Agenda, first session — Willits City Council, October 8, 2025 (part 1 of 3)

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

Page 1 of 3 ends

WILLITS CITY COUNCIL

AMENDED
AGENDA
OCTOBER 8, 2025 | 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

4. ENACTMENT OF ORDINANCES
a. Second Reading and Possible Adoption of Proposed Revisions to the City of Willits Municipal Code, Chapter 2.40- Airport, Sections 2.40.030 and 2.40.040, Entitled “Regulations for Use and Conduct-Generally”. As Ordered by the Director of the FAA.

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:

Willits City Council Agenda – October 8, 2025

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a. City Council Minutes:
i. September 24, 2025 – Special Meeting
ii. September 24, 2025
b. Discussion and Possible Approval to Extend for an Additional Month the At-will Employment Agreement with LACO Associates for Interim City Manager Services, at a Weekly Rate of $3,600, and Authorize the Mayor to Execute Same.

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

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

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

9. DEPARTMENT RECOMMENDATIONS (ACTION ITEMS)
a. Discussion and Possible Action on Application for General Plan Amendment #GPA 22-01 and Zone Change #ZC 22-01 For Sanhedrin Timber Company, LLC.

Presenting staff member: Dusty Duley, Community Development Director. b. Report from Finance of Activity within the Department.

Presenting staff member: Manuel Orozco, Finance Director.

10. CITY COUNCIL ANNOUNCEMENTS, COMMUNICATIONS AND REPORTS

11. GOOD & WELFARE

12. CLOSED SESSION NOTICE
a. None.

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

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

Dated this 3rd day of October 2025.

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. 4a
Meeting Date: October 8, 2025

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Kenan OShea for the City of Willits : Willits Municipal Airport Operations – O28 Agenda Title: SECOND READING AND POSSIBLE ADOPTION OF PROPOSED REVISIONS TO THE CITY OF WILLITS MUNICIPAL CODE, CHAPTER 2.40- AIRPORT, SECTIONS 2.40.030 AND 2.40.040, ENTITLED “REGULATIONS FOR USE AND CONDUCT-GENERALLY”. AS ORDERED BY THE DIRECTOR OF THE FAA.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 15 minutes.

Summary of Request:

On June 30th the FAA Director ordered that the Willits City Council adopt revise existing Municipal Code prohibiting unauthorized use of Willits Municipal Airport (O28) and define such use of O28 as a misdemeanor.

Staff has made the revisions to the ordinance as directed both by the FAA and Council, met with tenants for input, opened the matter to public comment at several City Council meetings, and posted notice of the ordinance modifications in accordance with policy and State law. Staff now requests that the Council approve the second reading and proposed changes, which would then take effect in thirty days from this 8th of October, 2025.

Recommended Action: Staff recommends that the Council vote to approve the revisions to the ordinance and adopt the changes to the City of Willits Municipal Code as directed by the FAA.

Alternative(s): Reject the revisions to the ordinance and potentially forfeit grant funding pending further determination by the controlling agency.

Fiscal Impact: Additional signage and staff time allocations.

Personnel Impact: Increased staff time spent monitoring, documenting and enforcing.

Identified City Council Conflict of Interest: NONE
2021 Adopted Goals: This item meets Goal #1 for Services & Facilities…Maintain and improve infrastructure systems of water, wastewater, public facilities, and streets capable of managing future growth while responding to current City needs.

California Environmental Quality Act: The proposed revisions to the City of Willits Municipal Code are exempt from the CEQA study and review process as they are not a project or development and pose no potential environmental impact.

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: Interim City Manager City Attorney City Clerk Finance Director Human Resources Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________

CITY OF WILLITS

NOTICE OF PUBLIC HEARING AND PROPOSED ORDINANCE SUMMARY NOTICE IS HEREBY GIVEN that the City Council of the City of Willits will consider the second reading and possible adoption of the following ordinance at its regular meeting on Wednesday, October 8th, 2025, at 6:30 p.m. in the Council Chambers, located at 111 E Commercial St, Willits, California:

An Ordinance of the City of Willits to modify Chapter 2.40- AIRPORT, of the Willits Municipal Code by the addition of section 2.40.040 regarding “Regulations for use and Conduct-Generally,” and by modifying section

2.40.130 regarding “Violations – Penalties.”
The City of Willits was ordered by the Director of the Federal Aviation Administration (FAA) to modify the City’s existing ordinance at chapter 2.40 of the WMC to codify and enforce airport rules and regulations and address unauthorized access to the property for non-aeronautical activities. To maintain compliance and continue grant fund eligibility, the City has put forth these changes in order to fulfill its obligations to the federal controlling agency in response to the Director’s determination.

The proposed ordinance changes and additions will more clearly define the rules and conduct for the use of Willits Municipal Airport O28 and make unauthorized and trespassing on Airport property punishable by law and potentially warrant citation as a misdemeanor.

Environmental Review: The proposed ordinance is not a project under the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15378, because it involves administrative activities of the City that will not result in direct or indirect physical changes to the environment.

Copies of the proposed ordinance and all related materials are available for public review at City Hall during regular business hours.

For additional information, contact Airport Operations for O28 - Kenan OShea:
[email protected].
/s/ Delores Pedersen, City Clerk
Publication Date: October 2, 2025
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ORDINANCE NO. 2025-

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF WILLITS, CALIFORNIA ADDING SECTION 2.40.040 “REGULATIONS FOR USE AND CONDUCT – GENERALLY” AND AMENDING SECTION 2.40.130
“VIOLATION-PENALTIES” TO CHAPTER 2.40 OF THE WILLITS MUNICIPAL CODE
SECTION 1. FINDINGS
The City Council of the City of Willits hereby finds and declares as follows:

WHEREAS, the City of Willits operates a federally obligated Airport located at 1320 Poppy Drive in Willits California 95490.

WHEREAS, as the operator of a federally obligated Airport, the City of Willits is required to adhere to the forty grant assurances established by the Federal Aviation Administration (FAA) as the controlling agency in order to continue to receive grant funds.

WHEREAS, on June 30th 2025 the Director of the FAA found the City of Willits in violation of Grant Assurance 19 – “Operation and Maintenance”. The Director ordered the City of Willits to amend the Willits Municipal Code to make trespassing and unauthorized use of O28 a violation punishable by law.

WHEREAS, the Willits City Council recognizes the need to revise Chapters 2.40.040 “Regulations for Use and Conduct – Generally” and 2.40.130 “Violations-Penalties” in order to comply with that order as directed.

NOW, THEREFORE, THE CITY COUNCIL HEREBY ORDAINS AS FOLLOWS:

SECTION 2. INCORPORATION OF FINDINGS
The above findings are incorporated herein and are each relied upon independently by the City Council for its adoption of this Ordinance.

SECTION 3. AMENDMENT OF CHAPTERS 2.40.040, 2.40.130
Section 2.40.040 of the Willits Municipal Code is hereby added to Chapter 2.40 to read as follow:

Chapter 2.40.040 – REGULATIONS FOR USE AND CONDUCT – AIRPORT

SECURITY
2 | Page
The following rules and regulations for the use and conduct of Willits Municipal Airport are adopted:

No person shall operate any vehicle or travel on the airport property by any manner except on roads, paths, walks, and areas provided for that particular means of travel. No obstructions shall be permitted on any road, path, or walk without permission from the Airport Manager or their designee. No person shall enter upon the paved runway of the Willits Municipal Airport, except when engaged in lawful business in the operation of aircraft or in assistance to operators of aircraft.

Section 2.40.130 of the Willits Municipal Code is hereby amended by the addition of the underscored text and deleted text is indicated by strike-through font to read as follows:

Chapter 2.40.130 – VIOLATIONS - PENALTIES

A. Any airport tenant or person operating or handling aircraft in violation of the regulations set forth in this chapter, commencing with Section 2.40.030 and any regulations promulgated hereunder, including those provided at Section 2.40.040, or refusing to comply therewith, may be removed or evicted from the airport by or under the authority of the airport manager; and upon the order of the city council may be deprived of the further use of the airport and its facilities for such length of time as may be deemed necessary to insure safeguarding of the same and the public and its interest therein.

B. Any person, firm or corporation who violates or refuses to abide by any provisions set forth in Section 2.40.030, Section 2.40.040, or any of the rules and regulations set forth herein, or pursuant hereto, or any of the provisions or law provided therein, is guilty of a misdemeanor and upon conviction thereof shall be punishable by a fine not exceeding five hundred one thousand dollars, or by imprisonment not exceeding six months, or by both such fine and imprisonment.

SECTION 4. EFFECTIVE DATE
This Ordinance shall be in full force and effect 30 days following its enactment in accordance with California law; and before the expiration of 15 days following passage, this Ordinance shall be published once with the names of the members of the City Council voting for and against the same in a newspaper of general circulation, published in the City of Willits.

SECTION 5. SEVERABILITY
If any section, subsection, sentence, clause, phrase or word of this Ordinance is for any reason held to be invalid by a court of competent jurisdiction, such decisions shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed and adopted this Ordinance, and each and all 3 | Page
provisions hereof, irrespective of the fact that one or more provisions may be declared invalid.

SECTION 6. CEQA EXEMPTION
The City Council finds that this ordinance is not subject to the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment),15060(c)(3) (the activity is not a project as defined in Section 15378 of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for resulting in physical change to the environment, directly or indirectly) and 15061(b)(3) (it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment).

The foregoing ordinance was introduced at the regular meeting of the City Council of the City of Willits, held on the 24th day of September 2025, and passed and adopted at a regular meeting, held on the 10th day of October 2025, by the following vote:

AYES:

NOES:

ABSENT:

ATTEST:
__________________________
__________________________
TOM ALMAN, Mayor
City Council of the City of Willits
DELORES PEDERSON, City Clerk
City of Willits
111 E. COMMERCIAL STREET
WILLITS, CALIFORNIA 95490
(707) 459-4601 TEL
(707) 459-1562 FAX

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WILLITS CITY COUNCIL

SPECIAL MEETING

MINUTES
TUESDAY SEPTEMBER 24, 2025
Mayor Allman called a regular meeting of the City Council to order at 5:30 p.m., in Council Chambers.

Roll Call: Councilmembers Gerardo Gonzalez, Larry Stranske, Bruce Burton, Vice Mayor Matthew Alaniz and Mayor Tom Allman were present.

Also present were staff members: Rodney Wilburn, Interim City Manager; Jim Lance, City Attorney; Walter Kolon, Services and Facilities Director; and Delores Pedersen, City Clerk.

2. CLOSED SESSION NOTICE
a. Conference regarding Labor Negotiation Pursuant to Government Code §54957.6 – Agency Negotiator Interim City Manager Wilburn and Patrick Clark Consulting. Employee Organization(s): International Brotherhood of Electrical Worker (IBEW), Willits Police Officers Association (WPOA) and Employee Organization; Management Team.

Public Comment: None.

3. Adjournment
The City Council reconvened to open session at 6:25 pm, reporting direction was given to staff.

Mayor Allman declared the meeting adjourned at 6:25 p.m. ___________________________________
THOMAS ALLMAN, Mayor
City Council for the City of Willits
ATTEST:
________________________________
DELORES PEDERSEN, City Clerk
111 E. COMMERCIAL STREET
WILLITS, CALIFORNIA 95490
(707) 459-4601 TEL
(707) 459-1562 FAX

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WILLITS CITY COUNCIL

MINUTES
WEDNESDAY SEPTEMBER 24, 2025
Mayor Allman called a regular meeting of the City Council to order at 6:30 p.m., in Council Chambers. The meeting was preceded by the pledge to the flag.

Roll Call: Councilmembers Gerardo Gonzalez, Larry Stranske, Bruce Burton, Vice Mayor Matthew Allaniz and Mayor Tom Allman were present.

Also, present were staff members: Rod Wilburn, Interim City Manager; Jim Lance, City Attorney; Dusty Duley, Community Development Director; Manuel Orozco, Finance Director; Walter Kolon, Services and Facilities Director; and Delores Pedersen, City Clerk.

2. Public Communications
 Emma Hulsey announced the 3rd Annual Tree Lighting Ceremony on December 13, 2005 in Bud Snider Park at 7:00 pm.

3. Public Matters
a. Third District County Supervisor, John Haschak Monthly Update.- Written report provided.
b. Little Lake Fire District Monthly Update. – Written report provided.

Public Comment: None presented.

4. Enactment of Ordinances
None presented.

5. Consent Calendar
The following item(s) are recommended for approval or denial, as follows:
a. City Council Minutes:
i. September 10, 2025.
b. Adoption of a Resolution Changing the Authorized Signatures for the City of Willits Checking Account, Payroll Account, and Safe Deposit Box at Savings Bank of Mendocino County.

Public Comment: None presented.

Willits City Council Minutes of September 24, 2025 Page 2 of 6 Moved by Gonzalez/Seconded by Alaniz and carried unanimously to approve Consent Calendar item(s) (a & b).
c. Adoption of a Resolution Authorizing Specific City Staff to Transfer Funds Between the Local Agency Investment Fund (LAIF) and Savings Bank of Mendocino County.
 Council Member Gonzalez requested that the Council be notified when funds need to be transferred from the LAIF Fund to the Savings Bank of Mendocino County Account. This was supported verbally by Council.  Council Member Gonzalez requested that the following be added to the Resolution:
o Council will be notified if fund need to be transferred at the next available City Council Meeting.

Public Comment: None.

Moved by Gonzalez/Seconded by Burton and carried unanimously to approve Consent Calendar item(s) (c).
d. City Response to 2024-25 Mendocino County Civil Grand Jury Report titles, “Healing the Toxic Culture in the City of Willits Workplace.” Public Comment:
 Nicole Caldwell spoke in disagreement to the Response to the 2024-25 Mendocino County Civil Grand Jury Report.
 Council Member Gonzalez stated that neither he or the Vice Mayor Alaniz were not the ones that interviewed the staff, the response was prepared with some input from Mr. Gonzalez, being that they did not interview the employees the had to agree that the Grand Jury found what they found. Mr.

Alaniz added that they could not confirm or deny but that they agreed that the Grand Jury claimed they found the City a Toxic Work Environment, Mr.

Gonzalez and Mr. Alaniz agreed that the Grand Jury Claimed they found something to support the claim of a Toxic Work Environment. Mr. Alaniz stated that there was no need to go over each item individually, that the Council is taking the claims seriously.
 Mayor Allman thanked the Grand Jury for the times they spent on the City of Willits Employee Complaint. Mr. Allman continues by saying that now we are at a situation where there are individuals that are discussed (not by name) that were the focus of the investigation. One individual does not work for the City any longer, the Council is at a point where they are at a point of rectifying a situation that appears to be rectified and is now a moot subject.  Nicole Caldwell asked where the employees can now go to with concerns and complaints to ensure that the things that happened over the last four years do not happen again.
 Mayor Allman responded that the City’s Personnel Policy states that staff would go to the Personnel Director. Since the City does not have a Personnel Director, the Council is working on rectifying that to make is so that whoever is working in the Personnel Department would be the person to go to or the Willits City Council Minutes of September 24, 2025 Page 3 of 6 City Manager would be the correct person to talk to. Unless one of those two people is the issue, if a City Employee wants, they can go to the Mayor, and he will direct the staff to whom they can talk to.

Moved by Alaniz/Seconded by Gonzalez and carried unanimously to approve Consent Calendar item(s) (d).

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 2025.
b. Building Permit Activity Report: August 2025.
c. Business License Activity Report: August 2025.

Public Comment: None presented.

7. Commissions, Agencies and Authorities
None presented.

8. City Manager Reports and Recommendations+
a. Verbal Reports – No Action.

Public Comment: None presented.

9. Department Recommendations (Action Items)
Mayor Allman requested that the items be presented in the following order. d. Zoning text and map amendments to implement the 2024 general plan land use element update
Public Comment:
 Bear Kamoroff inquired about the businesses that have ten or more locations, will they be prohibited or have to go through special permitting, Mr. Kamoroff is curious about the banks and insurance companies in town? Mayor Allman responded that the City is not looking to remove any businesses from downtown, it would affect any new business.
 Madge Strong spoke in favor of the Zoning Text and Map Amendments and feels that the Planning Department did a good job and that it is in the City’s best interest.

Moved by Gonzalez/Seconded by Alaniz and carried 4/1 with Burton abstaining to adopt Resolution No. 2025-42 certifying compliance with the California Environmental Quality Act and adopting findings for approval of Zone Text Amendment Ordinance and to amend the Zoning Map to implement the2024 General Plan Land Use Element Update.

Moved by Gonzalez/Seconded by Alaniz and carried 4/1 with Burton abstaining to adopt Ordinance No. 2025-03 amending Title 17 (Zoning) of the Willits Municipal Code including modifying Chapter 17.06 entitled Use Group Willits City Council Minutes of September 24, 2025 Page 4 of 6 Classifications and establishing the Main Street Mixed Use (DU) Zone (Chapter

17.23) and General Mixed Use (GU) Zone (Chapter 17.25).

