMUNITY SERVICES DISTRICT Comment received via mail
Comment
2-1
Comment
2-2
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [10] Comment
2-3
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [11] Comment
2-3 Continued
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [12] Comment
2-4
Comment
2-3 Continued Comment
2-5
Comment
2-6
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [13] Comment
2-7
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [14]
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [15]
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [16]
LETTER 2 – RESPONSE TO COMMENTS
Response to Comment 2-1
The comment letter states that most comments within the comment letter relate to the analysis is Draft EIR Section 3.18, Utilities and Service Systems, and express concern about the information cited in this section, or missing therefrom, which impacts the wastewater treatment plant capacity and the findings of the analysis and requests that these comments be addressed in the Final EIR and considered in the action approving the Land Use Element Update.

This is an introductory statement and not a comment EIR adequacy. No further response is necessary.

Response to Comment 2-2
The comment letter states that Section 3.18, Utilities and Service Systems Impact UTL-03, which relates to the capacity of the wastewater treatment plant to serve projected demand in addition to the provider’s existing commitments, relies on “information in the Local Agency Formation Commission (LAFCo) 2019 Municipal Service Review (MSR) as its wastewater flow data” and this information “should not be used for wastewater flow data when that data is being considered as justification for making findings that there is available capacity in the City’s wastewater treatment plant to accommodate growth.”
This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. The Environmental Setting in Section 3.18, Utilities and Service Systems, a background section for the environmental analysis, contains a section entitled “Wastewater System Service Area and Infrastructure” that describes the existing geographic service area and population served by the wastewater collection, treatment, and disposal system, and current wastewater production. This section attributes information to the Mendocino Local Agency Formation Commission (LAFCo) May 6, 2019, City of Willits Municipal Service Review (MSR) and Sphere of Influence Update, as well as to the North Coast Regional Water Quality Control Board (NCRWQB) Order R1-2021-0021 in relation to general statements about wastewater collection system components, design capacity, permitted average monthly flows, and the approximate percentage of effluent treated that is contributed by the Brooktrails Township Community Services District (CSD). References to wastewater treatment capacity and permit flows in the text of the LAFCo MSR are made to the City of Willits November 2018, response to the Administrative Draft from the Local Agency Formation Commission of Mendocino County in preparation for the Municipal Service Review and Sphere of Influence Update. The Environmental Setting in Section 3.18, Utilities and Service Systems uses data from “City of Willits. 2023 Wastewater Production Totals” for average daily wastewater production for the years 2021 and 2022, see Table 3.18f Average Daily Wastewater Production on page 3.18-13.

The impact analysis uses projected wastewater flow data (see Table 3.18j Projected Wastewater Flows on page 3.18-26) from Appendix F, LACO Associates (LACO). April 19, 2023. City of Willits Land Use Element Existing Conditions Report – Water, Wastewater, Stormwater, Recycling & and LACO Associates (LACO). September 22, 2023. City of Willits Land Use Element Update Infrastructure Assessment – Water, Wastewater, Stormwater, Recycling & Solid Waste. It should also be noted that Appendix F also makes the same references to the LAFCo 2018 MSR that are described above in the Environmental Setting in Section 3.18, Utilities and Service Systems.

Draft EIR analysis in Section 3.18, Utilities and Service Systems Impact UTL-03 uses City of Willits 2023 Wastewater Production Totals for current wastewater flows and projected wastewater City of Willits | Final PEIR Comments Received Following Circulation September 2024 [17]
flows are modified from Appendix F, which was prepared by LACO Associates as a background report for the Land Use Element Update. LACO Associates also prepared Section 3.18, Utilities and Service Systems. The above statements demonstrate that the Draft EIR does not rely on “information in the Local Agency Formation Commission (LAFCo) 2019 Municipal Service Review (MSR) as its wastewater flow data,” and no further response is necessary.

Response to Comment 2-3
The comment letter describes City of Willits wastewater flow data that is provided to the Brooktrails Township CSD from four flow meters, three of which measure City wastewater influent and one measures Brooktrails Township CSD influent and states that this information should be used for the Draft EIR rather than LAFCo MSR data to accurately reflect wastewater treatment plant needs in response to future growth. The comment letter further states that the Draft EIR reported wastewater treatment plant capacity, NCRWCB permitted flows, and the use of 2021 and 2022 flow data is supportable. The comment letter further states that actual Brooktrails Township CSD flow contribution in 2021 and 2022 was 21% of total recorded flow. The comment letter describes the City recorded flow data that is attached to the comment letter . The comment states that the “conclusion in Section 3.18-15 that the City has 64% capacity available for accommodating additional City wastewater flows, the flow records show that the City has only 6% available in its maximum share of capacity. New capacity at the wastewater treatment plant cannot be relied upon through encroachment into the Brooktrails existing and paid share. This is the most significant impact being overlooked by not using recorded wastewater flow data.” “Unfortunately, the current information in the Draft EIR cannot be used to adequately reflect future growth impacts to the City’s wastewater treatment plant. Due to the discrepancy between the actual wastewater flows and the planning numbers in the LAFCo MSR, the conclusions made on capacity should be revised before adopting the final Land Use Element Update EIR.” This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. As described in the Responses to 2-1 above, the LAFCo MSR references in the Draft EIR are to background wastewater system information and not to wastewater flows. The comment letter agrees that the use of “the use of 2021 and 2022 flow data is supportable” using City of Willits wastewater flow data. The Draft EIR in Section 3.18, Utilities and Service Systems Impact UTL-03, uses City of Willits wastewater flow data for the years 2021 and 2022.

The comment letter states that ”(t)he City provides a monthly wastewater flow log from four flow meters at the wastewater treatment plant, of which three are measuring City flows and one Brooktrails flow. According to NCRWCB Order No. R1-2021-0021, the City of Willits Wastewater Treatment Facility has three influent metering locations shown in Table E-1. Monitoring Station Locations:
• INF-001 - Influent at the headworks of the wastewater treatment facility (WWTF) prior to treatment and consisting of wastewater from both the collection system and septage receiving station;
• INF-002 - Influent diverted from the secondary influent splitter box to the equalization basins; and
• INF-003 - Influent returned from the equalization basins to the headworks.

Order No. R1-2021-0021 Section 3, Influent Monitoring Requirements, states that total “influent shall be metered at INF-001. During periods when high influent flows are diverted to the City of Willits | Final PEIR Comments Received Following Circulation September 2024 [18]
equalization basins, diverted flow shall be measured at INF-002. Flows returning from the equalization basins shall be measured at INF-003 then measured for a second time at INF-001.

In order to account for flows passing through INF-001 twice, the flows passing through INF-003 shall be automatically subtracted from the measured value at INF-001.” As a result, actual total influent flows are not correctly reflected in the Brooktrails Township CSD “ATTACHMENT Table of 2021 and 2022 wastewater flow records from City of Willits’ Telog System.” The table headings for Draft EIR Comment Letter - Attachment with Recorded Wastewater Flows Data for 2021 and 2022 “City 1a” “City 1b,” and “City 3” likely refer to INF-001, INF-002, and INF003, respectively. Given that the influent meters are located at the City of Willits Wastewater Treatment Facility, Brooktrails Township CSD wastewater flows are a part of the three influent flow values and are not a separate value that is added to the influent values to calculate total wastewater influent flows.

A comparison of the wastewater flow data provided by Brooktrails Township CSD and the wastewater flow data used in the Draft EIR analysis in Section 3.18, Utilities and Service Systems Impact UTL-03 is contained in the following tables.

BTCSD Wastewater Flow Attachment 2021
Month City 1a City 1b City 3 BTCSD Total BTCSD% Corrected Total (1) Corrected
BTCSD%
(3)
Jun 2,277,663 15,447,039 139 6,242,486 23,967,327 26% 17,724,563 35.2% Jul 2,024,197 15,234,925 45 5,793,945 23,053,112 25% 17,259,077 33.6% Aug 1,922,058 15,224,865 2,161 5,919,198 23,068,282 26% 17,144,762 34.5% Sep 1,820,331 14,995,660 774 6,137,310 22,954,075 27% 16,815,217 36.5% Calculated Monthly Wastewater Flows (MGD) Based on BTCSD Wastewater Flow Attachment 2021 Month
Days per
Month
Willits
(MGD)
BTCSD
(MGD) MGD (2)
Jun 30 0.38 0.21 0.59
Jul 31 0.37 0.19 0.56
Aug 31 0.36 0.19 0.55
Sep 30 0.36 0.20 0.56
BTCSD Wastewater Flow Attachment 2022
Month City 1a City 1b City 3 BTCSD Total BTCSD% Corrected Total (1) Corrected
BTCSD%
(3)
Jun 2,677,905 19,810,246 682 8,227,900 30,716,733 27% 22,487,469 36.6% Jul 2,408,671 16,853,048 137 5,467,396 24,729,252 22% 19,261,582 28.4% Aug 2,040,475 15,679,906 226 5,950,947 23,671,554 25% 17,720,155 33.6% Sep 1,850,375 15,980,724 645 6,335,985 24,167,729 26% 17,830,454 35.5% Calculate Monthly Wastewater Flows (MGD) Based on BTCSD Wastewater Flow Attachment 2022 Month
Days per
Month
Willits
(MGD)
BTCSD
(MGD) MGD (2)
Jun 30 0.48 0.27 0.75
Jul 31 0.44 0.18 0.62
Aug 31 0.38 0.19 0.57
Sep 30 0.38 0.21 0.59
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [19]
Average Monthly Dry Weather Flows Based on BTCSD Wastewater Flow Attachment 2021 Avg 0.37 0.20 0.57
2022 Avg 0.42 0.21 0.63
2021-22 Avg 0.39 0.21 0.60
Notes:

1. Total wastewater flows = City 1 + City 2 – City 3, consistent with Order No. R1-2021-0021 Section 3

2. MGD = million gallons per day (this is the unit of analysis that is averaged to determine average dry weather flow) and is calculated by dividing the total monthly flow by the days of the month, divided by 1,000,000.

3. Corrected BTCSD % = dividing BTCSD (which equal the total flow from BTCSD into the City of Willits collection system) by total flows
Based on the above tables, the flow data used in Draft EIR analysis in Section 3.18, Utilities and Service Systems Impact UTL-03 are the same as the data provided by Brooktrails Township CSD.

Given that average wastewater flows used in the analysis reflect City of Willits wastewater flow data, which is the best available data, the conclusion in Impact UTL-03 properly reflects future growth impacts to the City’s wastewater treatment plant. There is no need to revise the Draft EIR analysis in Section 3.18, Utilities and Service Systems Impact UTL-03.

Response to Comment 2-4
The comment letter provides detail regarding the automatic and mutual aid agreements between the Little Lake Fire Protection District and Brooktrails Township Fire Department for fire protection and requests clarification in Section 3.15 Public Services to reflect these details.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Nor is it a comment on the adequacy of the Draft EIR. Rather, this comment relates to additional detail regarding the automatic aid agreement and does not affect the conclusion in Impact PS-01, whereby impacts to fire protection services would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities would be less than significant. Section 3.15 Public Services on page 3.15- 1 describes the Environmental Setting for Fire Services and states that “Little Lake FPD provides automatic aid fire protection to Brooktrails and maintains mutual aid agreements with Laytonville, Redwood Valley, and the CalFire for wildland fire. There is a countywide mutual aid agreement so that fire departments in Mendocino County respond, as available, to the needs of nearby fire departments.” This section clearly indicates the presence of an automatic aid agreement with Brooktrails Township CSD Fire Department and the Little Lake FPD participation in a countywide mutual aid agreement.

In recognition of the request to provide greater detail, the following edits to Section 3.15 Public Services Environmental Setting for Fire Services on page 3.15-1 shall be made:

The Little Lake FPD covers an area of 239.4 square miles serving all of the City of Willits, as well as the highway corridors (Highways 101 and 20) and outlying rural areas (Mendocino LAFCo, 2019). This area includes Federal Bureau of Land Management (BLM) land on the eastern edge of the District, a small portion of the Jackson State Forest on the western boundary, and the City of Willits. Other fire-related districts in the region include the Brooktrails Township Community Services District (CSD, which provides fire protection services) adjacent to and west of Little Lake FPD, the Long Valley Fire Protection District to the northwest, the Potter Valley Community Services District (which provides fire protection services) to the southeast, and the Redwood Valley-Calpella Fire Protection District to the south. Little Lake FPD provides automatic aid fire protection to City of Willits | Final PEIR Comments Received Following Circulation September 2024 [20]
Brooktrails Township CSD on calls related to structure fire, CPR, and traffic collisions on Sherwood Road, and maintains mutual aid agreements with Laytonville, Redwood Valley, and the CalFire for wildland fire. There is a countywide mutual aid agreement so that fire departments in Mendocino County respond, as available, to the needs of nearby fire departments, including the Little Lake FPD and the Brooktrails Township CSD.

Response to Comment 2-5
The comment letter states that the solid waste discussion under Section 3.18-17 should be revised to reflect that Solid Wastes of Willits is no longer the provider and the new provider is Redwood Waste Solutions/C&S Waste Solutions.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Nor is it a comment on the adequacy of the Draft EIR. On December 13, 2023, the City of Willits, at the request of Solid Wastes of Willits, Inc. terminated the Franchise Agreement to Collect, Haul and Dispose of Residential and Commercial Solid Wastes from City Customers and approved the granting of the existing Franchise Agreement with the City of Willits to Redwood Wastes Solutions, Inc. with a new expiration date of December 31, 2032, and with an option for a ten-year extension. The terms of the Franchise Agreement between the City of Willits and Redwood Wastes Solutions, Inc., are the same as those with the prior waste hauler. This is not a comment on the adequacy of the Draft EIR. Rather, this comment relates to a correction to the name of the solid waste hauler and does not affect the conclusion in Section

3.18 Utilities and Service Systems Impact UTL-04, whereby impacts relating to the generation of solid waste would not be 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 Impact UTL05, whereby impacts relating to the compliance with federal, state, and local management and reduction statutes and regulation related to solid waste would be less than significant.

There are multiple references to Solid Wastes of Willits, Inc., or SWOW, within the Draft EIR.

This Final EIR will reflect that all references to Solid Wastes of Willits, Inc., or SWOW in the following sections shall be replaced with Redwood Wastes Solutions, Inc.:
• Table 1-1: Summary of Impacts, Mitigations, and Significance Levels page 1.0-51 • Section 3.18 Utilities and Service Systems, Existing Conditions page 3.18-17 • Impact UTL-04 page 3.18-26
• Impact UTL-05 page 3.18-26
• Section 3.18 Utilities and Service Systems Acronyms/Abbreviations page 3.18-31 Response to Comment 2-6
The comment letter states that the solid waste discussion under Section 3.18-17 should be revised to reflect the discussion on Senate Bill 1383 under Section 3.8 Greenhouse Gas Emissions should be included in the Regulatory Setting for Section 3.18 Utilities and Service Systems.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Nor is it a comment on the adequacy of the Draft EIR. The EIR authors agree that Senate Bill 1383, which relates to a variety of short-lived climate pollutants, should be referenced in the Regulatory Setting for Section 3.18 Utilities and Service Systems.

However, the omission of this reference does not change the analysis for Impact UTL-05, which City of Willits | Final PEIR Comments Received Following Circulation September 2024 [21]
states that the City is required to comply with federal, state, and local management regulation related to solid waste or the conclusion that “(w)ith continued compliance with the applicable regulations, leading to increased recycling and waste diversion, and adherence to the proposed General Plan goals, policies, and actions”, impacts relating to the compliance with federal, state, and local management and reduction statutes and regulation related to solid waste would be less than significant.”
The following text shall be added to the Regulator Setting for Section 3.18 Utilities and Service Systems under Solid Waste on page 3.18-21:

Senate Bill 1383
Adopted in September 2016, SB 1383 required a 50 percent reduction in the level of the statewide disposal of organic waste from 2014 levels by 2020 and a 75 percent reduction in the level of the statewide disposal of organic waste from 2014 levels by 2025.

Response to Comment 2-7
The comment letter states that Brooktrails Township CSD is moving forward on a planning study with our consultant, Carollo Engineers, to explore the feasibility of providing potable water reuse as an alternative source of supply to its customers.

This is a statement about Brooktrails Township CSD planning and not a comment on EIR adequacy. No further response is necessary.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [22]
LETTER 3 - VERONICA WILSON
Comment received via email
My name is Veronica Wilson and I am a resident of Willits. Please accept this email as written public comment on the Draft Environmental Impact Report for the City of Willits Land Use Element & Sphere of Influence Updates.

I attempted to review the 528 page EIR but was immediately overwhelmed by the density of the document and the complexity of the concepts contained. I understand this is the first major update since the year I was born at Howard Hospital, 1983, and such complexity is to be expected. However, it is the responsibility of the City to be transparent and accountable to the Public when making such major and extensive changes.

I attended the August 28th Public Hearing on the Land Use Update and a PowerPoint presentation was displayed during the City's presentation that clarified many areas and provided transparency on many important components of the Update. Unfortunately, I have not been able to locate a copy of this presentation and would encourage City Staff to include this presentation on the WillitsLandUseUpdate.com website before the close of the extended Public Comment period to aid in the Public's understanding of the Update. I also request this presentation be provided to me directly.

Comment
3-1
Comment
3-2
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [23]
LETTER 3 – RESPONSE TO COMMENTS
Response to Comment 3-1
The comment letter states that the Draft EIR is overwhelming and complex, and it is the City’s responsibility to be transparent and accountable to the Public.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. The preparers of the Draft EIR acknowledge that EIRs often cover a wide range of topics, each of which contain a great deal of information related to environmental settings, existing conditions, and potential impacts and can require significant effort to review. Chapter 1 provides a summary of environmental impacts in Table 1-1: Summary of Impacts, Mitigations, and Significance Levels, which is intended to serve as a summary that can guide readers to the topics of greatest interest.

Response to Comment 3-2
The comment letter requests that PowerPoint presentation be made available on the WillitsLandUseUpdate.com website.

This comment does not relate to the Draft EIR. The PowerPoint presentations for public meetings related to the Land Use Element Update are available on https://willitslanduseupdate.com/ website.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [24]
LETTER 4 - SHERWOOD VALLEY BAND OF POMO INDIANS
Comment received via email
Comment
4-1
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4-2
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4- 2
continued
Comment
4- 3 Comment
4- 4
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4- 4 continued
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4- 4 continued Comment
4- 5 Comment
4- 6
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4- 7 Comment
4- 8 Comment
4- 9
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LETTER 4 – RESPONSE TO COMMENTS
Response to Comment 4-1
The comment letter requests government to government consultation regarding the update to the General Plan Land Use Element and Environmental Impact Report.

This comment addresses the importance of working collaboratively, not Draft EIR adequacy. Draft EIR Section 3.5, 3.5 Cultural and Tribal Cultural Resources, on page 3.5-10 and 11 states that in “February 2023, the City of Willits sent a letter to the NAHC requesting a current SB 18 and AB 52 Native American Contact List for the Project vicinity and a Sacred Lands File (SFL) search.

On February 28, 2023, the NAHC provided a list of 13 tribal contacts with tribal connections to the Planning Area. In accordance with AB 52 and SB 18, on April 12, 2023, the City of Willits notified the following thirteen (13) tribes of the project and invited them to participate in consultation”. “No requests for consultation were received from the 13 Native American tribes that were sent formal notification of the project. As no requests for consultation were received within 30 days specified by PRC Section 21082.3 (d) for AB 52 nor within the 90 days specified by California Government Code Sections 65352.3 and 65352.4, the City of Willits, as Lead Agency, has deemed the tribal consultation process complete.” It is the understanding of the EIR preparers that the City of Willits is reaching out to the Sherwood Valley Rancheria of Pomo Indians to engage in discussions regarding the Draft Land Use Element.

Response to Comment 4-2
The comment letter requests that the Section 3.2 Agricultural and Forestry Resources Environmental Setting (B) Agriculture and Section 3.4 Biological Resources Environmental Setting Aquatic Resources be expanded to include a description of agricultural resources during the pre-contact period.

This comment does not identify a new impact or suggest that previously identified impacts would be more significant. Rather, the comment requests that additional environmental setting information be added related the agricultural history of the region. In response to this comment:
• the following text shall be added to Section 3.2 Agricultural and Forestry Resources Environmental Setting (B) Agriculture on page 3.2-3 before the heading “Regional History”:
“Regional Pre-contact
This is the unceded traditional territory of the local indigenous people past and present. Tribal communities with cultural ties to the land depend on access to maintain traditional ecological knowledge and continued lifeways. Indigenous people were not apart from nature but were a part of nature, and lived accordingly.

Throughout pre-contact and continuing to present day the local Indigenous groups stewarded the land as their cultural resource. Indigenous traditional agroecological practices were a lifeway built upon a rich oral tradition that passed along essential knowledge of stewardship techniques honed to perfection intergenerationally through application and observation. From burning, pruning, coppicing, to re-seeding, intentional application of these and other stewardship techniques at their proper time were the cultural lifeway to assure access to and a healthy balance of essential cultural resources. The contemporary view of Tribal Cultural Resources typically only accounts for the archaeological items left behind City of Willits | Final PEIR Comments Received Following Circulation September 2024 [31]
and neglects the “Living Tribal Cultural Resources” that were, and are, essential pieces of Native lifeways; cultural foods, fibers, and medicines.” • the following text shall be added to the first paragraph on page 3.4- of Section 3.4 Biological Resources Environmental Setting Aquatic Resources:

Prior to 1910, the aforementioned streams historically contributed to a large seasonal lake at the north end of the Planning Area, from which, Little Lake Valley derived its name.

Little Lake was a biologically rich area that supported many diverse species that local Indigenous people co-existed with in reciprocity though tending, burning, coppicing, and harvesting materials for housing, clothing, baskets, medicine and food. The lake was habitat for native species of plants, birds, fish, amphibians, reptiles, mollusks, insects, and mammals including species that today are threatened and endangered, such as coho salmon and steelhead. Water resources were utilized by local Indigenous people and kept pristine through good stewardship practices. Beginning in 1910, substantial diking, channelization, flow redirection, and other forms of hydrological modification were undertaken to connect the aforementioned streams to Outlet Creek and drain the seasonal lake in order to convert the former lakebed to grazing pasturage and cropland (LeDoux-Bloom and Downie 2007).

Subsequent flooding events, particularly in 1955 and 1964, resulted in additional channelization and levee construction along portions of some of the aforementioned streams to reduce flood-related impacts within the incorporated City limits and the surrounding area and to further facilitate drainage within Little Lake Valley.

Response to Comment 4-3
The comment letter requests that Tribal Cultural Resources as defined in Section 3.5 Cultural and Tribal Cultural Resources Environmental Setting on page 3.5-1 of the Draft EIR be expanded to include “living cultural resources”. This response to comment also addresses Comment 4-6 which also relates to the definition of Cultural Resources as defined in Section 3.5 Cultural and Tribal Cultural Resources Environmental Setting on page 3.5-1 of the Draft EIR.

This comment does not identify a new impact or suggest that previously identified impacts would be more significant. Rather, the comment requests that the definition of Tribal Cultural Resources, which references Assembly Bill 52 and is a threshold for impacts specified in CEQA Appendix G XVIII and defined in Public Resources Code Section 21074 be changed to include “living cultural resources”. The analysis in the Draft EIR adheres to the thresholds in CEQA Appendix G, which in checklist question XVII(a) asks if the project would “cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074.” The Draft EIR evaluates the potential impact to living cultural resources in Impact TCR-01, where potential impacts to Tribal Cultural Resources are evaluated. This analysis identifies that living cultural resources, such as “plants and other natural resources, as well as geographic locations can also be” Tribal Cultural Resources. This analysis indicates that the potential impacts of yet to be defined future projects would be analyzed for potential environmental impacts, consistent with the requirements of CEQA, pursuant to the City of Willits entitlement review process. This analysis determines that potential impacts are significant without mitigation and “would require implementation of Mitigation Measures TCR-1 and TCR-2 in order to ensure proper treatment of TCRs should they be encountered during implementation of future development facilitated by the City of Willits | Final PEIR Comments Received Following Circulation September 2024 [32]
Project. Therefore, impacts from the project would be less than significant with mitigation incorporated.”
In response to this request, which was made through government-to-government consultation, City staff has informed the EIR preparers that Implementation Measure LU-7A, Tribal Consultation, is to be modified to include specific reference to “living cultural resources”:

LU-7A TRIBAL CONSULTATION.

Consultation on ministerial permits shall be initiated if it has been determined the project may create a substantial adverse change to a significant cultural resource.

Response to Comment 4-4
The comment letter requests edits to the Section 3.5 Cultural Resources, Environmental Setting, Ethnographic Background on pages 3.5-2 and 3.5-3.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Rather, this comment requests that the Draft EIR better characterize local history and be sensitive to the need to protect Tribal Cultural Resources.

In response to this request, the following edits are made to Section 3.5 Cultural Resources, Environmental Setting, Ethnographic Background on pages 3.5-2 and 3.5-3:

Ethnographic Background
Around Euroamerican contact (circa 1769), Mendocino County housed diverse indigenous groups: Central Pomo, Northern Pomo, Coast Yuki, Yuki, Huchnom, Cahto, Sinkyone, and Wailaki. Central and Northern Pomo mainly inhabited the county, while other groups settled nearer its north. These tribes had similar material cultures, emphasizing basketry for essential tasks. However, each group had distinct territories, languages, practices, and societal norms.

Pomo
In Mendocino County, Central Pomo were in the southern area, Northern Pomo in the north. Northern Pomo controlled the coast to Clear Lake, including tribes like Coyote, Yokayo, Redwood, and Potter Valley. The Pomo had diverse social structures, used baskets for fishing, cooking, and ceremonies, and traded with neighbors. Conflicts arose over expansion and resources. Many Central and Northern Pomo Tribes were forced onto the Round Valley Reservation to clear the land for settlers.

Coast Yuki, Yuki, and Huchnom
Coast Yuki occupied Fort Bragg to Rockport (Miller 1978), adapteding to coastal life due to limited inland resources. Yuki and Huchnom were east in upper Eel River, past Round Valley and south of Willits (Miller 1978; Ukiah 2040 General Plan Update 2022). With scarce records and They had smaller populations than Pomo., tThey united in 1860s at were forced on to the Round Valley Reservation (Miller 1978), Mendocino's largest Indian land, established in 1858., along with many other Tribes from the region.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [33]
Cahto
Cahto's land includes Branscomb, Laytonville, Cummings, and valleys along South Fork Eel River, slightly beyond the Mendocino County border. There is limited ethnographic data on Cahto, as they were a smaller group than the Pomo, sharing the Athabaskan language group with their neighbors to the north. By 1920s, most Cahto moved to Round Valley or a tribal rancheria near Laytonville by force.

Historic Setting
Spanish Period (1769 – 1822)
From 1542, Spanish explored California without creating settlements. In 1769, Spain claimed Alta California and in the 18th century, Spain built presidios, missions, and towns to forcibly convert natives and settle Spaniards. In 1823, the closest mission to Willits was founded, Mission San Francisco Solano in Sonoma (California Missions 2023). Alta California later became New Spain's colony. During this time many Russian fur trappers came to Mendocino County and beaver populations were decimated as a result. Beaver ponds drying up changed the ecosystem and water cycle of the region to be drier and less diverse.

Mexican Period (1822 – 1848)
In California’s Mexican era (circa 1821-1848), missions were secularized, ranchos were formed, and Native Americans were forced to labored for the very people who took their land and ways of life from them. Counties were shaped by lLand grants issued by Mexican authorities shaped counties, including Mendocino, in the 1840s. No towns existed until 1859, and administration was under Sonoma County due to the low population of Mendocino County.

The Bear Flag Revolt in 1846 showed U.S. settlers' concerns about Mexican rule. The U.S./Mexico conflict in 1846 and the Treaty of Guadalupe Hidalgo in 1848 marked the beginning of California's American Period.

American Period (1848 – Present)
Statehood followed through the Compromise of 1850, designating territories. Horticulture, livestock, and cattle-based economy continued. The Gold Rush in 1848 shifted cattle's value. Severe drought in the 1860s hurt cattle herds and rancheros' income. Property boundary issues caused conflicts. Debt and legal costs led to rancho lands transfer to Americans, often converting to plots or towns. Native people were massacred, and the survivors rounded up by settlers and forced on to Rancherias. Many of the Rancherias were later terminated and Tribes had to fight legal battles to regain federal recognition, some are still fighting for recognition.