Moved by Gonzalez/Seconded by Alaniz and carried 4/1 with Burton abstaining to adopt Ordinance No. 2025-03 amending the City of Willits Zoning Map to apply Zoning Classifications consistent with the City of Willits Land Use Map adopted on October 24, 2024, through City Council Resolution No. 2024-57, Resolution No. 2024-58, and Resolution No. 2024-59. e. Discussion and Possible Action to Adopt Proposed Fiscal Year 2025/2026 Budget.
 Andy Heath, Finance Consultant, presented a PowerPoint presentation to council regarding the FY 2025-26 Budget.

Public Comment:
 Madge Strong stated that if she had known the true state of the City’s Finances when she was on council she would have been very alarmed, she states that council was not being told the true financial picture. Ms. Strong states that she has regrets that council was not able to start the process sooner. Ms. Strong suggested, if it could be done, to go back and see where the City started to go beyond the revenue. She does not feel it is fair to ask the department head to decide who the City will cut on staff, she feels the City Council has to decide where the City is spending money that the City cannot afford, where will the City tighten their belts and a look back at several fiscal years may help council do that.
 Bear Kamoroff inquired about the Capital Improvement Fund. Money that was taken out of the General Fund to pay for Capital Improvements that had Grants, wouldn’t the money from the Grants that have been reimbursed go back into the General Fund?
 Sherry Ebyam spoke in favor of preparing a three-year budget.  Nicole Caldwell asked if the Assistant City Manager position has been taken out of the budget. Ms. Caldwell questioned if the council would consider raising the rates again.

Moved by Gonzalez/Seconded by Alaniz and carried 4/1 with Burton dissenting to adopt Resolution No. 2025-46 approving and adopting the Annual Operating Budget for the City of Willits for Fiscal Year 2025-2026.

Council Adjourned for a five minute recess at 9:06 pm.

Council returned from recess at 9:15 pm.
a. Introduction of Proposed Revisions to the City of Willits Municipal Code, Chapter

2.40 - Airport, Sections 2.40.030 and 2.40.040, Entitled “Regulations for use and Conduct-Generally”. As Ordered by the Director of the FAA.

Public Comment: None presented.

Willits City Council Minutes of September 24, 2025 Page 5 of 6 Moved by Alaniz/Seconded by Gonzalez and carried unanimously to move the introduction of the Ordinance and waive the formal reading. b. Adoption of Resolution Identifying the Proposed Project List for SB1: Road Repair and Accountability Act for Fiscal Year 2025/2026.

Public Comment:
 Nick Johnson inquired if there will be a portion of General Funds used to cover any of the Road Projects. Walter Kolon responded, no, the City has funds that are for the Road Projects.

Moved by Gonzalez/Seconded by Stranske and carried unanimously to adopt Resolution No. 2025-47 authorizing the submittal of 2025-26 Pavement Preservation Project to the California Transportation Commission (CTC) in order to receive Fiscal Year 2025/2026 apportionment of SB1 Road Maintenance and Rehabilitation Account (RMRA) Funding.
b. Receive Report and Recommendation from the Community Development Department Regarding the Establishment of an Entertainment Zone for CityApproved Events.  Connor Stack, City Planner, presented a PowerPoint presentation on the suggested Entertainment Zone.

Public Comment:
 Nicole Caldwell expressed concern over Commercial Street being included in with the Zoning District, she suggested extending the zone down Main Street to State Street. Commercial Street is the Fire Departments Route. Ms.

Caldwell expressed concern over alcohol being able to be served and consumed on Main Street. Ms. Caldwell also inquired as to who would manage that the management plan is being followed during the event, who carries the insurance for the Entertainment Zones, how many security guards will be required and who will pay for the security and with the security company be required to be bonded and certified. Will the City be planning to include the South end of town in with the Entertainment Zone?  Caroline Rayburger stated that the way the alcohol license for Flying Dog Pizza works is they need to keep it within their designated zones.  Jamie Bouthillier stated that she did the insurance for the Christmas Light Parade. The cost was $400 and it covered the town and people standing on the side of the road.
 Nick Johnson, spoke in support of the Entertainment Zone.

10. DEPARTMENT MONTHLY REPORTS – (presented at the second meeting of each month)
a. Airport - Nothing to add.
b. Community Development Department – Nothing to add.
c. Finance Department - Nothing to add.

Willits City Council Minutes of September 24, 2025 Page 6 of 6 d. Police Department – Nothing to add.
e. Services & Facilities Department – Nothing to add.
f. Utilities Department – Nothing to add.

11. City Council Announcements, Communications and Reports Vice Mayor Alaniz
 Attended Assemblyman Rogers Town Hall, there were many updates on different issues including Home Insurance and what the State is trying to accomplish with their own funding problems.

Mayor Allman
 California Conservation Corps grand opening will be on Friday, September 26th.
 Mobile Food Truck Ad hoc – Moving forward, had a successful meeting on September 23. No food trucks will be allowed on Main Street, can be on Private Property with written permission from owner. No cap on number of Food trucks. Will be allowed on the South Side of Bud Snider Park.

Public Comment: None presented.

No action taken.

12. Good & Welfare
 Councilmember Burton
 Councilmember Gonzalez
 Councilmember Stranske
 Vice Mayor Alaniz
 Mayor Allman

13. Closed Session Notice
None presented.

14. Adjournment
Mayor Allman declared the meeting adjourned at 10:09 p.m.

For more information on the September 24, 2025 Willits City Council Meeting please view the recording on YouTube.
__________________________
Tom Allman, Mayor
City Council for the City of Willits
ATTEST:
__________________________

DELORES PEDERSEN
City Clerk
Item No. 5b
Meeting Date: October 8, 2025

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Jim Lance, City Attorney
Agenda Title: DISCUSSION AND POSSIBLE APPROVAL TO EXTEND FOR AN ADDITIONAL MONTH

THE AT-WILL EMPLOYMENT AGREEMENT WITH LACO ASSOCIATES FOR INTERIM CITY MANAGER SERVICES, AT A WEEKLY RATE OF $3,600, AND AUTHORIZE THE MAYOR TO EXECUTE SAME.

Type: Presentation Consent Regular Agenda Public Hearing Urgent Summary of Request: On April 14, 2025, the City entered into an agreement with LACO Associates for Interim City Manager Services. LACO Associates assigned Rod Wilburn to work approximately 24 hours per week unless the needs of the job are more or less in accordance with the terms of the agreement. The agreement is set to expired on October 14, 2025.

Recommended Action: Approve At-Will Employment Agreement Extension with LACO Associates for Interim City Manager Services, at a weekly rate of $3,600, effective October 14, 2025, and continue through November 14, 2025, unless terminated earlier in accordance with the terms of the agreement.

Alternative(s): None recommended.

Fiscal Impact: Continued cost as $3,600 per week for a total monthly cost of $14,400.

Personnel Impact: Provide essential Leadership to City personnel.

Identified City Council Conflict of Interest: None.
2021 Adopted Goals: The Goals do not cover this topic.

California Environmental Quality Act: Not applicable.

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: Interim City Manager City Attorney City Clerk Finance Director Human Resources
Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________ Resolution No. 2025-__ Page 1 of 1 October 8, 2025
RESOLUTION NO. 2025-__

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF WILLITS TO EXTEND THE

AGREEMENT WITH LACO ASSOCIATES FOR INTERIM CITY MANAGER SERVICES AND CONTINUE WITH RODNEY WILBURN AS INTERIM CITY MANAGER.

WHEREAS, On April 23, 2025 the City Council unanimously agreed to the terms of a written Agreement with LACO Associates to provide Interim City Manager Services with Rodney Wilburn being appointed as Interim City Manager, which agreement will expire, if not extended, on October 14, 2024; and
WHEREAS, the CITY requires the services of a manager with proven executive and administrative qualifications to fill the position of City Manager on an interim basis until a permanent appointment can be made; and
WHEREAS, the City Council finds that LACO Associates (“LACO”) has the requisite skills, personnel and experience to provide the services of Interim City Manager; and WHEREAS, the CITY, acting by and through its City Council, desires to extend the agreement with LACO to provide the services of Interim City Manager on an at-will basis for an additional month and to appropriately compensate LACO for such services in compliance with relevant law; and
WHEREAS, LACO agrees to continue to provide such services for an extended term beginning October 14 through November 15, 2025, on the terms set forth in the Interim City Manager Services Agreement (“Interim Agreement”) and will assign and dedicate the responsibility of performing the Interim City Manager services exclusively to its board chair and principal employee, Rodney Wilburn (“WILBURN”).

NOW, THEREFORE BE IT RESOLVED, that in consideration of the terms and conditions set forth in the interim Agreement dated April 23, 2025, and the mutual promises, covenants and stipulations contained therein, the City Council hereby extends the existing agreement with LACO Associates for Interim City Manager Services until November 14, 2025.

PASSED, APPROVED AND ADOPTED, this 8th day of October 2025.

THE CITY OF WILLITS
______________________________
Tom Allman, Mayor
ATTEST:

I, Delores Pedersen, City Clerk of the City of Willits, do hereby certify that the foregoing Resolution was duly and regularly passed, approved and adopted by the City Council of the City of Willits, California, at its regular meeting held on the 8th day of October 2025, by the following vote:

AYES:

NOES:

ABSENT:
______________________________
Delores Pedersen, City Clerk
Item No. 9a
Meeting Date: October 8, 2025

AGENDA SUMMARY REPORT
To: Honorable Mayor and Council Members
From: Dusty Duley, Community Development Director
Agenda Title: DISCUSSION AND POSSIBLE ACTION ON APPLICATION FOR GENERAL PLAN AMENDMENT #GPA 22-01 AND ZONE CHANGE #ZC 22-01 FOR SANHEDRIN TIMBER COMPANY, LLC Type: Presentation Consent Regular Agenda Public Hearing Urgent Time: 30 minutes.

Summary of Request: Sanhedrin Timber Company, LLC requests approval of a General Plan Amendment (GPA 22-01) and Zone Change (ZC 22-01) for two parcels totaling approximately 19.05 acres at 23701 North Highway 101 (Quail Meadows property, APNs 108-040-11 and -18).

The request would:
• Amend the General Plan designation from Commercial General (C-G) to Industrial General (M-G); • Rezone the same lands from Community Commercial (C1) and Heavy Commercial (C2) to Heavy Industrial (MH); and
• Establish an approximately 2.2-acre frontage parcel along North Main Street for commercial uses through an administrative Boundary Line Adjustment (BLA 22-04) (BLA not before Council for approval at this hearing).

The purpose of the proposed Proejct is to facilitate the expansion of the existing Sanhedrin Timber log yard operations currently located on the adjacent parcel (APN 005-030-31).

Key Issues:
• Fire Protection and Safety - Fire risk from log storage requires robust suppression. The applicant proposes on-site ponds, hydrants, and a Bark Management Plan coordinated with Little Lake Fire District. • Water Supply - The log yard would operate primarily on independent wells and recirculating ponds, preserving the City’s limited municipal water capacity. • Biological Resources - Wetlands, riparian habitat, and sensitive species are present; mitigation requires surveys, buffers, and agency permitting.
• Noise - Potential impacts on Willits High School and nearby residences; mitigation requires limited construction hours, mufflers, and future noise assessments for industrial operations.

Environmental Review: The City, acting as Lead Agency under CEQA, directed the preparation of an Initial Study/Mitigated Negative Declaration (IS/MND) (LACO Associates, September 2025). The IS/MND analyzed both the log yard expansion and potential future industrial uses consistent with MH zoning. It concluded that with implementation of mitigation measures, impacts to biological resources, air quality, water supply, noise, fire protection, and cultural resources would be reduced to less-than-significant levels.

The IS/MND was circulated for public review (June 5 – July 7, 2025). Comments were received from the California Department of Fish and Wildlife (CDFW), who emphasized clarification of the project description, protection of listed plant species (Baker’s meadowfoam and North Coast Semaphore grass), and potential for White-tailed kite habitat.

The IS/MND was revised to provide clarifying language in response to these comments and to ensure that the project description and mitigation measures are internally consistent.

Recommended Action: Conduct a public hearing and

1. Adopt a Resolution adopting the Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program (Attachment D); and

2. Adopt a Resolution approving General Plan Amendment #GPA 22-01 and Zone Change #ZC 22-01 (Attachment E).

Alternative(s): Should the City Council find significant issues with the project, staff recommends that the item be continued to a future hearing date to allow staff time to develop findings for project denial.

The City Council may also choose to delete, modify or add conditions of approval to the Minor Subdivision provided they do not affect the environmental determination that a Mitigated Negative Declaration can be adopted for the project.

Fiscal Impact: This is a cost recovery project in accordance with the City Fee Schedule. Any inspection or monitoring costs associated with mitigation measures will be reimbursed by the applicant.

Personnel Impact: Staff time will be required to monitor compliance with conditions of approval, mitigation measures, and agency coordination.

Identified City Council Conflict of Interest: None.
2021 Adopted Goals: CDD Goal #3 Develop and implement economic development strategies for the City of Willits that will promote the development and maintenance of strong business sector including business retention and attraction, tourism, marketing and revenue generation.

California Environmental Quality Act: The City prepared an Initial Study/Mitigated Negative Declaration (IS/MND), which concluded that with mitigation all potential impacts would be reduced to less-than-significant levels; 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: Interim City Manager City Attorney City Clerk Finance Director Human Resources Council Action: Approved Denied Other: ________________________________________ Records: Agreement Resolution #_________ Ordinance #_________ Other _________

CITY COUNCIL AGENDA STAFF REPORT
MEETING DATE: October 8, 2025

STAFF REPORT TO WILLITS CITY COUNCIL FOR

SANHEDRIN TIMBER COMPANY, LLC
GENERAL PLAN AMENDMENT NO. GPA-22-01,
ZONE CHANGE NO. ZC-22-01 and BOUNDARY LINE ADJUSTMENT NO. BLA 22-04 APPLICANT/OWNER: Sanhedrin Timber Company, LLC
REQUEST: General Plan Amendment and Rezone of two parcels totaling approximately 19.05 acres. The properties are currently designated Commercial-General under the General Plan with zoning classifications of Heavy Commercial (APN 108-040- 11) and Community Commercial (APN 108-040-18) under the Zoning Ordinance. The project seeks to amend the General Plan Designation to Industrial-General and rezone the parcels to Heavy Industrial to facilitate the expansion of a log yard operation currently located on the adjacent parcel (APN 005- 030-31). Further, the applicant, Sanhedrin Timber Company, is proposing a Boundary Line Adjustment (BLA) to relocate the boundary line between APN 108-040-18 (10.64 acres)
and 108-040-011 (10.61 acres). The adjustment would create a 2.2 acre parcel adjacent to N. Main Street and a 19.05 acre parcel for the expanded the log yard.

LOCATION: The project site is located at the northern end of the Willits city limits, on the east side of North Main Street, approximately 0.12 miles north of its intersection with Casteel Lane.

TOTAL ACREAGE: 19.05± Acres (General Plan and Rezone)
EXISTING GENERAL PLAN: Commercial General (C-G)
PROPOSED GENERAL PLAN: Industrial General (M-G)
EXISTING ZONING: Heavy Commercial (C2) and Community Commercial (C1) PROPOSED ZONING: Heavy Industrial (MH)
ENVIRONMENTAL DETERMINATION: Mitigated Negative Declaration (MND) RECOMMENDATION: Adopt the MND and approve the requested land use and zoning amendments
PROJECT DESCRIPTION:

The applicant, Sanhedrin Timber Company, LLC, requests approval of a General Plan Amendment (GPA 22-01), Zone Change (ZC 22-01), and Boundary Line Adjustment (BLA 22-04) for two parcels totaling approximately 21.25 acres located at 23701 North Highway 101 (N. Main Street), also known as the Quail Meadows property and adjoining Assessor’s Parcel Number (APN) 108-040-18.

The request would:
• Amend the General Plan designation of ±19.05 acres from Commercial General (C-G) to Industrial General (M-G).
• Rezone the same ±19.05 acres from Community Commercial (C1) and Heavy Commercial (C2) to Heavy Industrial (MH).

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• Reconfigure parcels through a boundary line adjustment to retain an approximately 2.2-acre parcel along N. Main Street with its existing C-G/C1 designations for future commercial use, while consolidating the remaining ±19.05 acres into one parcel for industrial use.

Existing Conditions
The Quail Meadows property (APN 108-040-11) is a former recreational vehicle park that contains an office structure, dilapidated tennis courts, landscaped areas, and an approximately 6,900-square-foot storage unit. The site is largely vacant and currently supports ruderal vegetation and scattered mature trees. An existing office building of approximately 1,500 square feet is connected to City water, sewer, and electrical utilities and will be retained.

The adjoining APN 108-040-18 is largely undeveloped but contains gravel access roads and some remnant infrastructure from previous uses.

The site is contiguous to the North Fork Lumber Company log yard to the south and is within proximity to North Main Street commercial uses, Willits High School, and residential homes Proposed Entitlements and Site Improvements
The applicant proposes to re-designate and rezone the project area to MH Heavy Industrial to facilitate the expansion of the existing log yard operation. Proposed site improvements and operations include:
• Log Storage and Circulation: The 19.05-acre parcel would be cleared, graded, and surfaced with compacted base rock to provide rocked storage decks for logs and to support circulation of log trucks and heavy equipment. Gravel access roads would connect the expanded yard with the existing log yard on Casteel Lane.
• Water Storage and Fire Suppression: Construction of two irrigation/fire suppression ponds (approximately 1.0 acre-foot and 0.85 acre-foot capacities) to provide water supply for log irrigation and emergency firefighting needs. Existing wells, tanks, and future wells would be integrated into a recirculating irrigation system for wetting log decks. A back-up City water connection would remain in place for emergency supply.
• Structures: Retention of the existing 1,500-square-foot office. Removal of old tennis courts and landscaping features. Potential demolition of the 6,900-square-foot storage building if deemed unnecessary. No new permanent structures are proposed at this stage beyond utility and safety infrastructure.
• Tree Removal: Removal of approximately 116 mature trees (greater than 12 inches DBH), including black poplar, willow, aspen, oaks, and sycamore, as identified in a professional tree survey. Trees along the eastern property boundary are proposed to be retained. • Access and Parking: Continued use of both the Quail Meadows entrance on N. Main Street and the Casteel Lane entrance at the existing log yard. Additional internal gravel circulation routes would provide truck queuing and separation of industrial traffic from administrative/office traffic.

ADA and employee parking would be provided adjacent to the office. • Utilities: Continued service from PG&E (electric), City of Willits (water/sewer for the office), and on-site wells and tanks for industrial irrigation/fire protection. Stormwater would be managed onsite through drainage ditches directing flows into the irrigation ponds, consistent with State Water Resources Control Board requirements.
• Fire Protection and Safety: Compliance with Little Lake Fire District fire flow requirements, installation of up to three fire hydrants, and preparation of an Emergency Action Plan (EAP) including a Bark Management Plan to reduce fire risk. Fire suppression equipment, water trucks, extinguishers, and foaming systems would be available on site.

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Operations
Daily operations would remain consistent with existing log yard activities and include:
• Storage and handling of non-retail logs.
• Truck deliveries averaging 50–60 incoming log trucks per day during the summer peak, with a maximum of 65–70 on rare occasions, and approximately 15–20 outgoing lumber trucks per day.

Winter operations are reduced, averaging 15 incoming and 25–30 outgoing trucks daily. • Use of heavy equipment such as Caterpillar loaders and log stackers, a water truck for dust suppression, and chainsaws for log trimming and cleanup. • Regular watering of surfaced yards to control dust emissions in compliance with Mendocino County Air Quality Management District rules.
• Accumulation and removal of bark material, typically 2–5 loads per week, managed in accordance with a Bark Management Plan.
• Normal hours of operation: 6:00 a.m. – 5:30 p.m. (summer), 7:00 a.m. – 4:00 p.m. (winter), with occasional extended hours as needed.

Future Industrial Development
Although the immediate intent is expansion of the log yard, the requested zoning would allow for a broader range of industrial uses under the MH district. The Initial Study analyzed impacts assuming a “typical industrial facility” consistent with MH zoning to ensure CEQA coverage for reasonably foreseeable future uses. Any subsequent development proposals would be subject to Site Plan Review and, if necessary, additional CEQA analysis.

ENVIRONMENTAL REVIEW
PURPOSE:

The proposed project is subject to the requirements of the California Environmental Quality Act (CEQA).

The City of Willits is the Lead Agency responsible for evaluating potential environmental impacts associated with the requested General Plan Amendment, Zone Change, and Boundary Line Adjustment.

The purpose of the environmental review is to:

1. Identify potential environmental effects of the proposed project, including reasonably foreseeable development that could occur under the requested MH zoning and M-G land use designations.

2. Determine the level of environmental documentation required under CEQA

3. Incorporate mitigation measures where necessary to avoid or reduce potentially significant environmental impacts to less than significant.

For this project, a third-party, LACO and Associates prepared a Public Draft Initial Study/Mitigated Negative Declaration (IS/MND) (May 2025) which analyzed both the proposed log yard expansion and a conceptual “typical industrial use” allowed under MH zoning. The IS/MND concluded that, with implementation of identified mitigation measures, the project’s potentially significant impacts (including biological resources, air quality, hydrology and water quality, cultural and tribal cultural resources, and noise) would be reduced to less-than-significant levels. The City reviewed, revised, and directed the scope of work to ensure compliance with CEQA and retains full authority for certification and adoption of the environmental review.

SITE CHARACTERISTICS:

The project site consists of two parcels totaling approximately 21.25 acres located at 23701 North Highway 101 (N. Main Street), at the northern limits of the City of Willits. The site is comprised of the former Quail Meadows property (APN 108-040-11) and an adjoining parcel (APN 108-040-18). The site is generally flat to gently sloping, with minimal elevation change
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Access and Circulation
The Site is currently accessed from N Main Street via a paved driveway at the southwest corner of Quail Meadows. The existing log yard is accessed via Casteel Lane. The Applicant proposes to utilize both the Quail Meadows entrance and the Casteel Lane entrance at the existing log yard for accessing the Site. An additional unimproved driveway is located at the northwest corner of the Site.

Utilities and Services
• Water: Served by existing wells and City water (office connection); additional wells and irrigation/fire suppression ponds are proposed.
• Sewer: Office connected to City sewer.
• Electricity/Natural Gas: PG&E provides service.
• Fire District: Little Lake Fire Protection District
Adjacent Land Uses and Zoning
The site is located at the northern edge of the City of Willits and is surrounded by a mix of commercial, industrial, residential, and public uses. The table below summarizes adjacent General Plan designations, zoning, lot sizes, and existing land uses:

GENERAL
PLAN

ZONING LOT SIZES USES
NORTH AG40 AG 40 25.5 acres Vacant State-Owned Land
EAST AG40 AG 40 26.8 acres Vacant State-Owned Land;
Railroad/GRTA R.O.W.

SOUTH M-G/R-L MH/R1 0.1 – 5.6 acres Existing Log Yard Operation; Single-Family Residence
WEST C-G C2 4.25 acres Mini-Storage Business

REFERRAL AGENCY COMMENTS
The project was referred to the agencies/departments listed in the table below. Comments received are discussed in the Key Issues section of this report and where applicable have been included as Mitigation Measures and/or Conditions of Approval.

REFERRAL AGENCIES NOT RETURNED “NO COMMENT” COMMENTS
City Engineering Division X
City Building Division X
City Water and Sewer Divisions X
City Manager X
City Police Department X
Willits Unified School District X
Little Lake Fire District X
Air Quality Management District X
California Department of Fish and Wildlife X
Caltrans, District 1 X
CalFire X
Mendocino County Div. of Env. Health X
North Coast RWQCB X
Native American Heritage Commission X
Sherwood Valley Rancheria Band of Pomo
Indians
X
Middletown Rancheria Band of Pomo Indians X
Torres Martinez Desert Cahuilla Indians X
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U.S. Army Corps of Engineers X
Mendocino County DOT X
As discussed in the Initial Study/Mitigated Negative Declaration, the project was also referred in accordance with AB 52 and SB 18 to Native American Tribes identified on the Tribal Consultation List provided by the Native American Heritage Commission. No responses to the tribal notifications or requests to consult on the project were received.

KEY ISSUES
The proposed General Plan Amendment and Zone Change would allow for a change in the permitted and conditionally permitted uses on the site. The current General Plan Land Use designation, Commercial General (C-G), is intended for 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. The project proposes to amend the General Plan Land Use designation to Industrial General (M-G) and rezone the site from Community Commercial (C1) and Heavy Commercial (C2) to Heavy Industrial (MH). The M-G designation is intended to be applied 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.

The following section includes a discussion of key issues identified through the environmental review process. These issues are primarily associated with the proposed log yard expansion and potential future industrial development allowed under the new designations. The Initial Study/Mitigated Negative Declaration (IS/MND) includes mitigation measures and operating conditions—such as biological protection, noise controls, and fire suppression requirements—that ensure potential environmental impacts are reduced to less-than-significant levels.

KEY ISSUE #1 – FIRE PROTECTION
The proposed project would expand industrial operations involving large volumes of log storage, which presents inherent fire risks. Fire protection and suppression are therefore critical considerations for project approval.

Water Supply and Fire Flow: The applicant proposes to construct two on-site irrigation/fire suppression ponds (with storage capacities of approximately 1.0 and 0.85 acre-feet) and to install up to three additional fire hydrants within the project area. Combined with existing wells, tanks, and City connections, the system is designed to maintain a minimum fire flow of 1,500 gallons per minute (gpm) for six hours, consistent with requirements from the Little Lake Fire District. A backup diesel generator will provide uninterrupted power to fire pumps in the event of an outage. These improvements are intended to ensure adequate water supply during emergencies and compliance with the California Fire Code.

Bark Management Plan: The accumulation of bark and wood debris during log yard operations is a potential fire hazard. The applicant proposes to prepare a Bark Management Plan as part of a comprehensive Emergency Action Plan (EAP), subject to approval by the Little Lake Fire District. The Bark Management Plan will identify strategies to:
• Limit the size and location of bark piles (generally 30’ x 30’, 10–15 feet high). • Maintain safe separation from log decks, stormwater drainage systems, and sensitive receptors. • Ensure consistent hauling of bark (2–5 loads per week) to prevent excessive buildup. • Provide fire prevention measures, such as controlling spontaneous combustion risks and reducing ignition sources near piles.

Emergency Action Plan (EAP): The EAP will address preparedness and response for fire events and other emergencies. Elements will include:
• Employee training in fire response protocols.
• Maps showing deck orientation, hydrant locations, and evacuation routes.

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• On-site firefighting equipment, including water trucks, extinguishers, fire tools, and portable foaming suppression systems.
• General housekeeping and inspection protocols to reduce fire hazards.

With implementation of the EAP and Bark Management Plan, and with the proposed on-site water storage, hydrants, and fire flow improvements, fire protection impacts of the project would be reduced to less than significant. These measures are required as conditions of approval and will be coordinated with the Little Lake Fire District to ensure compliance with local and state fire protection standards.

KEY ISSUE #2 – WATER SUPPLY
The City of Willits’ municipal water system has limited available capacity to serve new high-demand users.

Expansion of the Sanhedrin Timber log yard presents a concern because log storage operations require substantial amounts of water for dust suppression, log deck irrigation, and fire protection. Reliance on City water could place strain on municipal supplies, particularly during drought years or emergency conditions.

Independent Water Source Proposed:

To avoid increased dependence on the City system, the applicant proposes a self-sufficient water supply strategy, consisting of:
• On-Site Wells: Existing wells will be supplemented by the drilling of additional wells, capable of meeting operational water needs.
• Irrigation/Fire Suppression Ponds: Two new ponds (1.0 and 0.85 acre-feet) will store water pumped from wells and stormwater runoff. These ponds will serve dual purposes: irrigation for log decks to minimize dust and bark ignition risk, and as reservoirs for firefighting. • Recirculating Irrigation System: Water used for log wetting will be collected and returned to the ponds, reducing overall demand on wells.
• Backup Connection to City Water: A limited emergency-only connection will remain in place, ensuring redundancy but not as a primary source of supply.

City’s Role and Protection of Municipal Capacity: By developing its own independent water infrastructure, the project reduces reliance on the City’s municipal water supply. This is a critical factor given the City’s constrained water system and the need to reserve available capacity for residential growth and other priority uses. The City will condition project approval on maintaining wells and ponds as the primary water source, with City water used only as a backup during outages or emergencies.

The project’s approach to water independence is consistent with City goals to preserve municipal water capacity while allowing economic development. With wells, ponds, and a recirculation system in place, the log yard expansion can be adequately supplied without adverse impacts to the City’s limited water system.

KEY ISSUE #3 – PROTECTION OF SENSITIVE RESOURCES
The project site contains a number of sensitive environmental resources, including riparian vegetation, wetlands, mature trees, and the potential for cultural and tribal cultural resources. Protection of these resources is a central concern in project review and was the subject of detailed analysis in the Initial Study/Mitigated Negative Declaration (IS/MND).

Biological Resources:
• A formal Biological Resources Assessment identified jurisdictional waters, wetlands, and riparian habitat on the property. Project design includes avoidance of wetlands where feasible and compliance with permitting requirements from the California Department of Fish and Wildlife (Lake PAGE 7
or Streambed Alteration Agreement), North Coast Regional Water Quality Control Board (401 Water Quality Certification), and U.S. Army Corps of Engineers (404 Permit). • Approximately 116 mature trees (greater than 12” DBH) will be removed to accommodate site development. Tree removal will be conducted outside the nesting bird season or subject to preconstruction surveys in accordance with the Migratory Bird Treaty Act and California Fish and Game Code. Trees along the eastern property boundary and near sensitive drainage areas are proposed to be retained for screening and habitat value. • The project requires implementation of best management practices (BMPs) for erosion control, stormwater treatment, and protection of downstream water quality.

Cultural and Tribal Cultural Resources:
• Consultation was conducted with local tribal representatives pursuant to Assembly Bill 52 (AB 52) and Senate Bill 18 (SB 18). No concerns were raised, but the potential remains for inadvertent discovery of cultural resources during ground-disturbing activities. • The IS/MND requires implementation of a Mitigation and Monitoring Program, including construction worker training and procedures for halting work and notifying appropriate agencies and tribal representatives if resources are encountered.

Mitigation Measures: The IS/MND incorporates enforceable measures to ensure sensitive resource protection, including:
• Pre-construction biological surveys.
• Seasonal timing restrictions to protect nesting birds. • Wetland avoidance buffers and agency permitting.
• Cultural resource discovery protocols.
• Restoration of disturbed areas with native seed mixes and erosion control materials.

With adherence to the mitigation measures outlined in the MMRP, impacts to sensitive resources would be reduced to less-than-significant levels. The project conditions will require compliance with state and federal permitting agencies as well as implementation of biological and cultural monitoring during site preparation.

KEY ISSUE #4 – NOISE IMPACTS ON SENSTIVE RECEPTORS
The proposed rezone and expansion of the Sanhedrin Timber log yard would introduce or intensify noise sources associated with industrial operations, including log loading/unloading, heavy equipment use (e.g., loaders, log stackers, chainsaws), and heavy truck traffic. These activities have the potential to affect sensitive receptors located near the site, most notably Willits High School to the south and single-family residents to the southwest.

Noise Analysis: An Environmental Noise Assessment was prepared to evaluate if the proposed project would significantly impact the existing noise environment at sensitive receptors. The Assessment found:
• Truck Traffic: Increases in truck trips (averaging 50–60 inbound log trucks and 15–20 outbound lumber trucks daily during peak summer operations) would not exceed City thresholds on N. Main Street, given the existing truck traffic associated with current log yard activities. • On-Site Operations: Equipment noise, including intermittent use of chainsaws, loaders, and water pumps, would remain below City noise ordinance limits when measured at property boundaries.

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• Cumulative Exposure: Although noise levels would increase incrementally, the impact on nearby residences and the high school was determined to be less than significant with implementation of mitigation measures.

Mitigation Measures: To ensure noise impacts remain at acceptable levels, the following measures are included in the Mitigation Monitoring and Reporting Program (MMRP):
• Construction activities shall be limited to 7:00 a.m.–7:00 p.m., Monday through Saturday, unless otherwise approved by the City. Contractors shall use quieter equipment models where feasible, and all internal combustion equipment shall be fitted with appropriate mufflers. • Any future industrial development permitted under the proposed M-G land use and MH zoning designations must demonstrate compliance with City noise standards. A project-specific noise assessment shall be prepared if necessary, and abatement measures incorporated into project design to reduce noise to below allowable limits.

The analysis concluded that noise and vibration generated by the proposed project operations would be satisfactory relative to applicable City of Willits and CEQA noise criteria. As a result, no noise or vibration mitigation measures would be warranted for this project provided operations at the project site would be similar to operations currently occurring at the existing facility to the south.

COMMENTS RECEIVED
Comments on the IS/MND: In accordance with the California Environmental Quality Act, the IS/MND was circulated for a 30-day public review period from June 5, 2025 to July 7, 2025. CEQA Guidelines Section 15074 identifies the responsibilities of the Lead Agency when considering the adoption of a Mitigated Negative Declaration including the requirement of the decision-making body of the lead agency to consider the proposed Mitigated Negative Declaration together with any comments received during the public review process. The decision-making body shall adopt the Mitigated Negative Declaration only if it finds on the basis of the whole record before it that there is no substantial evidence that the project will have a significant effect on the environment. Consistent with CEQA requirements, comments received on the IS/MND have been reviewed and considered.