Local History
Within Little Lake Valley, the City of Willits (City) is surrounded by a secondary forest teeming with tan oak, madrone, Douglas fir, and redwood trees. This landscape resides within the Pacific Coast Range, earning the City the monikers "Gateway to the Redwoods" and the "Heart of Mendocino County." Notably, the region was originally inhabited by the Pomo Ttribe of Native Americans, who continue to live in the area and enjoyed a deeprooted connection with their ancestral land. Their presence echoes through time, enriching the City's heritage and present day culture. Several prehistoric sites have been noted in the vicinity of Willits and the ethnographic village of Mitoma is reported to be in the southwestern part of the City. Prehistoric cultural resources are most likely to be found City of Willits | Final PEIR Comments Received Following Circulation September 2024 [34]
at the base of hills and along seasonal and perennial water courses. These areas have been identified as potentially sensitive on the Historical and Archaeological Resources Map located in the City of Willits General Plan (1992). This Map is attached in Appendix C.

Response to Comment 4-5
The comment letter requests that an edit be made to Section 3.5 Cultural Resources, Regulatory Setting, State, relating to Senate Bill 18 on page 3.5-6.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Rather, this comment requests that the Drant EIR refer to the applicability of Senate Bill 18 to the entire Project Areas, which includes the City and proposed Sphere of Influence Area.

In response to this this request, the following edits are made to Section 3.5 Cultural Resources, Regulatory Setting, State, relating to Senate Bill 18 on page 3.5-6:

California Senate Bill 18 (Chapter 905, “Traditional Tribal Cultural Places”) Signed into law in 2004, Senate Bill (SB) 18 requires that cities and counties notify and consult with California Native American tribes about proposed local land use planning decisions for the purpose of protecting traditional tribal cultural sites. Cities and counties must provide general and specific plan amendment proposals to California Native American tribes that have been identified by the Native American Heritage Commission (NAHC) as having traditional lands located within a project’s the city’s boundaries. If requested by the Native American tribes, the city must also conduct consultations with the tribes prior to adopting or amending their general and specific plans. These consultations are for preserving or mitigating impacts to Native American historic, cultural, sacred sites, features, and objects located within the city or county. A tribe has 90 days from the date of contact to request a consultation, unless the tribe agrees to a shorter timeframe. SB 18 also added a new topic that must be addressed in the Open Space Element of the General Plan: open space land for the protection of Native American historic, cultural, sacred sites, features, and objects.

Response to Comment 4-6
The comment letter requests that Tribal Cultural Resources as defined in Section 3.5 Cultural and Tribal Cultural Resources Environmental Setting on page 3.5-1 of the Draft EIR be expanded to include “living cultural resources”. This response to comment also addresses Comment 4-6 which also relates to the definition of Cultural Resources as defined in Section 3.5 Cultural and Tribal Cultural Resources Environmental Setting on page 3.5-1 of the Draft EIR.

See Response to Comment 4-3.

Response to Comment 4-7
The comment letter requests edits to the introductory paragraph to Impact CUL-01: Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5, on page 3.5-12, in particular to remove reference to the name of a village site. An identical sentence is also included in the second paragraph of the analysis on page 3.15-14 in Impact CUL-02: Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [35]
This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Rather, this comment requests that the Draft EIR be sensitive to the need to protect Tribal Cultural Resources.

In response to this request, the following edits are made to the first two sentences in the introductory paragraph to Impact CUL-01 on page 3.5-12:

As previously discussed mentioned, there are several prehistoric sites noted in the vicinity of the City of Willits. The ethnograpohic village of Mitoma is noted to be located in the southwestern portion of the City of Willits.

In response to this request, the following edits are made to the first two sentences in the introductory paragraph to Impact CUL-02 on page 3.5-14:

As discussed above, there are four (4) historic structures within the City of Willits limits.

Response to Comment 4-8
The comment letter requests a minor wording change to Mitigation Measure CUL-1. Cultural Resource Discovery Protocols New Implementation Measure for “Coordinate with Local Communities” Group:

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Rather, this comment requests that edits be made to Mitigation Measure CUL-1 to reflect that archaeological resources or cultural resources, including human remains would be inadvertently uncovered rather than discovered.

In response to this request, the following edits are made to Mitigation Measure CUL-1. Cultural Resource Discovery Protocols New Implementation Measure for “Coordinate with Local Communities” Group:

Implementation Measure LU-7.X1: In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or undiscovered 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 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 City of Willits | Final PEIR Comments Received Following Circulation September 2024 [36]
proceed in other parts of the project area while mitigation for cultural resources is being carried out.

Response to Comment 4-9
The comment letter requests a minor wording change to Mitigation Measure TCR-1. Avoid Impacts to Tribal Cultural Resources New Implementation Measure for “Coordinate with Local Communities” Group:

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Rather, this comment requests that edits be made to Mitigation Measure TCR-1 to further specific protections and that the locally-affiliated Native American Tribe be contacted in a timely manner.

In response to this request, the following edits are made to Mitigation Measure TCR-1. Avoid Impacts to Tribal Cultural Resources New Implementation Measure for “Coordinate with Local Communities” Group:

Implementation Measure LU-7.X3: If previously unidentified tribal cultural resources are encountered during project implementation, altering the materials and their stratigraphic context shall be avoided and work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [37]
LETTER 5 - MENDOCINO LAFCO
Comment received via email
Comment
5-1
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LETTER 5 – RESPONSE TO COMMENTS
Response to Comment 5-1
The comment letter expresses appreciation to the City of Willits for addressing the Mendocino LAFCo Notice of Preparation comments in the Draft EIR.

This comment addresses continuing to work with the City on the Sphere of Influence (SOI) Update and does not address EIR adequacy. No further response is necessary.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [39]
LETTER 6 - WILLITS ENVIRONMENTAL CENTER
Comment received via email
Comment
6-1
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6-1
(continued)
Comment
6-2
Comment
6-3
Comment
6-4
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6-4 continued Comment
6-5
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6-6
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6-7
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6-7 (continued)
Comment
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Comment
6-9
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [44]
LETTER 6 – RESPONSE TO COMMENTS
Response to Comment 6-1
The comment letter states that the proposed expanded Sphere of Influence (SOI) defined in the Draft Land Use Element is very large and that only a small portion of the SOI area is developed, only a portion of the land within the City planned for development is currently developed, and that there is “ample room” within the City to accommodate infill development. The comment letter also states that the SOI should not include undeveloped areas, especially those that include natural habitats.

This comment addresses the proposed SOI size, not the Draft EIR. The SOI must be approved by Mendocino LAFCo in a separate action. The comment indicates that a large proposed SOI would likely include a variety of environmental resources, and could result in a more dispersed pattern of development, this comment does not address a specific aspect of EIR adequacy. The Draft EIR addresses 3.4 Biological Resources potential biological resource impacts in Section 3.4 Biological Resources and vehicles miles traveled in Section 3.17 Transportation and Circulation.

No further response is necessary.

Response to Comment 6-2
The comment letter states that future development of the South Haehl Creek land use change area would involve the removal of vegetation, especially trees.

This comment does not identify new information not already disclosed as part of this Draft EIR, or EIR adequacy. Vegetation removal would be evaluated and mitigated at time of development.

The Land Use Element does not include any specific projects and instead enables development that could occur in the future. The Draft EIR is a program EIR that identifies important resources and evaluates potential impacts at a higher, programmatic, level focusing on the degree to which the application of existing federal and state regulations and existing and proposed local policies and regulations to a future application for development will ensure that the impacts of future project would be less than significant.

The Biological Resources analysis describes this approach under the heading of “Assumptions” on page 3.4.26, with the following: “The proposed Project is intended to facilitate growth and also has the potential to induce additional future growth indirectly. The Land Use Element Update assumes that the City population will grow to 7,500 during the Planning Period; however, the timing, location, and scale of future development consistent with the Project is unknown. In order to ensure that potential impacts to biological resources are not underestimated in this analysis, we assume the maximum realization of potential development for which the Land Use Element Update and Sphere of Influence Amendment are intended to accommodate.” The Biological Resources analysis assumes that the existing federal and state regulations and local policies, as well as the proposed policies of the Land Use Element, would be fully implemented as applicable to each future application for development. Where the analysis cannot reasonably assume that the implementation of the existing and proposed regulations and policies would adequately reduce potential impacts, this section requires new policies and implementation measures be fully implemented as mitigations that are necessary to further reduce the likelihood for potential development-related impacts to protected biological organisms identified in this analysis to a level that would be less than significant.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [45]
The Draft EIR evaluates the South Haehl Creek land use change area and the potential biological resource impacts that could occur if future development were to occur in this area. The “Vegetation” section of the 3.4 Biological Resources Environmental Setting describes the vegetation types present in the City and proposed SOI area. Potential impacts to resources within the South Haehl Creek area was specifically addressed in the Impact BIO-01, Potentially Significant Impacts to Special Status and/or Otherwise Protected Fish, Wildlife, and/or Botanical Taxa, where potentially significant impacts had the potential to occur without mitigation. A new policy is required to address potential biological resource impacts in areas that are proposed for annexation as well as the South Haehl Creek area (Mitigation BIO-01.2. Require Pre-Project Biological Resource Assessments and Surveys New Policy for “Protect Natural Resources within Areas Planned for Development” Group, Mitigation BIO-01.2).

This policy would require the preparation of pre-project biological resource assessments and surveys that would involve site- and/or project-specific biological resource assessments prior to annexing any properties into the City from the Proposed Sphere of Influence additions, and prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area. Biological resource assessments would also be required to identify mitigation measures to avoid and/or reduce impacts to protected biological resources to less than significant levels from all new development allowed within the study area by the General Plan. No further response is required.

Response to Comment 6-3
The comment letter recommends reducing or eliminating proposed SOI area due to potential open space, agricultural, watershed, riparian, and wetlands impacts.

This comment addresses the proposed Land Use Element Update and does not identify a specific aspect of EIR adequacy. SOIs can include and protect natural areas and resources. Section 3.4 Biological Resources addresses potential watershed, riparian, and wetlands impacts within the proposed SOI area and requires a series of mitigations to address potential resource impacts of future development. The mitigation described above specifically addresses biological resource assessments and measures to avoid and/or reduce impacts to protected biological resources to less than significant levels from all new development allowed within the study area by the General Plan proposed SOI area. Section 3.2 Agricultural and Forestry Resources evaluates agricultural uses within the proposed SOI, agricultural soils, and applies the Local Agency Formation Commission criteria for identifying Prime Agricultural Land and finds that potential impacts to agricultural resources are potentially significant and requires that a new policy be adopted as mitigation that would protect designated open space land and existing agricultural activities in potential annexation areas. No further response is required.

Response to Comment 6-4
The comment letter recommends planning the Baechtel Road land use change area be designated as open space to protect the riparian area and to provide land for a park. The comment letter states that the purpose of the secondary roadway that is a component of the planning for this land use change area is now unnecessary. The comment letter also encourages the creation of parks throughout the City.

This comment addresses the proposed Land Use Element Update and does not identify a specific aspect of EIR adequacy. No further response is necessary.

City of Willits | Final PEIR Comments Received Following Circulation September 2024 [46]
Response to Comment 6-5
The comment letter states that there are errors and omissions in the Draft EIR, including the lack of detail regarding class I streams within the City and the lack of specificity in describing potential significant impacts, details regarding mitigation measures including when or if they will be implemented. The comment letter also states that the following mitigation measures do not address potential impacts to the four Class I streams and are not CEQA mitigations, nor do they assure the streams will be protected: New Policy LU-9.X1-BIO-01.1. Utilize Biological Resource Inventory Assessment Tools During Project Review; Policy LU-9.X2-BIO-01.2. Require PreProject Biological Resource Assessments and Surveys; and New Policy LU-9.X3 - BIO-01.4.

Require Low Impact Development (LID) Stormwater Design Standards and Use of Appropriate Plant Species in LID and Other Development-Related Landscaping and Revegetation Efforts.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Chapter 1 of the Draft EIR defines the CEQA document for the Land Use Element and Sphere of Influence Update as a Draft Program Environmental Impact Report. The State of California General Plan Guidelines, 2017, on page 273 Chapter 10, CEQA, states that a “program EIR prepared for a general plan examines broad policy alternatives, considers the cumulative effects and alternatives to later individual activities where known, and contains plan-level mitigation measures. Later activities that have been described adequately under the program EIR will not require additional environmental documents (CEQA Guidelines § 15168(c)(2)).” The General Plan Guidelines further state on page 271 that the General Plan “EIR must identify mitigation measures and alternatives to avoid or minimize potential impacts, to the extent feasible. The general plan EIR is a particularly useful tool for identifying measures to mitigate the cumulative effects of new development.” “Pursuant to Public Resources Code section 21081.6, the general plan must incorporate the approved mitigation measures identified in the EIR into its policies and programs.”
Draft EIR Chapter 1, page 1.0-1 states the “PEIR provides a first-tier analysis of the potential environmental effects of the proposed Project. Section 15152 of the CEQA Guidelines indicates that tiering is appropriate when the sequence of analysis is from an EIR prepared for a general plan, policy, or program to an EIR or negative declaration for another plan, policy, or program of lesser scope, or to a site specific EIR or negative declaration if additional analysis is necessary.

Subsequent activities in accordance with the proposed Project are examined in light of this PEIR to determine whether an additional environmental document must be prepared. If a subsequent project or later activity would have effects that were not examined in this PEIR, or not examined at an appropriate level of detail to be used for the later activity, an initial study would need to be prepared to determine the appropriate environmental document.” This Draft EIR analyzes the potential impacts of implementing the Land Use Element Update and associated zoning, as well as a subsequent application to the Mendocino Local Agency Formation Commission to expand the City Sphere of Influence, which constitutes the Project as defined by CEQA. The Draft EIR evaluates the environmental conditions that currently exist and how those conditions could potentially be impacted by the implementation of the Land Use Element Update.

This evaluation takes into account the geography and nature of the City of Willits and proposed SOI, the setting, and other physical characteristics that affect the environment. The Land Use Element Update is a policy document that does not, and cannot, speculate on the specific characteristics or details of individual future projects that may be proposed. This EIR provides as much detail as possible and focuses on the secondary effects that can be expected from adoption City of Willits | Final PEIR Comments Received Following Circulation September 2024 [47]
of the of the General Plan but is not as detailed as an EIR for a specific construction project.

Content and process requirements for Program EIRs are found in the Title 14 CCR Chapter 3:

Guidelines for Implementation of the CEQA.

The comment letter states that the Draft EIR lacks detail regarding class I streams within the City and lacks specificity regarding potential significant impacts. The letter also specifically highlighted several mitigation measures and states that these mitigations do not address potential impacts to the four Class I streams and are not CEQA mitigations. The following paragraphs address the preceding statements in the comment letter.

Streams. Streams are described in Section 3.4, Biological Resources, Environmental Setting, Aquatic Resources, beginning on page 3.4-1. This section states that the “most significant streams within the Planning Area that feed Outlet Creek flow through the incorporated City limits and proposed expanded Sphere of Influence and include Willits, Mill, Broaddus, Baechtel, and Haehl Creeks.” This section generally describes the historic and present conditions of these streams and indicates that these streams are identified in the U.S. Fish and Wildlife Service’s National Wetlands Inventory. Figure 3.4a, Planning Area Aquatic Resources within the City of Willits Planning Area, shows the location of the specific creeks identified in the comment letter.

Table 3-4a identifies special status fish and wildlife taxa known from, or that have reasonable potential to occur within the City of Willits Planning Area and Table 3.4c. identifies Designated Critical Habitat and/or Essential Fish Habitat for Federally-Listed Taxa known from, or that have reasonable potential to occur within, the City of Willits Planning Area.

The Draft EIR states on pages 3.4-9 through 13: “Much of Outlet, Upp, Mill, Willits, Broaddus, Baechtel, Haehl, Davis, and Berry Creeks—including portions of their associated riparian habitats—within the incorporated City limits, the proposed expanded Sphere of Influence, and elsewhere within the Planning Area are federally-designated Critical Habitat for Coho Salmon (Oncorhynchus kisutch—Southern Oregon/Northern California ESU), Chinook Salmon (Oncorhynchus tshawytscha—California Coastal ESU), and “winter-run” Steelhead (Oncorhynchus mykiss irideus—Northern California DPS) (Table 3.4c). Although there is considerable overlap, the extent of the Critical Habitat designation for each species varies both within and between each of the aforementioned watersheds, all of which are also federallydesignated as Essential Fish Habitat for both Coho and Chinook Salmon as well (Table 3.4c).” Draft EIR Appendix B - Biological Resources, Table 1. Special Status Fish and Wildlife Taxa Known From, or That Have Reasonable Potential to Occur Within, the City of Willits Planning Area details pertinent distribution information for, and describes potentially suitable habitat for various life history stages of, special status fish (and other wildlife) taxa identified within the City of Willits Planning Area, and specifies individual tributary streams where that resolution of geographical information is available—including those streams identified within the comment letter.

Detail Regarding Potential Impacts. In Impact BIO-01: Potentially Significant Impacts to Special Status and/or Otherwise Protected Fish, Wildlife, and/or Botanical Taxa, the analysis describes potential direct impacts to streams and riparian areas in the following sentence: “Ministerial and/or discretionary projects that involve instream work (e.g., road or utility crossings, etc.) could result in the incidental take of special status aquatic (or semi-aquatic) organisms (including their eggs, larva, and/or immature individuals) such as state- and/or federally-listed Coho Salmon (Oncorhynchus kisutch—Southern Oregon/Northern California ESU), Chinook Salmon City of Willits | Final PEIR Comments Received Following Circulation September 2024 [48]
(Oncorhynchus tshawytscha—California Coastal ESU), and “winter-run” Steelhead (Oncorhynchus mykiss irideus—Northern California DPS); as well as other stream-dependent or associated special status organisms such as Pacific Lamprey (Entosphenus tridentatus), California Floater (Anodonta californiensis), Northwestern Pond Turtle (Emys marmorata), Redbellied Newt (Taricha rivularis), and/or Foothill Yellow-legged Frog (Rana boylii).” The analysis further enumerates the special status species that could be affected by development under the heading “Special Status Organisms Associated with Riparian Habitats.” Impact BIO-01 also describes and enumerates potential indirect and/or cumulative impacts, in particular under the headings “Potential Impacts to Special Status Aquatic Organisms Due to Development-Related Hydrological Alterations” and “Potential Impacts to Special Status Organisms Due to Removal or Degradation of Riparian Vegetation.” Additional analyses relating to streams and riparian areas can be found in Impact BIO-02: Potentially Significant Impacts to Riparian Habitats and/or Other Sensitive Natural Communities and Impact BIO-03: Potentially Significant Impacts to Stateand/or Federally-Regulated Wetlands and/or Waters. All of these impact analyses refer to the various tributary streams of the Outlet Creek watershed and other sensitive natural communities within the Proposed Sphere of Influence and/or within the City of Willits’ proposed Land Use Change Areas, as described in the Environmental Setting.

Mitigations. Given that the proposed project is an update to the General Plan Land Use Element and the nature, location, timing, and details of future projects are unknown, the biological resources impact analyses, summarized above, consider the degree to which existing and proposed goals, policies, and implementation measures proposed in the current City of Willits General Plan and proposed Land Use Element Update would protect streams, riparian habitats, other sensitive natural communities, and the biological organisms they support from development that may occur following the adoption of Land Use Element policy and changes to the General Plan Land Use Map. The impact analyses list each existing or proposed policy or implementation measure that could protect important resources. The analyses conclude that policies would likely reduce potential impacts to special status fish, wildlife, and/or botanical taxa identified herein, but additional mitigation is necessary to further reduce the likelihood for future potential developmentrelated impacts to protected biological organisms to a level that would be less than significant.

As described above, each of the impact topics lists current and proposed policies that would lessen potential environmental impacts. Those policies and the mitigations that revise them are summarized in the following (the policy numbering is revised to reflect the current Public Review Draft Land Use Element):

Policy LU-8.1 Riparian Buffer Areas is a high-level policy echoing Conservation and Open Space Policies and Mitigation Measures requiring project applicants that are located adjacent to streams to include appropriate measures to achieve stream channel and native riparian vegetation preservation. This is not a standalone policy, rather it is made operational by Policy LU-8.3 Riparian Area Land Use Overlay and Implementation Measure LU-8A Stream and Riparian Combining Zone which prohibits development within a buffer around stream/riparian areas and makes this the requirement for all projects.

Policy LU-8.2 No Net Loss of Wetlands Resulting from Development requires that the presence of potential wetlands in the vicinity of a proposed project be determined during the review process for discretionary projects and for ministerial building and grading permit applications to ensure that no net loss of wetlands results from development, consistent with Conservation and Open Space Policies and Mitigation Measures.

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Policy LU-8.3 Riparian Area Land Use Overlay is a policy, coupled with implementation Measure LU-8A Stream and Riparian Combining Zone, that further operationalizes Conservation and Open Space Element Implementation Measure 3.320 by requiring the implementation of a combining zone around streams that prohibits development within a prescribed buffer area, provides clear procedures requiring findings, in consultation with CDFW, for exceptions, vegetation removal and to avoid takings, and defines allowable uses in streams and riparian areas that shall not result in significant adverse effects to biological resources.

Mitigation BIO-01.2 revises Policy LU-8.3, Riparian Area Land Use Overlay, to define riparian buffer area metrics (100 feet for perennial streams and 50 feet for intermittent streams and 150 for perennial wetlands and 50 feet for seasonal wetlands) to ensure a minimum level of resources protection, requires the use of wildlife-permeable fencing materials and designs, and requires low impact development standards implementation and the use of locally-appropriate native vegetation in landscaping.

Policy LU-8.4 Protect Oak Trees and Woodlands, coupled with Implementation Measure LU-8B Oak Tree Protections, integrates important tree protections from the Urban Forest Management Plan into the Zoning Regulations to establish an oak tree and oak woodland retention and protection program applicable to new ministerial and discretionary development approvals that emphasizes the avoidance, minimization, or mitigation of oak tree and oak woodlands removal. (Source: New Policy) Mitigation BIO-01. New Policy LU-9.X1 Utilize Biological Resource Inventory Assessment Tools During Project Review requires the adoption of a new policy directing City staff to ensure that the best available biological resource mapping data (with specific references) is used as a screening tool during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to insignificant levels consistent with CEQA.

Mitigation BIO--01.2. New Policy LU-9.X2 Require Pre-Project Biological Resource Assessments and Surveys requires that site- and/or project-specific biological resource assessments be prepared by a qualified professional prior to annexing any properties into the City from the Proposed Sphere of Influence additions and prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area and specifies what the assessments shall address and that mitigation measures be defined to avoid and/or reduce impacts to less than significant levels and requires pre-project biological surveys and/or habitat delineations.

Mitigation BIO-01.4. New Policy LU-9.X3 Low Impact Development Stormwater Design Standards Near Important Streams requires that all development within 250 feet of Willits, Broaddus or Baechtel Creeks and their tributaries implement stormwater requirements from the Mendocino County Low Impact Development Standards Manual.

Mitigation BIO-01.4. New Policy LU-9.X4 Local Native Plant List requires that the City develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for development-related landscaping and revegetation and encourage the use of locally appropriate and locally sourced native City of Willits | Final PEIR Comments Received Following Circulation September 2024 [50]
vegetation, appropriately-selected revegetation seed applications, or blends for use in revegetation and landscaping efforts and prohibit the use of any plant species designated as: “invasive,” “noxious weed,” or “federal noxious weed.” Mitigation BIO-01. New Policy LU-9.X5 Require Appropriate Design Standards to Minimize Artificial Light Pollution requires that the design and location of all outdoor lighting fixtures associated with development prevent direct illumination of streams, wetlands, and Riparian Buffer Areas. This mitigation measure and new policy serve to avoid and/or reduce light pollution associated with development, which is known to adversely affect the migration, movements, and other important behaviors of salmonids, as well as other fish and wildlife taxa.

Mitigation BIO-01. New Policy LU-9.X6 Initiate Community Outreach to Reduce Impacts to Wildlife directs the City to partner with local organizations to educate applicants and residents about the impacts to special status and otherwise protected wildlife from toxic pest control methods and free-ranging house cats on special status and otherwise protected wildlife.

As described above, the Land Use Element update is not a specific project and therefore sitespecific impacts and mitigations cannot be developed. The proposed policies, as revised by the mitigations, should be considered comprehensive and appropriately protective of the biological resources within the City and proposed SOI expansion areas for future development, given that they:

1. ensure that the best available biological resource mapping data (with specific references) is used as a screening tool during the review of all ministerial and discretionary projects;

2. establish explicitly defined buffers around streams, known wetlands, and their associated riparian habitats within the City to be protected during development for all projects and require that consultation with CDFW occur and that findings be made for any exceptions;

3. establish a range of protective requirements, including low impact drainage infrastructure, native plantings, and non-pollutive lighting for development near riparian areas;

4. require that an oak tree and oak woodland retention and protection program be added to the Zoning Regulations applicable to new ministerial and discretionary development; and

5. require that annexations and development in the South Haehl Creek area prepare and adhere to the requirements of a biological resources assessment and mitigations to protect biological resources.

The Draft EIR preparers acknowledge that the implementation of General Plan measures through Zoning Regulations or otherwise by local agencies is not immediate and may be delayed for one reason or another. However, state law directs local agencies to ensure that all development occurs in a manner consistent with the General Plan.

Response to Comment 6-6
The comment letter recommends that Land Use Element implementations, such as the riparian protection overlay zone or changes to the Zoning Regulation relating to oak tree protections, be approved prior to the adoption of the Land Use Element. The comment letter also suggests that the Urban Forest Management Plan is used as a mitigation in the Draft EIR.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. Regarding the Urban Forest Management Plan, the Draft EIR City of Willits | Final PEIR Comments Received Following Circulation September 2024 [51]
states that “Implementation of the Land Use Element could result in potential impacts from development within open and wooded hillslope areas, grading for roads and other developed areas, and the removal of mature tree groves that contribute to visual quality. New development in areas such as the Baechtel Road land use change area (a change from Industrial-General (MG) to Geneal Mixed-Use (GM-U)) may allow more intense future development within an undeveloped area containing a riparian area along Baechtel Creek, periodic grazing, and potential oak woodlands. Policies LU-8.1, Riparian Buffer Areas, and LU-8.4, Protect Oak Trees and Woodlands, and associated policies and implementations would enhance protections for riparian areas and oak woodlands and limiting potential impacts to scenic vistas from Baechtel Road.” Policy LU-8.4, Protect Oak Trees and Woodlands, directs the City to Integrate important tree protections from the Urban Forest Management Plan into the Zoning Regulation and LU-8B, Oak Tree Protections requires the adoption of Zoning Standards to protect oak trees as part of new ministerial and discretionary development consistent with Urban Forest Management Plan. The policies and implementation measures use aspects of the Urban Forest Management Plan, adopted as Zoning Regulations, to protect oak trees and oak woodlands as part of development approval.

The proposed project is an update to the City of Willits Land Use Element. Based on the project description, the General Plan Land Use Element policy would be updated and subsequent amendments to the Zoning Regulations would occur to assure consistency with the General Plan.

As stated in response to comment 6-5, the proposed policies, as revised by the mitigations, should be considered comprehensive and appropriately protective of the biological resources within the City and proposed SOI expansion areas for future development. The EIR preparers acknowledge that the implementation of General Plan measures through Zoning Regulations or otherwise by local agencies is not immediate and may be delayed for one reason or another. However, state law directs local agencies to ensure that all development occurs in a manner consistent with the General Plan.

Response to Comment 6-7
The comment letter suggests that the Draft EIR concludes that there are no impacts to scenic resources because there are no designated state scenic highways and that the absence of certain state designated farmlands resulted in a conclusion that there are no soils “worthy of protection” or “vulnerable to significant impacts.” The comment letter also states that the Draft EIR bases it conclusion on the state of California designation of the Little Lake Groundwater Basin “very low priority”.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. In Section 3.1 Aesthetics, the Draft EIR identifies potential scenic resources and evaluates potential impacts thereto. Regarding state designated scenic highways, Threshold AES-02 is specific to CEQA Guidelines Appendix G Topic I(b) and assesses whether the Land Use Element Update would substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.

The Draft EIR analysis of impacts to state designated scenic highways was conducted based on this definition. For the purposes of CEQA, this analysis is sufficient to consider the potential impacts on state designated scenic highways. This analysis concludes that, given that there are no designated state scenic highways within the Planning Area, the proposed project would not damage scenic resources within a state scenic highway. Consequently, the project would have no impact.