The City received a letter of comment via email on August 11,2025 from the California Department of Fish and Wildlife (CDFW). CDFW staff met onsite with the City, the City’s consultant (LACO), and the applicant on July 24, 2025, to review the proposed project, following earlier discussions on June 19, 2025. Key points from CDFW’s review of the Initial Study/Mitigated Negative Declaration (IS/MND) and site visit include:
• Clarity in Project Description:

CDFW requested revisions to the IS/MND to clarify activities within the 2.2-acre commercial parcel, including existing access roads and drainage ditches, and the extent of sensitive resources on-site, including listed plant species and Sensitive Natural Communities. • Sensitive Natural Communities and Plant Species:

CDFW provided updated references to the State’s Natural Communities and Sensitive Natural Communities lists. CDFW noted the presence of Baker’s meadowfoam (Limnanthes bakeri) and North Coast Semaphore grass (Pleuropogon hooverianus) on the site and encouraged consultation with CDFW’s Native Plant Program to determine whether a state permit for species management is warranted.
• Future Development Review:

CDFW acknowledged the City’s Site Plan Review process, whereby the City can review future development proposals, in consultation with CDFW, to ensure protection of biological resources.

Such as wetlands, riparian habitat, oak woodlands, and other sensitive communities. • Wildlife Concerns:

The site may provide foraging or nesting habitat for the White-tailed Kite (Elanus leucurus), a PAGE 9
State fully protected species. CDFW recommended that a qualified avian biologist conduct seasonal surveys to inform avoidance measures and site management plans for the log yard or any future industrial use. See Mitigation MeasureBIO-3.

Revisions were made to Public Draft IS/MND to provide requested clarification in response to CDFW comments. Mitigation Measures BIO-1 through BIO-8 are provided to ensure protection of Biological Resources.

RECOMMENDATION
It is recommended that the City Council consider the adequacy of the Initial Study/Mitigated Negative Declaration (IS/MND) in analyzing potential environmental impacts of the proposed project and the reasonably foreseeable future industrial development that would be permitted under the requested Industrial General (M-G) land use designation and Heavy Industrial (MH) zoning classification.

If the Council determines that the IS/MND, together with the Mitigation Monitoring and Reporting Program (MMRP) and responses to comments received, adequately addresses environmental impacts pursuant to the California Environmental Quality Act (CEQA), it is recommended that the IS/MND and MMRP be adopted by Resolution (Attachment B).

Additionally, if the Council determines that the proposed change in land use and zoning represents a more appropriate and compatible designation than the existing commercial classifications, it is recommended that the General Plan Amendment (GPA 22-01) and Zone Change (ZC 22-01) be adopted by Resolution (Attachment C).

While related to the project proposal, approval of the Boundary Line Adjustment (BLA 22-04) is not before the Council tonight. The BLA is an administrative action subject to approval by the Community Development Director upon determination that the adjustment complies with applicable standards such as zoning, lot size, and lot configuration. If approved administratively, the BLA would establish the 2.2-acre commercial frontage parcel and the 19.05-acre industrial parcel consistent with the Council’s land use and zoning actions.

FINDINGS
Pursuant to Section 17.78.090 (Finding by Council) of the Willits Municipal Code the following findings must be made prior to approving an amendment to the General Plan:

A. The proposed amendment is in general conformance with the General Plan; The proposed amendment, as conditioned, is in conformance with the General Plan consistent with this finding. Specifically, the project is consistent with the following General Plan policies:
• Land Use Policy 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.

The project will consolidate industrial activities on a large, contiguous parcel at the northern edge of the City, adjacent to existing industrial uses (the North Fork Lumber log yard), thereby clustering similar uses. Project approval is conditioned on implementation of mitigation measures through the Site Plan Review process to reduce potential conflicts with nearby sensitive receptors, including Willits High School and residential uses southwest of North Main Street. As a result, the project supports the General Plan’s intent under LU-6.1 by locating heavy industrial uses where they are compatible and by applying development standards and mitigation measures to reduce conflicts with surrounding commercial, residential, and public uses.

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• Land Use Policy 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.

Mitigation measures require the implementation of noise limits, dust control, and fire protection systems, which reduce potential conflicts with sensitive receptors such as nearby residences. By conditioning the project with performance standards, the project fulfills the General Plan directive under LU-6.2 to limit conflicts between industrial and residential land uses. • Conservation and Open Space Policy 3.210: Conserve, to the greatest feasible extent, the City's existing natural resources, with particular emphasis on air and water quality, open space, tree preservation and riparian habitat maintenance and enhancement.

The site currently contains trees along the northern property boundary between the site and the adjacent railroad. Additionally, there is an intermittent stream onsite which runs through the northeastern portion of the site. As conditioned, future development of the site will be required to incorporate design features that protect, to the extent feasible, the intermittent stream onsite.

Design features include incorporation of a buffer, Low Impact Development design features, and native landscape plantings, which will contribute to native resources on the site. As such, the project is consistent with this General Plan policy.
• Conservation and Open Space Policy 3.220: Ensure that all adverse environmental impacts of proposed development projects are identified and acceptably mitigated prior to approval.

The Initial Study/Mitigated Negative Declaration (IS/MND) prepared for the Sanhedrin Timber Company General Plan Amendment and Rezone identifies and evaluates potential environmental impacts associated with the proposed land use and zoning changes and the reasonably foreseeable industrial uses that could occur under the new Industrial General (M-G) and Heavy Industrial (MH) designations. The IS/MND analyzes impacts across all environmental topic areas, including biological resources, air quality, hydrology and water quality, noise, cultural and tribal cultural resources, and fire protection and safety.

Where potentially significant impacts were identified—such as disturbance to sensitive habitats, noise from industrial operations, or fire risk from bark storage—the IS/MND includes mitigation measures to avoid, minimize, or offset these effects. These measures, incorporated into the Mitigation Monitoring and Reporting Program (MMRP) and as conditions of approval, ensure that future site development and industrial activity remain consistent with CEQA and City environmental standards.

Noise Policy 4.210: The City seeks to maintain ambient noise levels of 55 dBA (CNEL) in existing residential areas.

The proposed project is consistent with this policy because the Initial Study/Mitigated Negative Declaration (IS/MND) includes analysis demonstrating that both short-term construction activities and long-term industrial operations would not elevate ambient noise levels at nearby residential areas above City standards. Noise modeling conducted for the IS/MND concluded that the increase in noise from equipment operation and truck traffic associated with the expanded log yard would remain below the City’s exterior residential noise limit of 55 dBA CNEL, when measured at the nearest sensitive receptors.

Noise Policy 4.260: Noise created by temporary activities necessary to provide construction or required services should be permitted for the shortest duration possible and limited to time periods that will have the least possible adverse effect on surrounding land uses.

As a project condition of approval, future development of the site will be required to incorporate best management practices during the construction phase to ensure noise emanating from the site is reduced to the extent feasible. Furthermore, consistent with time limits set forth by the City, construction hours will be limited to 7:00 a.m. to 6:00 p.m., Monday through Friday, 9:00 a.m. to PAGE 11
5:00 p.m. on Saturdays, with no construction activities permitted on Sundays and holidays. As such, the project is consistent with this General Plan policy. • Noise Policy 4.270: Uses should be located where they will be most acoustically compatible with elements of the man-made and natural environment.

The project site is positioned at the northern boundary of the City, directly adjacent to the existing Sanhedrin Timber log yard and other industrial uses and buffered by the railroad right-of-way and U.S. Highway 101 bypass to the east. There are existing single-family homes in the project vicinity that could be impacted by future industrial uses. Noise modeling conducted for the IS/MND concluded that the increase in noise from equipment operation and truck traffic associated with the expanded log yard would remain below the City’s exterior residential noise limit of 55 dBA CNEL, when measured at the nearest sensitive receptors. Further, the City can require a project-specific noise assessment for any future industrial development through the site plan review process to confirm compliance with City standards and incorporate additional abatement measures if needed. • Economic Development Policy 8.220: Designate industrial employment development and downtown revitalization as the City's two most important economic development objectives.

The proposed project is consistent with this goal as it allows the Sanhedrin Timber Company to expand its log yard operations on land directly adjacent to its existing facility. By re-designating and rezoning the property for industrial use, the City provides the necessary land use framework for continued operation and growth of the local timber industry. The project is expected to help retain jobs and generate additional employment associated with log storage, hauling, and ancillary industrial activities.

B. The public necessity, convenience and general welfare require the adoption of the proposed amendment;
As previously discussed, the General Plan amendment and rezone would change the designation of the site from commercial to industrial. The public necessity, convenience, and general welfare require adoption of the proposed General Plan Amendment and Zone Change because the project:
• Supports the local economy by allowing the expansion of an existing long-standing timber and log storage operation that contributes to jobs, goods movement, and the regional forest products industry.
• Reduces potential land use conflicts by placing heavy industrial uses at the City’s northern boundary, buffered by the railroad right-of-way and U.S. 101 bypass, and separated from sensitive commercial and residential uses by transitional zoning and operational conditions. • Protects public health and safety through required fire suppression measures, bark pile management, independent water sourcing, and noise and dust mitigation, ensuring the project can operate without overburdening City utilities or adversely affecting nearby residents, schools, and businesses.
• Implements General Plan policies that call for the appropriate siting of industrial uses, protection of sensitive resources, and mitigation of environmental impacts, thereby balancing economic development with conservation and community well-being.

C. Any other appropriate findings.

No other appropriate findings for the project have been identified by staff.

CONDITIONS OF APPROVAL:

Standard Conditions
PAGE 12

1. Prior to establishment of a new use on the subject parcels, a site plan review application shall be submitted and approved by the Community Development Director.

2. All natural drainage areas on the property shall be considered as easements unless otherwise approved by the City Engineering Department.

3. All future public utilities shall be installed underground in accordance with the regulations contained the Willits Municipal Code to the satisfaction of the City Building Official.

4. Prior to approval of building permits on the subject property, the property owner(s) shall submit a plan for review and approval to the Community Development Department identifying adequate area for storage of garbage and recyclable materials. The storage area shall be accessible to the City’s franchise waste hauler with containers designed to be consistent with current methods of collection.

Prior to occupancy of the buildings, the applicant shall submit written verification that the plan for garbage and recyclables has been reviewed and accepted by the City’s franchise waste hauler.

5. The applicant of a future development at the site shall obtain all necessary permits and fully comply with all the requirements of the Fire, Health, Water, Sewer, Building and Public Works Departments of the City of Willits as well as any State or Federal Agency.

6. The application and supplementary information submitted by the applicant shall become entitlements of this permit and compliance therewith shall be mandatory.

7. The City, its officers, agents and employees may inspect this property at any time and the applicant agrees not to deny or impede access to the subject property for the City.

8. The permit shall have no force or effect unless, and until, accepted and the terms thereof agreed to, in writing, by the applicant.

9. Submittal of a future development proposal shall include a copy of the conditions contained herein.

Fish and Wildlife Fee

10. This entitlement does not become effective or operative and no work shall be commenced under this entitlement until the California Department of Fish and Wildlife filing fees required or authorized by Section 711.4 of the Fish and Game Code are submitted to the Mendocino County Department of Planning and Building Services. Said fee of $2,968.75 (inclusive of $50 clerk filing fee) shall be made payable to the Mendocino County Clerk and submitted to the Department of Planning and Building Services within 5 days of the end of any appeal period. Any waiver of the fee shall be on a form issued by the Department of Fish and Wildlife upon their finding that the project has “no effect” on the environment. If the project is appealed, the payment will be held by the Community Development Department until the appeal is decided. Depending on the outcome of the appeal, the payment will either be filed with the County Clerk (if the project is approved) or returned to the payer (if the project is denied). The applicant has the sole responsibility to ensure timely compliance with this condition.

LIST OF ATTACHMENTS:

A. Initial Study/Mitigated Negative Declaration (IS/MND) B. IS/MND Appendices
C. Mitigation Monitoring and Reporting Program
D. Resolution certifying CEQA compliance
E. Resolution approving GPA-22-01 and ZC 22-01
F. CDFW IS/MND comments - email 8-11-2025
PAGE 13
FINAL INITIAL STUDY and ENVIRONMENTAL CHECKLIST
FOR

SANHEDRIN TIMBER COMPANY

GENERAL PLAN AMENDMENT, REZONE, AND BOUNDARY LINE

ADJUSTMENT
CITY PROJECT FILE NO. GPA 22-01; ZC 22-01, BLA 22-04
May 2025 ~ Revised September 2025
Lead Agency:

City of Willits
Lead Agency Contact:

Dusty Duley, Community Development Director
City of Willits
Community Development Department
111 E. Commercial Street, Willits, California 95490
Prepared by:

LACO Associates
1072 N. State Street
Ukiah, California 95482
(707) 462-0222
State Clearinghouse No.: 2025060333

TABLE OF CONTENTS
I. PROJECT SUMMARY .................................................................................................................................1 II. PROJECT DESCRIPTION............................................................................................................................3 III. PROJECT SETTING AND LOCATION ...................................................................................................115 IV. ENVIRONMENTAL EFFECTS.................................................................................................................115 V. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED.........................................................................17 VI. REFERENCES ..........................................................................................................................................91

FIGURES AND APPENDICES
Figure 1: Project Location Map
Figure 2: Vicinity Map
Figure 3: General Plan Amendment Figure
Figure 4: Rezone Figure
Figure 5: Site Plan
Appendix A: Tree Survey, prepared by Victor Hollister of North Fork Lumber Company, April 2023 Appendix B: Photo Log
Appendix C: Biological Resources Assessment, prepared by Clifton Environmental LLC, September 27, 2022 Appendix D: Mitigation Monitoring and Reporting Program (MMRP) Appendix E: Focused Transportation Impact Study, prepared by W-Trans, November 29, 2023 Appendix F: Native American Heritage Commission Sacred Lands File Search and Contact List Appendix G: GeoTracker and EnviroStor Database Queries
Appendix H: FEMA Flood Insurance Rate Map (FIRM)
Appendix I: Well Impact Report, prepared by VESTRA Resources, October 5, 2023 Appendix J: Environmental Noise Assessment, prepared by Bollard Acoustical Consultants, Inc., March 11, 2024
Appendix K: Little Lake Fire District Correspondence, March 17, 2023

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
I. PROJECT SUMMARY
Date: May 2025 ~ Revised September 2025
Project Title: Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment
Lead Agency: City of Willits
Contact: Dusty Duley, Community Development Director
City of Willits
Planning Department
111 E. Commercial Street, Willits, California 95490
Location: The proposed Project is located on the properties located at 23701 N. Highway 101 (N Main Street), Willits, California and identified by Assessor’s Parcel Numbers (APNs):
108-040-11, also known as “Quail Meadows,” and 108-040-18 (Site). See Figure 1:

Location Map. The Site is located at the northern end of the Willits city limits, adjacent to the north of an existing log yard located on Casteel Lane and operated by North Fork Lumber (existing log yard). See Figure 2: Vicinity Map.

Coastal Zone: No
Affected Parcel(s): APNs: 108-040-11 and 108-040-18
City of Willits Land Use Designation: Commercial General (C-G) (see Figure 3: General Plan Amendment Figure)
City of Willits Zoning Designation: APN 108-040-11: Heavy Commercial (C2); APN 108-040-18: Community Commercial (C1) (see Figure 4: Rezone Figure)
Anticipated Permits and Approvals:
1) Adoption of Mitigated Negative Declaration by the City of Willits 2) General Plan Amendment through the City of Willits
3) Rezone through the City of Willits
4) Boundary Line Adjustment through the City of Willits 5) Site Plan Review and Grading Permit through the City of Willits 6) Lake or Streambed Alteration Agreement (LSAA) through the California Department of Fish and Wildlife (CDFW)
7) Section 401 Water Quality Certification (WQC) through the North Coast Regional Water Quality Control Board (NCRWQCB)
8) Section 404 Nationwide Permit (NWP) through the U.S. Army Corps of Engineers (USACE) 9) Scientific, Education, or Management Permit through CDFW Tribal Cultural Resources: Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
On December 14, 2022, in compliance with Assembly Bill (AB) 52 and Senate Bill (SB) 18, the City of Willits sent consultation letters to the Tribal Historic Preservation Officer (THPO) or appropriate representative for each of the following 15 Native American tribes: Coyote Valley Band or Pomo Indians, Guidiville Indian Rancheria, Hopland Band of Pomo Indians, Cahto Tribe, Manchester Band of Pomo Indians of the Manchester Rancheria, Middletown Rancheria of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, Robinson Rancheria of Pomo Indians, Round Valley Reservation/Covelo Indian Community, Scotts Valley Band of Pomo, Sherwood Valley Rancheria of Pomo, Yokayo Tribe, and Torres Martinez Desert Cahuilla Indians. Two Native American tribes, the Manchester Band of Pomo Indians of the Manchester Rancheria and the Sherwood Valley Rancheria of Pomo, responded to request additional information. No Native American tribes responded with concerns regarding the proposed Project.

CEQA Requirement:

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

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

Section 15063(d) of the State CEQA Guidelines states that an IS shall contain the following information in brief form:
1) A description of the project including the project location 2) Identification of the environmental setting
3) Identification of environmental effects by use of a checklist, matrix, or other method, provided that entries on a checklist or other form are briefly explained to provide evidence to support the entries 4) Discussion of means to mitigate significant effects identified, if any 5) Examination of whether the project would be consistent with existing zoning, plans, and other applicable land use controls
6) The name of the person or persons who prepared and/or participated in the Initial Study CEQA Discussion: In June 2025 the City of Willits (City) prepared and circulated a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) for the proposed project. The Draft IS/MND was submitted to the State Clearinghouse (SCH No. 2025060333) and circulated for public review and comment for a period of 30 days, beginning on June 6, 2025, and ending on July 7, 2025. The City received one (1) comment letter on the Draft IS/MND within the circulation period and one (1) site visit request following completion of the circulation period.

Following circulation of the Draft IS/MND and the receipt of comments both during and following the circulation period, minor clarifying revisions were made to the Draft IS/MND. In accordance with State CEQA Guidelines Section 15073.5, recirculation of the Draft IS/MND is not required as the revisions merely clarify, amplify, and make insignificant modifications to the document.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
II. PROJECT DESCRIPTION
This Initial Study (IS) has been prepared to evaluate potential environmental impacts from the proposed Sanhedrin Timber Company Entitlements project (Project), which includes a General Plan Amendment (GPA), Rezone, and Boundary Line Adjustment (BLA). The Project is proposed on the properties located at 23701 North Highway 101 (N Main Street), Willits, California and identified by Assessor’s Parcel Numbers (APNs):
108-040-11, also known as “Quail Meadows,” and 108-040-18 (Site). See Figure 1: Location Map. The Site is located at the northern end of the Willits city limits, adjacent to the north of an existing log yard located on Casteel Lane and operated by North Fork Lumber (existing log yard). See Figure 2: Vicinity Map.

The Site has a land use designation of Commercial General (C-G) per the Willits General Plan 2020 (1992).

Quail Meadows has a zoning designation of Heavy Commercial (C2) pursuant to Ordinance No. 90-13 adopted by the Willits City Council June 13, 1990, and APN: 108-040-18 has a zoning designation of Community Commercial (C1) according to the City of Willits Zoning map dated May 2010. Sanhedrin Timber Company, LLC (Applicant) requests a GPA and Rezone to change the existing land use and zoning designations of the Site to Industrial General (M-G) and Heavy Industrial (MH), respectively, to facilitate expansion of an existing log yard operation. See Figures 3 and 4: General Plan Amendment Figure and Rezone Figure, respectively. Additionally, the Applicant requests a BLA to retain an approximately 2.2-acre portion of APN: 108-040-18 along N Main Street for future commercial use. The approximately 2.2-acre parcel would maintain the C-G and C1 land use and zoning designations, respectively, and would not be included in the proposed GPA and Rezone (see Figures 3 and 4). See Figure 5: Site Plan for the approximate location of the proposed BLA. For the purposes of this IS, the portion of the Site proposed for land use and zoning changes is referred to as “Project Area.”
Though the Applicant requests a GPA and Rezone in order to expand an existing log yard, the proposed entitlements would allow for future development of industrial uses permitted under the M-G land use designation and MH zoning designation. Pursuant to the City of Willits Municipal Code (Code) Chapter 17.28 – Heavy Industrial (MH) Zone, the MH zoning designation allows for principal permitted uses of a variety of industrial uses, as defined in Code Sections 17.28.010 – Purpose and 17.28.020 – Principal permitted uses, subject only to such regulations as are needed to control nuisances and protect surrounding areas.

Therefore, for the purposes of this analysis, it is presumed that the proposed GPA and Rezone would result in the development of a typical industrial use allowed in the MH zoning district, which may directly result in physical changes to the existing environment.

Project Proposal
General Plan Amendment, Rezone, and Boundary Line Adjustment As discussed above, the Applicant proposes to amend the land use designation of the Project Area from CG to M-G and zoning designations from C1 and C2 to MH through a GPA and Rezone, respectively (see Figures 3 and 4). Additionally, the Applicant proposes a BLA to relocate the boundary line between APN:
108-040-18 (currently approximately 10.64 acres) and Quail Meadows (currently 10.61 acres) to the northwest in order to establish an approximately 2.2-acre parcel adjacent to N Main Street and an approximately 19.05- acre parcel for the expanded log yard. The proposed boundary line configuration is shown on Figure 5 (a and b): Site Plan. The GPA and Rezone are proposed for the 19.05-acre parcel (Project Area), while the 2.2- acre parcel would remain with C-G and C1 land use and zoning designations, respectively, for future commercial use. The proposed acreages within each land use and zoning district, following the proposed BLA and GPA/Rezone, are provided in Table 1, below.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Table 1. Proposed Acreages, Land Use, and Zoning.

APN Size (acres) Land Use Zoning
Existing Proposed Existing Proposed Existing Proposed
108-040-18 10.64 2.2 C-G C-G C1 C1
108-040-11 10.61 19.05 C-G M-G C2 MH
As a result of the proposed GPA and Rezone, principally permitted and conditionally permitted uses in the MH zoning district, as defined in Code Chapter 17.28 – Heavy Industrial (MH) Zone, would be permitted in the Project Area. Table 2, below, lists the uses principally and conditionally permitted in the MH, C1, and C2 zoning districts. As shown, a portion of the uses currently allowed in the C1 and C2 zoning districts, as defined in Code Chapters 17.22 – Community Commercial (C1) Zone and 17.24 – Heavy Commercial (C2) Zone, respectively, would continue to be allowed, subject to the same or alternative permitting requirements in the MH zoning district. Use Groups listed in Table 2, below, are defined in Code Chapter 17.06 – Use Group Classifications.

Table 2. Principally Permitted and Conditionally Permitted Uses Allowed in Existing and Proposed Zoning Designations.

Use
Group Use Type Zoning District
C1 C2 MH
Group 2 – Residential
2(a) Single-family residence C* C* C*
2(b) Two family residences C -- --
2€ Group residential C -- --
2(f) Supportive housing C C* C*
2(g) Transitional housing C C* C*
2(i) Single room occupancy units C C --
Group 4 – Visitor Accommodation
4(a) Campgrounds -- C --
4(b) Tourist accommodations C P --
Group 6 – Business and professional offices P P --
Group 8 – Business support services P P --
Group 10 – General consumer services P P --
Group 12 – Retail trade
12(a) General retail trade P P --
12 Retail trade, except general retail trade C C --
Group 14 – Eating and drinking places
14(a) Eating places P P --
14(b) Drinking places C C --
14(c) Drive-in restaurants C C --
Group 16 – Adult entertainment C P --
Group 18 – Social services P P --
18(c) Child day care services -- -- P*/C*
Group 20 – Private institutions
20(a) Private educational or religious institutions P P -- 20(b) Cultural or social institutions P P --
20(c) Health care institutions C C --

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Use
Group Use Type Zoning District
C1 C2 MH
Group 22 – Sports and recreational facilities
22(a) Indoor sports and recreation facilities P P --
22(b) Outdoor sports or recreational facilities -- C C
Group —4 - Automotive
24(a) Light automotive repair C P P
24(b) Major auto repair -- C P
24(c) Auto sale and rental -- P P
24(d) Car washes -- P P
Group 26 – Vehicular storage
26(a) Impound storage -- -- P
26(b) Recreational vehicle storage -- -- P
26(c) Fleet storage -- -- P
26(d) General parking C -- P
Group 28 – Vehicle fuel sales
28(a) Retail gasoline sales C C --
28(b) Truck stops -- C P
Group 30 – Light equipment repair and sale P P --
Group 32 – Heavy equipment repair and sale
32(a) Heavy equipment repair -- C P
32(b) Heavy equipment sale -- P P
Group 34 – Wholesaling, Storage, and Distribution
34(a) Indoor wholesaling and storage -- C P
34(b) Outdoor wholesaling and storage -- -- P
34(c) Fuel jobbing -- -- C
34(d) Construction yards -- C P
Group 36 – Public Services
36(a) Minor Transportation -- -- P
36(b) Public Service Facilities -- -- P
36(c) Major Transportation -- -- P
Group 40 – Festival activities C C C
Group 42 – Agriculture
42(a) General agriculture -- -- P
42(b) Concentrated stock operations -- -- C
42(c) Heavy agriculture -- -- C
Group 46 – Interment services
46(a) Cremation P P --
46(b) Interment C C --
46(c) Undertaking P P --
Group 47 – Custom printing -- P --
Group 48 – Custom manufacturing C C P
Group 50 – Industrial
50(a) General industrial -- -- P
50(b) Intermediate industrial -- -- P
50(c) Heavy industrial -- -- C

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Use
Group Use Type Zoning District
C1 C2 MH
50(d) Very heavy industrial -- -- C
Group 54 – Extractive -- -- C
Group —6 - Scrap operations -- -- C
Group 57 – Medical and Adult Use Cannabis Activities and Industrial Hemp Activities 57(a) Indoor cannabis cultivation -- -- P
57(b) Cannabis and industrial hemp manufacturing -- -- P 57(c) Cannabis dispensary -- P P
57(d) Cannabis and industrial hemp laboratories and research P P P 57(e) Cannabis distribution -- P P
57(f) Cannabis packaging and processing -- -- P
57(g) Cannabis infusion -- -- P
Notes: P=Principally permitted; C=Conditionally permitted; *=as an accessory to a permitted use Source: Chapters 17.22, 17.24, & 17.28 of the City of Willits Municipal Code Principally permitted and conditionally permitted uses in the portion of the Site to be retained in the C-G land use and C1 zoning designation would remain unchanged.

Site Plan Review
Following approval of the proposed entitlements, the Project would be subject to the City’s Site Plan Review process described in Code Chapter 17.70 – Site Plan Review. This process would enable the Director of Community Development to confirm that the proposed development is in conformity with Title 17 – Zoning of the Code and the standards listed in Code Section 17.70.040 – Planning director findings and conditions, and apply conditions to the Project, as deemed necessary, to protect the public health, safety, and welfare.

This review may include project referral to City departments and outside agencies, as deemed necessary by the Director of Community Development. This same process would be required for conceptual industrial development as per Code Section 17.70.020 – Site plan review requirement, the Site Plan Review process is required before a building permit is issued for applications involving new construction, additions or structural alterations. Any conditions of approval, including mitigation measures identified in the CEQA Initial Study, would be applied through the Site Plan Review process.

Site Development
Development associated with the proposed Project would generally include vegetation removal; grading; and reuse or removal of existing structures. Vegetation removal and grading activities in the central portion of the Site would facilitate the construction of rocked log storage areas, internal access roads, and access points between the existing log yard and the Site, parking near the office, and two (2) water storage ponds.

The Site would be leveled and surfaced with compacted base rock, sufficient to withstand log storage and truck traffic. Gravel access roads would be maintained, upgraded, and/or constructed, as needed, to facilitate on-site circulation and to connect the existing log yard and the Site. This would require upgrades to existing drainage crossings and the construction of multiple new drainage crossings between the existing log yard and the Site. Additionally, up to two (2) irrigation ponds would be constructed for storage and fire suppression needs. Refer to Figure 5: Site Plan for approximate locations of the proposed ponds. At this preliminary stage, it is anticipated that the ponds will be designed to have storage capacities of approximately 1.0 acre-feet (ac-ft) and 0.85 ac-ft. However, details on the specific locations, capacities, and dimensions of the proposed ponds would be refined following project entitlements.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
An existing approximately 1,500-square-foot office structure, located in the southwestern portion of Quail Meadows, would be retained. This office structure was previously utilized as an office and has existing connections to electricity (PG&E), water (City), and wastewater disposal (City). This structure is proposed to be utilized as an office to support the log yard operation. Dilapidated tennis courts, located in the southeastern portion of the Site, landscaping, and other minor improvements associated with the RV park that previously occupied Quail Meadows would be removed. An approximately 6,900-square-foot existing storage unit building located in the eastern portion of the Site may additionally be removed.

The Site is currently accessed from N Main Street via a paved driveway at the southwest corner of Quail Meadows. The Applicant proposes to utilize both the Quail Meadows entrance and the Casteel Lane entrance at the existing log yard for accessing the Site. An additional unimproved driveway is located at the northwest corner of the Site. This driveway is located within the 2.2-acre portion of the Site proposed to be maintained in the C1 zoning designation, is intended for light administrative use only and not for industrial truck or equipment traffic. The Applicant seeks to extend this driveway southeast to connect to internal access roads as shown on Figure 5: Site Plan. The northwest driveway also serves a northern access road that is utilized by Caltrans to access off-site properties to the east. No changes are proposed to Caltrans’ ongoing maintenance activities to the northern access road.

See Figure 5: Site Plan for details on the conceptual proposed site development. Site development would require removal of 116 mature [greater than or equal to 12 inches in diameter at breast height (DBH)] trees as provided in Table 3, below. As shown on the Tree Survey map (Appendix A), the trees along the eastern edge of the Site are proposed to be retained. Pursuant to a Tree Survey completed by Victor Hollister, Registered Professional Forester (RPF) No. 3180, in April 2023 (see Appendix A), tree species anticipated to be removed include American sycamore (Platinus occidentalis), apple (Malus domesticate), Austrian pine (Pinus nigra), bigtooth aspen (Populus tremula), black poplar (Populus nigra), black willow (Salix nigra), California black oak (Quercus kelloggii), Chinese juniper (Juniperus chinensis), Lombardy poplar (Populus nigra), non-native maple (Acer spp.), olive (Olea europaea), Oregon ash (Fraxinus latifolia), Oregon white oak (Quercus garryana), ponderosa pine (Pinus ponderosa), sweet gum (Liquidambar styracifula), valley oak (Quercus lobata), and walnut (Juglans spp.).

Table 3. Inventory of Mature Trees to be Removed.

Tree Type Mature Tree Size Ranges (DBH)
>12 to <18 inches >18 inches TOTAL
California black oak 1 1 2
Valley oak 1 1
Oregon white oak 4 4
Bigtooth aspen 7 10 17
Austrian pine 1 1 2
Non-native maple 15 5 20
Chinese juniper 1 1
Ponderosa pine 1 1 2
Walnut 1 1
Oregon ash 1 1
American sycamore 5 1 6
Black willow 14 1 15
Black poplar 16 28 44
TOTAL 66 50 116

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
During construction, Best Management Practices (BMPs) would be implemented in accordance with a Stormwater Pollution Prevention Plan (SWPPP) to be prepared for the project pursuant to the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (CGP), administered through the State Water Resources Control Board (SWRCB). Compliance with the CGP and a project-specific SWPPP would help to prevent the discharge of construction waste, debris, and contaminants from construction materials, tools, and equipment from leaving the Site.

Conceptual Industrial Development
Although the Applicant proposes to utilize the Site for an expanded log yard, the analysis contained in this IS includes an evaluation of environmental impacts as they relate to a future typical industrial development that would be principally permitted under the MH zoning district. To determine the extent of potential environmental impacts, it is assumed that a future project would entail a General Industrial or Intermediate Industrial use. As defined in Code Section 17.06.020 – Listing of use groups, a General Industrial (Use Group 50a) includes “Industrial plants and facilities used primarily for the manufacturing compounding, processing, assembling, packaging, treatment or fabrication of goods, materials and products” and an Intermediate Industrial use (Use Group 50b) includes “Any production, processing, cleaning, service, testing, repair, or storage of materials other than those listed under [General Industrial].” It is further assumed that other principally permitted uses in the MH zoning district would result in similar or lessened impacts as the conceptualized General Industrial or Intermediate Industrial use and, therefore, environmental impacts would be adequately captured by this analysis. As mentioned above, should industrial development, aside from the proposed log yard, be proposed in the future, upon receipt of an application for the proposed use, the City would make a determination if additional CEQA analysis is warranted.

According to Code Section 17.28.040 – MH Lot regulations, as the southwest corner of the Site is adjacent to a property within the Single-Family Residence (R1) zoning district (see Figure 3), a 20-foot setback from the residential zone would be required for future development. However, no residential districts are adjacent to the remainder of the Site and pursuant to the Land Use Density and Building Intensity Standards provided in the Willits General Plan 2020 (1992) Volume II – Technical Appendices (page II-33), no lot regulations would apply to the remainder of the Site. Additionally, the Code does not include applicable lot regulations for either the C1 or C2 zoning designations (pursuant to Code Section 17.22.040 – C1 Lot regulations and

17.24.040 – C2 Lot regulations), aside from minimum lot area, lot width, and yards, none of which are a concern at the Site. Building height in the C1, C2, and MH zoning designations would be limited to 45 feet.

Besides the 20-foot setback required from the R1 zoning district at the southwest corner of the Site, as the Code does not contain lot regulations that would place limitations on development in the C1, C2, or MH zoning designations, for the purposes of this analysis, it is assumed that the proposed GPA and Rezone would not affect the area of a potential future development.

Development of the Site for a typical industrial facility would generally include vegetation removal; grading for access roads, building pads, and parking areas; landscaping; installation of water storage facilities such as water tanks and/or ponds to serve as back-up water supplies and for fire suppression needs; reuse and/or removal of existing structures; infrastructure improvements related to water supply, wastewater, solid waste, and storm drainage; regular maintenance activities; and in many cases, construction of new structures.