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In addition to Impact Topic AES-02, Section 3.1 Aesthetics evaluated the potential for significant environmental effects relating to scenic resources in the following:
• Threshold AES-01 evaluated whether the Land Use Element would have a substantial adverse effect on a scenic vista and found that it could result in potential impacts from future development within open and wooded hillslope areas, grading for roads and other developed areas, and the removal of mature tree groves that contribute to visual quality.

Implementation of the Land Use Element could also result in potential impact the character of scenic vistas along State Route 20 west of Willits. However, the Land Use Element does not contain policies that would require that development on highly visible hillslopes be clustered or requiring that grading be minimized to protect scenic vistas. Therefore, this impact would be potentially significant, and mitigation would be required to minimize adverse effects on scenic vistas. Mitigation AES-1 requires clustered development, minimizing grading, and minimizing the removal of trees, potential adverse effects on a scenic vista would be reduced to less than significant levels. • Threshold AES-03 evaluates whether the Land Use Element would substantially degrade the existing visual character or quality of public views of the site and its surroundings and found that it could degrade existing visual character or quality of public views in non-urban areas and impacts would be potentially significant. Impacts would be reduced to less than significant levels with the implementation of Mitigation AES-1 that clusters new development, minimizes grading and preserves trees and native vegetation that contribute to visual quality
The Draft EIR comprehensively identifies potential agricultural resources and evaluated potential impacts thereto. Impact Topic AG-01 is specific to CEQA Guidelines Appendix G Topic II(a), which is focused on whether the project would convert Prime Farmland, Farmland of Statewide Importance, or unique farmland, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency to non-agricultural use. The City conducted its analysis of impacts in Impact Topic AG-01 based on this definition. For the purposes of CEQA, this analysis is sufficient to consider the potential impacts on agricultural resources relating to Impact Topic AG-01. The Draft EIR sought to comprehensively evaluate the potential for impacts to agricultural resources by evaluating County General Plan Land Use and Zoning, soils based on the USDA Natural Resources Conservation Service (NRCS), and the use of land based on Assessor’s and geographic information data.

In addition to Impact Topic AG-01, Section 3.2 Agricultural and Forestry Resources evaluated the potential for significant environmental effects relating to agricultural resources in the following:
• Threshold AG-02 evaluated whether the project would conflict with existing zoning for agricultural use, or a Williamson Act contract, finding that there are lands within the proposed SOI that are zoned for an agricultural use and that there are no lands subject to Williamson Act contracts, although there are Williamson Act lands adjacent to the proposed SOI and City. This analysis found that there is the potential for the proposed Land Use Element Update to convert land currently used for agricultural purposes to a non-agricultural uses, and that land adjacent to the proposed SOI is enrolled in the Williamson Act and the potential future annexation and development of SOI land could increase the likelihood that these lands may be converted to non-agricultural uses and as a result the proposed land uses in the Sphere of Influence area represent a potentially significant environmental effect that requires mitigation. Mitigation AG-01: Proposed New City of Willits | Final PEIR Comments Received Following Circulation September 2024 [53]
Policy: Annexation Planning adds a requirement that, when the City is considering proposals for annexation, designated open space land and existing agricultural activities must be protected This proposed policy adds consideration of open space preservation to other proposed annexation policy considerations included in the Land Use Element Update. Proper planning by the City in these proposed SOI areas prior to annexation would result in less than significant impacts.
• Threshold AG-05 evaluated whether the project involves 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. This analysis identified each parcel within the proposed SOI that contains irrigated or prime soils if irrigated and drained as mapped by the NRCS. The analysis found that The proposed Land Use Element Update would apply land use designation that would allow more intensive residential uses and as a result, the Project could result in the conversion of prime agricultural soils to a non-agricultural use. The Land Use Element Update contains Policy LU-2.4 that is intended to preserve open space land as part of annexation.

However, this policy may not be adequate to ensure that the potential for the conversion of Farmland to a non-agricultural use is less than significant. By including Mitigation Measure AG-01, the annexation planning process would be expanded to protect agricultural operations on prime agricultural soils. Through the implementation of this mitigation measure, potential impacts from the conversion of prime agricultural soils would be less than significant.

In Impact HYD-01, the Draft EIR evaluates whether the proposed Land Use Element Update would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. In Impact HYD-02, the Draft EIR evaluates whether the proposed Land Use Element Update would substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that it may impede sustainable groundwater management of the basin. Impact HYD-01 states that the Little Lake Groundwater Management Plan is voluntary and non-regulatory; which is due to the fact the state of California designates this groundwater basin as “low priority.” The state Sustainable Groundwater Management Act requires” medium- and high-priority basins” to develop groundwater sustainability agencies, develop groundwater sustainability plans and manage groundwater for long-term sustainability. The City of Willits has prepared a voluntary, non-regulatory groundwater management plan that describes existing local groundwater management policies and recommends a range of actions that the City of Willits may take within the boundaries of its legal authority, to monitor, analyze, and interpret characteristics of the Little Lake Valley groundwater basin. The analysis in Impact HYD-02 concludes that because the City of Willits water system has sufficient water to serve the Planning Area during times of non-drought, and the City of Willits Council could approve an increase in groundwater usage during time of emergency, the water system would have adequate water supply to serve current demand and future development that may be facilitated by the proposed Project. Additionally, as groundwater in the Basin appears to recover quickly from declines, the proposed Project would not interfere with groundwater recharge or impede sustainable groundwater management. A less than significant impact would occur.

Impact HYD-01 evaluates whether the Land Use Element Update would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. This analysis concludes that development facilitated by the proposed Land Use Element Update would be required to comply with the state Construction General Permit City of Willits | Final PEIR Comments Received Following Circulation September 2024 [54]
Order 2022-0057-DWQ and City of Willits Design and Construction Standards, and because the existing General Plan and proposed Land Use Element Update contains policies consistent with protecting surface water and groundwater quality, the proposed Land Use Element Update would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. The impact would be less than significant.

The conclusion in Impact HYD-02 also relates to the analysis in Impact UTL-02, which evaluates whether the Land Use Element Update would have sufficient water supplies available to serve the planned growth and reasonably foreseeable future development during normal, dry and multiple dry years. This analysis concluded that the City currently produces an average of 867 AF of water per year, it is anticipated that the City would produce approximately 1,076 AF per year with the development anticipated in the Land Use Element Update. The City’s theoretical water supply is 4,317 AF. If the projected development were to occur, the projected water usage would equate to approximately 25 percent of the City’s theoretical water supply. Therefore, the City has sufficient water supply to serve the City’s current and projected water demand.

Response to Comment 6-8
The comment letter states that new development will hinder or block water infiltration and could cause increased flooding and that Little Lake Valley groundwater, on which the city is now relying for adequate water, is solely recharged from rainfall, every impermeable surface limits the recharge of the basin, and that a state-of-the-art groundwater assessment should be done prior to any expansion proposal.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. This comment appears to relate to the proposed Land Use Element and to not the adequacy of the Draft EIR. The Draft EIR addresses groundwater recharge in Section 3.10, Hydrology and Water Quality, Environmental Setting, Groundwater, on page 3.10-

1. The Draft EIR, citing the Little Lake Valley Groundwater Management Plan, states that the “main source of recharge in the Basin is precipitation, although other sources of recharge include surface water infiltration, return flows from sewage and irrigation, and the potential up flow of groundwater along fault zones. Groundwater levels in the Basin fluctuate principally in response to pumping and precipitation, with seasonal variations. Long term groundwater levels have been observed to be relatively flat to slowly recovering from heavy well pumping and drought.

Additionally, current groundwater levels are as high or higher than the earliest recorded data.” As described in Response to Comment 6-7, the Draft EIR in HYD-02 concludes that groundwater in the Little Lake Valley Groundwater Basin appears to recover quickly from declines, the proposed Land Use Element Update would not interfere with groundwater recharge or impede sustainable groundwater management and that a less than significant impact would occur.

Response to Comment 6-9
The comment letter states that the City of Willits is out of compliance with its State water right and that the City should be operating under a State-approved water right prior to approval of the Land Use Element Update.

This comment addresses the proposed Land Use Element content and not the adequacy of the Draft EIR. Draft EIR Section 3.18 Utilities and Service Systems, Environmental Setting, Surface Water on page 3.18-1 and Source Water Summary on page 3.18-5 describes the City’s surface water rights to Davis Creek.

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LETTER 7 - RUTH FORD
Comment received via email
Comment
7-1 Comment
7-2
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LETTER 7 – RESPONSE TO COMMENTS
Response to Comment 7-1
The comment letter states that housing units are not appropriate uses within the East Hill land use change area and would be incompatible and could create conflicts with the surrounding area and with neighboring agricultural uses. Agriculture is the appropriate use for the East Hill land use change area. The Willits Geneal Plan emphasizes infill before annexation of new areas, limiting incompatible uses, and other aspects of open space and resource protection. This land use change would not be consistent with these aspects of the General Plan.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. This comment appears to relate to the proposed Land Use Element and not to the adequacy of the Draft EIR. The Draft EIR evaluates potential impacts to agricultural resources in Section 3.2 Agricultural and Forestry Resources, including impact topics that evaluate the following:
• Threshold AG-01, the potential to 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 nonagricultural use. The Draft EIR comprehensively identifies potential agricultural resources and evaluated potential impacts thereto. Impact Topic AG-01 is specific to CEQA Guidelines Appendix G Topic II(a), which is focused on whether the project would convert Prime Farmland, Farmland of Statewide Importance, or unique farmland, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency to non-agricultural use. The City conducted its analysis of impacts on agricultural resources based on this definition. For the purposes of CEQA, this analysis is sufficient to consider the potential impacts on agricultural resources relating to Impact Topic AG-01.
• Threshold AG-02 evaluated whether the project conflict with existing zoning for agricultural use, or a Williamson Act contract, finding that there are lands within the proposed SOI that are zoned for an agricultural use there are no land subject to Williamson Act contracts, although there Williamson Act lands adjacent to the proposed SOI and City. This analysis found that there is the potential for the proposed Land Use Element Update to convert land currently used for agricultural purposes to a non-agricultural uses, and that land adjacent to the proposed SOI is enrolled in the Williamson Act and the potential future annexation and development of SOI land could increase the likelihood that these lands may be converted to non-agricultural uses, the proposed land uses in the Sphere of Influence area represent a potentially significant environmental effect that requires mitigation. Mitigation AG-01: Proposed New Policy: Annexation Planning adds a requirement that, when the City is considering proposals for annexation, designated open space land and existing agricultural activities must be protected This proposed policy adds consideration of open space preservation to existing annexation policy considerations.

Proper planning in these proposed SOI areas by the City prior to annexation would result in less than significant impacts.
• Threshold AG-05 evaluated whether the project involves 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. This analysis identified each parcel within the proposed SOI that contains irrigated or prime soils if City of Willits | Final PEIR Comments Received Following Circulation September 2024 [57]
irrigated and drained as mapped by the NRCS. The analysis found that The proposed Land Use Element Update would apply land use designation that would allow more intensive residential uses and as a result, the Project could result in the conversion of prime agricultural soils to a non-agricultural use. The Land Use Element Update contains Policy LU-2.4 that is intended to preserve open space land as part of annexation.

The analysis in Section 3.2 Agricultural and Forestry Resources lists a number of policies of the City of Willits General Plan and Land Use Element Update that seek to preserve agricultural land and that allow agricultural uses as interim uses of vacant land. Unlike most other land evaluated in Section 3.2 Agricultural and Forestry Resources, the East Hill land use change area is located within the City, and no annexation is needed. This land is currently planned Open Space - Recreation (0-R), which is applied to sites which are to be used primarily for open space and/or recreation purpose. The Zoning that is currently applied allows recreational, conservation or light agricultural types. Although there is no record of this in the General Plan, City staff indicates that this Land Use Designation was applied as a holding designation to areas that may be involved in the U.S. 101 bypass project.

This property is one of very few City parcels that are located on the east side of U.S. 101 and is directly adjacent to smaller parcels that contain single family residences and U.S. 101. Further east of the East Hill land use change area there is property zoned for agriculture uses that is across the street from land planned and zoned for rural residential uses containing lots that range from less than one acre in size to several acres. There are other similar areas adjacent to the City within the unincorporated area that area planned by the County for zoned for residential uses residential uses of varying density (e.g., multiple family or suburban residential) and are adjacent to land zoned for agriculture.

The above referenced agricultural resources analyzed whether the Land Use Element Update involves other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use. The Land Use Element includes several policies in the Planning Area group under Goal LU-1, to maintain a compact City boundary as well as surrounding open space, working lands and natural resources and Goal LU-2, which promotes growth within infill and redevelopment sites near neighborhood commercial areas that are intended to support County land use regulations that protect the viability of local agriculture in the Little Lake Valley. The Land Use Element encourages the County to protect agricultural land and open space within the Planning Area. Policy LU-1.1, Planning Area, request that Mendocino County and the Local Agency Formation Commission refer applications for development or changes in organization within the Planning Area to the City for review and comment and encourages the County to implement measures to protect areas within the Planning Area not planned for development, including the City watersheds and groundwater recharge areas.

This analysis concluded that the Land Use Element Update has the potential for the conversion of Farmland to a non-agricultural use and by including Mitigation Measure AG-01, the annexation City of Willits | Final PEIR Comments Received Following Circulation September 2024 [58]
planning process would be expanded to protect agricultural operations on prime agricultural soils.

Through the implementation proposed policies and this mitigation measure, potential impacts from the conversion of prime agricultural soils would be less than significant.

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LETTER 8 - MENDOCINO COUNTY FARM BUREAU
Comment received via email
Comment
8-1
City of Willits | Final PEIR Comments Received Following Circulation September 2024 [60] Comment
8-2 Comment
8-3 Comment
8-4
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LETTER 8 – RESPONSE TO COMMENTS
Response to Comment 8-1
The comment letter states that the concerns relate to the potential impact to agriculture, particularly within the neighboring unincorporated areas, from the application of new General Plan Land Use Designations and Zoning Classifications within the SOI and the potential conflict between City land use and zoning and County land use and zone.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. The following paragraphs are intended to demonstrate that the Draft EIR addresses potential impacts to agriculture, particularly within the neighboring unincorporated areas, from the application of new General Plan Land Use Designations and Zoning Classifications within the SOI and the potential conflict between City land use and zoning and County land use and zone.

The Draft EIR evaluates potential impacts to agricultural resources and potential conflict with existing zoning for agricultural use in Section 3.2 Agricultural and Forestry Resources, including impact topics that evaluate the following:
• Threshold AG-01, the potential to 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 nonagricultural use. The Draft EIR comprehensively identifies potential agricultural resources and evaluated potential impacts thereto. Impact Topic AG-01 is specific to CEQA Guidelines Appendix G Topic II(a), which is focused on whether the project would convert Prime Farmland, Farmland of Statewide Importance, or unique farmland, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency to non-agricultural use. The City conducted its analysis of impacts on agricultural resources based on this definition. For the purposes of CEQA, this analysis is sufficient to consider the potential impacts on agricultural resources relating to Impact Topic AG-01.
• Threshold AG-02 evaluated whether the project conflicts with existing zoning for agricultural use, or a Williamson Act contract, finding that there are lands within the proposed SOI that are zoned for an agricultural use there are no land subject to Williamson Act contracts, although there Williamson Act lands adjacent to the proposed SOI and City.

Table 3.3a East Valley Street Sphere of Influence Land Use Designation Changes, on page 3-2.9 lists the parcels within the proposed SOI that are planned and zoned for agricultural use and identifies the actual use of land. The analysis states that in most all cases the proposed Land Use Designations reflect the current use of land. For instance, APN 007-031-07 is zoned AG-40 and is less than one acre and contains a single-family dwelling which is proposed to be planned R-M, Residential Medium Density, like the current County Zoning of the five adjacent parcels to the east. As these proposed land use zoning changes do not change the current use, they will have no new impact on any existing agricultural use on the property or potential adjacent agricultural activities. Three adjacent developed parcels that average 2.5 acres in area are planned and zoned for agriculture by Mendocino County and show evidence of grazing or haying. The City proposed to plan and zone these three parcels in a manner consistent with the current County plan and zone. There are no other parcels within the proposed SOI that are planned and zoned for agricultural use.

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The analysis in Threshold AG-02 found that there is the potential for the proposed Land Use Element Update to convert land currently used for agricultural purposes to a nonagricultural uses, and that land adjacent to the proposed SOI is enrolled in the Williamson Act and the potential future annexation and development of SOI land could increase the likelihood that these lands may be converted to non-agricultural uses, the proposed land uses in the Sphere of Influence area represent a potentially significant environmental effect that requires mitigation. Mitigation AG-01: Proposed New Policy: Annexation Planning adds a requirement that, when the City is considering proposals for annexation, designated open space land and existing agricultural activities must be protected This proposed policy adds consideration of open space preservation to existing annexation policy considerations. Proper planning in these proposed SOI areas by the City prior to annexation would result in less than significant impacts. • Threshold AG-05 evaluated whether the project involves 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. This analysis identified each parcel within the proposed SOI that contains prime soils or prime soils if irrigated and drained as mapped by the NRCS. Table 4.3b: Use of Parcels in SOI with Prime Soils, beginning on page 3-2.13 lists all parcels in the proposed SOI where are least some portion of the parcels contains prime agricultural soils This table lists the County, and proposed City, Land Use Designation and Zone and the Assessor’s, or observed, use of land for that parcel.

The analysis found that the proposed Land Use Element Update would apply land use designation that would allow more intensive residential uses and as a result, the Project could result in the conversion of prime agricultural soils to a non-agricultural use. The Land Use Element Update contains Policy LU-2.4 that is intended to preserve open space land as part of annexation. However, this policy may not be adequate to ensure that the potential for the conversion of Farmland to a non-agricultural use is less than significant.

By including Mitigation Measure AG-01, the annexation planning process would be expanded to protect agricultural operations on prime agricultural soils. Through the implementation of this mitigation measure, potential impacts from the conversion of prime agricultural soils would be less than significant.

It is important to note that the Land Use Designations applied to the proposed SOI area do not have any effect on the land use policies and regulations that apply within County land use jurisdiction. City land use jurisdiction, General Plan policy, and Zoning Regulations would only apply to areas within the proposed SOI only after a future annexation application, that is consistent with the City General Plan, undergoes CEQA review, is consistent with Mendocino Local Agency Formation Commission policy, and is approved by the Local Agency Formation Commission. The City has stated that it does not have plans to annex any land in the proposed SOI and would likely do so only when consistent with City General Plan policies regarding infill, population growth, residential land supply, annexations, and planned growth in the Planning Area and Planning for Growth policy groups, and after an interested land owner requests to be annexed.

Most of the proposed SOI is planned for some level of rural or suburban residential development, aside from the parcels on East Valley Street described above, and most developed parcels have City of Willits water. Policy LU-1.3, County General Plan Land Use Within Sphere Of Influence, City of Willits | Final PEIR Comments Received Following Circulation September 2024 [63]
seeks an agreement with the County on appropriate interim land use designations and zoning classifications for Sphere of Influence areas that any development prior to annexation is consistent with the City of Willits General Plan and does not prevent attainment of planned densities. The Land Use Element encourages the County to protect agricultural land and open space within the Planning Area. Policy LU-1.1, Planning Area, request that Mendocino County and the Local Agency Formation Commission refer applications for development or changes in organization within the Planning Area to the City for review and comment and encourages the County to implement measures to protect areas within the Planning Area not planned for development, including the City watersheds and groundwater recharge areas. In addition, Mitigation AG-01 would add a new Policy, LU-2.X Annexation Planning, that would discourage the approval of urban development within the City’s Sphere of Influence until such lands are annexed by the City, support County land use regulations that protect the viability of local agriculture in the Little Lake Valley, and would direct the City to, when considering proposals for annexation, protect designated open space land and existing agricultural activities.

Response to Comment 8-2
The comment letter states that the inclusion of agricultural lands in the SOI could result in the loss of prime farmland and open space and the Draft EIR should provide more detail on potential impacts to agriculture, including potential agricultural conversion and water availability.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. The Draft EIR evaluates potential impacts to prime farmland in Threshold AG-01, which evaluated the potential to 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 nonagricultural use; Threshold AG-02, which evaluated whether the project conflicts with existing zoning for agricultural use, or a Williamson Act contract; and Threshold AG-05, which evaluated whether the project involves other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use. The 3.2 Agricultural and Forestry Resources Environmental Setting and analysis in Threshold AG-05 provide extensive detail regarding the presence of prime soils within the proposed SOI using the USDA Natural Resource Conservation Service Web Soil Survey and the use of parcels that contain prime soils.

The analysis in Threshold AG-02 and Threshold AG-05 evaluates the potential for the Land Use Element Update and potential future annexations to the City of Willits to convert prime soils or agricultural activities to an urban use. See Response to Comment 8-3 for information regarding the Draft EIR evaluation of water availability.

Response to Comment 8-3
The comment letter states that the expansion of the SOI raises concerns about water availability an infrastructure capacity and that the Draft EIR should contain more detailed information about the impact of the Land Use Element Update on water supply, stormwater management, and wastewater treatment.

This comment does not identify a new impact or identify information that has not already been disclosed as part of this Draft EIR. In Impact HYD-01, the Draft EIR evaluates whether the proposed Land Use Element Update would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Impact HYD-02, the Draft EIR evaluates whether the proposed Land Use Element Update would substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that it City of Willits | Final PEIR Comments Received Following Circulation September 2024 [64]
may impede sustainable groundwater management of the basin. Impact HYD-01 states that the Little Lake Groundwater Management Plan is voluntary and non-regulatory; which is due to the fact the state of California designates this groundwater basin as “low priority.” The state Sustainable Groundwater Management Act requires medium- and high-priority basins to develop groundwater sustainability agencies, develop groundwater sustainability plans and manage groundwater for long-term sustainability. The City of Willits has prepared a voluntary, nonregulatory groundwater management plan that describes existing local groundwater management policies and recommends a range of actions that the City of Willits may take within the boundaries of its legal authority, to monitor, analyze, and interpret characteristics of the Little Lake Valley groundwater basin. The analysis in Impact HYD-02 concludes that because the City of Willits water system has sufficient water to serve the planned land uses identified in the Land Use Element Update during times of non-drought, and the City of Willits Council could approve an increase in groundwater usage during time of emergency, the water system would have adequate water supply to serve current demand and future development that may be facilitated by the proposed Project. Additionally, as groundwater in the Basin appears to recover quickly from declines, the proposed Project would not interfere with groundwater recharge or impede sustainable groundwater management. A less than significant impact would occur.

The conclusion in Impact HYD-02 also relates to the analysis in Impact UTL-02, which evaluates whether the Land Use Element Update would have sufficient water supplies available to serve the planned growth, a total of 7,500 people within City limits, and reasonably foreseeable future development during normal, dry and multiple dry years. This analysis concluded that the City currently produces an average of 867 AF of water per year, it is anticipated that the City would produce approximately 1,076 AF per year with the development anticipated in the Land Use Element Update. The City’s theoretical water supply is 4,317 AF. If the projected development were to occur, the projected water usage would equate to approximately 25 percent of the City’s theoretical water supply. Therefore, the City has sufficient water supply to serve the City’s current and projected water demand.

Impact HYD-01 evaluates whether the Land Use Element Update would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. This analysis concludes that development facilitated by the proposed Land Use Element Update would be required to comply with the state Construction General Permit Order 2022-0057-DWQ and City of Willits Design and Construction Standards, and because the existing General Plan and proposed Land Use Element Update contains policies consistent with protecting surface water and groundwater quality, the proposed Land Use Element Update would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. The impact would be less than significant.

3.10 Hydrology and Water Quality, Environmental Setting, Flooding and Dam Inundation, on page

3.10-1 describes the conditions relating to flooding within the Planning Area and Figure 3.10a shows Federal Emergency Management Agency Flood Zones. The Environmental Setting relating Stormwater Runoff is presented on page 3.10-3. Impact HYD-03 analyzes whether the Land Use Element Update would substantially alter the existing drainage patterns in a manner which would result in substantial erosion or siltation, substantially increase the rate or amount of surface runoff, 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 flood flows. This analysis is organized by first evaluating the potential for City of Willits | Final PEIR Comments Received Following Circulation September 2024 [65]
the Land Use Element Update to cause erosion and siltation; next the potential for increased surface runoff or polluted runoff, then whether he Land Use Element Update would impede or redirect flood flows. The analysis finds that adherence to the State Water Resources Control Board National Pollutant Discharge Elimination System General Permit and City of Willits Design and Construction Standards would result in less than significant impacts relating to stormwater drainage and flood flows.

Impact HYD-04 analyzes whether the Land Use Element and facilitated development would result in flood hazard, tsunami, or seiche zones, or risk release of pollutants due to project inundation.

This analysis notes that portions of the City and proposed SOI area are within the mapped 100- year and 500-year flood zones, primarily in the northeastern portion of the Project Area and that the Sphere of Influence Areas and Land Use Change Areas containing flood zones would have the potential to facilitate additional residential development. The analysis finds that compliance with the and City of Willits Design and Construction Standards and Construction General Permit requires stormwater controls and specific best management practices to be implemented to minimize the amount of sediment and other pollutants associated with construction sites from being discharged in stormwater runoff. Additionally, development located within a flood zone would be required to comply with Title 17 Sections 38 and 40 of the City of Willits Municipal Code, which regulates development in flood zones and requires that development and construction within flood zones be designed to withstand floods.

Draft EIR Section 3.18, Utilities and Service Systems Impact UTL-03, analyzes the capacity of the wastewater treatment plant to serve projected demand. The Environmental Setting in Section

3.18, Utilities and Service Systems, a background section for the environmental analysis, contains a section entitled “Wastewater System Service Area and Infrastructure” that describes the existing geographic service area and population served by the wastewater collection, treatment, and disposal system, and current wastewater production, design capacity, permitted average monthly flows. Impact UTL-03 provides an estimate of projected wastewater flows (see Table 3.18j Projected Wastewater Flows on page 3.18-26) and finds that that the treatment plant would have adequate capacity to provide wastewater services to the projected population and that a less than significant impact would occur. Please see response to comments 2-2 through 2-4 for additional details regarding the sources of data used in the Impact UTL-03 analysis.

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3. COMMENTS RECEIVED FOLLOWING CIRCULATION

3.1 COMMENTS RECEIVED VIA LETTER OR EMAIL
No Draft EIR related comments have been received since the close of the comment period on September 12, 2024.

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4. ERRATA, REVISIONS AND CLARIFICATIONS
The following revisions and clarifications reflect the response to comments in Chapter 2 Response to Comments and additional revisions and clarifications that have been identified by the Draft EIR preparers during the review of the Draft EIR.

4.1 TEXT REVISIONS AND CLARIFICATIONS
CHAPTER 1.0 INTRODUCTION AND SUMMARY
• 1.1 Project Background and Purpose. Page 1.0-2 first full paragraph should be revised to remove all yellow highlighting and to show the correct reference Appendix A. Scoping Comments.

To define the scope of the investigation of the Draft PEIR. The City distributed a Notice of Preparation (NOP) on February 8, 2023, to the State Clearinghouse, State agencies, Cities, and Humboldt County; other public agencies; and interested private organizations and individuals, in accordance with the requirements of the California Code of Regulations, Title 14, Sections 15082(a), 15103, and 15375. Pursuant to Section 15082 of the CEQA Guidelines, recipients of the NOP were requested to provide responses within 30 days after their receipt of the NOP. An initial study was not prepared with NOP; CEQA Guidelines Section 15063(a) permits a lead agency to omit an initial study if it determines that an EIR is clearly required. The purpose of the NOP was to identify agency and public concerns regarding potential impacts of the proposed Project. The following is a list of the comment letters received during the NOP public comment period, a brief summary of the issues raised, and reference to where the issues are discussed in the EIR. The NOP comment letters are included in Appendix XA of the EIR.
• All instances of the word “Tribe” in Section 1.7 Summary of Impacts and Mitigation Measures should be should have a capitalized “T”.

CHAPTER 2.0 PROJECT DESCRIPTION
• Corrections to Section 2.5 Features of the Land Use Element Update, Zoning Map and Regulations, Add Stream and Riparian Area Combining Zone, page 2.0-48 Add Stream and Riparian Area Combining Zone
Add a Stream and Riparian Area Combining Zone to parcels that contain or are adjacent to natural creeks, streams, and riparian habitats that specifies protective criteria consistent with consistent with to the Land Use Element Riparian Area Land Use Overlay. The Combining Zone shall prohibit development within buffer areas30 feet from the top of bank on either side of the stream, and shall contain regulations tohe implement the following requirements and exceptions: buffers may be reduced or eliminated where the City determines, in consultation with CDFW, that the reduction will not significantly affect the biological resources of the creek or stream within the property; when the prescribed buffer prohibits development of the site for the primary use for which it is designated, measures shall be applied that allow development that results in the least environmentally damaging feasible project; road, bridge, and trail City of Willits | Final PEIR Errata
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construction or replacement may be permitted that would not degrade fish and wildlife resources or water quality, and where vegetative clearing is kept to a minimum; the removal of vegetation for disease control or public safety purposes may be approved, in consultation with CDFW.

CHAPTER 3.0 ENVIRONMENTAL ANALYSIS – GLOBAL CHANGE
• The following references to “Section 4”, not otherwise corrected in this Final EIR, should be revised to refer to “Section 3” on the following pages:
o Section 3.6 Energy in the third and fourth paragraph on page 3.6-11 should be revised as follows, replace Chapter 4.17 with Section 3.17 Transportation and Circulation.
o Section 3.9 Hazards and Hazardous Materials, Environmental Setting, Hazardous Materials, second paragraph on page 3.9-1 should be revised as follows, replace Section 4.13 Noise with Section 3.13 Noise.
o Section 3.9 Hazards and Hazardous Materials, Environmental Setting, Fire Hazards on page 3.9-8 should be revised as follows, replace Section 4.13 Noise with Section 3.13 Noise.
o Section 3.9 Hazards and Hazardous Materials, Impact HAZ-07 on page 3.9-24 should be revised as follows, replace Section 4.19 Wildfire with Section 3.19 Wildfire.
o Section 3.15 Public Services introductory paragraph on page 3.15-1 should be revised as follows, replace section 4.17 Recreation with Section 3.16 Recreation. o Section 3.15 Public Services Environmental Setting, Parks on page 3.15-1 should be revised as follows, replace section 4.16 Recreation with Section 3.16 Recreation.
o Section 3.15 Public Services, Impact PS-01d on page 3.15-1 should be revised as follows, replace section 4.17 Recreation with Section 3.16 Recreation. o Section 3.19 Wildfire, B. Wildfire Conditions, Pre-Fire Management Tactics on page 3.19-9 should be revised as follows, replace Section 4.16 Public Services with Section 3.15 Public Services.
o Section 3.19 Wildfire, Impact WF-04 on page 3.19-32 should be revised as follows, replace Section 4.10 Hydrology and Water Quality with Section 3.10 Hydrology and Water Quality.
o Section 3.19 Wildfire, Impact WF-05A, Category 6. Evacuation Egress, on page

3.19-37 should be revised as follows, replace Section 4.15 Public Services with Section 3.15 Public Services.

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CHAPTER 3.0, SECTION 3.4 BIOLOGICAL RESOURCES
• References to Figure 2-1 should be revised on the following pages:
o Section 3.4, Environmental Setting, Aquatic Resources pages 3.4-2 through 3.4- 3: references to Figure 2-1 should be changed to Figure 3.4a to refer to Planning Area Aquatic Resources within the City of Willits Planning Area • Appendix B PDF pages 2 through 28:

Appendix BA, Table 1. Special Status Fish and Wildlife Taxa Known From, or That Have Reasonable Potential to Occur Within, the City of Willits Planning Area. Within each category, taxa are listed alphabetical order. Referenced sources of distribution information reflect the results of “positive reporting” methodologies; a lack of occurrence data for any particular resource in any particular location should not be misconstrued to represent “absence” or lack of suitable habitat unless explicitly stated as such with substantiating information.
• Appendix B PDF pages 30 through 41:

Appendix BA Table 2. Special Status Botanical Taxa Known From, or That Have Reasonable Potential to Occur Within, the City of Willits Planning Area. Within each botanical category, taxa are listed alphabetically. Referenced sources of distribution information reflect the results of “positive reporting” methodologies; a lack of occurrence data for any particular resource in any particular location should not be misconstrued to represent “absence” or lack of suitable habitat unless explicitly stated as such with substantiating information.
• Appendix B PDF pages 43 through 54, delete the following because it is the same as Appendix BA Table 2:

Table Botanical. Special Status Botanical Taxa Known From, or That Have Reasonable Potential to Occur Within, the City of Willits Planning Area. Within each botanical category, taxa are listed alphabetically. Referenced sources of distribution information reflect the results of “positive reporting” methodologies; a lack of occurrence data for any particular resource in any particular location should not be misconstrued to represent “absence” or lack of suitable habitat unless explicitly stated as such with substantiating information. • Appendix B PDF pages 56 through 54, delete the following Table because it is the same as Appendix BA Table 1:

Table Wildlife. Special Status Fish and Wildlife Taxa Known From, or That Have Reasonable Potential to Occur Within, the City of Willits Planning Area. Within each category, taxa are listed alphabetical order. Referenced sources of distribution information reflect the results of “positive reporting” methodologies; a lack of occurrence data for any particular resource in any particular location should not be misconstrued to represent “absence” or lack of suitable habitat unless explicitly stated as such with substantiating information.

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CHAPTER 3.0, SECTION 3.5 CULTURAL AND TRIBAL CULTURAL RESOURCES • All instances of the word “Tribe” in Section 3.5 Cultural and Tribal Cultural Resources should have a capitalized “T”.
• the following text shall be added to Section 3.2 Agricultural and Forestry Resources Environmental Setting (B) Agriculture on page 3.2-3 before the heading “Regional History”:
“Regional Pre-contact
This is the unceded traditional territory of the local indigenous people past and present. Tribal communities with cultural ties to the land depend on access to maintain traditional ecological knowledge and continued lifeways. Indigenous people were not apart from nature but were a part of nature, and lived accordingly.

Throughout pre-contact and continuing to present day the local Indigenous groups stewarded the land as their cultural resource. Indigenous traditional agroecological practices were a lifeway built upon a rich oral tradition that passed along essential knowledge of stewardship techniques honed to perfection intergenerationally through application and observation. From burning, pruning, coppicing, to re-seeding, intentional application of these and other stewardship techniques at their proper time were the cultural lifeway to assure access to and a healthy balance of essential cultural resources. The contemporary view of Tribal Cultural Resources typically only accounts for the archaeological items left behind and neglects the “Living Tribal Cultural Resources” that were, and are, essential pieces of Native lifeways; cultural foods, fibers, and medicines.” • the following text shall be added to the first paragraph on page 3.4- of Section 3.4 Biological Resources Environmental Setting Aquatic Resources:

Prior to 1910, the aforementioned streams historically contributed to a large seasonal lake at the north end of the Planning Area, from which, Little Lake Valley derived its name. Little Lake was a biologically rich area that supported many diverse species that local Indigenous people co-existed with in reciprocity though tending, burning, coppicing, and harvesting materials for housing, clothing, baskets, medicine and food. The lake was habitat for native species of plants, birds, fish, amphibians, reptiles, mollusks, insects, and mammals including species that today are threatened and endangered, such as coho salmon and steelhead. Water resources were utilized by local Indigenous people and kept pristine through good stewardship practices. Beginning in 1910, substantial diking, channelization, flow redirection, and other forms of hydrological modification were undertaken to connect the aforementioned streams to Outlet Creek and drain the seasonal lake in order to convert the former lakebed to grazing pasturage and cropland (LeDoux-Bloom and Downie 2007). Subsequent flooding events, particularly in 1955 and 1964, resulted in additional channelization and levee construction along portions of some of the aforementioned streams to reduce flood-related impacts within the incorporated City limits and the surrounding area and to further facilitate drainage within Little Lake Valley. • The following edits are made to Section 3.5 Cultural Resources, Environmental Setting, Ethnographic Background on pages 3.5-2 and 3.5-3:

Ethnographic Background
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Around Euroamerican contact (circa 1769), Mendocino County housed diverse indigenous groups: Central Pomo, Northern Pomo, Coast Yuki, Yuki, Huchnom, Cahto, Sinkyone, and Wailaki. Central and Northern Pomo mainly inhabited the county, while other groups settled nearer its north. These tribes had similar material cultures, emphasizing basketry for essential tasks. However, each group had distinct territories, languages, practices, and societal norms.

Cahto
Cahto's land includes Branscomb, Laytonville, Cummings, and valleys along South Fork Eel River, slightly beyond the Mendocino County border. There is limited ethnographic data on Cahto, as they were a smaller group than the Pomo, sharing the Athabaskan language group with their neighbors to the north. By 1920s, most Cahto moved to Round Valley or a tribal rancheria near Laytonville by force.

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The Bear Flag Revolt in 1846 showed U.S. settlers' concerns about Mexican rule. The U.S./Mexico conflict in 1846 and the Treaty of Guadalupe Hidalgo in 1848 marked the beginning of California's American Period.

Local History
Within Little Lake Valley, the City of Willits (City) is surrounded by a secondary forest teeming with tan oak, madrone, Douglas fir, and redwood trees. This landscape resides within the Pacific Coast Range, earning the City the monikers "Gateway to the Redwoods" and the "Heart of Mendocino County." Notably, the region was originally inhabited by the Pomo Ttribe of Native Americans, who continue to live in the area and enjoyed a deeprooted connection with their ancestral land. Their presence echoes through time, enriching the City's heritage and present day culture. Several prehistoric sites have been noted in the vicinity of Willits and the ethnographic village of Mitoma is reported to be in the southwestern part of the City. Prehistoric cultural resources are most likely to be found at the base of hills and along seasonal and perennial water courses. These areas have been identified as potentially sensitive on the Historical and Archaeological Resources Map located in the City of Willits General Plan (1992). This Map is attached in Appendix C.
• The following edits are made to Section 3.5 Cultural Resources, Regulatory Setting, State, relating to Senate Bill 18 on page 3.5-6:

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As previously discussed mentioned, there are several prehistoric sites noted in the vicinity of the City of Willits. The ethnograpohic village of Mitoma is noted to be located in the southwestern portion of the City of Willits.
• The following edits are made to the first two sentences in the introductory paragraph to Impact CUL-02 on page 3.5-14:

As discussed above, there are four (4) historic structures within the City of Willits limits.

The ethnograpohic village of Mitoma is noted to be located in the southwestern portion of the City of Willits. In addition, prehistoric cultural resources are likely to be found at the base of hills and along seasonal and perennial water courses. • The following edits are made to Mitigation Measure CUL-1. Cultural Resource Discovery Protocols New Implementation Measure for “Coordinate with Local Communities” Group:

Implementation Measure LU-7.X1: In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or undiscovered 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 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.
• The following edits are made to Mitigation Measure TCR-1. Avoid Impacts to Tribal Cultural Resources New Implementation Measure for “Coordinate with Local Communities” Group:

Implementation Measure LU-7.X3: If previously unidentified tribal cultural resources are encountered during project implementation, altering the materials and their stratigraphic context shall be avoided and work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

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CHAPTER 3.0, SECTION 3.8 GREENHOUSE GAS EMISSIONS
The Draft EIR incorrectly refers to the threshold relating to “conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHG” (CEQA Appendix G VIII(b)) as Impact GHG-01, when it should have been referred to as Impact GHG-02. The following pages contain incorrect reference to Impact GHG-01 when it should have been referred to as Impact GHG-02

1. Table 1-1: Summary of Impacts, Mitigations, and Significance Levels on page 1.0- 32 in the second row under the heading 3.8 Greenhouse Gas Emissions should read as follows:

Threshold GHG-021: For the
impacts on other GHG emission
reduction plans, the analysis
focuses on whether the project
would be consistent with
statewide GHG emission
reduction goals?
Quantitative information about
GHG emissions from future
development projects resulting
from the Project are unknown at
this time and GHG emission
reduction measures developed
through Policy LU-3.9 are yetto-be developed so it is
uncertain how much GHG
emissions will result from the
Project and whether those
emissions are consistent with or
conflict with the targets
established in the state’s 2022
Scoping Plan. Accordingly, this
impact is conservatively
determined to be significant.

Developing mitigation measures
to ensure the Project’s GHG
emissions will be consistent with
state targets is not feasible at
this time.

Potentially
Significant
Mitigation GHG-1 Revise
Policy LU-3.9 Plan for
Climate Change
Revise Policy LU-3.10 Plan
for Climate Change.

Significant
and
Unavoidable

2. Section 3.8 Greenhouse Gas Emissions, Impact GHG-01, on pages 3.8-7 and 3.8-8 should refer to Section 3.17 Transportation and Circulation and not to Chapter 4.17 Compared to current conditions the Project is likely to reduce the GHG emissions associated with transportation of goods and services into and out of the newly developed areas. This is because of its focus on encouraging higher density residential and mixeduse projects in areas close to existing population and employment centers. Section 3.17 Transportation and Circulation Chapter 4.17 of this EIR documents the transportation impacts of the proposed Project and concludes vehicle trips generated under the Project City of Willits | Final PEIR Errata
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are expected to be shorter in length compared current conditions which means less gasoline and diesel will be used in transportation supporting residents and businesses in the Planning Area resulting in fewer GHG emissions.

Specifically, Chapter 4.17 Section 3.17 Transportation and Circulation Impact TRAN01 on page 3.17-16 states, “(a)ttracting growth to the city and adjacent to the city instead of outlying unincorporated areas of the county could reduce future (Vehicle Miles Travelled or “VMT”) growth in the region.” The discussion in Section 3.17 Transportation and Circulation Impact TRAN-01 Chapter 4.17 goes on to surmise that even lower vehicle use rates and corresponding lower gasoline and diesel energy use are possible due to the proposed Project’s policy changes that support infill and mixed-use growth and improved active transportation conditions including LU-2.2 Infill Development and LU-3.1 Complete Streets and several others. Lower amounts of gasoline and diesel used in transportation under the Project are expected to reduce GHG emissions compared to current conditions.

3. Section 3.8 Greenhouse Gas Emissions, Impact Analysis, page 3.8-8 should read as follows:
“Impact GHG-021: The proposed project may conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHG, resulting in a significant, unavoidable impact.”
CHAPTER 3.0, SECTION 3.9 HAZARDS AND HAZARDOUS MATERIALS, The following modifications to the EIR will be made to Section 3.9, Hazards and Hazardous Materials, Regulatory Environment, State, under the heading “Cortese List” on page 3.9-13 to clarify the responsibilities of the applicant and the City for applications for development:

California Government Code Section 65962.5(e) requires that the Secretary for Environmental Protection “distribute (the Cortese List) in a timely fashion to each city and county in which sites on the lists are located.” Section 65962.5(f) requires that an applicant for any development project “consult the lists sent to the appropriate city or county and shall submit a signed statement to the local agency indicating whether the project and any alternatives are located on a site that is included” on the Cortese List, and if the site is within a site on the Cortese List not specified by the applicant “the lead agency shall notify the applicant” thereof.

City of Willits | Final PEIR Errata
September 2024 [76]
CHAPTER 3.0, SECTION 3.15 PUBLIC SERVICES
The following modifications to the EIR shall be made to Section 3.15 Public Services Environmental Setting for Fire Services on page 3.15-1 to provide greater detail regarding automatic and mutual aid agreements between the Brooktrails Township CSD and the Little Lake FPD:

The Little Lake FPD covers an area of 239.4 square miles serving all of the City of Willits, as well as the highway corridors (Highways 101 and 20) and outlying rural areas (Mendocino LAFCo, 2019). This area includes Federal Bureau of Land Management (BLM) land on the eastern edge of the District, a small portion of the Jackson State Forest on the western boundary, and the City of Willits. Other fire-related districts in the region include the Brooktrails Township Community Services District (CSD, which provides fire protection services) adjacent to and west of Little Lake FPD, the Long Valley Fire Protection District to the northwest, the Potter Valley Community Services District (which provides fire protection services) to the southeast, and the Redwood Valley-Calpella Fire Protection District to the south. Little Lake FPD provides automatic aid fire protection to Brooktrails Township CSD on calls related to structure fire, CPR, and traffic collisions on Sherwood Road, and maintains mutual aid agreements with Laytonville, Redwood Valley, and the CalFire for wildland fire. There is a countywide mutual aid agreement so that fire departments in Mendocino County respond, as available, to the needs of nearby fire departments, including the Little Lake FPD and the Brooktrails Township CSD.

CHAPTER 3.0, SECTION 3.18 UTILITIES AND SERVICE SYSTEMS This Final EIR will reflect that all references to Solid Wastes of Willits, Inc., or SWOW, in the following sections shall be replaced with Redwood Wastes Solutions, Inc.:
• Table 1-1: Summary of Impacts, Mitigations, and Significance Levels, Threshold UTL-05: page 1.0-51
• Section 3.18 Utilities and Service Systems, Existing Conditions “Recycling and Solid Waste Collection System” page 3.18-17
• Impact UTL-04 page 3.18-27
• Impact UTL-05 page 3.18-26
• Section 3.18 Utilities and Service Systems Acronyms/Abbreviations page 3.18-31 The following text shall be added to the Regulatory Setting for Section 3.18 Utilities and Service Systems under Solid Waste on page 3.18-21:

CHAPTER 6.0 EIR PREPARERS
J.B. Lovelace & Associates
Principal Environmental Scientist .....................................................J. Brett Lovelacer City of Willits | Final PEIR Errata
September 2024 [77]
…….

City of Willits | Final PEIR References
September 2024 [78]

5. MITIGATION MONITORING AND REPORTING
To avoid, reduce or mitigate significant effects resulting from the proposed Project, the City of Willits General Plan Land Use Element Update, Public Resources Code Section 21081.6 requires that a reporting or monitoring program be designed to ensure compliance during project implementation through the implementation of a Mitigation Monitoring and Reporting Program (MMRP). The following table provides the MMRP for the proposed City of Willits General Plan Land Use Element Update in accordance with those guidelines.

City of Willits | Final PEIR Errata
September 2024 [79]
TABLE 5A MITIGATION MONITORING AND REPORTING PROGRAM
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
Mitigation AES-1 - New Policy
LU-9.X. Development in Hillside Areas. Require new
development in hillside areas be sited and designed to retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas. The City shall encourage clustered dwelling units in hillside areas to preserve the scenic character of the hillsides.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
Mitigation AG-01: Proposed New Policy:

New Policy LU-2.X. Annexation Planning. Discourage urban development within the City’s Sphere of Influence until such lands are annexed by the City and support County land use regulations that protect the viability of local agriculture in the Little Lake Valley. When considering proposals for annexation, protect designated open space land and existing agricultural activities.

The City shall ensure that the best available biological resource mapping data is used during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to insignificant levels consistent with CEQA. At a minimum, the following biological resource mapping data sources shall be used for project City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
City of Willits | Final PEIR Errata
September 2024 [80]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
evaluation: California Department of Fish and Wildlife’s California Natural Diversity Database (CNDDB) and their Biogeographic Information and Observation System (BIOS), EcoAtlas and the California Aquatic Resource Inventory
(CARI), and U.S Fish and Wildlife Service’s National Wetland Inventory (NWI).

Mitigation BIO-01.2.

Policy LU-8.X2 Require Pre-Project Biological Resource
Assessments and Surveys The City shall require site- and/or project-specific biological resource assessments: 1) prior to annexing any properties into the City from the Proposed Sphere of Influence additions, and 2) prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area. Biological resource assessments shall address potential impacts to special status and/or otherwise protected fish, wildlife, and botanical taxa (including potential interferences with their movement, migration, and/or
dispersal); sensitive natural communities; and wetland
habitats. Biological resource assessments shall also identify mitigation measures to avoid and/or reduce impacts to
protected biological resources to less than significant levels from all new development allowed within the study area by the General Plan.

Where biological resource assessments identify potentially suitable habitat for special status fish, wildlife, and/or botanical taxa; nesting bird or roosting bat habitat; sensitive natural communities; and/or wetlands or other state- or federally regulated waters within respective study areas, appropriate pre-project biological surveys or habitat delineations shall also City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
City of Willits | Final PEIR Errata
September 2024 [81]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
be required. All biological resource assessments, surveys, and delineations shall be performed in coordination with CDFW by qualified professionals with demonstrated familiarity and experience within the region and consistent with respective current field survey protocols.

Apply an overlay to the Land Use Map, consistent with
Conservation and Open Space Element Implementation
Measure 3.320 identifying streams and wetlands within the City to be protected from development. Prohibit development within a buffer area on both sides of streams subject to the following criteria:
(a) A combining zone for stream and riparian areas
shall also be established and applied to parcels
adjacent to streams and subject to the Riparian
Area Land Use Overlay that specifies protective
criteria consistent with this policy.
(b) Riparian Buffer Areas associated with
streams shall be established on both sides
of streams and shall be measured from
either the outer drip-line of riparian
vegetation or the top-of-bank, whichever is
furthest from the stream centerline, and
shall extend horizontally for a distance of:

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
revision to a
proposed
policy in the
Land Use
Element
City of Willits | Final PEIR Errata
September 2024 [82]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
• 100 feet for perennial streams, or
• 50 feet for intermittent streams.

Riparian Buffer Areas associated with
wetlands shall extend horizontally from the
delineated wetland boundary for a distance
of:
• 150 feet for perennial wetlands, or
• 50 feet for seasonal wetlands.
(bc) Buffers may be reduced or eliminated where the
City determines, based on factual findings and
in consultation with CDFW, that the reduction
will not result in significant adverse effects to the
water quality, dependent biological resources,
or ecological functional capacity of the aquatic
resource of interest.
(cd) For ministerial projects that are located on land
planned R-L, C-G, GM-U, DM-U containing
occupied structures or on vacant parcels that
are substantially surrounded by developed
parcels where improvements are located within
the buffer area, exceptions to these standards
may be allowed after a site evaluation has been
conducted by City staff and factual findings are
made that development is sited to minimize
potential impacts to streams, wetlands, and
associated riparian resources; does not involve
the removal of native riparian vegetation; and
the incorporation of performance standards
relating to the revegetation of locallyappropriate riparian species and the City of Willits | Final PEIR Errata
September 2024 [83]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
implementation of best management practices
for erosion control.
(de) When the prescribed buffer prohibits
development of the site for the primary use for
which it is designated, measures shall be
applied that allow development that results in
the least environmentally damaging feasible
project.
(ef) Road, bridge, and trail construction or
replacement may be permitted that would not
result in significant adverse effects to water
quality, dependent biological resources, or
ecological functional capacity of the aquatic
resource of interest, where vegetative clearing
is kept to a minimum, and where revegetated
with locally-appropriate native riparian species.
(g) The installation or replacement of new or
existing fencing contiguous with Riparian
Buffer Areas shall require the use of wildlifepermeable materials and designs to reduce the likelihood of wildlife entrapment and
otherwise facilitate wildlife movement.
(h) All projects shall implement stormwater
requirements from the Mendocino County
Low Impact Development Standards Manual
to protect water quality and associated
aquatic habitats, avoid the use of noxious
weeds or other invasive plants identified by
the California Invasive Plant Council (CalIPC) in associated revegetation and landscaping efforts, and prioritize use of
City of Willits | Final PEIR Errata
September 2024 [84]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
locally-appropriate native vegetation during
any such revegetation.
(fi) The removal of vegetation for disease control or
public safety purposes may be approved, in
consultation with CDFW.)
(gj) An exception to the implementation of
regulations for this policy shall be included for
“minor additions” to buildings or structures
provided the aggregated total increase in
square footage for all changes does not exceed
thee hundred (300) square feet of floor area.

Mitigation BIO-01.4. Require Low Impact Development
(LID) Stormwater Design Standards and Use of
Appropriate Plant Species in LID and Other DevelopmentRelated Landscaping and Revegetation Efforts New Policy for “Protect Natural Resources within Areas
Planned for Development” Group:

Policy LU-8.X3 To reduce stormwater impacts to streams and wetlands and improve water quality associated with
discretionary development and all development within 250 feet of Willits, Broaddus or Baechtel Creeks and their tributaries, the City shall implement stormwater requirements from the Mendocino County Low Impact Development Standards
Manual to attenuate runoff, reduce scouring and erosion, promote on-site infiltration, and to protect water quality and associated aquatic habitats.

City of Willits | Final PEIR Errata
September 2024 [85]
New Policy for “Protect Natural Resources within Areas
Planned for Development” Group:

Policy LU-8.X4 The City shall develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for developmentrelated landscaping and revegetation. The City shall encourage the use of locally appropriate and locally sourced native vegetation for use in revegetation and landscaping efforts as well as encourage the planting of native milkweed (Asclepias spp.) species (i.e., the sole plant group within the Planning Area region suitable for egg laying and larval development for the federal candidate species, Western
Monarch butterfly [Danaus plexippus plexippus]). Where rapid plant establishment and development is required for purposes of soil stabilization and to minimize erosion potential, the City shall encourage the use of sterile hybrid “wheatgrass” x ”wheat” (Elymus x Triticum) or other similar non-reproductive seed material in conjunction with otherwise appropriatelyselected revegetation seed applications or blends.

Department of Agriculture (USDA), as well as any other plants that the City has determined warrant concern based on a known potential for preventing the establishment of the intended vegetation assemblage within respective
revegetation areas.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
Mitigation BIO-01.5. Require Appropriate Design
Standards to Minimize Artificial Light Pollution
City of Willits City of Willits Prior to the
adoption of
the Land Use
Incorporation
of this
mitigation
measure as a
City of Willits | Final PEIR Errata
September 2024 [86]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
New Policy for “Protect Natural Resources within Areas
Planned for Development” Group:

Policy LU-8.X5 The design and location of all outdoor lighting fixtures shall prevent direct illumination of streams, wetlands, and Riparian Buffer Areas.

Element
Update
new policy in
the Land Use
Element
Mitigation BIO-01.6. Initiate Community Outreach to
Reduce Impacts to Wildlife from Pesticide-Related
Poisonings and Free-Ranging House Cats.

New Policy for “Protect Natural Resources within Areas
Planned for Development” Group:

Policy LU-8.X6 Partner with local organizations to educate applicants and residents about the impacts to special status and otherwise protected wildlife from toxic pest control methods, and to discourage their use within the City; as well as to educate the community about the impacts of free-ranging house cats on special status and otherwise protected wildlife.

Implementation Measure LU-7.X1: In the event
archaeological resources or cultural resources, including human remains, are inadvertently unearthed or undiscovered 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 City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
City of Willits | Final PEIR Errata
September 2024 [87]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
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 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.

Mitigation TCR-1. Avoid Impacts to Tribal Cultural
Resources
New Implementation Measure for “Coordinate with Local
Communities” Group:

Implementation Measure LU-7.X2: When feasible,
development facilitated by the project shall be designed to avoid known tribal cultural resources. Known tribal cultural resources within 60 feet of planned construction activities shall be protected by establishing an Environmentally Sensitive Area (ESA) that would be fenced, or otherwise protected, to ensure avoidance. The feasibility of avoidance of tribal cultural resources shall be determined by the City of Willits and applicants in consultation with local California Native American tribe(s).

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
City of Willits | Final PEIR Errata
September 2024 [88]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
Mitigation TCR-2. Inadvertent Discovery of Tribal Cultural Resources
New Implementation Measure for “Coordinate with Local
Communities” Group:

Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A
representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
Mitigation GEO-1: Adopt Draft Safety Element
Prior to, or within six months following, the adoption of the Land Use Element, the City of Willits shall complete the process of updating and adopting the Draft Safety Element consistent with state law and initiate the process of putting into effect the implementation program.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update or
within six
months after
adoption
Adoption of the
updated City of
Willits Safety
Element
Mitigation GEO-2: Other Paleontological or Geological
Resource Discover Protocols
Implementation Measure LU-7.X4 If fossils are encountered during construction (i.e., bones, teeth, or unusually abundant and well-preserved invertebrates or plants), the City and its contractor shall divert construction activities away from the City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
City of Willits | Final PEIR Errata
September 2024 [89]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
discovery within 50 feet of the find, and a professional paleontologist shall be contracted to document the discovery as needed, to evaluate the potential resource, and to assess the nature and importance of the find. Based on the scientific value or uniqueness of the find, the paleontologist may record the find and allow work to continue, or recommend salvage and recovery of the material, if it is determined that the find cannot be avoided. The paleontologist shall make recommendations for any necessary treatment that is consistent with currently accepted scientific practices. Any fossils collected from the area shall then be deposited in an accredited and permanent scientific institution where they would be properly curated and preserved.