Building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the California Fire Code (CFC) in place at the time of building permit application submittal. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed.

Improvements associated with a typical industrial facility would be reviewed by applicable City departments and outside agencies as warranted upon submittal of a formal application. For purposes of this analysis, it is assumed that a future industrial development application would conform with applicable Code requirements and regulations established for the MH zoning district.

Due to the size of the Site and the nature of industrial uses, it can be assumed that construction activities would cause disturbance to greater than 1 acre of land and would therefore be subject to the CGP, administered through the SWRCB. Compliance with the CGP would ensure that BMPs would be implemented in accordance with a project-specific SWPPP. The SWPPP would help to prevent the discharge of construction waste, debris, and contaminants from construction materials, tools, and equipment from leaving the Site.

Operations Plan
Operation of a typical industrial facility would be subject to Code Chapter 17.50 – Performance Standards.

Pursuant to Code Section 17.50.040 – Locations where determinations are made for enforcement of performance standards (1982), compliance with performance standards would generally be enforced within 500 feet of the Project Area. A general industrial would be anticipated to operate between 7:00am and 7:00pm up to six (6) days per week; however, specific hours of operation would be dependent on the use proposed and would be subject to approval by the City. Typical operational activities would be anticipated to include employee trips to the typical industrial facility, operation of heavy equipment within and outside of structures, heavy truck traffic to/from the facility for materials transfers, and use of machinery within structures.

Daily operations of the Project would be consistent with the existing operations of the existing log yard and would include: the storage and sale of non-retail logs; log and lumber trucks transporting logs to and from the Site; log clean-up (including periodic chainsaw work to logs to cut into shorter lengths, flush knots (limb ends) and clean up and flush the ends of the logs to remove any unevenness, splinters, or other log defects); loading of bark and other byproducts using heavy equipment; lumber trailer staging; and site maintenance, including minor grading, resurfacing, and watering using heavy equipment. Log truck loading and unloading would be completed using two (2) Caterpillar 966 front end loaders, or equivalent; two (2) Caterpillar 568 Heel Boom Log Loader, or equivalent; and one (1) water truck. The proposed expanded log yard operation would be managed by the existing four (4) full-time staff, one (1) new full-time Log Procurement Manager, and one (1) seasonal employee generally from April 1 to November 30 (summer period). Operations would be managed in compliance with the City performance standard regulations provided in Section 17.50.050 of the Code – Performance of standard regulations (1982).

Existing and proposed dust control practices consist of watering the operating surfaces of the log yard at regular intervals during dry weather periods. Maintaining sufficient moisture content on ground surfaces effectively minimizes the quantity of airborne particulates created by heavy equipment and truck traffic.

Operation of the Project shall comply with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment, and Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), which suppresses fugitive dust during construction and operation. This would limit the generation of fugitive dust at the Site, including the driveways, access roads, and the rest of the Site. To

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
further limit the potential for dust generation during operation, the Applicant intends to prepare a Dust Control Plan for approval by the City.

The Project is not anticipated to significantly increase the truck trips to and from the log yard operations. The purpose of the Project is to increase operational efficiencies for the Applicant’s operations. As observed at the existing log yard, the majority of log deliveries occur during the summer period, five (5) to six (6) days per week, generally between the hours of 6:00am and 5:00pm, with occasional peak delivery times from 5:30am to 7:00pm. At times during the summer and fall months, the operators work until 5:30 or 6:00pm to clean up the yard after the trucks have stopped coming in. During this period, logs are delivered to the Site on approximately 50 to 60 incoming log trucks per day, up to a maximum of 65 to 70 incoming trucks per day, on rare occasions. During this summer period, logs are transported from the Site on approximately 15 to 20 outbound lumber trucks per day, up to approximately 25 outbound lumber trucks per day, on rare occasions.

Hours of operation between December 1 and March 30 (winter period) are generally from 7:00am to 4:00pm, up to five (5) days per week, with occasional needs to operate between 6:00am and 5:00pm to accommodate lumber truck scheduling for backhauls and log deliveries during mild weather windows in spring. Incoming log deliveries during the winter period are minimal, up to approximately 15 incoming log trucks per day, in isolated circumstances. Log deliveries during the winter period are dependent on weather at the source of logs and harvest permit and wet season logging restrictions. During this winter period, logs are transported from the Site on approximately 25 to 30 outbound lumber trucks per day. Additionally, bark hauling occurs intermittently throughout the year at rates of two (2) to five (5) loads per week. Trips associated with bark hauling are limited to normal operating hours described above. Bark loads are not significant enough to increase the daily truck averages over the incoming and outgoing load forecasts described.

These forecasted truck trips and operating hours are consistent with the existing operation. With implementation of the proposed project, it is anticipated that truck trips per day to and from the expanded log yard would average towards the upper end of the ranges provided with more consistency. The existing log yard experiences truck trips within these ranges with less consistency. The majority of log trucks would access the Site from the north, via the Highway 101 offramp directly north of the Site; however, log trucks traveling from the coast via Highway 20, would access the Site from the south, via N Main Street.

Current operations produce varying amounts of bark that falls off logs during handling. This bark is cleaned up at the end of shift every day and placed into a pile located at the southeast end of the existing log yard.

Bark accumulations generated vary throughout the year but generally do not exceed over one chip van load per day (or approximately 15 cubic yards per day) on average. The Applicant intends to prepare a Bark Management Plan as part of the Emergency Action Plan (EAP) described below. The Bark Management Plan would include details such as strategies to reduce the risk of bark piles catching on fire, and would be subject to approval by the Little Lake Fire District. The bark pile in the existing log yard is planned to remain in same location in southeast corner due to its higher elevation and distance away from the stormwater drainage system, distance from sensitive receptors including residences and the public school, its separation from regular log handling activities, and its preferred location for loading. Bark piles in the proposed log yard are planned to be located near the southeast corner of Quail Meadows. This location appears ideal being located at a higher elevation away from stormwater drainage, distance from wetland areas, distance from sensitive receptors, separation from regular log handling, and preferred location for loading bark trucks. Bark piles in the existing and new log yards would range in size but would generally be between 30 feet in length and width and 10 to 15 feet high. It is standard practice in the existing log yard operation and planned future operations to not build large inventories of accumulated bark, and rather maintain a steady and even truck flow of two (2) to five (5) loads per week to maintain low inventories.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
The Applicant intends to prepare an EAP, to the satisfaction of the Little Lake Fire District, prior to operation of the expanded log yard. The EAP would describe plans and preparedness for emergency response and as noted above, would include a Bark Management Plan. The EAP would include a list of emergency contacts, access requirements, evacuation routes and procedures, employee training procedures, deck orientation maps, adequate water supply, and on-site firefighting equipment. Firefighting equipment to keep on-site for use in emergencies would include but not be limited to a water truck, fire extinguishers, fire tools, and a portable foaming fire suppression system. The EAP would also include fire prevention and mitigation strategies, including identification of potential fire hazards, general housekeeping, and required training.

Implementation of the EAP would provide employees with the ability to put out a 10-foot by 10-foot, or equivalent, spot fire should the need arise.

It should be noted that the existing log yard contains a mobile self-contained 1,000-gallon fuel tank, located near the main gate to the log yard. If needed on the Site in the future, it may be placed in the southwestern corner of the Site, near the Quail Meadows entrance; however, for the foreseeable future it is anticipated that the fuel tank would stay in its current location on the existing log yard. For reference, the possible location on the Site is shown on Figure 5: Site Plan. All other chemical storage is located within the two (2), 450-squarefoot shipping containers in the southwest portion of the existing log yard. The approximate location of these shipping containers is shown on Figure 5: Site Plan.

Access, Circulation, and Parking
The Site is currently accessed from N Main Street via a paved driveway at the southwest corner of Quail Meadows. The existing log yard is accessed via Casteel Lane. The Applicant proposes to utilize both the Quail Meadows entrance and the Casteel Lane entrance at the existing log yard for accessing the Site. An additional unimproved driveway is located at the northwest corner of the Site. This driveway is intended for light administrative use only and not for industrial truck or equipment traffic. The Applicant seeks to extend this driveway southeast to connect to internal access roads as shown on Figure 5: Site Plan. The northwest driveway also serves a northern access road that is utilized by Caltrans to access off-site properties to the east. No changes are proposed to Caltrans’ ongoing maintenance activities to the northern access road.

As noted above, the central portion of the Site contains various internal gravel access roads utilized for the previous development. These gravel access roads would be maintained, upgraded, and/or constructed, where needed, to facilitate on-site circulation and to connect the existing log yard and the Site. The approximate locations of these roads are shown on Figure 5: Site Plan. With the connection between the existing log and the Site, queuing log and lumber trucks would have sufficient space to queue on-site, off of publicly maintained roadways.

One (1) ADA parking space is currently under construction directly adjacent to the office on Quail Meadows.

Additional graded and rocked parking areas are intended to be established adjacent to the southern property line of the Site, next to the office structure.

Utilities
Water
In a typical industrial facility, water sources and storage would be required for daily operation and in emergency situations. The water usage proposed under typical industrial facilities principally permitted within the MH zoning district that may be proposed in the future is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage.

Details on the specific locations, capacities, and dimensions of the ponds and/or other water storage facilities would be subject to grading and/or building permits through the City. Significant changes to existing water usage proposed for a future industrial facility would be reviewed by the City in conjunction with a

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
planning or building permit application review. Significant changes to existing water usage proposed for a future industrial facility would be reviewed by the City in conjunction with a planning or building permit application review or through the Site Plan Review process described above.

Existing water sources include three (3) wells and four (4) 10,000-gallon water tanks within the Project Area and an additional well and water tank at the existing log yard that the Applicant proposes to integrate into the water supply system that would serve the Project. The Applicant intends to install up to three (3) additional wells and construct up to two (2) irrigation ponds within the Project Area to store water for use in the log-yard fire hydrant system, when needed. The irrigation ponds are currently designed for volumes of 1.0 ac-ft and

0.85 ac-ft. Additionally, the existing office is connected to the City water system via a 2-inch connection. This connection would remain consistent with its current use for the office. The existing log yard has a 2-inch connection to the City water system, and it is assumed that this connection may be utilized for short-term irrigation in the event of a water system emergency such as well problems and/or mechanical failures. The Site is also served by a fire suppression connection that is overseen by the Little Lake Fire District and would only be utilized in the event of a fire-related emergency.

Under the Project, the Applicant proposes a recirculating log irrigation system for wetting the log decks. The proposed system would generally consist of up to two (2) holding ponds and series of return ditches to collect and transport the water back to the ponds. A pump station at the end of the ponds would charge an approximately 12-inch PVC manifold that would run to the ends of the log decks. From there a 2-inch poly line would be run across the top of the decks from one end to the other and a series of rainbird sprinkler heads would be installed at intervals needed for sufficient coverage. The increased water output from the rainbird sprinklers would cause ground saturation and overland flow, which would be captured by a series of drainage ditches to direct flow back to the ponds. To combat evaporation, the wells would be plumbed to the ponds to supply make-up water, as needed, to keep the ponds full and pumps primed. It is anticipated that this would require an average of up to 80,000 gallons per day (gpd), peak usage (accounting for evaporation and dust abatement uses), from July through October. During the months of May, June, and November, the estimated water usage would be approximately 40,000 gpd and little to no water would be anticipated to be required for the remainder of the year (December through April, which generally coincides with the rainy season). This would equate to approximately 41.5 ac-ft per year, as shown in Table 4, below.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Table 4. Estimated* Average Water Usage by Month.

Month Gallons per day (gpd) Gallons per month Acre-feet per month January 0 0 0
February 0 0 0
March 0 0 0
April 0 0 0
May 40,000 1.24 million 3.81
June 40,000 1.20 million 3.68
July 80,000 2.48 million 7.61
August 80,000 2.48 million 7.61
September 80,000 2.40 million 7.37
October 80,000 2.48 million 7.61
November 40,000 1.24 million 3.81
December 0 0 0
AVERAGE 36,670 1.13 million 3.46
TOTAL (per year) 13.5 million gallons 41.5 ac-ft
Note: *The estimated water usage is based on average water use at the existing log yard and other facilities operated by the Applicant.

The Applicant anticipates that the four (4) existing wells plus the up to three (3) proposed wells would be sufficient for meeting the needs of the current and expanded log yards, with the proposed ponds available for irrigation water storage and fire suppression needs. However, as noted above, the existing connection to the City water system would be maintained and/or upgraded, as needed, to serve as a back-up supply for irrigation needs when necessary in the event of emergency well problems and/or mechanical failures during the dry months when water is needed on the log decks. A separate connection exists to serve fire suppression needs in the event of a fire emergency. The Applicant intends to have a self-sustaining water system through the use of on-site wells and wintertime collection and storage in the proposed ponds for use during the following summer. It is not anticipated that City water would be needed as an emergency backup water supply during the months of January through April and December when the need for log deck wetting is limited, and the ponds would most likely contain water. For the months of May through November, up to approximately 90,000 gpd (peak usage) may be necessary as an emergency backup water supply. This estimate is based on the recorded highest usage of City water during a water system emergency at the existing log yard. A 10-day period of water use in the event of a water system emergency is anticipated to be more than adequate to complete water system repairs or to allow for other unforeseen circumstances that would require the use of City water as a backup supply. Over a 10-day period, approximately 2.76 acft (900,000 gallons) would be anticipated to be necessary. This estimate would allow for 10 days of makeup water to combat evaporation and four (4) water truck loads per day for dust abatement.

Four (4) City fire hydrants are located within the vicinity of the Site, with the closest hydrant located approximately 200 feet southwest of the existing office structure. The Applicant intends to install up to three (3) additional fire hydrants within the Project Area such that fire hydrants are available throughout the Project Area and that for the purposes of the Project, no log deck would be greater than 600 feet from a fire hydrant.

In order to meet fire flow requirements of the Little Lake Fire District provided in a letter dated March 17, 2023 (see Appendix K), the Applicant proposes to install three (3) standard municipal Clow Valve Medallion Hydrants with a minimum flow capacity of 4,500 gpm at 20 pounds per square inch (psi). Once the system has been installed, a 6-hour flow test would be performed to demonstrate the hydrant flow rate at the

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
required pressure. Additionally, a 100-kilowatt (kW) Cat Diesel generator is proposed to provide uninterrupted power to the fire pump in the event of a power outage.

Electricity and Natural Gas
Electricity and natural gas connections currently exist on-site. The Applicant anticipates upgrading the existing power supply to meet operational needs of the Project. Potential typical industrial facility operators would coordinate with PG&E at the time a project is proposed if additional electricity or natural gas connections or supplies are needed.

Telecommunications
Telecommunications services would be obtained by the Applicant and typical industrial facility operators if services are needed.

Stormwater
While the City does not operate a municipal separate storm sewer system (MS4) that would otherwise be subject to the Municipal Storm Water Program administered by the SWRCB, including typical requirements for Low Impact Development (LID) feature in site design, compliance with the CGP would help to ensure post-construction stormwater flows are properly managed in accordance with the Clean Water Act.

Furthermore, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the Statewide General Permit for Stormwater Discharges Associated with Industrial Activities, Order 2014-0057-DWQ (IGP), administered by the SWRCB.

Post-construction stormwater would continue to infiltrate as the Project does not propose the introduction of impervious surfaces. However, stormwater would be collected in the two (2) ponds proposed at the Site for use as an emergency water supply and for irrigation needs.

Solid Waste
Waste generated by the Project or other typical industrial facilities would be hauled off-site to a licensed disposal facility or collected by the local waste hauling company, if needed.

Fire Protection
It is anticipated that the Site would contain 12 log decks: nine (9) on Quail Meadows and three (3) on APN:
108-040-18. These decks would be approximately 250 to 300 feet in length with a proposed height of 30 feet.

As required by the Fire Marshal of the Little Lake Fire District, pursuant to the 2019 CFC, log decks at the existing log yard are a maximum of 300 feet by 500 feet (150,000 square feet), and the maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshal and incorporation of sprinkled log decks. Additionally, the required 100-foot separation from other log decks and exposures is able to be expanded by using measures such as sprinkled log decks and other exceptions. The existing log yard currently contains a 100-foot driveway between the two large continuous decking areas and a 100-foot gap between the log decks and the property line shared with the houses to the west. The proposed Project would operate in accordance with the CFC and other applicable standards, including the log deck size and setback requirements described above. Additionally, as required by the Fire Marshal, all log decks shall maintain minimum 20-foot-wide vehicle access on at least three (3) sides of each log deck, and on-site hydrants and ponds shall remain accessible by vehicle to ensure Type 1 fire engines have unobstructed access to the Site.

Furthermore, the Applicant would maintain a minimum water supply of 1,500 gpm for a 6-hour duration as required by Little Lake Fire District in a letter dated March 17, 2023 (see Appendix K). The pump system is

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
designed to have the capacity to pump 4,500 gpm to on-site hydrants with a power supply backup for the electric pumps.