Land Use
Element
Mitigation GHG-1 Revise Policy LU-3.9 Plan for Climate
Change
Revise Policy LU-3.10 Plan for Climate Change. Plan for the public health implications of climate change, including potential disease and temperature effects, and work with state and county public health agencies to identify necessary programs to reduce, adapt to, and increase resiliency to potential impacts and develop and implement programs to achieve City-wide reductions in greenhouse gas emissions consistent with
state targets.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update
Incorporation
of this
mitigation
measure as a
revision to a
new policy in
the Land Use
Element
Mitigation Measure WF-01.

Prior to adoption of the Draft Safety Element, review, an update shall be required to is consistent with applicable state legislation that has been passed since the draft’s preparation in 2019.

City of Willits City of Willits Prior to the
adoption of
the Land Use
Element
Update or
within six
Adoption of an
updated City of
Willits Safety
Element that is
s consistent
with applicable
state
City of Willits | Final PEIR Errata
September 2024 [90]
Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
months after
adoption
legislation that
has been
passed since
2019
City of Willits | Final PEIR Errata
September 2024 [91]
City of Willits | Final PEIR Report of Preparers
September 2024 [92]

6. REPORT OF PREPARERS
Name .............................................................................................................Title City of Willits
Dusty Duley ..............................................................Community Development Director Planwest Partners, Inc.

Colette Sanche, AICP ........................................................................... Principal Planner/Partner John Miller ......................................................................................... Project Manager Sarah Wickman .......................................................................................Associate Planner LACO Associates
Rodney L. Wilburn, PE, JD ...............................................................................Principal Civil Engineer Becky Clark, AICP .................................................................Senior Planner/Project Manager J.B. Lovelace & Associates
J. Brett Lovelace ................................................................Principal Environmental Scientist City of Willits Land Use Element Update
CEQA Findings of Fact
and Statement of Overriding Considerations
(Pursuant to Public Resources Code Sections 21081 and
21081.6, and State CEQA Guidelines Section 15091 and 15093) Final Programmatic Environmental Impact Report
(State Clearinghouse Number 2022020107)
Project Files May Be Reviewed At:

City of Willits
Community Development Department
111 E. Commercial Street
Willits, CA 95490
October 16, 2024

TABLE OF CONTENTS

1. Introduction........................................................................................................... 1

1.1 Purpose............................................................. Error! Bookmark not defined.

1.2 Organization/Format of Findings....................................................................... 2

1.3 Summary of Project Description........................................................................ 2

1.4 Summary of Project Entitlements...................................................................... 3

1.5 Project Objectives ............................................................................................. 3

1.6 Notice of Preparation and Environmental Scoping Document .......................... 4

1.7 Environmental Impact Report............................................................................ 4

1.8 Recirculation Not Required ............................................................................... 5

2. Findings Regarding Significant Unavoidable Adverse Impact .............................. 7

2.1 Topic ................................................................................................................. 7

2.2 Topic ................................................................. Error! Bookmark not defined.

3. Findings Regarding Impacts Analyzed in the EIR And Determined To Be Mitigated To Less Than Significant ................................................................................. 9

3.1 Topic ................................................................. Error! Bookmark not defined.

3.2 Topic ................................................................. Error! Bookmark not defined.

4. Findings Regarding Impacts Analyzed in the Eir And Determined To Be Less Than Significant Requiring No Mitigation Or No Impact ................................................ 26

5. Other CEQA Required Analysis in the Eir .......................................................... 33

5.1 Topic ................................................................. Error! Bookmark not defined.

5.2 Topic ................................................................. Error! Bookmark not defined.

6. Feasibility of Project Alternatives........................................................................ 36

6.1 Project Alternatives ......................................................................................... 36

6.1.1 Alternatives Considered but Rejected ......................................................... 36

6.1.2 Alternatives Considered .............................................................................. 36

7. Statement of Overriding Considerations............................................................ 40

8. Adoption of a Mitigation Monitoring and Reporting Program for the CEQA Mitigation Measures ...................................................................................................... 45

City of Willits Land Use Element Update Final PEIR
1 1. INTRODUCTION

1.1 STATUTORY REQUIREMENTS FOR FINDINGS
The California Environmental Quality Act (CEQA) requires that written findings be made by the lead agency in connection with certification of an environmental impact report (EIR) prior to approval of the project pursuant to Sections 15091 and 15093 of the CEQA Guidelines and Section 21081 of the Public Resources Code. This document provides the findings required by CEQA. The potential environmental effects of the proposed City of Willits General Plan Land Use Element Update (Project) have been analyzed in a Draft Programmatic Environmental Impact Report (Draft EIR) (State Clearinghouse [SCH] 2023030321) dated July 2024. A Final Environmental Impact Report (FEIR) has also been prepared that incorporates the DRAFT EIR and contains comments received on the DRAFT EIR, responses to the individual comments, revisions to the DRAFT EIR including any clarifications based on the comments and the responses to the comments, and the Mitigation Monitoring and Reporting Program (MMRP) for the proposed project. This document provides the findings required by CEQA for approval of the proposed project.

California Environmental Quality Act (CEQA) Guidelines Section 15091 states that:
(a) No public agency shall approve or carry out a project for which an Environmental Impact Report (EIR) has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.

CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to avoid or mitigate significant environmental impacts that will otherwise occur with implementation of the project. For those significant effects that cannot be mitigated to a less-than-significant level, the public agency is required to find that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment.

For each significant impact identified in the Draft EIR, the lead agency must find, based on substantial evidence, that a) the project has been changed to avoid or substantially City of Willits Land Use Element Update Final PEIR
2 reduce the magnitude of the impact; b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (CEQA Guidelines Section 15091). If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision. The CEQA Guidelines state in Section 15093 that “If the specific economic, legal, social, technological, or other benefits of a proposal project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable’.”

1.2 ORGANIZATION/FORMAT OF FINDINGS
Section 1.0 contains a summary description of the project and background facts relative to the environmental review process. Section 2.0 identifies the significant impacts of the project that cannot be mitigated to a less‐than‐significant level (even though all feasible mitigation measures have been identified and incorporated into the project). Section 3.0 identifies the project’s potential environmental effects that were determined to be lessthan-significant and, therefore, do not require mitigation measures. Section 4.0 discusses impacts analyzed and determined to not have potential significant impacts and do not require mitigation. Section 5.0 discusses other CEQA required analyses such as cumulative impacts. Section 6.0 discusses the feasibility of the project alternatives, and Section 7.0 presents the Statement of Overriding Considerations.

Section 8.0 incorporates the mitigation and monitoring requirements.

1.3 SUMMARY OF PROJECT DESCRIPTION
The proposed Project is an amendment to the City of Willits Land Use Element, Land Use Diagram, Zoning Map and Regulations, and an application to amend the City’s SOI.

The Project includes:
1) the identification of a Planning Area that includes the City as well as surrounding land that bears relation to City planning;
2) changes to existing and new Land Use Element policy intended to expand the land supply for housing of all types, provide for focused planning for Willits’ commercial centers, provide for land use flexibility and compatibility, ensure community health and vitality and environmental health and sustainability, and to expand and improve land use designations and general plan maintenance; 3) changes to Land Use Designations within the City to support residential and commercial development, as well as for open space purposes, and changes to apply Land Use Designations that best reflect the use and character of existing development within the City where the current Land Use Designation is not appropriate;
4) proposed expansions to the City’s SOI, with the application of appropriate City Land Use Designations, to support a potential SOI Amendment application to the Mendocino Local Agency Formation Commission;
City of Willits Land Use Element Update Final PEIR
3 5) amendments to the Zoning Map and Zoning Regulations to ensure consistency with the Land Use Element and Land Use Map, which may occur simultaneously with or closely following Land Element adoption, and that may include the application of consistent Zoning Classifications and edits to the Zoning Regulations to ensure consistency.

Adoption of the Plan requires certification of the EIR, a General Plan Amendment, Zoning Map and Text Amendments by the Willits City Council and an application to the Mendocino Local Agency Formation Commission to amend the City SOI.

1.4 SUMMARY OF PROJECT ENTITLEMENTS
Following adoption of the Land Use Element by the City Council, all subsequent activities and any future development within the City would be guided by the goals and policies contained in the Land Use Element and the other Elements of the City of Willits General Plan. The City of Willits would also be required to coordinate with Mendocino County and other public agencies to implement policies that affect their respective jurisdictions or the overall region. Implementing these policies in accordance with new development would be subject to the City’s review and approval processes, with final review and approval by the appropriate departmental staff as well as the appointed and elected officials. The principal responsibilities that City officials and staff have for project implementation are briefly summarized below:
 Adoption of amended Zoning Regulations and an amended Zoning Map to achieve consistency with the adopted Land Use Element, and  Adoption of an application to the Mendocino LAFCo to amend the City of Willits Sphere of Influence.
 Rezoning other properties to further the objectives of the Land Use Element and as prescribed by future development approvals;
 Approving tentative maps, development agreements, variances, conditional use permits, and other land use permits and entitlements;
 Planning for public infrastructure such as roadway improvements, other capital improvements, and natural/capital resource preservation and/or restoration; and,  Conducting or considering further focused planning studies, as appropriate to future development in the City

1.5 PROJECT OBJECTIVES
The City’s following objectives contributed to the policy focus areas development of the Land Use Element, listed as follows:
1) Plan for a range of potential population growth levels within the City. 2) Facilitate infill development and commercial vitality. 3) Define an expanded Sphere of Influence that includes appropriate areas around the City for potential future residential development to help ensure an adequate City supply of developable land.

City of Willits Land Use Element Update Final PEIR
4 4) Ensure adequate public utilities, services, infrastructure, and a street network that supports all users and plan for phased improvements to support existing, and new land planned for residential and commercial development. 5) Plan new and sustain existing parks and recreation facilities for the entire community, especially underserved areas.
6) Facilitate the vitality of Downtown and South Main Street by improving important City gateways and by defining flexible land use regulations to encourage adaptive re-use of existing structures and design standards that improve the streetscape and create a comfortable atmosphere for walking, biking, outdoor seating and gathering.
7) Define a Land Use Map and policy that minimizes the number of non-conforming uses and protects existing communities from incompatible uses, reduces energy consumption, and vehicle miles travelled.
8) Streamline the permitting process and maximize opportunities for housing development to address the local, regional and statewide housing shortage, especially infill development within current city limits. 9) Protect and conserve natural resources and avoid hazards.

1.6 NOTICE OF PREPARATION AND ENVIRONMENTAL SCOPING DOCUMENT Pursuant to CEQA Guidelines, the City of Willits circulated a Notice of Preparation (NOP) for a 30-day public review period on March 10, 2023, which was received by the State Clearinghouse on the same day and assigned SCH# 2023030321. The NOP review period ended on April 10, 2023. The NOP Scoping Comments received are included as Appendix A in the Draft EIR.

1.7 ENVIRONMENTAL IMPACT REPORT
The Land Use Element Update requires discretionary approval by the City of Willits and as such is subject to CEQA. The City, as the lead agency, must identify and document the potential environmental impacts of the project in accordance with CEQA (Public Resources Code §21000 et seq.), and the State CEQA Guidelines (California Administrative Code Section 15000 et seq.).

The City of Willits prepared the Draft EIR in accordance with CEQA and the State CEQA Guidelines. The Willits EIR is a full‐disclosure informational document that informs public agency decision‐makers and the public of the significant environmental effects of the project. Mitigation measures intended to minimize significant effects are identified in the Draft EIR and reasonable alternatives to the project are evaluated.

The Draft EIR for the City of Willits General Plan Land Use Element Update was submitted to the State Clearinghouse on July 25, 2024 for distribution to State agencies, and was distributed using a Notice of Availability to the general public, local, State, and federal responsible and trustee agencies and tribal governments, that was also posted at the County Clerk by law, and through a posting in a local newspaper, the Willits Weekly, on August 1, 2024. The review period of the Draft EIR lasted over the 45 days required by Section 15205 of the CEQA Guidelines and ended at 5:00 pm on September 13, 2024. The document was made available for review at City of Willits Community Development department at 111 E. Commercial Street, Willits, CA and City of Willits Land Use Element Update Final PEIR
5 online at: https://willitslanduseupdate.com/. The Draft EIR was uploaded to the State Clearinghouse and available for download at
https://ceqanet.opr.ca.gov/Project/2023030321.

The Notice of Availability of the Draft EIR was also emailed to parties who requested to receive project updates via https://willitslanduseupdate.com/ (104 recipients), as well as direct emailing to trustee agencies, responsible agencies, area schools, and regional planning agencies. A public hearing was held before the City Council on September 11, 2024, to receive comments on the Draft EIR.

All comment letters received in response to the Draft EIR were reviewed and are included in Chapter 2 of the Final EIR, along with written responses to each of the comments. In accordance with State CEQA Guidelines §15132, the Final EIR consists of: (a) the Draft EIR or a revision of the draft; (b) comments and recommendations received on the Draft EIR; (c) a list of the persons, organizations, and public agencies commenting on the Draft EIR; (d) responses of the Lead Agency to significant environmental points raised in the review and consultation process; and (e) any other information added by the Lead Agency.

A public hearing to receive comments on the Final EIR will be held during the October 23, 2024, City Council meeting at 6:00 p.m., consistent with state law, which will also be a public hearing to consider approval of the Land Use Element Update. The Final EIR will be provided to the City Council for review and consideration on certification of the as a full disclosure of potential impacts, mitigation measures and alternatives. The Final EIR will be sent to the public agencies who commented on the Draft EIR at least 10 days prior to certification of the EIR per CEQA Guidelines Section 15088.

1.8 RECIRCULATION NOT REQUIRED
Certain revisions have been made to the Draft EIR, which can be found in Chapter 4 (Errata, Revisions and Clarifications) of the Final EIR. The revisions are minor corrections or edits to the text to clarify the information contained in the Draft EIR. The revisions do not identify new significant environmental impacts, do not constitute “significant new information,” and do not alter the conclusions of the environmental analysis. Per CEQA Guidelines Section 15088.5, recirculation of an EIR is required if “significant new information” is presented to the lead agency. “Significant new information” requiring recirculation includes, for example, a disclosure showing that:
1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.

City of Willits Land Use Element Update Final PEIR
6 4) The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded (Mountain Lion Coalition v. Fish and Game Com. [1989] 214 Cal.App.3d 1043).

Thus, recirculation of the Draft EIR is not required and subsequently not conducted.

City of Willits Land Use Element Final PEIR
7 2. FINDINGS REGARDING SIGNIFICANT UNAVOIDABLE

ADVERSE IMPACT
This section identifies the significant unavoidable impacts that require a statement of overriding considerations to be adopted by the City Council if the project is approved.

Based on the substantial record evidence, certain impacts in the following areas have been determined to fall within this ʺsignificant unavoidable impactʺ category:

2.1 GREENHOUSE GAS EMISSIONS
Impact GHG-01: Would the Project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment? Impact GHG-02: Threshold GHG-01: For the impacts on other GHG emission reduction plans, the analysis focuses on whether the project would be consistent with statewide GHG emission reduction goals?
The proposed the Land Use Element Update will result in development that may generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment even with the mitigation measures described below, resulting in a significant, unavoidable impact. AB 32 establishes by law that GHG emissions cause significant adverse impacts to the environment, so this impact is conservatively determined to be significant. Ensuring that the Land Use Element Update’s GHG emissions will be mitigated through programs reducing emissions is not feasible at this time.

Quantitative information about GHG emissions from future development projects allowed by the Land Use Element Update are unknown at this time and GHG emission reduction measures developed through Policy LU-3.9 are yet-to-be developed so it is uncertain how much GHG emissions will result from the Project and whether those emissions are consistent with or conflict with the targets established in the state’s 2022 Scoping Plan. Accordingly, this impact is conservatively determined to be significant.

Developing mitigation measures to ensure the Project’s GHG emissions will be consistent with state targets is not feasible at this time.

Mitigation Measures:

Mitigation Measure GHG-1: Revise Policy LU-3.9 Plan for Climate Change to ensure that City planning is consistent with state
targets
LU-3.10 Plan for Climate Change. Plan for the public health implications of climate change, including potential disease and temperature effects, and work with state and county public health agencies to identify necessary programs to reduce, adapt to, and increase resiliency to potential impacts and develop and implement programs to achieve City-wide reductions in greenhouse gas emissions consistent with state targets.

City of Willits Land Use Element Final PEIR
8 Policy LU-3.9, Plan for Climate Change, directs the City to develop and implement programs to achieve City-wide reductions in greenhouse gas emissions, and Policy LU3.10 Greenhouse Gas Emission Reductions, directs the City to evaluate new largerscale residential, commercial, and industrial projects for compliance with state regulations and require feasible mitigation measures to reduce GHG emissions. Other policies in the proposed Land Use Element may also reduce GHG emissions from the Project. Policy LU-3.8 Energy Conservation and Reduction encourages the installation of renewable energy systems and community-wide reductions in energy consumption, which will reduce GHG emissions associated with energy use. The Draft EIR analysis found that Policy LU-3.10 Greenhouse Gas Emission Reductions, did not specify the requirement that GHG reductions be “consistent with state targets” and required the addition of this text to that policy.

Section 3.17 of the Draft EIR documents the transportation impacts of the proposed Project and concludes vehicle trips generated under the Project are expected to be shorter in length compared current conditions which means less gasoline and diesel will be used in transportation supporting residents and businesses in the Planning Area resulting in fewer GHG emissions because “(a)ttracting growth to the city and adjacent to the city instead of outlying unincorporated areas of the county could reduce future (Vehicle Miles Travelled or “VMT”) growth in the region.” The analysis in Section 3.17 goes on to surmise that even lower vehicle use rates and corresponding lower gasoline and diesel energy use are possible due to the proposed Project’s policy changes that support infill and mixed-use growth and improved active transportation conditions and several others. Lower amounts of gasoline and diesel used in transportation under the Project are expected to reduce GHG emissions compared to current conditions.

In spite of the required mitigation, the Draft EIR analysis conservatively concludes that future City-wide GHG emission reductions to meet state targets through the implementation of policies and programs identified in the Land Use Element Update cannot be assured. Therefore, this impact is considered significant and unavoidable.

Findings:

Development facilitated by the 2040 General Plan would make progress towards achieving State goals but would not necessarily meet State 2030 or 2045 goals.

Mitigation Measure GHG-1 (a revision to Policy LU-3.10, Plan For Climate Change, which (together with Policy LU-3.11 Greenhouse Gas Emissions Reductions) would require that the City plan for climate change and identify programs to reduce, adapt to, and increase resiliency to potential climate change impacts and to implement programs to achieve City-wide reductions in greenhouse gas emissions, consistent with state targets, which are specified in the Section 3.8, Greenhouse Gas Emissions, Regulatory Setting on Draft EIR pages 3.8-2 through 3.8-6. However, it is not feasible at this time for the City to ensure that development facilitated by the Land Use Element Update would meet state targets. This impact would be significant and unavoidable (see Draft EIR pp. 3.8-8 and 3.8-9).

City of Willits Land Use Element Final PEIR
9 3. FINDINGS REGARDING IMPACTS ANALYZED IN THE

EIR AND DETERMINED TO BE MITIGATED TO LESS THAN

SIGNIFICANT

3.1 AESTHETICS
Discussion of Impacts:

The proposed Land Use Element could change the intensity of development, potentially affecting scenic vistas from viewpoints within Willits and the Planning Area, allowing higher density residential development that may affect views of wooded hillslopes and rangeland, riparian corridors, and mature trees. The Land Use Element adds Zoning performance standards relating to design and would not conflict with City regulations governing scenic quality in urban areas. However, the existing Conservation and Open Space Element Policy and proposed Land Use Element Update may not adequately protect the visual character of the hillslopes in SOI areas such as the State Route 20 SOI area.

Mitigation Measure AES-1
LU-9.X. Development in Hillside Areas. Require new development in hillside areas be sited and designed to retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas. The City shall encourage clustered dwelling units in hillside areas to preserve the scenic character of the hillsides.

Findings:

The requirement that new development in hillside areas be sited and designed to retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas is incorporated into the Land Use Element Update to avoid or substantially lessen the significant environmental effect as identified in the Draft EIR.

This change is identified in the form of the mitigation measure above. The City Council hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted, and based upon substantial evidence in the record, the aesthetics impacts of the project are less than significant.

Rationale for Finding:

Mitigation Measure AES-1 requires implementation of a policy within the Land Use Element Update, which would apply to development in hillside areas, especially subdivisions. Implementation of Mitigation Measure AES-1 would reduce aesthetics impacts to less than significant.

City of Willits Land Use Element Final PEIR
10 3.2 AGRICULTURAL AND FORESTRY RESOURCES
Discussion of Impacts:

Implementation of the project would apply non-agricultural land use designations to 18.9 acres of land planned and zoned for agricultural use by Mendocino County within the proposed expanded Sphere of Influence areas. However, only a small portion of developed parcels may contain agricultural activities and the proposed land use designations are intended to reflect the current use of the property. In addition, there are likely agricultural activities within portions of the Sphere of Influence areas and prime agricultural soils. The Land Use Element Update could result in the conversion of currently undeveloped prime agricultural land, as defined by LAFCo, to a nonagricultural use. Land Use Element policy may not be adequate to ensure that the potential for the conversion of Farmland to a non-agricultural use.

Mitigation Measuer AG-01:

Policy LU-2.X, Annexation Planning. Discourage urban development within the City’s Sphere of Influence until such lands are annexed by the City and support County land use regulations that protect the viability of local agriculture in the Little Lake Valley. When considering proposals for annexation, protect designated open space land and existing agricultural activities.

Findings:

The requirement that agricultural activities within annexation areas be protected and that the City supports County land use regulations that protect the viability of agriculture in the Little Lake Valley is incorporated into the Land Use Element Update to avoid or substantially lessen the significant environmental effect as identified in the Draft EIR.

This change is identified in the form of the mitigation measure above. The City Council hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted, and based upon substantial evidence in the record, the agricultural resource impacts of the project are less than significant.

Rationale for Finding:

Mitigation Measure AG-01 requires implementation of a policy within the Land Use Element Update, which would apply to annexation planning and applications.

Implementation of Mitigation Measure AES-1 would reduce agricultural resource impacts to less than significant.

City of Willits Land Use Element Final PEIR
11 3.3 BIOLOGICAL RESOURCES
Discussion of Impacts:

Future development allowed by the Land Use Element Update has the potential to result in direct, indirect, and/or cumulative adverse impacts within the incorporated City limits and the proposed expanded Sphere of Influence to:
• Special status and/or otherwise protected fish, wildlife, and/or botanical taxa identified in Impact BIO-01;
• Riparian habitats associated with the various tributary streams of the Outlet Creek watershed and other sensitive natural communities; • State- and/or federally regulated wetlands and/or waters within the proposed Sphere of Influence and/or within the City of Willits’ proposed Land Use Change Areas; and
• Interfere with the movements and migration of native wildlife within the proposed expanded Sphere of Influence, and to a lesser extent, within the existing incorporated City limits.

Although the existing and proposed regulations and policies described above would likely reduce potential impacts to the resources listed above, the Draft EIR analysis determined that additional protections would be necessary to further reduce the likelihood for potential development-related impacts to such resources to a level that would be less than significant.

Mitigation BIO-01.1
LU-8.X1 Utilize Biological Resource Inventory Assessment Tools During Project Review. The City shall ensure that the best available biological resource mapping data is used during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to insignificant levels consistent with CEQA. At a minimum, the following biological resource mapping data sources shall be used for project evaluation: California Department of Fish and Wildlife’s California Natural Diversity Database (CNDDB) and their Biogeographic Information and Observation System (BIOS), EcoAtlas and the California Aquatic Resource Inventory (CARI), and U.S Fish and Wildlife Service’s National Wetland Inventory (NWI).

Mitigation BIO-01.2.

LU-8.X2 Require Pre-Project Biological Resource Assessments and Surveys The City shall require site- and/or project-specific biological resource assessments: 1) prior to annexing any properties into the City from the Proposed Sphere of Influence additions, and 2) prior to approval of principally permitted development of multifamily housing on properties planned Residential-Medium Density in the South Haehl Creek area. Biological resource assessments shall City of Willits Land Use Element Final PEIR
12 address potential impacts to special status and/or otherwise protected fish, wildlife, and botanical taxa (including potential interferences with their movement, migration, and/or dispersal); sensitive natural communities; and wetland habitats.

Biological resource assessments shall also identify mitigation measures to avoid and/or reduce impacts to protected biological resources to less than significant levels from all new development allowed within the study area by the General Plan.

Mitigation BIO-01.3
Revise Policy LU-8.3, Riparian Area Land Use Overlay. Apply an overlay to the Land Use Map, consistent with Conservation and Open Space Element Implementation Measure 3.320 identifying streams and wetlands within the City to be protected from development. Prohibit development within a buffer area on both sides of streams subject to the following criteria:
(a) A combining zone for stream and riparian areas shall also be established and applied to parcels adjacent to streams and subject to the Riparian Area Land Use Overlay that specifies protective criteria consistent with this policy.
(b) Riparian Buffer Areas associated with streams shall be established on both sides of streams and shall be measured from either the outer drip-line of riparian vegetation or the top-of-bank, whichever is furthest from the stream centerline, and shall extend horizontally for a distance of:
• 100 feet for perennial streams, or
• 50 feet for intermittent streams.

Riparian Buffer Areas associated with wetlands shall extend horizontally from the delineated wetland boundary for a distance of:
• 150 feet for perennial wetlands, or
• 50 feet for seasonal wetlands.
(bc) Buffers may be reduced or eliminated where the City determines, based on factual findings and in consultation with CDFW, that the reduction will not result in significant adverse effects to the water quality, dependent biological resources, or ecological functional capacity of the aquatic resource of interest.
(cd) For ministerial projects that are located on land planned R-L, C-G, GM-U, DM-U containing occupied structures or on vacant parcels that are City of Willits Land Use Element Final PEIR
13 substantially surrounded by developed parcels where improvements are located within the buffer area, exceptions to these standards may be allowed after a site evaluation has been conducted by City staff and factual findings are made that development is sited to minimize potential impacts to streams, wetlands, and associated riparian resources; does not involve the removal of native riparian vegetation; and the incorporation of performance standards relating to the revegetation of locally-appropriate riparian species and the implementation of best management practices for erosion control.
(de) When the prescribed buffer prohibits development of the site for the primary use for which it is designated, measures shall be applied that allow development that results in the least environmentally damaging feasible project.
(ef) Road, bridge, and trail construction or replacement may be permitted that would not result in significant adverse effects to water quality, dependent biological resources, or ecological functional capacity of the aquatic resource of interest, where vegetative clearing is kept to a minimum, and where revegetated with locally-appropriate native riparian species. (g) The installation or replacement of new or existing fencing contiguous with Riparian Buffer Areas shall require the use of wildlife-permeable materials and designs to reduce the likelihood of wildlife entrapment and otherwise facilitate wildlife movement. (h) All projects shall implement stormwater requirements from the Mendocino County Low Impact Development Standards Manual to protect water quality and associated aquatic habitats, avoid the use of noxious weeds or other invasive plants identified by the California Invasive Plant Council (Cal-IPC) in associated revegetation and landscaping efforts, and prioritize use of locally-appropriate native vegetation during any such revegetation.
(fi) The removal of vegetation for disease control or public safety purposes may be approved, in consultation with CDFW.)
(gj) An exception to the implementation of regulations for this policy shall be included for “minor additions” to buildings or structures provided the aggregated total increase in square footage for all changes does not exceed thee hundred (300) square feet of floor area.

Mitigation BIO-01.4
Policy LU-8.X3 Protect Natural Resources within Areas Planned for Development To reduce stormwater impacts to streams and wetlands and improve water quality associated with discretionary development and all development within 250 feet of Willits, Broaddus or Baechtel Creeks and their tributaries, the City shall implement stormwater requirements from the Mendocino County Low Impact Development Standards Manual to attenuate runoff, reduce scouring and erosion, promote on-site infiltration, and to protect water quality and associated aquatic habitats.

City of Willits Land Use Element Final PEIR
14 Policy LU-8.X4 The City shall develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for development-related landscaping and revegetation. The City shall encourage the use of locally appropriate and locally sourced native vegetation for use in revegetation and landscaping efforts as well as encourage the planting of native milkweed (Asclepias spp.) species (i.e., the sole plant group within the Planning Area region suitable for egg laying and larval development for the federal candidate species, Western Monarch butterfly [Danaus plexippus plexippus]). Where rapid plant establishment and development is required for purposes of soil stabilization and to minimize erosion potential, the City shall encourage the use of sterile hybrid “wheatgrass” x ”wheat” (Elymus x Triticum) or other similar non-reproductive seed material in conjunction with otherwise appropriately-selected revegetation seed applications or blends.

Mitigation BIO-01.5.

Policy LU-8.X5 Require Appropriate Design Standards to Minimize Artificial Light Pollution The design and location of all outdoor lighting fixtures shall prevent direct illumination of streams, wetlands, and Riparian Buffer Areas.

Mitigation BIO-01.6.

Findings:

The requirement that biological resources, including special status species, riparian habitats, state- and/or federally regulated wetlands, and the movements and migration of native wildlife be protected through specific buffers and criteria for development near riparian areas and wetlands, and comprehensive project review requirements is incorporated into the Land Use Element Update to avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. This change is identified in the form of the mitigation measures above. The City Council hereby finds that City of Willits Land Use Element Final PEIR
15 implementation of these mitigation measures is feasible, and the measures are therefore adopted, and based upon substantial evidence in the record, the biological resource impacts of the project are less than significant.

Rationale for Finding:

Given that the proposed project is an update to the General Plan Land Use Element and the nature, location, timing, and details of future projects are unknown, the biological resources impact analyses, summarized above, consider the degree to which existing and proposed goals, policies, and implementation measures proposed in the current City of Willits General Plan and proposed Land Use Element Update would protect streams, riparian habitats, other sensitive natural communities, and the biological organisms they support from development that may occur following the adoption of Land Use Element policy and changes to the General Plan Land Use Map.

The impact analyses list each existing or proposed policy or implementation measure that could protect important resources. The analyses conclude that policies would likely reduce potential impacts to special status fish, wildlife, and/or botanical taxa identified herein, but additional mitigation is necessary to further reduce the likelihood for future potential development-related impacts to protected biological organisms to a level that would be less than significant.

This is not a standalone policy, rather it is made operational by Policy LU-8.3 Riparian Area Land Use Overlay and Implementation Measure LU-8A Stream and Riparian Combining Zone which prohibits development within a buffer around stream/riparian areas and makes this the requirement for all projects.

Policy LU-8.3 Riparian Area Land Use Overlay is a policy, coupled with implementation Measure LU-8A Stream and Riparian Combining Zone, that further operationalizes Conservation and Open Space Element Implementation Measure 3.320 by requiring the implementation of a combining zone around streams that prohibits development within a prescribed buffer area, provides City of Willits Land Use Element Final PEIR
16 clear procedures requiring findings, in consultation with CDFW, for exceptions, vegetation removal and to avoid takings, and defines allowable uses in streams and riparian areas that shall not result in significant adverse effects to biological resources.

Mitigation BIO-01. New Policy LU-9.X1 Utilize Biological Resource Inventory Assessment Tools During Project Review requires the adoption of a new policy directing City staff to ensure that the best available biological resource mapping data (with specific references) is used as a screening tool during the ministerial and discretionary project review process to identify biological resource concerns, evaluate project alternatives, and guide mitigation to avoid or reduce biological resource impacts to insignificant levels consistent with CEQA.

City of Willits Land Use Element Final PEIR
17 Mitigation BIO-01.4. New Policy LU-9.X4 Local Native Plant List requires that the City develop and make available a list of locally appropriate native vegetation suitable for planting within low impact development features and for development-related landscaping and revegetation and encourage the use of locally appropriate and locally sourced native vegetation, appropriately-selected revegetation seed applications, or blends for use in revegetation and landscaping efforts and prohibit the use of any plant species designated as: “invasive,” “noxious weed,” or “federal noxious weed.”
Mitigation BIO-01. New Policy LU-9.X5 Require Appropriate Design Standards to Minimize Artificial Light Pollution requires that the design and location of all outdoor lighting fixtures associated with development prevent direct illumination of streams, wetlands, and Riparian Buffer Areas. This mitigation measure and new policy serve to avoid and/or reduce light pollution associated with development, which is known to adversely affect the migration, movements, and other important behaviors of salmonids, as well as other fish and wildlife taxa.

As described above, the Land Use Element update is not a specific project and therefore site-specific impacts and mitigations cannot be developed. The proposed policies, as revised by the mitigations, should be considered comprehensive and appropriately protective of the biological resources within the City and proposed SOI expansion areas for future development, given that they:

1. ensure that the best available biological resource mapping data (with specific references) is used as a screening tool during the review of all ministerial and discretionary projects;

3. establish a range of protective requirements, including low impact drainage infrastructure, native plantings, and non-pollutive lighting for development near riparian areas;

4. require that an oak tree and oak woodland retention and protection program be added to the Zoning Regulations applicable to new ministerial and discretionary development; and
City of Willits Land Use Element Final PEIR
18 5. require that annexations and development in the South Haehl Creek area prepare and adhere to the requirements of a biological resources assessment and mitigations to protect biological resources.

As clearly defined above, Implementation of Mitigation Measures BIO-01.1 through 1.6 would reduce biological resource impacts to less than significant.

3.4 CULTURAL AND TRIBAL CULTURAL RESOURCES
Discussion of Impacts:

Cultural and Tribal Cultural Resources could be disturbed, damaged, destroyed, or inadvertently uncovered, and adverse changes in the significance of such resources could occur, by ground-disturbing activities associated with future development allowed under the proposed Land Use Element Update. Potential impacts on Cultural and Tribal Cultural Resources include:
• Historical and pre-contact archaeological resources or human remains that meet the definition of archaeological resources under CEQA;
• Native American human remains as well as other human remains, including those interred outside of formal cemeteries.
• Prehistoric archaeological sites and isolates are Tribal Cultural Resources; additionally, plants and other natural resources, as well as geographic locations can also be Tribal Cultural Resources. Grading of original in situ soils could expose buried TCRs and features including sacred sites. • Cumulatively considerable impact to Cultural and Tribal Cultural Resources.

Mitigation CUL-1.

Implementation Measure LU-7.X1 Inadvertent Encounter with Archaeological or Cultural Resources In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or uncovered 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 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.

City of Willits Land Use Element Final PEIR
19 Mitigation TCR-1.

Implementation Measure LU-7.X2: Tribal Cultural Resources Avoidance. When feasible, development facilitated by the project shall be designed to avoid known tribal cultural resources. Known tribal cultural resources within 60 feet of planned construction activities shall be protected by establishing an Environmentally Sensitive Area (ESA) that would be fenced, or otherwise protected, to ensure avoidance. The feasibility of avoidance of tribal cultural resources shall be determined by the City of Willits and applicants in consultation with local California Native American tribe(s).

Mitigation TCR-2.

Implementation Measure LU-7.X3: Inadvertent Encounter with Tribal Cultural Resources. If previously unidentified tribal cultural resources are encountered during project implementation, altering the materials and their stratigraphic context shall be avoided and work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or disturb cultural resources. A representative from a locally-affiliated Native American Tribe shall be contacted in a timely manner to evaluate the resource and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in consultation with the City of Willits.

Findings:

The requirement that Cultural and Tribal Cultural Resources, including historical and pre-contact archaeological resources or human remains that meet the definition of archaeological resources under CEQA; Native American human remains as well as other human remains, including those interred outside of formal cemeteries; prehistoric archaeological sites and isolates are Tribal Cultural Resources; additionally, plants and other natural resources, as well as geographic locations can also be Tribal Cultural Resources, be protected through avoidance and detailed protocols relating to resources encountered during development is incorporated into the Land Use Element Update to avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. This change is identified in the form of the mitigation measures above. The City Council hereby finds that implementation of these mitigation measures is feasible, and the measures are therefore adopted, and based upon substantial evidence in the record, the Cultural and Tribal Cultural Resources impacts of the project are less than significant.

City of Willits Land Use Element Final PEIR
20 Rationale for Finding:

Mitigation Measures CUL-1, TCR-1, and TCR-2, coupled with implementation measure LU-7A, Tribal Consultation, require the implementation of policies and implementation measures within the Land Use Element Update, would apply to all development and to discretionary development applications or General Plan amendments. Implementation of Mitigation Measures CUL-1, TCR-1, and TCR-2 would reduce Cultural and Tribal Cultural Resources impacts to less than significant.

3.5 GEOLOGY AND SOILS
Discussion of Impacts:

Development allowed by the Land Use Element Update may place structures in areas with seismic sensitivity, areas subject to ground shaking and potential secondary hazards (i.e., liquefaction and subsidence) as a result of earthquakes or unstable geologic units or soil that is unstable, or that would become unstable and potentially result in on or offsite landslide, lateral spreading, subsidence, liquefaction or collapse. In addition, development allowed by the Land Use Element Update may result in the improvements to existing roadways, construction of infrastructure (water and sanitary sewer facilities), and additional commercial, residential, and industrial development, which could remove topsoil, disturbing and potentially exposing the underlying soils to erosion from a variety of sources, including wind and water. In addition, construction activities may involve the use of water, which may further erode the topsoil as the water moves across the ground. Implementation of existing General Plan Safety Element policies and implementations as well as compliance with the California Building Code, would reduce potential impacts from seismic activities. However, the Draft Safety Element (2019), which was prepared to bring up to date the City’s hazard reduction policies, is not yet adopted and cannot yet be relied upon to lessen potential impacts.

Mitigation GEO-1:

Adopt Draft Safety Element Prior to, or within six months following, the adoption of the Land Use Element, the City of Willits shall complete the process of updating and adopting the Draft Safety Element consistent with state law and initiate the process of putting into effect the implementation program.

The existing General Plan (1992) and Mendocino County General Plan Draft EIR (2008) do not identify the presence of paleontological or unique geological features within the City or surrounding area. The Mendocino County Draft EIR (2008) identified 182 paleontological resources in Mendocino, the majority of which were found in the Coastal Zone. Regardless, due to the prevalence of paleontological resources in the subsurface, it is possible that future development activities facilitated by the Project could uncover previously unknown paleontological resources.

City of Willits Land Use Element Final PEIR
21 Mitigation GEO-2:

LU-7x, Inadvertent Discovery of Paleontological Resources, If fossils are encountered during construction (i.e., bones, teeth, or unusually abundant and wellpreserved invertebrates or plants), the City and its contractor shall divert construction activities away from the discovery within 50 feet of the find, and a professional paleontologist shall be contracted to document the discovery as needed, to evaluate the potential resource, and to assess the nature and importance of the find. Based on the scientific value or uniqueness of the find, the paleontologist may record the find and allow work to continue, or recommend salvage and recovery of the material, if it is determined that the find cannot be avoided. The paleontologist shall make recommendations for any necessary treatment that is consistent with currently accepted scientific practices. Any fossils collected from the area shall then be deposited in an accredited and permanent scientific institution where they would be properly curated and preserved.

Findings:

The requirement that the Draft Safety Element be adopted within six months of the adoption of the Land Use Element Update is made a requirement of the approval of the Land Use Element Update and to include a new implementation measure into the Land Use Element regarding the inadvertent discovery of paleontological resources would avoid or substantially lessen the significant environmental effect as identified in the Draft EIR. This change is identified in the form of the mitigation measures above. The City Council hereby finds that implementation of these mitigation measures is feasible, and the measures are therefore adopted, and based upon substantial evidence in the record, the Cultural and Tribal Cultural Resources impacts of the project are less than significant.

Rationale for Finding:

Mitigation Measures GEO-1 and GEO-2 require the adoption of a Safety Element meeting current state requirements and the incorporation of a new implementation measures within the Land Use Element Update that would apply to all development.

Implementation of Mitigation Measures GEO-1 and GEO-2 would reduce geology and soils impacts to less than significant.

3.6 HAZARDS AND HAZARDOUS MATERIALS
Discussion of Impacts:

Future development allowed by the Land Use Element Update may result in impacts relating to hazards and hazardous materials, which could include the following:
• involve the transportation, use, and/or disposal of hazardous materials and may involve equipment or construction activities that use hazardous materials (e.g., City of Willits Land Use Element Final PEIR
22 coatings, solvents and fuels, and diesel- fueled equipment), cleanup of sites with known hazardous materials, the transportation of excavated soil and/or groundwater containing contaminants from areas that are identified as being contaminated, or disposal of contaminated materials at an approved disposal site;
• result in hazardous emissions or require handling of hazardous or acutely hazardous materials, substances, or waste;
• result in a safety hazard or excessive noise for people residing or working near an airport;
• impair 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.

Development allowed by the proposed Land Use Element Update would be required to comply with federal and state regulations regarding the routine transport, use, or disposal of hazardous materials or through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment and regulations relating to ensure that existing hazards, including those associated with known hazardous materials sites. However, local policies and regulations regarding the hazards listed above are addressed in the Draft Safety Element (2019), which is not yet adopted and cannot yet be relied upon to lessen potential impacts.

Mitigation GEO-1:

Findings:

By including Mitigation Measure GEO-01 the updated hazards hazardous materials policies of the Draft Safety Element, including policies relating to industrial land use compatibility, as well as policies and programs relating to wildland fire and airport land use compatibility, would apply to future development within the City. Through the implementation of this mitigation measure, potential impacts related to land use compatibility and hazardous materials would be less than significant. A less than significant impact would occur with mitigation incorporated.

Rationale for Finding:

Mitigation Measure GEO-01 requires the adoption of an update to data Safety Element within six months of the adoption of the Land Use Element, after which and all hazard policies therein would apply to development allowed by the Land Use Element Update.

Implementation of Mitigation Measure GEO-01 would reduce hazards and hazardous materials impacts to less than significant.

City of Willits Land Use Element Final PEIR
23 3.7 WILDFIRE
Discussion of Impacts:

Future development allowed by the Land Use Element Update may result in impacts relating to wildland fire, which could include the following:
• substantially impair an adopted emergency response plan or emergency evacuation plan;
• due to slope, prevailing winds, and other factors of a development allowed by the Land Use Element Update, 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;
• expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes; and
• have other potentially significant wildfire impacts relating to the proximity of development allowed by the Land Use Element Update to wildfire hazard, or potential future characteristics such as density; location with respect to wildfire hazard; demographics; evacuation access and egress.

The proposed Land Use Element contains a series of policies, in particular LU-2.4, Annexations, intended to provide for orderly development of the City and to provide for a framework for future potential City expansion into the City’s Sphere of Influence in a manner consistent with the General Plan, considering preservation of open space lands, and that create a logical City boundary; result in the efficient use of City services and utilities; and support a robust transportation network. The proposed Land Use Element also contains a policy, LU-9.7, Emergency Evacuation, that prohibits subdivisions in neighborhoods having only one access or that are vulnerable to isolation if access roads are impacted. The proposed Land Use Element Update is intended to ensure that the City does not impair the adopted Emergency Operation Plan and Evacuation Plan.

The City of Willits is in the process of updating its Safety Element, 2019 Draft Safety Element. The City of Willits has comprehensive emergency response and evacuation policies outlined in the Emergency Operations Plan (EOP) section of the Draft Safety Element. Goal 5 outlines policies covering various hazards such as earthquakes, extreme weather, landslides, transportation accidents, hazardous materials, wildlife fires, energy shortages, dam failures, civic disturbances, terrorist activities, and national security. Draft Safety Element Goal 3 seeks to safeguard the community from the threat of urban and wildfire hazards. However, the Draft Safety Element has not been adopted and cannot yet be relied upon to lessen potential impacts and the existing Safety City of Willits Land Use Element Final PEIR
24 Element may not reflect recent legislative requirements relating to wildfire since the preparation of the Draft in 2019.

Mitigation GEO-1:

Mitigation Measure WF-01.

Prior to adoption of the Draft Safety Element, review, an update shall be required to is consistent with applicable state legislation that has been passed since the draft’s preparation in 2019.

Findings:

By including Mitigation Measure GEO-01 and WF-01, including Draft Safety Element policies updated to reflect changes in law relating to wildfire hazards that have been adopted since 2019, would apply to existing and future development within the City.

When adopted, the Safety Element:
• promotes comprehensive structural modification and fuel modification guidelines for new and existing (non-conforming) buildings and structures located within the high and very high fire hazard severity zones,
• restricts new development in high and very high fire hazard severity zones, unless designed using the most up to date wildfire mitigation techniques and code requirements,
• requires compliance with recommendations from the Little Lake Fire Protection District to ensure adequate service is provided to residents and businesses, locate new critical facilities outside of the Very High Fire Hazard Severity Zones, unless no alternate location is available or feasible,
• requires all new development and major redevelopment/reconstruction within the high and very high wildfire hazard severity zones to prepare a Fire Protection Plan would avoid or substantially lessen the significant environmental effect as identified in the Draft EIR.

This change is identified in the form of the mitigation measure above. The City Council hereby finds that implementation of the mitigation measure is feasible, and the measure is therefore adopted, and based upon substantial evidence in the record, the wildland fire impacts of the project are less than significant.

City of Willits Land Use Element Final PEIR
25 Rationale for Finding:

Implementation of Mitigation Measure GEO-01 would reduce hazards and hazardous materials impacts to less than significant.

City of Willits Land Use Element Final PEIR
26 4. FINDINGS REGARDING IMPACTS ANALYZED IN THE

EIR AND DETERMINED TO BE LESS THAN SIGNIFICANT

REQUIRING NO MITIGATION OR NO IMPACT
Aesthetics
• Threshold AES-02: Would the project substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway? There are no officially designated State Scenic Highways within the Planning Area.
• Threshold AES-04: Would create a new source of substantial light or glare that would adversely affect day or nighttime views in the area? Policies and measures of the proposed Land Use Element promote infill and compatible development to minimize light or glare related impacts of new development.

Agricultural and Forestry Resource
• Threshold AG-01 – Would the project 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? The Planning Area does not contain mapped Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. DOC Farmland Mapping and Monitoring Program maps show Grazing Land, Other Land, and Urban and Built-Up Land within the Planning Area and do not show any Important Farmland categories within the Planning Area.
• Threshold AG-03: Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? There are no existing areas zoned as timberland or timberland production zones within the Planning Area.
• Threshold AG-04: Would the project result in the loss of forest land or conversion of forest land to non-forest use? There are no forest lands in the Planning Area, so no impacts would occur.

Air Quality
• Threshold AQ-01: Would the Project conflict with or obstruct implementation of the applicable air quality plan? The proposed Project would be consistent with Mendocino County Air Quality Management District’s (MCAQMD) Particulate Matter Attainment Plan and rules and regulations.
• Threshold AQ-02: Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region in in non-attainment under an applicable federal or state ambient air quality standard? New development would be required to comply with the MCAQMD’s Attainment Plan City of Willits Land Use Element Final PEIR
27 (2005) and rules and regulations and would be required to obtain applicable permits from the MCAQMD.
• Threshold AQ-03: Would the Project expose sensitive receptors to substantial pollutant concentrations? Future development would be required to comply with the MCAQMD’s rules and regulations (2011) and Attainment Plan (2005). • Threshold AQ-04: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? Land Use Element Update policies and implementation measures would ensure that new development and land uses are compatible with surrounding uses.

Biological Resources
• Threshold BIO-05: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? The Land Use Element would be consistent with, or improve upon, local policies and ordinances protecting biological resources and would therefore not conflict with Local Policies or Ordinances Protecting Biological Resources. • Threshold BIO-06: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? There are no adopted habitat conservation plans, natural community conservation plans, or other approved local, regional, or state habitat conservation plans within the Planning Area.

Cultural and Tribal Cultural Resources
• Threshold CUL-01: Would the Project cause a substantial adverse change in the significance of a historic resource as defined by CEQA Guidelines Section 15064.5?
Energy
• Threshold EN-01: Would the project 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 proposed project will result in development that has more efficient, and less wasteful energy use during construction and operation, resulting in a beneficial impact
• Threshold EN-02: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency. The proposed project will result in development that will not disrupt baseline renewable energy facilities or services or interfere with the implementation of planned renewable energy or energy efficiency improvements.

Geology and Soils
• Threshold GEO-04: Would the Project 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? The majority of the Planning Area is depicted as not rated or not available in areas where development has already occurred, reflecting the urbanized areas of Willits. Design criteria and specifications set forth in the design-level geotechnical investigation, pursuant to the California Building Standards Code, would ensure impacts from expansive soils are minimized.

City of Willits Land Use Element Final PEIR
28 • Threshold GEO-05: Would the Project 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? The Land Use Element would not be anticipated to facilitate development that would require new septic tanks or alternative wastewater disposal systems.

Hazards and Hazardous Materials
• Threshold HAZ-03b: Development facilitated by the Project has the potential to 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, create a significant hazard to the public or the environment? Compliance with federal and state regulations would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5 Cortese List would be less than significant
Hydrology and Water Quality
• Threshold HYD-01: The proposed project would have a significant impact on the environment associated with hydrology and water quality if it would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Water quality within the Planning Area is regulated by federal, state, and local regulations. Development allowed by the Land Use Element Update would be required to comply with the state Construction General Permit Order 2022-0057-DWQ and City of Willits Design and Construction Standards, and because the existing General Plan and proposed Land Use Element Update contains policies consistent with protecting surface water and groundwater quality, the proposed Land Use Element Update would not violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.. • Threshold HYD-02: The proposed project would have a significant impact on the environment associated with hydrology and water quality if it would substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that may impede sustainable groundwater management of the basin. The City of Willits water system has sufficient water to serve the planned land uses identified in the Land Use Element Update during times of nondrought, and the City of Willits Council could approve an increase in groundwater usage during time of emergency, the water system would have adequate water supply to serve current demand and future development that may be facilitated by the proposed Project. Additionally, as groundwater in the Basin appears to recover quickly from declines, the proposed Project would not interfere with groundwater recharge or impede sustainable groundwater management. • Threshold HYD-03: The proposed project would have a significant impact on the environment associated with hydrology and water quality if it would substantially alter the existing drainage pattern of the site or area in a manner which would result in substantial erosion or siltation, substantially increase the rate or amount of surface runoff, 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 flood flows.

Adherence to the State Water Resources Control Board National Pollutant City of Willits Land Use Element Final PEIR
29 Discharge Elimination System General Permit and City of Willits Design and Construction Standards would result in less than significant impacts relating to stormwater drainage and flood flows.
• Threshold HYD-04: The proposed project would have a significant impact on the environment associated with hydrology and water quality if it would result in flood hazard, tsunami, or seiche zones, or risk release of pollutants due to project inundation. Compliance with the City of Willits Design and Construction Standards and Construction General Permit requires stormwater controls and specific best management practices to be implemented to minimize the amount of sediment and other pollutants associated with construction sites from being discharged in stormwater runoff. Additionally, development located within a flood zone would be required to comply with Title 17 Sections 38 and 40 of the City of Willits Municipal Code, which regulates development in flood zones and requires that development and construction within flood zones be designed to withstand floods.
• Threshold HYD-05: The proposed project would have a significant impact on the environment associated with hydrology and water quality if it would conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. The City of Willits Little Lake Valley Groundwater Management Plan is a voluntary and non-regulatory plan, and therefore, the proposed Project does not need to comply with it. No relevant water quality control plan or sustainable groundwater management plan to the Planning Area exists.

Land Use and Planning
• Threshold LU-01: Would the project physically divide an established community? Implementation of the Land Use Element would update land use designations to current land use conditions ensuring orderly development in the Project Area and would not physically affect an established neighborhood. • Threshold LU-02: Would the project 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? The Land Use Element takes into consideration existing plans, policies, and regulations to create cohesive policies and implementation measures for the Willits Project Area.

Mineral Resources
• Threshold Min-01: Would the project 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? There are no known or identified mineral resource sites anywhere within the Planning Area or sites utilized for mineral extraction. • Threshold Min-02: Would the project 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? There are no sites within the City of Willits or Proposed SOI Area utilized for rock or sand extraction or that are identified by the City or the County’s General Plans.

Noise
City of Willits Land Use Element Final PEIR
30 • Threshold NOI-01 and 02: Would the Project generate 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 generate excessive groundborne vibration or groundborne noise levels? Future development allowed by the Land Use Element Update would be evaluated by the City for conformance with existing Noise Element policies and regulations, the Land Use Element would not cause the generation of a substantial temporary or permanent increase in ambient noise levels in the Planning Area in excess of established standards. • Threshold NOI-03: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? The Ells Field compatibility zones do not extend very far beyond the runway and would not affect noise-sensitive receptors within the City or proposed expanded Sphere of Influence.

Population and Housing
• Threshold Pop-1: Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). Implementation of the Land Use Element Update would allow the construction of new housing to accommodate population growth, and development would be consistent with the Housing Element and Land Use Element policies and implementation measures.
• Threshold Pop-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? Implementation of the Land Use Element would improve existing housing stock and provide new housing and result in a less than significant impact on displacement of people or housing and/or construction of replacement of housing.

Public Services
• Threshold PS-01a: 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 fire protection? Existing General Plan policies direct the City to cooperate with Little Lake FPD in developing standards and guidelines to assure adequate fire protection to accommodate population growth. • Threshold PS-01b: 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 police protection? The increase in estimated population would City of Willits Land Use Element Final PEIR
31 increase demand for police protection services but not beyond the capacity of the current facility to meet the increased demand at an acceptable service ratio. • Threshold PS-01c: 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 or other performance objectives for schools? K-12 grade school enrollment at Willits Unified School District is not anticipated to exceed school capacity with population growth and campus grounds have space for expansion from new additions or modular units, impacts are therefore expected to be less than significant.

Recreation
• Threshold REC-01: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Existing General Plan’s Public Services and Facilities, Parks and Recreation Element and proposed policies of the Land Use Element Amendment requires that the parklands to resident ratio standard be maintained limiting the potential for parks physical deterioration.
• Threshold REC-02: Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The General Plan requires residential developers to set aside lands or provide in-lieu fees and the Land Use Element Update would implement strategic planning to ensure that the City's parkland standard of five acres per 1,000 residents is maintained. Future park development by the City or developers would be subject to CEQA review.

Transportation Circulation
• Threshold TRAN-01: Would the Project disrupt existing bicycle and pedestrian facilities or interfere with planned facilities or cause a physical change inconsistent with bicycle and pedestrian policies contained in the City of Willits General Plan and the City of Willits Bicycle and Pedestrian Specific Plan? The City will remain relatively compact with existing development and new growth concentrated in an area of approximately 2.5 by 3 miles where any vehicle trips generated will be relatively short in length compared to 9.5-mile average trip lengths for Mendocino County. As a result, population and employment growth in this area would be expected to generate VMT per capita at rates similar to baseline conditions.
• Threshold TRAN-02: Would the Project disrupt existing transit service, interfere with planned transit service, or cause a physical change inconsistent with transit policies contained in the City of Willits General Plan? The proposed project’s land use and policy changes may generate demand for new bicycle trips. The city’s compact form makes it highly accessible by both pedal and electric bicycles (ebicycles). The policy changes below will contribute to improving the existing bicycle environment
• Threshold TRAN-03: Would the Project result in modifications to the study area transportation network that are not consistent with the applicable design City of Willits Land Use Element Final PEIR
32 standards? The Land Use Element Update does not include transportation network modifications that would disrupt existing or interfere with planned pedestrian facilities. The proposed project’s land use and policy changes may generate demand for higher levels of walking. The policy changes below will contribute to improving the existing pedestrian environment. • Threshold TRAN-04: Would the Project generate home-based VMT per resident or home-based work VMT per employee at rates that are greater than the citywide average under baseline conditions? The Land Use Element Update does not propose transportation network modifications that would disrupt existing or interfere with planned transit facilities or services. As growth occurs within the proposed sphere of influence, new transit needs may emerge such as new stops along MTA Route 65. The Mendocino Council of Governments annually seeks public input and citizen participation to identify unmet transit needs in the region Utilities and Service Systems
• Threshold UTL-01: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects? Relevant policies of the Land Use Element Update plan for a range of potential population growth levels within the City. These direct growth to where infrastructure either already exists or doesn’t exceed the capacity of existing infrastructure.
• Threshold UTL-02: Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years? The City appears to have sufficient water supply to serve the projected population of 7,500 persons planned for in this Draft PEIR, and additional development within the population planned for in this Draft PEIR would not necessitate the development of an additional water source. • Threshold UTL-03: Would the Project 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? The City’s would have adequate capacity to provide wastewater services to the projected population under the Project. • Threshold UTL-04: Would the Project 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? Development allowed by the Land Use Element Update would not generate solid waste in excess of state or local standards or the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
• Threshold UTL-05: Would the Project comply with federal, state and local management and reduction statutes and regulations related to solid waste? With continued compliance with the applicable regulations, leading to increased recycling and waste diversion, and adherence to the proposed General Plan goals, policies, and actions, anticipated rates of solid waste disposal from the proposed project would be less than significant with respect to permitted landfill capacity.