Lighting
Details on the location and proposed fixtures for future outdoor lighting of a typical industrial facility would be speculative at this time. However, it is assumed that exterior lighting would be required to illuminate exterior operational areas during working hours and for security purposes. While the location, number and design of the lighting fixtures would be determined in conjunction with building permit application(s) for potential future industrial uses, the lighting would comply with City standards, including the Site Plan Review requirements found in Code Chapter 17.70 – Site Plan Review, which requires that lighting be arranged so that light is deflected away from adjoining properties.

Outdoor lights for the proposed expanded log yard operation would be limited to downcast security lights located on or within 150 feet of the office and the Quail Meadows entrance. No additional lighting is planned or proposed at this time.

Noise
Noise generating-uses would be subject to the Noise Policies and Implementation Measures found in Volume I of the Willits General Plan 2020 (1992) and Code Chapter 17.50 – Performance Standards, which provides performance standard regulations that specify noise limits, distances for measurement of noise and vibration levels, and parameters for understanding the type, location, and character of noise and vibration sources.

The City would evaluate future typical industrial uses for conformance with existing policies and regulations.

The operation of the Project would generate noise in the form of log and lumber trucks transporting logs to and from the Site, log remanufacturing, and site maintenance. As the proposed Project is an extension of the existing log yard, noise levels are anticipated to be consistent with the existing log yard.

III. PROJECT SETTING AND LOCATION
The approximately 21.25-acre Site is comprised of two (2) vacant parcels identified by Quail Meadows and APN: 108-040-18 located at the northern end of the Willits city limits. Surrounding uses include the GlenMark Self Storage adjacent to the west of the Site, the existing log yard adjacent to the south, railroad tracks within the Great Redwood Trail Agency (GRTA) right-of-way adjacent to the east, the Highway 101 bypass to the northeast, and residential structures on parcels with land use designations of R-L and M-G and zoning designations of R1 and ML to the southwest. Nearby uses include N Main Street (previously Highway 101) and commercial uses to the west, Willits High School to the south, industrial uses to the east, and undeveloped agricultural land to the northeast. The existing storage unit facility located adjacent to the west of the Site is currently the northernmost development within the Willits city limits. Views of the Site are obscured from N Main Street to the west due to dense vegetation and existing development, including the storage unit facility, from the railroad located within the GRTA right-of-way to the east due to thick vegetation along the property boundary, and from Highway 101 to the northeast due to thick vegetation and the distance from the highway. Refer to the Photo Log (Appendix B) for photos of existing site conditions from various directions.

A Biological Resources Assessment (BRA) was prepared by Clifton Environmental July 2022 to identify specialstatus plant and wildlife species and sensitive habitats (including wetlands) that have the potential to occur on or in the vicinity of the study area to determine if the proposed project could potentially affect these resources. Refer to the BRA (Appendix C). For the purposes of the BRA, the BRA Area (BRAA) was defined as the Site; however, it should be noted that the BRAA was mapped as approximately 21.84 acres, while Figure

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
5: Site Plan approximates the size of the Site as 21.25 acres. For the purposes of this IS, it is assumed that the BRAA is an overestimation of the Site size.

As provided in the BRA, Quail Meadows is a nearly level former agricultural field that was previously developed with an RV park. Based on review of aerial imagery, it appears the RV park ceased operation between 2011 and 2013. Quail Meadows contains three (3) primary structures: an approximately 1,500- square-foot office structure; an approximately 6,900-square-foot storage structure; and dilapidated tennis courts. The office structure was previously utilized as a manager’s residence and RV park supporting facilities (bathrooms) when the RV park was operational. The office structure has existing connections to electricity (PG&E), water (City), and wastewater disposal (City). The overgrown RV parking stalls are surrounded by landscaping and other minor improvements associated with the previous RV park, such as graded access roads, light poles, and electric utility boxes. A windrow of cottonwood is located along the eastern edge of the parcel, adjacent to the tennis courts. Quail Meadows gently drains from the southwest to the northeast, is bounded on three (3) sides by constructed drainage ditches (identified as Ditches 1, 2, and 4 in the BRA) and is bisected by a fourth ditch (identified as Ditch 3 in the BRA). The drainage ditches contain riparian forest, scrub, and herbaceous species. Upland areas are forested, primarily with landscaped trees, or are grassland. APN: 108-040-18 is largely undeveloped aside from gravel access roads along the northern and western edges. The north/northwest portion of this parcel contains fill from previous development. The remainder of this parcel contains areas of meadow, wet meadow to the north and pockets of wet meadow in the south, riparian woodland and oak woodland to the east, and Ditches 5 and 6, as identified in the BRA.

The ephemeral and intermittent ditches throughout the Site drain into an unnamed tributary to Mill Creek, east of the Site, which is mapped as a Water of the U.S. The unnamed tributary to Mill Creek flows under the Highway 101 bypass into Mill Creek approximately 0.3 miles north of the Site.

The BRA identifies the biological communities at the Site as meadow, wet meadow/seasonal wetland, oak woodland, riparian woodland, and ditch/water. See Table 5, below for the approximate acreages of each biological community.

Table 5. Biological Communities at the Site.

Mapped Community Type Acres
Meadow 6.78
Wetland 0.97
Oak Woodland 1.26
Riparian Woodland 1.96
Ditch/Water 0.39
Landscaped Woodland 3.51
Disturbed/Fill Scrub 4.51
Paved/Disturbed/Barren 2.46
Total 21.84
Source: BRA by Clifton Environmental, July 2022
The most prominent biological community at the Site is meadow, at approximately 7.7 acres. The meadow biological community is in the center and western edge of APN: 108-040-18 in the southeast corner of Quail Meadows. The wet meadow biological community is generally concentrated at the northern end of APN:
108-040-18. A small population of sensitive community blue wildrye prairie habitat is mapped in the meadow.

Approximately 3.5 acres of landscaped woodland occupies the southern half of Quail Meadows. The valley oak woodland is primarily located in the northeast portion of APN 108-040-18 and valley oak riparian

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
woodland is located along Ditches 2 and 6. As noted above, other communities include landscaped woodland, disturbed fill/scrub, and paved/disturbed/barren.

Three special-status plants - Baker’s meadow foam (Limnanthes bakeri, State Rare/CNPS 1B.1), Davy’s semaphore grass (Plueropogon californicus var. davyi, CNPS 4.3) and North Coast semaphore grass (Plueropogon hooverianus, State Threatened/CNPS 1B.1) were identified within the emergent wetland habitat at the northern end of the Site between the northern access road and Ditch 5, and several special status plant communities (described in Section 4.0 of the BRA) were identified in the northern portion of the Site.

Victor Hollister, Registered Professional Forester (RPF No. 3180) surveyed 367 trees 5 inches in diameter at breast height (DBH) or greater at the Site. Tree species observed include American sycamore (Platinus occidentalis), apple (Malus domesticate), Austrian pine (Pinus nigra), bigtooth aspen (Populus tremula), black poplar (Populus nigra), black willow (Salix nigra), California black oak (Quercus kelloggii), Chinese juniper (Juniperus chinensis), Lombardy poplar (Populus nigra), London plane tree (Plananus hispanica), nonnative maple (Acer spp.), olive (Olea europaea), Oregon ash (Fraxinus latifolia), Oregon white oak (Quercus garryana), ornamental cypress (Cupressus spp.), ponderosa pine (Pinus ponderosa), sweet gum (Liquidambar styracifula), valley oak (Quercus lobata), and walnut (Juglans spp.). Of the 367 trees surveyed, 206 were found to be mature trees (considered to be 12 inches or greater DBH), as provided in Table 6, below.

Table 6. Inventory of Mature Trees Observed On-Site.

Tree Type Mature Tree Size Ranges (DBH)
>12 to <18 inches >18 inches TOTAL
California black oak 1 1 2
Valley oak 0 1 1
Oregon white oak 31 26 57
Bigtooth aspen 7 10 17
Austrian pine 1 1 2
Non-native maple 18 8 26
Chinese juniper 1 0 1
London Plane Tree 0 1 1
Ponderosa pine 1 1 2
Walnut 1 0 1
Oregon ash 0 1 1
Ornamental Cypress 6 24 30
American sycamore 5 1 6
Black willow 14 1 15
Black poplar 16 28 44
TOTAL 102 104 206
Source: Tree Survey by North Fork Lumber Company, April 2023 (RPF No. 3180).

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

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
V. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this Project, involving at least one impact that is a “Potentially Significant Impact“” or "Potentially Significant Unless Mitigation Incorporated" as indicated by the checklists on the following pages.

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

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

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
DETERMINATION: (To be completed by the Lead Agency on the basis of this initial evaluation) I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Dusty Duley, Community Development Director
Name and Title

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
I. AESTHETICS. Would the project:

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

DISCUSSION
The Site has a land use designation of C-G, and Quail Meadows and APN: 108-040-18 have zoning designations of C2 and C1, respectively. The proposed Project involves a GPA and Rezone to change the land use and zoning designations of the Project Area to M-G and MH, respectively (see Figures 3 and 4).

Quail Meadows is a nearly level former agricultural field that was previously developed with an RV park.

Quail Meadows contains three (3) primary structures: a 1,500-square-foot office structure; an approximately 6,900-square-foot storage structure; and dilapidated tennis courts. The overgrown RV parking stalls are surrounded by landscaping and other minor improvements associated with the previous RV park.

Surrounding uses include the GlenMark Self Storage adjacent to the west of the Site, the existing log yard adjacent to the south, railroad tracks within the Great Redwood Trail Agency (GRTA) right-of-way adjacent to the east, the Highway 101 bypass to the northeast, and residential structures on parcels with a land use designation of M-G and zoning designation of ML to the southwest. Nearby uses include N Main Street (previously Highway 101) and commercial uses to the west, Willits High School to the south, industrial uses to the east, and undeveloped agricultural land to the northeast. The Site is visible from N Main Street, located west of the Site, when looking down the Quail Meadows entrance; however, views of the Site are generally obscured from N Main Street to the west due to dense vegetation and existing development, including the storage unit facility. Views of the Site are obscured from Highway 101 to the northeast due to thick vegetation and the distance from the highway. Although the existing storage structure at the Site is visible from the railroad located within the GRTA right-of-way to the east, views are generally obscured due to thick vegetation along the property boundary. Photos of the views of the Site from the railroad located within the GRTA right-of-way are shown in Appendix B.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
as water tanks and/or ponds to serve as back-up water supplies and for fire suppression needs; reuse and/or removal of existing structures; infrastructure improvements related to water supply, wastewater, solid waste, and storm drainage; regular maintenance activities; and in many cases, construction of new structures.

Neither the Site nor the surrounding properties possess significant scenic aspects that might be impacted by the proposed use of the Site. According to the Resource Management Element of the County of Mendocino General Plan (2020), there are no officially designated State Scenic Highways in Mendocino County, although there are two designated State Scenic Byways through forests, which include the North Central Coast Heritage Corridor on State Route 1 and the Tahoe-Pacific Heritage Corridor encompassing sections of State Route 20 and Highway 101. While not officially designated as State Scenic Highways, Highway 20 through Mendocino County is eligible for designation and Highway 128, which passes through Yolo, Napa, Sonoma, and Mendocino Counties and is 140 miles long, was recently made eligible for designation under Assembly Bill (AB) 998 signed by Governor Gavin Newsom in July 2019. However, Highways 20 and 128 are not in the vicinity of the Site.

I.a-b) Neither the Project nor other typical industrial facilities would have a significant effect on the aesthetics of the surrounding area or scenic vistas. While the Site is located along Highway 101, according to the California Department of Transportation (Caltrans) State Scenic Highway Program (2023), this portion of the highway is not designated as a scenic highway nor eligible for such status. Since the Site is not a designated scenic vista and is not located in the vicinity of a designated scenic vista or state scenic highway, neither Project nor other typical industrial facilities would impact a scenic vista or damage scenic resources or views along a state scenic highway. No impact would occur.

I.c) Construction of the proposed Project or other typical industrial facilities may temporarily alter the visual character of the Site with equipment, construction materials, and workers. However, the changes to these views during construction would be minor, temporary, and would generally only be visible to the public in the immediate vicinity of the active portion of construction.

Although the Project and other typical industrial facilities would slightly modify the existing visual character of the Site and its surroundings, they would not substantially degrade the existing visual characteristics or quality of public views of the Site and its surroundings or conflict with other regulations governing scenic quality. There are no designated scenic vistas in the vicinity of the Site nor any significant viewsheds. As discussed above, public views of the Site are limited. The Site is visible from N Main Street, located west of the Site, when looking down the Quail Meadows entrance; however, views of the Site are generally obscured from N Main Street to the west due to dense vegetation and existing development, including the storage unit facility. Views of the Site are obscured from Highway 101 to the northeast due to thick vegetation and the distance from the highway. The existing storage structure at the Site is visible from the railroad located within the GRTA right-of-way to the east; however, views are generally obscured due to thick vegetation along the property boundary. Although the Site may be partially visible when looking down the Quail Meadows entrance and from portions of the railroad, the visual character of the Site would not be substantially degraded, as the existing log yard adjacent to the south is an industrial use. Therefore, the Project and other typical industrial facilities would be consistent with surrounding uses, and views would be of a similar nature. A less than significant impact would occur.

I.d) The Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. New lighting is proposed in the form of outdoor security lights located on or within 150 feet of the office and the Quail Meadows entrance. All outdoor lighting would be limited to downcast security lights. Additionally, no aspects of the Project involve materials that would produce glare.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Access to the Site would be limited to typical business hours for operations of a similar nature, 7:00 a.m. to 7:00 p.m. Monday through Saturday, unless alternative hours of operation are approved by the City. The Project would be anticipated to operate between 6:00am and 5:00pm, with occasional peak deliveries as early as 5:30 a.m. and as late as 7:00pm. Therefore, the Project would have a less than significant impact on day or nighttime views due to light and glare.

Other typical industrial facilities would also not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Should additional industrial facilities be introduced to the Site, the location, number, and design of associated lighting fixtures would be determined in conjunction with building permit application(s) and would be required to comply with City standards, including the Site Plan Review requirements found in Code Chapter 17.70 – Site Plan Review, which requires that lighting is arranged so that light is deflected away from adjoining properties. Therefore, other typical industrial facilities would have a less than significant impact on day or nighttime views due to light and glare.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less than Significant Impact on Aesthetics.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
II. AGRICULTURE AND FORESTRY RESOURCES. Would
the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g), timberland (as defined by PRC
section 4526), or timberland zoned Timberland
Production (as defined by Government Code section
51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use?
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forestland to non-forest use?

DISCUSSION
The Site is neither designated nor zoned for agricultural use or forest land. The Site has a land use designation of C-G, and Quail Meadows and APN: 108-040-18 have zoning designations of C2 and C1, respectively. The proposed Project involves a GPA and Rezone to change the existing land use and zoning designations of the Site to M-G and MH, respectively (see Figures 3 and 4). Additionally, the Applicant requests a BLA to retain an approximately 2.2-acre portion of APN: 108-040-18 as C-G and C1 land use and zoning designations, respectively. No land use or zoning changes are proposed to this portion of APN: 108-040-18.

The United States Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) has defined Important Farmlands based upon several factors, including the physical and chemical characteristics of the land and the suitability of the land for producing crops. Important Farmlands are afforded special protection due to their importance to agricultural production.

California Department of Conservation’s Farmland Mapping and Monitoring Program (FMMP) shows that the Site is characterized as ‘Grazing Land’ and ‘Urban and Built-up Land’ and therefore does not categorize the Site as having any type of Important Farmland [DOC, 2016 (a)].

II.a) The Site would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the FMMP, to non-agricultural uses. As noted above, the Site is designated as “Urban and Built-Up Land” [DOC, 2016 (a)] and is not currently designated or zoned for agricultural use under the City of Willits General Plan (1992) or City Code. No impact would occur.

II.b) As previously discussed, Quail Meadows has a zoning designation of C2, and APN 108-040-18 has a zoning designation of C1 under the City Code. Neither parcel is currently under a Williamson Act contract.

Therefore, the proposed Project would not conflict with existing zoning for agricultural use or a Williamson Act contract. No impact would occur.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
II.c) The Site is neither designated nor zoned as forest land or timberland. No impact would occur.

II.d) As discussed above, the Site is currently zoned C2 and C1 under the City Code, is partially developed with remnants of an RV park on Quail Meadows and is surrounded by development including the existing log yard, a self-storage facility, the Highway 101 bypass, and residential uses. As the Site is not forest land nor located in close proximity to forest land, neither the proposed Project nor other typical industrial facilities would result in the loss of forest land or conversion of forest land to non-forest use. No impact would occur.

II.e) The proposed Project would not trigger other changes in the existing environment, on or off-site, which are not discussed herein. While the proposed Project would facilitate use of the Site as a log yard, the Site would receive harvested logs that would otherwise be stored at an alternative location. Therefore, the proposed Project does not involve other changes in the existing environment that could result in the loss of forest land or the conversion of forest land to non-forest use. No impact would occur.