City of Willits Land Use Element Final PEIR
33 5. OTHER CEQA REQUIRED ANALYSIS IN THE EIR

5.1 ENERGY USE
Pursuant to CEQA Guidelines Appendix F, an EIR must “include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful and unnecessary consumption of energy.” Impacts related to the energy consumption of the Land Use Element Update and the applicability of state or local plans for renewable energy and energy efficiency are discussed in Section

3.6. (Energy) of the Draft EIR.

5.2 GROWTH INDUCING IMPACTS
CEQA requires an EIR to describe any growth-inducing impacts that would result from the proposed action. This section first describes the types of actions that tend to induce growth, and then discusses those impacts as they generally relate to the proposed action. The section then addresses four specific actions that potentially lead, directly or indirectly, to more growth, namely: (1) fostering economic or population growth; (2) removing existing obstacles to growth; (3) other precedent-setting actions; and (4) developing or encroaching upon existing open space.

Based on Section 15126.2(e), a general plan would considered growth-inducing if it would: directly or indirectly foster economic growth, population growth, or the construction of additional housing; if it would remove obstacles to population growth; if it would draw down the capacity of community service facilities to the extent that construction of new facilities would be necessary; or if it would encourage or facilitate other activities that cause significant environmental effects. For example, expanding road capacity or sewer and water facilities is typically considered “growth inducing” because such projects generally alleviate existing problems and/or inefficiencies, as well as provide capacity for some additional growth.

State law requires the general plan to serve as a comprehensive, long-term plan for the physical development of a community, for which the Land Use Element plays a central role. The Land Use Element Update does not propose any specific development projects, so it will not directly involve any growth inducing impacts. However, indirect growth-inducing impacts would occur because the proposed land use changes and their locations, including the proposed expansion of the Sphere of Influence, along with the proposed goals, policies, and implementation measures of the City General Plan, in particular the propose changes associated with the Land Use Element Update will provide a framework for future growth and development within the City of Willits. The environmental impacts that could result from potential growth are analyzed in detail in Chapter 3 of the Draft EIR.

5.3 SIGNIFICANT AND UNAVOIDABLE IMPACTS OF THE PROPOSED PROJECT Section 15126.2(c) of the CEQA Guidelines require that an EIR identify any significant environmental effects that cannot be avoided if the Project were implemented, including City of Willits Land Use Element Final PEIR
34 those that can be mitigated but not reduced to a level of insignificance. Impacts relating to Greenhouse Gas Emissions, as detailed in Section 2.1, would remain significant and unavoidable after feasible mitigation measures are applied:

5.4 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
Section 15126.2(d) of the CEQA Guidelines requires that an EIR include a discussion of significant irreversible environmental changes that would result from project implementation.

Implementation of the proposed Land Use Element Update would allow development that would result in long-term irretrievable commitments of nonrenewable resources associated with the construction of new housing units, non-residential structures, streets, and other infrastructure. The commitment of natural resources would include lumber and forest products, sand and gravel, asphalt, petrochemicals, and other construction materials. The resulting consumption of fossil fuels would incrementally reduce existing supplies of fuel oil, natural gas, and gasoline. Consumption of these resources would occur with any development in the region and are not unique to the City of Willits or the Land Use Element Update.

An incremental increase in energy demand would also take place during construction and postconstruction activities, including lighting, plumbing, and heating of commercial, industrial, school, and residential buildings. The Land Use Element Update includes policies to encourage energy conservation and reduction and the use of renewable energy systems. However; even renewable energy systems involve the use of fossil fuels and minerals in their manufacture, although these systems are designed to result in considerably less demand for fossil fuels during their lifecycle than technologies powered by fossil fuel combustion.

Growth facilitated by the Land Use Element Update would incrementally increase regional air pollutant and greenhouse gas (GHG) emissions. As discussed in Section

3.3 (Air Quality) and Section 3.8 (Greenhouse Gas Emissions) of the Draft EIR, implementation of the proposed plan policies, regional air pollution programs, and mitigation measures would reduce the air pollutant and GHG emissions associated with individual future development projects. Although individual projects may be less than significant, the total development anticipated by the Land Use Element Update would contribute to higher generation of toxic air contaminants and particulate matter (PM2.5).

The Land Use Element Update includes goals, policies, and implementation measures that anticipate future changes to ensure that they will be effectively planned for and protect open space, biological resources, and design of the built environment. The development and further urbanization within the City would result in irreversible environmental changes; once an area is developed into a built environment, the likelihood of ‘reversing’ developed areas back to an undeveloped state is highly improbable because the investment of resources and infrastructure for new development is an asset that tends to be protected over time. Therefore, such changes are considered irreversible. From a larger geographic perspective, attracting growth to City of Willits Land Use Element Final PEIR
35 the City of Willits, where infill development is prioritized and the footprint of the City would be allowed to expand to accommodate growth thereafter, instead of allowing growth in outlying unincorporated areas of the county could reduce the scale of irreversible environmental effects.

City of Willits Land Use Element Final PEIR
36 6. FEASIBILITY OF PROJECT ALTERNATIVES
An EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are feasible, and therefore, merit in-depth consideration, and which ones are infeasible.

6.1 PROJECT ALTERNATIVES

6.1.1 ALTERNATIVES CONSIDERED BUT REJECTED
The City considered an alternative that would only consider including the Locust Street area within the Proposed Sphere of Influence. This alternative was originally considered to meet all project objectives and was considered to be environmentally superior, in comparison to the Proposed Project, because it would not involve any additional Sphere of Influence areas. However, early on within the planning process it was learned that Locust Street is a dead-end road and a costly secondary access, which could include a new bridge across Baechtel Creek, would be required to allow more than 30 new residential units in this this area. In addition, a preliminary windshield review of potential indicated that wetlands may be present within the areas thought best to accommodate new development. As a result, this alternative was rejected.

6.1.2 ALTERNATIVES CONSIDERED
• Alternative 1: No Project
• Alternative 2: No Expanded Sphere of Influence
CEQA Guidelines Section 15126.6(c) provides that the factors that may be used to eliminate an alternative include: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental effects of the project.

Pursuant to CEQA requirements, the No Expanded Sphere of Influence Alternative would be considered the environmentally superior alternative; however, the Proposed Project would offer benefits that would not be achieved by the No Expanded Sphere of Influence Alternative, primarily expanded housing opportunities matching the demand for residential development.

Comparison of Direct Impact of Alternatives
Proposed Project
No
Expanded
Sphere of
Influence No Project
Aesthetics Less than Significant <= >
Agricultural and Forestry
Resources
Less than Significant
with Mitigation
Incorporated
<= <=
Air Quality Less than Significant = >=
City of Willits Land Use Element Final PEIR
37 Comparison of Direct Impact of Alternatives
Proposed Project
No
Expanded
Sphere of
Influence No Project
Biological Resources Less than Significant
with Mitigation
Incorporated
<= >=
Cultural Resources Less than Significant <= >=
Energy Less than Significant <= >=
Geology and Soils Less than Significant
with Mitigation
Incorporated
= =
Greenhouse Gas Emissions Significant and
Unavoidable
>= >
Hazards and Hazardous
Materials
Less than Significant
with Mitigation
Incorporated
= =
Hydrology and Water Quality Less than Significant = >=
Land Use and Planning Less than Significant = =
Mineral Resources Less than Significant = =
Noise Less than Significant = >=
Population and Housing Less than Significant = =
Public Services Less than Significant = =
Recreation Less than Significant >= >=
Transportation Circulation Less than Significant <= >=
Utilities and Service Systems Less than Significant = = Wildfire Less than Significant
with Mitigation
Incorporated
<= >=
Alternative 1 - No Project
This is the only EIR alternative that is specifically required by the CEQA Guidelines (Section 15126.6[e]). The No Project alternative does not represent a no-development or no change scenario as the City has an existing General Plan Land Use Element. This would not result in an update to the Land Use Element to include changes to state law that have occurred since the adoption of the current plan.

As summarized in the table above, the No Project Alternative has a greater impact than the proposed project for most impact topics because this alternative does not include policies to conform with updated state land use planning requirements relating to hazards, resource protection, or complete streets, nor does it contain policies that encourage mixed uses or provide buffers to ensure land use compatibility. The No City of Willits Land Use Element Final PEIR
38 Project Alternative would not result in lower environmental effects in any impact category.

Findings:

This alternative is rejected because it would not meet any of the project’s objectives.

The No Project Alternative has a greater impact than the proposed project in relation to aesthetics because it does not implement policies relating to buffers and would not contain mitigations relating to hillside/forest development. Greenhouse gas impacts are greater because densities and intensities would be lower, and no mixed uses are planned and areas outside the City would develop at lower densities and state policies related to greenhouse gas emissions and state housing needs would not be met and VMT would not be reduced by mixed use development. There would be no additional biological resource protections for development near aquatic resources or special status species.

Alternative 2 - No Expanded Sphere of Influence t
The no expanded Sphere of Influence Alternative could have greater recreation-related impacts because no additional land within the proposed Sphere of Influence could be used for expanded public facilities including parks. If more population growth occurs in outlying unincorporated areas under the No Expanded Sphere of Influence Alternative, potential VMT impacts would be greater than the Proposed Project because the expanded Sphere of Influence accommodate significantly more development near to the existing City core than the County land use map.

Potential environmental impacts resulting from No Expanded Sphere of Influence Alternative are generally lower or equivalent to the proposed Project. Reduced impacts would occur in many topics due to no expanded sphere area and include lower levels of aesthetic impacts due to less City development within undeveloped hill slopes; less potential impacts to agricultural resources; lower impacts to biological resources and cultural resources because residential densities are lower; potentially lower greenhouse City-wide gas emissions because only infill development occurs; and lower level of development in higher wildfire hazard areas.

Findings:

Potential environmental impacts resulting from the No Expanded Sphere of Influence Alternative are generally equivalent to or lower than the proposed Project. The No Expanded Sphere of Influence Alternative would generally meet the project objectives, but to a lesser extent because the land supply could not be expanded to meet market needs and population growth. While this Alternative is considered the Environmentally Superior Alternative, it is rejected because it would not meet project objectives to the extent of the proposed project.

6.2 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Of the other alternatives evaluated in the Draft EIR, the No Expanded Sphere of Influence Alternative would be the environmentally superior alternative. The although City of Willits Land Use Element Final PEIR
39 impacts would be less than the Proposed Project, the No Expanded Sphere of Influence Alternative would potentially result in lower direct levels of aesthetic impacts due to less City development within undeveloped hill slopes, and less potential impacts to agricultural and forestry resources, biological resources, cultural resources, energy, greenhouse gas emissions, VMT and wildfire hazards because the project would not involve expansions of the City Sphere of Influence where the likely of direct potential impact would be greater. It should be noted though, that the Proposed Project prioritizes infill development and would limit expansion of new development into Sphere areas according to the needs to expand the supply of residential land because there is a mismatch between the willingness of landowners to develop within the City and the demand for residential land. Indirect impacts may occur if large lot rural residential development using on-site water and wastewater systems occurs in areas within the Planning Area and outside the City.

City of XXX Project
40 7. FINDINGS OF FACT AND STATEMENT OF OVERRIDING

CONSIDERATIONS

7.1 CEQA FINDINGS OF FACT
A. The City of Willits Land Use Element Update or "the Project" is described in full in the EIR (Draft EIR and Final EIR), at pp. 2.0-1 through 2.0-51 This project description is incorporated herein by reference.

B. The EIR evaluated the impacts of the Land Use Element Update, both individual and cumulative, along with recommended mitigation measures and suggested conditions, are summarized in the Executive Summary, Section 1.7 Summary of Impacts and Mitigation Measures, provided in Draft EIR pp. 1.0-6 through 1.0-54.

C. The City finds that, based upon substantial evidence in the record, as discussed throughout the EIR (Draft EIR Chapter 3, Environmental Analysis), the Project's impacts on the topical areas outlined in Appendix G of the CEQA Guidelines are as follows:
o Less than Significant Impact: Air Quality, Energy, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise, Population and Housing, Public Services, Recreation, Transportation Circulation, and Utilities and Service Systems.
o Less than Significant Impact with Mitigation: Aesthetics, Agricultural and Forestry Resources; Biological Resources; Cultural and Tribal Cultural Resources; Geology and Soils; Hazards and Hazardous Materials; and Wildfire.
o Significant and Unavoidable: Greenhouse Gas Emissions.

D. Mitigation measures designed to avoid or substantially lessen the significant environmental effects of the Project as identified in the EIR are set forth in the Mitigation, Monitoring, and Reporting Plan ("MMRP"), and incorporated herein by reference. The measures constitute binding commitments, and those measures shall be incorporated into the Project and monitored in accordance with the MMRP.

E. Based on substantial evidence presented and discussed throughout the EIR (Draft EIR Chapter 3, Environmental Analysis), the City Council finds that these mitigation measures will avoid or reduce impacts on Aesthetics, Agricultural and Forestry Resources; Biological Resources; Cultural and Tribal Cultural Resources; Geology and Soils; Hazards and Hazardous Materials; and Wildfire to less than significant levels.

F. The City finds that, based upon substantial evidence in the record, as discussed throughout the EIR (Draft EIR Chapter 4, Environmental Impact Analysis), the Project's impacts on the following topical areas outlined in Appendix G of the CEQA Guidelines would remain significant and unavoidable: Greenhouse Gas Emissions.

G. Based on the foregoing and pursuant to Public Resources Code Section 21081 (b) and CEQA Guidelines Section 15091 (a)(3) and 15093(b), the City Council City of XXX Project
41 finds that the remaining significant unavoidable impacts of the Project are acceptable in light of its economic, fiscal, technological, and social benefits as well as other considerations. Such benefits outweigh identified significant and unavoidable impacts and provide the substantive and legal basis for this Statement of Overriding Considerations.

H. The City Council finds that the specific benefits and economic, legal, social, technological or other considerations below outweigh the Project's significant and unavoidable impacts and make the Project alternatives identified in the EIR infeasible.
o The City’s objectives for the Land Use Element are presented in the Draft EIR, on page 2.0-21 and 3.0-22. The Land Use Element is intended to function as the core of the City General Plan to guide the City's long-term framework for future growth and resource management within the planning area for at least the next 20 years.
“The policy focus areas contributed to the development of the City’s objectives for the Land Use Element, listed as follows:

1. Plan for a range of potential population growth levels within the City.

2. Facilitate infill development and commercial vitality.

3. Define an expanded Sphere of Influence that includes appropriate areas around the City for potential future residential development to help ensure an adequate City supply of developable land.

5. Plan new and sustain existing parks and recreation facilities for the entire community, especially underserved areas.

7. Define a Land Use Map and policy that minimizes the number of nonconforming uses and protects existing communities from incompatible uses, reduces energy consumption, and vehicle miles travelled.” I. Infeasibility of Project Alternatives Discussed in EIR. The following social, economic, legal, technological, and other considerations make the two alternatives identified in the EIR as infeasible (Draft EIR pp. 4.0-1 through 4.0- 15). The two alternatives are: 1) No Project Alternative; and 2) No Expanded Sphere of Influence Alternative. Findings related to the Alternatives can be found in this document in Section 6.1.2.

J. Alternatives Considered but Rejected in the EIR. Section 6.1.1 provides findings relating to Alternatives Considered but Rejected in the EIR.

City of XXX Project
42 K. Environmentally Superior Alternative. CEQA requires identification of the environmentally superior alternative among the alternatives to the proposed project. The environmentally superior alternative must be an alternative that reduces some of the project's environmental impacts, regardless of the financial costs associated. Identification of the environmentally superior alternative is an informational procedure, and the alternative identified as the environmentally superior alternative may not be that which best meets the goals or needs of the proposed project. Section 6.2 contains findings relating to the Environmentally Superior Alternative. Pursuant to CEQA requirements, the No Expanded Sphere of Influence Alternative would be considered the environmentally superior alternative; however, the Land Use Element Update would offer benefits that would not be achieved by No Expanded Sphere of Influence Alternative primarily housing opportunities and a diversity of land uses.

7.2 STATEMENT OF OVERRIDING CONSIDERATIONS
CEQA requires decision makers to balance the benefits of the proposed project against its unavoidable environmental risks when determining whether to approve the proposed project. If, in the opinion of the City Council, the benefits of the proposed project outweigh the unavoidable adverse effects, those effects may be considered “acceptable” (State CEQA Guidelines § 15093[a]). CEQA requires the agency to support, in writing, the specific reasons for considering a project acceptable when significant impacts are infeasible to mitigate. Such reasons must be based on substantial evidence in the FEIR or elsewhere in the administrative record (State CEQA Guidelines § 15093 [b]). The agency’s statement is referred to as a Statement of Overriding Considerations.

The following is a description of the Land Use Element Updates significant and unavoidable impact and the justification for adopting a statement of overriding considerations:
• Greenhouse Gas Emissions Impact GHG-01 and Impact GHG-02: Development facilitated by the 2040 General Plan would make progress towards achieving State goals but would not necessarily meet State 2030 or 2045 goals. Mitigation Measure GHG-1 (a revision to Policy LU-3.10, Plan For Climate Change, which (together with Policy LU-3.11 Greenhouse Gas Emissions Reductions) would require that the City plan for climate change and identify programs to reduce, adapt to, and increase resiliency to potential climate change impacts and to implement programs to achieve City-wide reductions in greenhouse gas emissions, consistent with state targets, which are specified in the Section 3.8, Greenhouse Gas Emissions, Regulatory Setting on Draft EIR pages 3.8-2 through 3.8-6. However, it is not feasible at this time for the City to ensure that development facilitated by the Land Use Element Update would meet state targets. This impact would be significant and unavoidable (see Draft EIR pp. 3.8- 8 and 3.8-9).

City of XXX Project
43 Implementation of the project would enable the City to achieve the project objectives, as established in the proposed Land Use Element Update, while avoiding significant environmental effects to the extent possible through feasible mitigation measures as described previously herein and balancing the benefits of the proposed project against its potential unavoidable adverse impacts. Given the imperative for future growth in the City, the following statements identify the reasons why, in the City Council’s judgment, based on substantial evidence, the benefits of the project outweigh the significant and unavoidable effects. The substantial evidence supporting the enumerated benefits of the project can be found in the preceding findings, which are herein incorporated by reference; in the project itself; and in the record of proceedings.

In accordance with the requirements of CEQA and the CEQA Guidelines, the City Council finds that the mitigation measures identified in the Final EIR and the Mitigation Monitoring and Reporting Program, when implemented, will avoid, or substantially lessen the significant effects identified in the Final EIR for the Project. However, certain significant impacts of the project are unavoidable even after incorporation of all feasible mitigation measures. Significant unavoidable impacts would result from the proposed project are associated with greenhouse gas emissions as discussed in Section 3.8 of the Draft EIR.

The City Council finds that all feasible mitigation measures identified in the Final EIR under the purview of the City will be implemented with the project, and that the remaining significant unavoidable effects are outweighed and are found to be acceptable due to the following specific overriding economic, legal, social, technological, and other benefits based upon the facts set forth above, the Final EIR, and the record, as follows:

Findings:

For the following reasons, the City Council finds that the economic, social, technological or other benefits of the Project outweigh the significant and unavoidable greenhouse gas emissions impacts and identified in the EIR. The City finds that each of the benefits set forth below in this Statement constitutes a separate and independent ground for finding that the benefits of the proposed plans outweigh the risks of their potential significant adverse environmental impacts. The benefits of the proposed General Plan Update are as follows:
• Under State law, the City must have an adopted General Plan, including a Land Use Element, which is its long-term framework or "constitution" for future growth and development. The General Plan represents the community's desires for its future growth and development. The General Plan contains the objectives, goals, and policies upon which the City Council will base decisions regarding land use. • The City has prepared the Land Use Element Update to bring the General Plan into conformance with state planning law, address current conditions, and to consider important issues affecting the community. This has led to a comprehensive overhaul of the General Plan Land Use Element that allows the City of XXX Project
44 City to implement best practices in planning to define a pathway for the City of Willits to become resilient to future risks and improve quality of life. • The Land Use Element Update process was guided by an Advisory Community and public outreach that sought to engaged the community, property owners, and decision-makers. The City hosted a community workshop, project website, and a series of City Council meetings. The Land Use Element Update reflects this public input and consideration.
• The Land Use Element Update would achieve a number of economic benefits that address both City and regional goals relating to a robust land supply for housing and economic development, enhancement of parks, recreation, and open space and improved quality of employment opportunities (as demonstrated through the Project's Objectives listed above).
• The Land Use Element Update reflects the stated vision, goals and objectives of the City of Willits (summarized above under Finding of Fact H above and incorporated here by reference).
• The Land Use Element Update will ensure orderly development patterns to accommodate projected increases in population through buildout of the General Plan by providing strategic land use designations that avoid or minimize land use conflicts.
• The Land Use Element Update will sustain and broaden the City's sales tax base by providing land planned for local and regional tax-generating uses and discouraging the establishment of freeway commercial development at exits along U.S. 101.
• Through numerous legislative actions in the past several years, the State of California has identified the lack of housing as a significant area of public concern, leading to an unsustainable lack of housing affordability, increased homelessness, social stress related to increased poverty and a reduction in economic prosperity for many state residents. The Land Use Element Update will provide a variety of housing opportunities with a range of densities, styles, sizes and values that will be designed to satisfy existing and future demand for quality housing in the area, and aid in achieving the City's regional housing needs allocation (RHNA).

The City Council finds that any one or more of these overriding considerations are sufficient to outweigh adverse impacts. As the CEQA Lead Agency for the proposed action, the City Council has carefully reviewed the Project and the alternatives presented in the EIR, and fully understands the Project and Project alternatives.

Further, this City Council finds that all potential adverse environmental impacts and all feasible mitigation measures to reduce the impacts from the Project have been identified in the Draft EIR, the Final EIR and public testimony. On balance, the City finds that there are specific considerations associated with The Land Use Element Update that serve to override and outweigh the Land Use Element Update’s significant unavoidable impacts. Therefore, pursuant to CEQA Guidelines Section 15093(b), these adverse effects are considered acceptable, and the City Council adopts this Statement of Overriding Considerations.

City of XXX Project | Final EIR Report of Preparers
45 8. ADOPTION OF A MITIGATION MONITORING AND

REPORTING PROGRAM FOR THE CEQA MITIGATION

MEASURES
To avoid, reduce or mitigate significant effects resulting from the proposed Project, the City of Willits General Plan Land Use Element Update, Public Resources Code Section 21081.6 requires that a reporting or monitoring program be designed to ensure compliance during project implementation through the implementation of a Mitigation Monitoring and Reporting Program (MMRP). The following table provides the MMRP for the proposed City of Willits General Plan Land Use Element Update in accordance with those guidelines.

City of Willits | Final PEIR Errata
46 TABLE 8A MITIGATION MONITORING AND REPORTING PROGRAM Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
Mitigation AES-1 - New Policy
LU-9.X. Development in Hillside Areas. Require new
development in hillside areas be sited and designed to
retain the natural hillside setting by minimizing grading and other major disruptions of the natural slope areas.

The City shall encourage clustered dwelling units in
hillside areas to preserve the scenic character of the
hillsides.

City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
Mitigation AG-01: Proposed New Policy:

New Policy LU-2.X. Annexation Planning.

Discourage urban development within the City’s Sphere
of Influence until such lands are annexed by the City
and support County land use regulations that protect
the viability of local agriculture in the Little Lake Valley.

When considering proposals for annexation, protect
designated open space land and existing agricultural
activities.

The City shall ensure that the best available biological resource mapping data is used during the ministerial
and discretionary project review process to identify
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
City of Willits | Final PEIR Errata
47 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
biological resource concerns, evaluate project
alternatives, and guide mitigation to avoid or reduce
biological resource impacts to insignificant levels
consistent with CEQA. At a minimum, the following
biological resource mapping data sources shall be used
for project evaluation: California Department of Fish
and Wildlife’s California Natural Diversity Database
(CNDDB) and their Biogeographic Information and
Observation System (BIOS), EcoAtlas and the
California Aquatic Resource Inventory (CARI), and U.S
Fish and Wildlife Service’s National Wetland Inventory
(NWI).

Mitigation BIO-01.2.

Policy LU-8.X2 Require Pre-Project Biological
Resource Assessments and Surveys The City shall
require site- and/or project-specific biological resource assessments: 1) prior to annexing any properties into
the City from the Proposed Sphere of Influence
additions, and 2) prior to approval of principally
permitted development of multifamily housing on
properties planned Residential-Medium Density in the
South Haehl Creek area. Biological resource
assessments shall address potential impacts to special
status and/or otherwise protected fish, wildlife, and
botanical taxa (including potential interferences with
their movement, migration, and/or dispersal); sensitive natural communities; and wetland habitats. Biological
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
City of Willits | Final PEIR Errata
48 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
resource assessments shall also identify mitigation
measures to avoid and/or reduce impacts to protected
biological resources to less than significant levels from all new development allowed within the study area by
the General Plan.

Mitigation BIO-01.3. Revise LU-9.3, Riparian Area
Land Use Overlay, as follows to Define Riparian
Buffer Area Metrics, Facilitate Landscape
Permeability, Reduce Stormwater-Related Impacts,
and Require Use of Appropriate Plant Species in
Revegetation and Landscaping Efforts
Revise Policy LU-8.3, Riparian Area Land Use
Overlay. Apply an overlay to the Land Use Map,
consistent with Conservation and Open Space Element
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
revision to a
proposed
policy in the
Land Use
Element
City of Willits | Final PEIR Errata
49 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
Implementation Measure 3.320 identifying streams and
wetlands within the City to be protected from
development. Prohibit development within a buffer area
on both sides of streams subject to the following
criteria:
(a) A combining zone for stream and riparian
areas shall also be established and
applied to parcels adjacent to streams
and subject to the Riparian Area Land
Use Overlay that specifies protective
criteria consistent with this policy.
(b) Riparian Buffer Areas associated with
streams shall be established on both
sides of streams and shall be
measured from either the outer dripline of riparian vegetation or the top-ofbank, whichever is furthest from the stream centerline, and shall extend
horizontally for a distance of:
• 100 feet for perennial streams, or
• 50 feet for intermittent streams.

City of Willits | Final PEIR Errata
50 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
(bc) Buffers may be reduced or eliminated
where the City determines, based on
factual findings and in consultation with
CDFW, that the reduction will not result in
significant adverse effects to the water
quality, dependent biological resources,
or ecological functional capacity of the
aquatic resource of interest.
(cd) For ministerial projects that are located on
land planned R-L, C-G, GM-U, DM-U
containing occupied structures or on
vacant parcels that are substantially
surrounded by developed parcels where
improvements are located within the
buffer area, exceptions to these standards
may be allowed after a site evaluation has
been conducted by City staff and factual
findings are made that development is
sited to minimize potential impacts to
streams, wetlands, and associated
riparian resources; does not involve the
removal of native riparian vegetation; and
the incorporation of performance
standards relating to the revegetation of
locally-appropriate riparian species and
the implementation of best management
practices for erosion control.

City of Willits | Final PEIR Errata
51 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
(de) When the prescribed buffer prohibits
development of the site for the primary
use for which it is designated, measures
shall be applied that allow development
that results in the least environmentally
damaging feasible project.
(ef) Road, bridge, and trail construction or
replacement may be permitted that would
not result in significant adverse effects to
water quality, dependent biological
resources, or ecological functional
capacity of the aquatic resource of
interest, where vegetative clearing is kept
to a minimum, and where revegetated
with locally-appropriate native riparian
species.
(g) The installation or replacement of new
or existing fencing contiguous with
Riparian Buffer Areas shall require the
use of wildlife-permeable materials and
designs to reduce the likelihood of
wildlife entrapment and otherwise
facilitate wildlife movement.
(h) All projects shall implement
stormwater requirements from the
Mendocino County Low Impact
Development Standards Manual to
protect water quality and associated
City of Willits | Final PEIR Errata
52 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
aquatic habitats, avoid the use of
noxious weeds or other invasive plants
identified by the California Invasive
Plant Council (Cal-IPC) in associated
revegetation and landscaping efforts,
and prioritize use of locallyappropriate native vegetation during any such revegetation.
(fi) The removal of vegetation for disease
control or public safety purposes may be
approved, in consultation with CDFW.)
(gj) An exception to the implementation of
regulations for this policy shall be
included for “minor additions” to buildings
or structures provided the aggregated
total increase in square footage for all
changes does not exceed thee hundred
(300) square feet of floor area.

Mitigation BIO-01.4. Require Low Impact
Development (LID) Stormwater Design Standards
and Use of Appropriate Plant Species in LID and
Other Development-Related Landscaping and
Revegetation Efforts
New Policy for “Protect Natural Resources within
Areas Planned for Development” Group:

City of Willits | Final PEIR Errata
53 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
Policy LU-8.X3 To reduce stormwater impacts to
streams and wetlands and improve water quality
associated with discretionary development and all
development within 250 feet of Willits, Broaddus or
Baechtel Creeks and their tributaries, the City shall
implement stormwater requirements from the
Mendocino County Low Impact Development
Standards Manual to attenuate runoff, reduce scouring
and erosion, promote on-site infiltration, and to protect water quality and associated aquatic habitats.

City of Willits | Final PEIR Errata
54 New Policy for “Protect Natural Resources within
Areas Planned for Development” Group:

Policy LU-8.X4 The City shall develop and make
available a list of locally appropriate native vegetation suitable for planting within low impact development
features and for development-related landscaping and
revegetation. The City shall encourage the use of
locally appropriate and locally sourced native
vegetation for use in revegetation and landscaping
efforts as well as encourage the planting of native
milkweed (Asclepias spp.) species (i.e., the sole plant group within the Planning Area region suitable for egg
laying and larval development for the federal candidate species, Western Monarch butterfly [Danaus plexippus
plexippus]). Where rapid plant establishment and
development is required for purposes of soil
stabilization and to minimize erosion potential, the City shall encourage the use of sterile hybrid “wheatgrass” x ”wheat” (Elymus x Triticum) or other similar nonreproductive seed material in conjunction with otherwise appropriately-selected revegetation seed
applications or blends.

In all low impact development infrastructure and other
development-related landscaping and revegetation, the
City shall prohibit the use of any plant species
designated as: “invasive” by the California Invasive
Plant Council (Cal-IPC), a “noxious weed” by the
California Department of Food & Agriculture (CDFA), or
a “federal noxious weed” by the U.S. Department of
Agriculture (USDA), as well as any other plants that the City has determined warrant concern based on a
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
City of Willits | Final PEIR Errata
55 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
known potential for preventing the establishment of the intended vegetation assemblage within respective
revegetation areas.

Mitigation BIO-01.5. Require Appropriate Design
Standards to Minimize Artificial Light Pollution
New Policy for “Protect Natural Resources within
Areas Planned for Development” Group:

Policy LU-8.X5 The design and location of all outdoor
lighting fixtures shall prevent direct illumination of
streams, wetlands, and Riparian Buffer Areas.

New Policy for “Protect Natural Resources within
Areas Planned for Development” Group:

Policy LU-8.X6 Partner with local organizations to
educate applicants and residents about the impacts to
special status and otherwise protected wildlife from
toxic pest control methods, and to discourage their use within the City; as well as to educate the community
about the impacts of free-ranging house cats on special status and otherwise protected wildlife.

City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new policy in
the Land Use
Element
Mitigation CUL-1. Cultural Resource Discovery
Protocols
City of Willits City of Willits Prior to the
adoption of
Incorporation
of this
City of Willits | Final PEIR Errata
56 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
New Implementation Measure for “Coordinate with
Local Communities” Group:

Implementation Measure LU-7.X1: In the event
archaeological resources or cultural resources,
including human remains, are inadvertently unearthed
or uncovered 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 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
the Land
Use Element
Update
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
City of Willits | Final PEIR Errata
57 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
project area while mitigation for cultural resources is being carried out.

Mitigation TCR-1. Avoid Impacts to Tribal Cultural
Resources
New Implementation Measure for “Coordinate with
Local Communities” Group:

The feasibility of avoidance of tribal cultural resources shall be determined by the City of Willits and applicants in consultation with local California Native American
tribe(s).

City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
Mitigation TCR-2. Inadvertent Discovery of Tribal
Cultural Resources
New Implementation Measure for “Coordinate with
Local Communities” Group:

Implementation Measure LU-7.X3: If previously
unidentified tribal cultural resources are encountered
during project implementation, altering the materials
and their stratigraphic context shall be avoided and
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
City of Willits | Final PEIR Errata
58 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
work shall halt immediately. Project personnel shall not collect, move, photograph, post on social media, or
disturb cultural resources. A representative from a
locally-affiliated Native American Tribe shall be
contacted in a timely manner to evaluate the resource
and prepare a tribal cultural resources plan identifying methods necessary to protect the resource, in
consultation with the City of Willits.

Mitigation GEO-1: Adopt Draft Safety Element
Prior to, or within six months following, the adoption of the Land Use Element, the City of Willits shall complete the process of updating and adopting the Draft Safety
Element consistent with state law and initiate the
process of putting into effect the implementation
program.

City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update or
within six
months after
adoption
Adoption of the
updated City of
Willits Safety
Element
Mitigation GEO-2: Other Paleontological or
Geological Resource Discover Protocols
Implementation Measure LU-7.X4 If fossils are
encountered during construction (i.e., bones, teeth, or unusually abundant and well-preserved invertebrates or
plants), the City and its contractor shall divert
construction activities away from the discovery within
50 feet of the find, and a professional paleontologist
shall be contracted to document the discovery as
needed, to evaluate the potential resource, and to
assess the nature and importance of the find. Based on
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
new
implementation
measure in the
Land Use
Element
City of Willits | Final PEIR Errata
59 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
the scientific value or uniqueness of the find, the
paleontologist may record the find and allow work to
continue, or recommend salvage and recovery of the
material, if it is determined that the find cannot be
avoided. The paleontologist shall make
recommendations for any necessary treatment that is
consistent with currently accepted scientific practices.

Any fossils collected from the area shall then be
deposited in an accredited and permanent scientific
institution where they would be properly curated and
preserved.

Mitigation GHG-1 Revise Policy LU-3.9 Plan for
Climate Change
Revise Policy LU-3.10 Plan for Climate Change.

Plan for the public health implications of climate
change, including potential disease and temperature
effects, and work with state and county public health
agencies to identify necessary programs to reduce,
adapt to, and increase resiliency to potential impacts
and develop and implement programs to achieve Citywide reductions in greenhouse gas emissions consistent with state targets.

City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update
Incorporation
of this
mitigation
measure as a
revision to a
new policy in
the Land Use
Element
Mitigation Measure WF-01.

Prior to adoption of the Draft Safety Element, review,
an update shall be required to is consistent with
City of Willits City of Willits Prior to the
adoption of
the Land
Use Element
Update or
Adoption of an
updated City of
Willits Safety
Element that is
s consistent
City of Willits | Final PEIR Errata
60 Mitigation
Responsible
Party for
Monitoring
and
Reporting
Responsible
Party for
Verifying
Compliance Timing
Performance
Criteria
applicable state legislation that has been passed since the draft’s preparation in 2019.
within six
months after
adoption
with applicable
state
legislation that
has been
passed since
2019
City of Willits | Final PEIR Errata
61 1
RESOLUTION NO. 2024 -

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS ADOPTING THE GENERAL MIXED USE (designated GM-U) COMPONENT OF THE GENERAL PLAN LAND

USE ELEMENT, AN ELEMENT OF THE CITY OF WILLITS GENERAL PLAN WHEREAS, the Land Use Element of the General Plan is a framework that establishes the general distribution and types of land uses for a given area, as well as the policies and standards that guide how that land is developed and conserved; and WHEREAS, the Land Use Element has not been comprehensively updated since 1994; and
WHEREAS, in July of 2022, the City Council initiated work on a comprehensive update to the General Plan Land Use Element; and
WHEREAS, the objectives of the Land Use Element Update were:
• Accommodate desired population growth;
• Address current community needs;
• Meet new statutory requirements;
• Streamline the permitting process;
• Accelerate housing development;
• Amend the City Sphere of Influence; and
WHEREAS, the proposed amendments to the Land Use Element include:
• the identification of a Planning Area that includes the City as well as surrounding land that bears relation to City planning;
• changes to existing and new Land Use Element policy intended to expand the land supply for housing of all types, provide for focused planning for Willits’ commercial centers, provide for land use flexibility and compatibility, ensure community health and vitality and environmental health and sustainability, and to expand and improve land use designations and general plan maintenance;
• changes to Land Use Designations within the City to support residential and commercial development, as well as for open space purposes, and changes to apply Land Use Designations that best reflect the use and character of existing development within the City where the current Land Use Designation is not appropriate; • proposed expansions to the City’s Sphere of Influence, with the application of appropriate City Land Use Designations, to support a potential Sphere of Influence Amendment application to the Mendocino Local Agency Formation Commission (LAFCo); and
WHEREAS, during the two (2) year process of updating the Land Use Element, the City provided many opportunities for public participation and input through the use of a survey, project website, open house, public workshops, advisory committee meetings and public meetings; and WHEREAS, a Final Environmental Impact Report prepared for the City of Willits Land Use Element and Sphere of Influence Update (State Clearinghouse Number 2023030321) was released for public review on October 10, 2024; and
2 WHEREAS, the City complied with the requirements of the California Environmental Quality Act, in the manner described in the City of Willits Resolution 2024-__ adopted on October 23, 2024, certifying the City of Willits Land Use Element and Sphere of Influence Update; and
WHEREAS, due to potential City Council Member conflict(s) of interest with respect to the proposed General Mixed-Use Component of the General Plan Land Use Element Update, that component is hereby segregated and decided separately from the remaining components of the General Plan Land Use Element Update.

NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Willits has separately reviewed and considered the proposed General Mixed-Use component of the General Plan Land Use Element Update included within Exhibit A and incorporated into this resolution as if included in their entirety herein, and
BE IT FURTHER RESOLVED, ordered and determined that the City Council has considered the public comments made at the public hearings and that all the following findings are hereby made:

1. A Final EIR was prepared for the City of Willits Land Use Element Update which was certified by the City Council to have been prepared in compliance with the requirements of the California Environmental Quality Act, and which was reviewed and considered by the City Council; and

2. The Land Use Element Update to the City of Willits General Plan is in the public interest because it further social, economic, housing and other goals, is incorporated herein by reference.

3. Neither the adoption of the Land Use Element Update to the City of Willits General Plan, nor any part thereof, will operate to limit the number of housing units which may be constructed on an annual basis in the in the City of Willits consistent with the certified City of Willits Housing Element; and
BE IT FURTHER RESOLVED that the City Council of the City of Willits hereby adopts the proposed General Mixed-Use component of the Land Use Element of the City of Willits General Plan and the Land Use Map, attached hereto within Exhibit A, which incorporates all of the mitigation measures described in the Final EIR.

BE IT FURTHER RESOLVED ordered and determined that the City of Willits Community Development Department is authorized to make minor corrections to the text of Land Use Element of the City of Willits General Plan Attachment 5 to correct grammar and typos.

BE IT FURTHER RESOLVED, ordered and determined that all the amendments described in this resolution will become effective October 23, 2024.

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 23rd day of October 2024, by the following vote:
3 AYES:

NOES:

ABSENT:

ATTEST:
________________________________
_________________________________
GERARDO GONZALEZ, Vice Mayor
City Council of the City of Willits
DELORES PEDERSEN, City Clerk
1 RESOLUTION NO. 2024 -

A FINAL RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS ADOPTING THE

GENERAL PLAN LAND USE ELEMENT, AN ELEMENT OF THE CITY OF WILLITS

GENERAL PLAN
WHEREAS, the Land Use Element of the General Plan is a framework that establishes the general distribution and types of land uses for a given area, as well as the policies and standards that guide how that land is developed and conserved; and WHEREAS, the Land Use Element has not been comprehensively updated since 1994; and
WHEREAS, in July of 2022, the City Council initiated work on a comprehensive update to the General Plan Land Use Element; and
WHEREAS, the objectives of the Land Use Element Update were:
• Accommodate desired population growth;
• Address current community needs;
• Meet new statutory requirements;
• Streamline the permitting process;
• Accelerate housing development;
• Amend the City Sphere of Influence; and
WHEREAS, the proposed amendments to the Land Use Element include:
• the identification of a Planning Area that includes the City as well as surrounding land that bears relation to City planning;
• changes to existing and new Land Use Element policy intended to expand the land supply for housing of all types, provide for focused planning for Willits’ commercial centers, provide for land use flexibility and compatibility, ensure community health and vitality and environmental health and sustainability, and to expand and improve land use designations and general plan maintenance;
• changes to Land Use Designations within the City to support residential and commercial development, as well as for open space purposes, and changes to apply Land Use Designations that best reflect the use and character of existing development within the City where the current Land Use Designation is not appropriate; • proposed expansions to the City’s Sphere of Influence, with the application of appropriate City Land Use Designations, to support a potential Sphere of Influence Amendment application to the Mendocino Local Agency Formation Commission (LAFCo); and
WHEREAS, during the two (2) year process of updating the Land Use Element, the City provided many opportunities for public participation and input through the use of a survey, project website, open house, public workshops, advisory committee meetings and public meetings; and WHEREAS, a Final Environmental Impact Report prepared for the City of Willits Land Use Element and Sphere of Influence Update (State Clearinghouse Number 2023030321) was released for public review on October 10, 2024; and
2 WHEREAS, the City complied with the requirements of the California Environmental Quality Act, in the manner described in the City of Willits Resolution 2024-__ adopted on October 23, 2024, certifying the City of Willits Land Use Element and Sphere of Influence Update; and
WHEREAS, due to potential City Council Member conflicts of interest both the Main Street Mixed Use component (designated DM-U) and the General Mixed-Use component (designated GM-U) of the General Plan Use Element were segregated and decided by separate resolutions from this Final Resolution adopting the General Plan Land Use Element.

NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Willits: has reviewed and considered the City of Willits Land Use Element Update attached as Exhibit A and incorporated into this resolution as if included in its entirety herein, and such review and consideration was made separately from the review and approval of segregated components of the Plan consisting of the Main Street Mixed Use component and the General Mixed-Use component.

BE IT FURTHER RESOLVED, ordered and determined that the City Council has considered the public comments made at the public hearings and that all the following findings are hereby made:

2. The Land Use Element Update to the City of Willits General Plan is in the public interest because it further social, economic, housing and other goals, is incorporated herein by reference.

3. Neither the adoption of the Land Use Element Update to the City of Willits General Plan, nor any part thereof, will operate to limit the number of housing units which may be constructed on an annual basis in the in the City of Willits consistent with the certified City of Willits Housing Element; and
BE IT FURTHER RESOLVED that except for the adoption of both the Main Street Mixed Use and General Mixed-Use components of the General Plan which were considered separately from the remaining components of the General Plan Land use Plan, the City Council of the City of Willits hereby adopts the Land Use Element of the City of Willits General Plan and the Land Use Map, attached hereto as Exhibit A, which incorporates and all of the mitigation measures described in the Final EIR.

BE IT FURTHER RESOLVED, ordered and determined that all the amendments described in this resolution will become effective October 23, 2024.

The above and foregoing Resolution was introduced by Councilmember seconded 3 by Councilmember , and passed and adopted at a regular meeting of the City Council of the City of Willits, held on the 23rd day of October 2024, by the following vote:

AYES:

NOES:

ABSENT:

ATTEST:
________________________________
_________________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits
DELORES PEDERSEN, City Clerk
1 RESOLUTION NO. 2024 -

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS ADOPTING THE MAIN STREET MIXED USE (designated DM-U) COMPONENT OF THE GENERAL PLAN LAND

USE ELEMENT, AN ELEMENT OF THE CITY OF WILLITS GENERAL PLAN WHEREAS, the Land Use Element of the General Plan is a framework that establishes the general distribution and types of land uses for a given area, as well as the policies and standards that guide how that land is developed and conserved; and WHEREAS, the Land Use Element has not been comprehensively updated since 1994; and
WHEREAS, in July of 2022, the City Council initiated work on a comprehensive update to the General Plan Land Use Element; and
WHEREAS, the objectives of the Land Use Element Update were:
• Accommodate desired population growth;
• Address current community needs;
• Meet new statutory requirements;
• Streamline the permitting process;
• Accelerate housing development;
• Amend the City Sphere of Influence; and
WHEREAS, the proposed amendments to the Land Use Element include:
• the identification of a Planning Area that includes the City as well as surrounding land that bears relation to City planning;
• changes to existing and new Land Use Element policy intended to expand the land supply for housing of all types, provide for focused planning for Willits’ commercial centers, provide for land use flexibility and compatibility, ensure community health and vitality and environmental health and sustainability, and to expand and improve land use designations and general plan maintenance;
• changes to Land Use Designations within the City to support residential and commercial development, as well as for open space purposes, and changes to apply Land Use Designations that best reflect the use and character of existing development within the City where the current Land Use Designation is not appropriate; • proposed expansions to the City’s Sphere of Influence, with the application of appropriate City Land Use Designations, to support a potential Sphere of Influence Amendment application to the Mendocino Local Agency Formation Commission (LAFCo); and
WHEREAS, during the two (2) year process of updating the Land Use Element, the City provided many opportunities for public participation and input through the use of a survey, project website, open house, public workshops, advisory committee meetings and public meetings; and WHEREAS, a Final Environmental Impact Report prepared for the City of Willits Land Use Element and Sphere of Influence Update (State Clearinghouse Number 2023030321) was released for public review on October 10, 2024; and
2 WHEREAS, the City complied with the requirements of the California Environmental Quality Act, in the manner described in the City of Willits Resolution 2024-__ adopted on October 23, 2024, certifying the City of Willits Land Use Element and Sphere of Influence Update; and
WHEREAS, due to potential City Council Member conflict(s) of interest with respect to the proposed Main Street Mixed Use Component of the General Plan Land Use Element Update, that component is hereby segregated and decided separately from the remaining components of the General Plan Land Use Element Update.

NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Willits has separately reviewed and considered the proposed Main Street Mixed Use component of the General Plan Land Use Element Update included within Exhibit A and incorporated into this resolution as if included in their entirety herein, and BE IT FURTHER RESOLVED, ordered and determined that the City Council has considered the public comments made at the public hearings and that all the following findings are hereby made:

2. The Land Use Element Update to the City of Willits General Plan is in the public interest because it further social, economic, housing and other goals, is incorporated herein by reference.

3. Neither the adoption of the Land Use Element Update to the City of Willits General Plan, nor any part thereof, will operate to limit the number of housing units which may be constructed on an annual basis in the in the City of Willits consistent with the certified City of Willits Housing Element; and
BE IT FURTHER RESOLVED that the City Council of the City of Willits hereby adopts the proposed Main Street Mixed Use component of the Land Use Element of the City of Willits General Plan and the Land Use Map, attached hereto as Exhibit A, which incorporates all of the mitigation measures described in the Final EIR.

BE IT FURTHER RESOLVED, ordered and determined that all the amendments described in this resolution will become effective October 23, 2024.

NOES:

ABSENT:

ATTEST:
______________________________
_________________________________
SAPRINA RODRIGUEZ, Mayor
City Council of the City of Willits
DELORES PEDERSEN, City Clerk
Item No.3b
Meeting Date: October 23, 2024

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Logan Shine, Contract Planner
Agenda Title: PUBLIC HEARING - A RESOLUTION ADOPTING THE 2024 CITY OF WILLITS EMERGENCY OPERATIONS PLAN PART 2: FLOOD RESPONSE ANNEX, TO FACILITATE COORDINATED RESPONSE AND RECOVERY TO LOCAL FLOOD HAZARD INCIDENTS.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 20 minutes Agenda Summary: The City secured a Proposition 84 grant from the Division of Water Resources Statewide Flood Emergency Response Grant Round #3 to develop a Flood Emergency Response Plan for the Little Lake Fire District and the City.

This Flood Response Annex Plan supplements the Emergency Operations Plan Part 1: Basic Plan, adopted by the City Council at their September 11th meeting. The intent of the Flood Annex is to provide an additional level of specificity of responses for flood incidents to maximize public safety. The Annex provides a comprehensive operational framework and aligns with the County’s Emergency Operations Plan.

The Flood Response Annex addresses known flood threats identified in the Willits General Plan Safety Element (2019) and the Multi-Jurisdiction Hazard Mitigation Plan (2021) such as flood elevation impacts from dam failures.

Attachment A: Flood Response Annex Plan.

Recommended Action: Review the Staff Report and adopt the accompanying Resolution to approve the Emergency Operations Plan, Part 2: Flood Response Annex. This action appends the Flood Response Annex to the Emergency Operations Plan Part 1: Basic Plan.

Alternative(s): None.

Fiscal Impact: There is no direct fiscal impact associated with the recommended action.

Personnel Impact: City staff will review and practice response and recovery roles and procedure at least once per year through tabletop exercises, or other practice drills.

Identified City Council Conflict of Interest: None.
2021 Adopted Goals: This item supports 2021 City Council Goal #2 for the Police Department… Interact with the City’s Emergency partners to complete the Emergency Operations Plan (EOP) that will reflect the City Manager as Chief Emergency Officer.

California Environmental Quality Act: This staff report does not represent a project under the California Environmental Quality Act (CEQA).

Reviewed by: City Manager City Attorney Assistant City Manager City Clerk Finance Director Human Resources Risk Manager
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________ STAFF REPORT: FLOOD RESPONSE ANNEX
PAGE 1

CITY COUNCIL AGENDA STAFF REPORT
MEETING DATE: October 23, 2024 AGENDA ITEM NO:

TO: Honorable Mayor and Members of the City Council
PREPARED BY: Logan Shine, Contract Planner
ITEM: Emergency Operations Plan Part 2: Flood Response Annex REQUEST: Adoption of the Hazard Specific Flood Response Annex to the City Emergency Operations Plan Part 1: Base Plan.

SUMMARY
The City of Willits adopted a local Emergency Operations Plan Part 1: Basic Plan, on September 11, 2024, with the understanding that specific hazard Annexes to the plan will be developed in a timely manner.

BACKGROUND
The City of Willits faces diverse natural hazards that pose significant risks to its residents and businesses. The Draft Safety Element of the General Plan, anticipated to come before the City Council for adoption in the next six months, systematically identifies these hazards and outlines policies and practices to mitigate them. One key objective, Draft Safety Element Goal S-5, aims to "promote the well-being of all community members through comprehensive emergency management."
To achieve this goal, several policies are established:

Policy S-5.1 Identify and maintain existing critical facilities to ensure proper functionality during and after an emergency.

Policy S-5.2 Coordinate with key Willits Departments and other local utility companies to
provide or restore essential services during and after
emergency situations.

Policy S-5.3 Periodically review and update the Emergency Operations Plan to address new or emerging issues within the
community, as necessary.

In the Draft Safety Element, floods are identified as a specific hazard within the City of Willits due to the flooding of drainages and floodplains. Notably, the northeastern portions of Willits are within a FEMA designated Flood Hazard Zone, as are areas alongside waterways. Risks arise from excessive precipitation and blockages in drainages.

A third-party consultant, KSN, was contracted to create the Hazard Specific Flood Response Annex (FRA) and a Public Safety Map. The map serves as a critical tool for emergency STAFF REPORT: FLOOD RESPONSE ANNEX
PAGE 2
responses, aids resource allocation, hazard visualization, incident management, evacuation planning, inter-agency communication, and community awareness. It also supports training by simulating scenarios, ensuring readiness and identifying necessary updates.

Additionally, the grant funded "tabletop" and functional training exercises, such as the conductedon February 10, 2022, which covered the Incident Command System, flood preparedness, Unified Flood Fight Command activation, EOC operations, and multi-agency coordination during flood events and post-disaster.

City Vulnerabilities. The Flood Response Annex identifies two primary flood threats to the City:
(1) Overflow from creeks due to heavy precipitation; and (2) Potential dam failures. Creeks: Mill, Broaddus, Baechtel, and Davis Creeks are vulnerable to flooding from substantial rainfall and blockages impeding flow. Undersized or underperforming drainage facilities further contribute to localized flooding, as exemplified by North Lenore Street, which has been affected by flooding from Baechtel and Davis Creeks. Dams: The City oversees the Centennial and Morris Dams. While the FRA does not address dam-related flooding, the Dam Emergency Action Plans, currently being updated, outline specific procedures for dam failure scenarios. According to the City's Safety Element of the General Plan and the Mendocino County MultiJurisdictional Hazard Mitigation Plan, inundation from dam failure floodwaters would be confined to the 100-year floodplain, impacting the northeastern parts of the City and adjacent unincorporated areas, as illustrated in Draft Safety Element Figure S4 FEMA Flood Zones (Attachment C).

City Responsibilities. The Flood Response Annex delineates the City of Willits' responsibilities across various phases of flood emergency response.

Readiness and Training (Pre-Flood Phase): The City has the task of flood event preparation.

The FRA specifies activities such as inspecting and monitoring pump stations, maintaining drainage canals, performing routine levee maintenance, managing equipment, vegetation management, and removing debris and sediment from drainage systems. Staff must collect and maintain flood statistics and information, including flood history, potential vulnerabilities, and the status of flood control infrastructure. During the rainy season, staff will monitor known trouble spots, reporting to the Director of Services & Facilities and Police Department. The FRA also encourages Departments to establish operating procedures and checklists for flood emergencies relevant to their emergency response functions. The City also has a responsibility to document opportunities for subsequent improvements, recovery costs, and/or mitigation project funds.

Operations, Management, and Coordination (All Flood Phases): The City leads flood operations from the Emergency Operations Center (EOC), supporting the Field Incident Commander to coordinate all response operations with the Willits Police Department, Little Lake Fire District Mendocino Operational Area, and other jurisdictions as necessary. The EOC serves as the information and resource management hub during significant emergency situations, when functions include: resource prioritization and allocation, mutual aid coordination, information sharing, and inter-jurisdictional collaboration.

Emergency Phase: Upon reaching critical water elevations or conditions, the City will activate the Emergency Phase. The EOC will be activated to manage the emergency operation, with personnel and resources assigned and mobilized for response. The City allocates public safety resources to restore or activate essential public facilities and systems and participates in unified command organizations to coordinate field response with other authorities.

STAFF REPORT: FLOOD RESPONSE ANNEX
PAGE 3
Recovery Phase: Post-flood, the City may require public assistance for an extended period.

Recovery activities include documentation of damage and loss, debris removal from rights-ofway, demolishing unsafe structures, reestablishing public services, and providing care and welfare for the affected population.

Environmental Analysis. As determined through the City of Willits’ Environmental Review Process, adopting the Flood Response Annex is exempt from the California Environmental Quality Act per CEQA Section 15061(b)(3) - The activity is covered by the commonsense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment…
It is certain that the proposed Flood Response Annex will not significantly affect the environment, as it does not create physical changes or alter the General Plan or Implementing Zoning Ordinance land use policies. Any future development subject to these standards will undergo independent analysis as required by CEQA.

ATTACHMENTS:

Attachment A – Hazard Specific Flood Response Annex to the Emergency Operations Plan.

City of Willits EOP
To the City Emergency Operations Plan
October 2024
Joint flood response effort among the City of Willits,
Little Lake Fire Protection District, and Mendocino
County
City of Willits
Hazard Specific Flood
Response Annex
Willits
October 2024 Page 1
Table of Contents

1.0 INTRODUCTION ........................................................................................................................................ 3 PURPOSE................................................................................................................................................................................... 3 SCOPE........................................................................................................................................................................................ 3 Relationship to other Local/County Emergency Operations Plans.................................................................. 3 SITUATION OVERVIEW FOR FLOOD EVENTS ...................................................................................................................... 4 PLANNING ASSUMPTIONS FOR FLOOD RESPONSE............................................................................................................. 5

2.0 CONCEPT OF OPERATIONS................................................................................................................... 5 REGIONAL RESPONSE............................................................................................................................................................. 5 RESPONSE CONSIDERATIONS................................................................................................................................................ 6 GENERAL APPROACH TO SEASONAL FLOOD OPERATIONS .............................................................................................. 7 Concept of Operations – Jurisdictional Plans and Display Format................................................................... 7 Concept of Operations – Maintenance of the Operational Picture................................................................... 7 Concept of Operations – Command and Control....................................................................................................... 8 Concept of Operations – Inter-agency and Inter-jurisdictional Communications.................................... 9 Concept of Operations – Activation of Flood Response Command and Control Systems....................... 9 Concept of Operations – Recovery ................................................................................................................................... 9 PHASES OF OPERATIONS........................................................................................................................................................ 9 Flood Normal Preparedness............................................................................................................................................... 9 Flood Increased Readiness...............................................................................................................................................10 Flood Emergency Preparedness.....................................................................................................................................10 Flood Emergency Phase.....................................................................................................................................................11 Flood Recovery Phase .........................................................................................................................................................11

Willits City CouncilOctober 23, 2024

Willits City Council
October 23, 2024