Other typical industrial facilities would not be anticipated to trigger other changes in the existing environment, on or off-site, which could result in the conversion of farmland, to non-agricultural use or conversion of forestland to non-forest use. As the Site is not farmland or forest land, as described in Section II.a-d (Agriculture and Forestry Resources), industrial facilities would not impact farmland or forest land onsite. Upon review of the uses principally and conditionally permitted in the MH district in Table 2, none of the allowed uses would be anticipated to result in off-site conversion of farmland or forest land. No impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Agricultural and Forestry Resources.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
III. AIR QUALITY. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state
ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
DISCUSSION: Air pollution control in the State of California is based on federal, state, and local laws and regulations. According to the 2005 Mendocino County Air Quality Management District (MCAQMD) Particulate Matter Attainment Plan (PM Attainment Plan) (pg. 5), the United States Environmental Protection Agency (EPA), California Air Resources Board (CARB), and regional clean air agencies all regulate air quality.

The EPA and the CARB have set thresholds for each of the criteria pollutants, which include ozone (O3), carbon monoxide (CO), oxides of nitrogen (NOx), lead (Lb), sulfur dioxide (SO2), particulate matter less than 10 microns in size (PM10), and particulate matter less than 2.5 microns in size (PM2.5). The standards set by the CARB are generally more stringent than those set by the EPA and the CARB has set additional standards for visibility-reducing particles (of any size), sulfates, and hydrogen sulfide (H2S). These standards are based on observable short-term (acute) health effects (MCAQMD, 2005).

The Site is located within the North Coast Air Basin (NCAB) and is subject to the requirements of the MCAQMD.

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

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Emissions from construction of the Project would be comprised of direct and indirect emissions. Direct temporary emissions during construction, including exhaust and fugitive dust, would result from operation of construction equipment. Indirect emissions would be produced during operation by log trucks, lumber trucks, and other vehicles, including employees traveling to and from the Site.

Operation of a typical industrial facility would be subject to Code Chapter 17.50 – Performance Standards.

Pursuant to Code Section 17.50.040 – Locations where determinations are made for enforcement of performance standards (1982), compliance with performance standards would generally be enforced within five hundred (500) feet of the Project Area. Operations would be anticipated to generally occur between 7:00am and 7:00pm up to six (6) days per week. Typical operational activities would be anticipated to include employee trips to the typical industrial facility, operation of heavy equipment within and outside of structures, heavy truck traffic to/from the facility for materials transfers, and use of machinery within structures.

A Focused Transportation Impact Study for the Sanhedrin Timber Company Entitlements Project (Focused Traffic Study) was prepared by W-Trans on November 29, 2023 (Appendix E), to assess the potential transportation related impacts associated with the proposed Project and other typical industrial facilities.

According to the Focused Traffic Study, the Project is intended to increase operational efficiencies for the Applicant by reducing the number of truck trips between Eureka and Willits. The Project is not expected to increase trips on peak days (W-Trans, 2023).

III.a-b) Neither the Project nor other typical industrial facilities would conflict with or obstruct implementation of any air quality plan or result in a cumulatively considerable net increase of PM10, the only criteria pollutant for which the Site region is in non-attainment. As noted above, the MCAQMD is in “non-attainment” for PM10 (MCAQMD, 2005). Therefore, any use or activity that generates unnecessary airborne particulate matter may be of concern to MCAQMD and has the potential to create significant Project-specific and cumulative effects to air quality. MCAQMD has advised that generally an activity that individually complies with the state and local standards for air quality emissions would not result in a cumulatively considerable net increase in the countywide PM10 emissions.

While Project construction would generate temporary emissions, construction activities would be managed in accordance with the Rules and Regulations of the MCAQMD (February 2011) and the Applicant would obtain air quality permits from the MCAQMD, as needed. The contractor would maintain all construction equipment in good working order and would control exhaust emissions from construction equipment in accordance with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the CARB. In addition, the contractor would

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
comply with Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), which requires the suppression of fugitive dust during construction and operation. Furthermore, the Project would be subject to current and future regulations adopted by MCAQMD, including the PM Attainment Plan (2005), and compliance with these regulations would ensure the Project would not result in a substantial increase of PM10 within the vicinity of the Site.

Additionally, Project operations would not result in a substantial increase of PM10, as the overall Project Vehicle Miles Traveled (VMT) is expected to be reduced. Additional employees may be expected to increase the VMT associated with the operation of the Project. However, according to the Focused Traffic Study, the Project is intended to increase operational efficiencies for the Applicant by reducing the number of truck trips between Eureka and Willits (W-Trans, 2023). Therefore, the Project is not expected to increase VMT.

Construction of other typical industrial facilities would not conflict with or obstruct implementation of any air quality plan or result in a cumulatively considerable net increase in PM10. Construction of typical industrial facilities would be required to obtain air quality permits from the MCAQMD, as needed, and would be required to comply with the abovementioned regulations to limit idling and suppress fugitive dust.

Operation of typical industrial facilities would not be anticipated to result in a substantial increase of PM10.

The Focused Traffic Study used standard trip generation rates for various uses to analyze potential trip generation of other typical industrial facilities. Table 1 of the Focused Traffic Study (Appendix E) shows that trip generation for light industrial uses is substantially lower than those for typical commercial uses, such as office, retail, or service uses (W-Trans, 2023). The proposed Rezone is for MH, heavy industrial, rather than light industrial. However, commercial uses tend to generate a higher number of trips, as commercial uses are often utilized by the public. Light and heavy industrial uses are not utilized by the public to the same level as commercial uses. Based on a review of the uses permitted in C1, C2, and MH in Table 2 of this IS, it appears that uses permitted in C1 and C2 tend to involve more interaction with the public than uses permitted in MH.

Based on the substantially lower trip generation of light industrial uses than typical commercial uses and the nature of public utilization of commercial uses, it is reasonable to anticipate that other typical industrial facilities permitted by the GPA and Rezone would not result in a higher trip generation than would be anticipated with the existing zoning designations of C1 and C2. Other emissions generated by typical industrial facilities, aside from transportation emissions, would not be significant, as the Applicant would obtain air quality permits from the MCAQMD, as needed.

As construction of the Project would comply with State and local standards for air quality emissions, and overall Project VMT is expected to be reduced by Project operations, the Project would not result in a cumulatively considerable net increase in the countywide PM10 emissions. As other typical industrial facilities would also comply with State and local standards for air quality emissions, would not result in additional trip generation than would be anticipated in the existing zoning designations of C1 and C2, and would obtain air quality permits from the MCAQMD, as needed, a less than significant impact would occur.

III.c-d) The Project would not expose sensitive receptors to substantial pollutant concentrations, nor create objectionable odors affecting a substantial number of people. Sensitive receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants, and include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and residential dwelling unit(s). The nearest locations of potential sensitive receptors to the Site include residential dwellings southwest of the Site on land

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
with a land use designation of M-G and zoning designation of ML and Willits High School approximately 600 feet south of the Site.

The proposed Project would be anticipated to create exhaust and fugitive dust during construction or operation of the Project. Due to the close proximity of sensitive receptors to the Site, the Project shall comply with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit DieselFueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment, and Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), which suppresses fugitive dust during construction and operation and would maintain all construction equipment in good working order such that exhaust and fugitive dust emissions are minimized. Additionally, existing and proposed dust control practices consist of watering the operating surfaces of the log yard at regular intervals during dry weather periods. Maintaining sufficient moisture content on ground surfaces effectively minimizes the quantity of airborne particulates created by heavy equipment and truck traffic. The Applicant will prepare a Dust Control Plan for approval by the City. By complying with these regulations and implementing these dust control practices, potential impacts to sensitive receptors would be reduced to less than significant. Waste generated by the Project would be hauled off-site to a licensed disposal facility, and as such, waste storage piles would not generate fugitive dust. Additionally, the overall Project VMT is expected to decrease. A less than significant impact would occur.

Other typical industrial facilities would not be anticipated to create exhaust and fugitive dust during construction or operation. Future projects would be required to comply with the abovementioned regulations to limit idling and suppress fugitive dust. Additionally, based on the substantially lower trip generation of light industrial uses than typical commercial uses and the nature of public utilization of commercial uses, it is reasonable to anticipate that other typical industrial facilities permitted by the GPA and Rezone would not result in a higher trip generation than would be anticipated with the existing zoning designations of C1 and C2. As such, vehicle emissions during operations would not be anticipated to exceed what would be allowed under the existing zoning designations of C1 and C2. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Air Quality.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
IV. BIOLOGICAL RESOURCES. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Game or U.S.

Fish and Wildlife Service?
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other
means?
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state
habitat conservation plan?

DISCUSSION
The following environmental setting is generally based on the BRA dated September 27, 2022, and prepared by Clifton Environmental LLC (see Appendix C) to document biological species and determine to what extent the proposed Project may affect special status species and natural resources (2022). For the purposes of the BRA, the BRAA was defined as the Site.

The findings of the BRA are based on both research and field surveys. A list from the U.S. Fish and Wildlife Service’s (USFWS) Critical Habitat Portal was obtained in 2020 and updated on April 22, 2022, to identify federal-listed, candidate, or proposed species that potentially occur in or could be affected by the Project.

CDFW’s California Natural Diversity Database (CNDDB) and California Native Plant Society (CNPS) online searches were queried for the Willits 7.5’ USGS quad and the eight surrounding quads to determine likely and known occurrences of special status species on or near the Site. Fieldwork for the BRA included botanical surveys conducted on April 16, May 22, and June 6, 2021, and May 7, May 13, and May 31, 2022. A routinelevel preliminary wetland delineation of the Site was conducted on April 3, 2021, and April 30, May 5, May 7, May 10, and May 13, 2022, by Estelle Clifton (Clifton, 2022).

The BRAA is a nearly level former agricultural field, part of which was formerly developed as an RV park. There are multiple ditches and riparian habitat adjoining and within the BRAA. While undisturbed natural communities are present, considerable anthropogenic disturbance has occurred in the BRAA as evidenced

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
by recreational buildings and structures, paved, rocked, and seasonal roads, disturbance vegetation, berms near drainages, and the ditch structures present. The biological communities present in the Site include meadow, wet meadow (wetlands), oak woodland, riparian woodland, and ditch/water (Clifton, 2022).

The BRA identified several natural communities of special concern by CDFW, including Blue Wildrye Prairie, Valley Oak Woodland, and Oak Riparian Woodland. Blue Wildrye Prairie is ranked as an “inexact” or “uncertain” natural community of special concern, and occurs in three patches across the property, totaling approximately 0.2 acres. While Valley Oak Woodland is considered a common natural community in the area, it is considered a natural community of special concern by CDFW. Approximately 1.3 acres of Valley Oak Woodland was observed at the Site. Valley Oak Riparian Woodland, also a natural community of special concern by CDFW, approximately 2 acres was observed at the Site, primarily along drainages (Clifton, 2022).

Aquatic resources on-site were determined in the BRA by a combination of background materials and a routine-level preliminary wetland jurisdiction. Six (6) seasonal wetlands, totaling approximately 1 acre, that may be considered jurisdictional features regulated under Section 401 and Section 404 of the Clean Water Act (CWA) were identified within the BRAA. Additionally, the BRA identified seven (7) drainage ditches (shown on Figure 2 of the BRA). Ditch 1 is an intermittent water mapped as a Relatively Permanent Water and appears to be located off-site to the east, parallel to the Site. Ditch 2 is an intermittent drainage containing wetlands and is located along the southern boundary of the Site, between the Site and the existing log yard. Ditch 3 is an ephemeral and sparsely vegetated drainage that runs through the center of Quail Meadows. It is believed to be the original channel for Ditch 2. Ditch 4 is ephemeral drainage with wetland vegetation that is located along the northern edge of Quail Meadows, and appears to have been dredged in the past. Ditch 5 is intermittent drainage in the northern portion of APN: 108-040-18 and is surrounded by wetlands with pockets of rare plants. According to the BRA, it appears that Ditch 5 drains the storage unit facility adjacent to the west of the Site (APN: 108-040-17) via a culvert in the northeast corner of that property. Ditch 6 is an intermittent stream that shows less signs of alteration than other drainages in the Site, and is located near the eastern edge of APN: 108-040-18 within the Riparian Woodland community.

Ditch 7 is an intermittent drainage ditch located at the north edge of the existing log yard, just south of Ditch

2. Aquatic habitats within the Site were not found to be suitable for Northern California steelhead, Chinook salmon, and coho salmon, as the Highway 101 by-pass culvert may be an impassable barrier for fish. In addition, the ditches within and adjacent to the Site appear to be low-quality habitat, due to the low gradient flows creating brackish water and soil substrate (Clifton, 2022).

Special status plants and animals, legally protected under the California and federal Endangered Species Acts (CESA and ESA, respectively) or other regulations, and species that are considered rare by the scientific community, were evaluated for their potential for occurrence within the BRAA. Special status species include those plants and wildlife species that have been formally listed, are proposed as endangered or threatened, or are candidates for such listing under the ESA or CESA; CDFW Species of Special Concern; USFWS Birds of Conservation Concern; CDFW special status invertebrates; and those with California Rare Plant Rank (CRPR) 1A (Plants Presumed Extinct in California), CRPR 1B (Plants Rare, Threatened, or Endangered in California and Elsewhere), or CRPR 2 (Plants Rare, Threatened, or Endangered in California, But More Common Elsewhere), as indicated by the CNPS Inventory. In addition to regulations for special status species, most birds in the United States, including non-status species, are protected by the Migratory Bird Treaty Act (MBTA) of 1918.

Under this legislation, destroying active nests, eggs, and young is illegal. The MBTA generally prohibits the take of migratory birds, and their nests and roosting bats are protected under CDFW regulations (Clifton, 2022).

Table 1 of the BRA contains regional species and habitats of concern, along with the potential for each species to occur within the BRAA, with data received from USFWS, CNDDB, and CNPS records. Thirty-four (34)

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special status plant species were identified during Project scoping, although nineteen (19) were found not to have potential suitable habitat present on-site. Three (3) special status plant species were identified onsite during the field surveys, including: Baker’s meadowfoam (Limnanthes bakeri), North Coast semaphore grass (Pleuropogon hooverianus), and Davy’s sephamore grass (Pleuropogon californicus var. davyi).

Additionally, during Project scoping, twenty-three (23) special status wildlife species were identified and reviewed to determine if suitable habitat is present within or directly adjacent to the Site (see BRA, Table 1).

Of these 23 species, three (3) were found to potentially have suitable habitat within the Site, and one (1) was observed during field surveys. White-tailed kites (Elanus leucurus) were observed at the Site. While yellow warbler (Dendroica petechia brewsteri) and American badger (Taxidea taxus) were not identified on-site, suitable habitat for each species exists at the Site (Clifton, 2022).

Victor Hollister, RPF No. 3180, surveyed 367 trees 5 inches or greater DBH at the Site. Tree species observed include American sycamore (Platinus occidentalis), apple (Malus domesticate), Austrian pine (Pinus nigra), bigtooth aspen (Populus tremula), black poplar (Populus nigra), black willow (Salix nigra), California black oak (Quercus kelloggii), Chinese juniper (Juniperus chinensis), Lombardy poplar (Populus nigra), London plane tree (Plananus hispanica), non-native maple (Acer spp.), olive (Olea europaea), Oregon ash (Fraxinus latifolia), Oregon white oak (Quercus garryana), ornamental cypress (Cupressus spp.), ponderosa pine (Pinus ponderosa), sweet gum (Liquidambar styracifula), valley oak (Quercus lobata), and walnut (Juglans spp.).

Pursuant to a Tree Survey completed by Victor Hollister, RPF No. 3180, in April 2023 (see Appendix A), the Project involves the removal of 116 mature trees to facilitate grading and site development for the log yard, as shown in Table 3 of this IS. While the log yard is one of various uses that would be allowed in the Project Area upon approval of the GPA and Rezone, for the purposes of this IS, it is assumed that the tree removal proposed is representative of the tree removal required for development of a typical industrial facility at the Site, as trees would be removed in the center of the Project Area and generally retained along the eastern property boundary.

Although the design of future projects at the Site that would be allowed by the GPA and Rezone are unknown, development of the Site for a typical industrial facility would generally include vegetation removal; grading for access roads, building pads, and parking areas; landscaping; installation of water storage facilities such as water tanks and/or ponds to serve as back-up water supplies and for emergency situations; reuse and/or removal of existing structures; infrastructure improvements related to water supply, wastewater, solid waste, and storm drainage; and in many cases, construction of new structures.

IV.a) Three (3) special status plant species and three (3) special status animal species were either observed on-site or identified as having the potential to occur on-site. Each special status species is described in further detail below:

Special Status Plant Species
Baker’s meadowfoam (Limnanthes bakeri) is listed as a State Rare species that is seriously endangered in California. Approximately eight (8) square feet of Baker’s meadowfoam was located near the northernmost access road on APN: 108-040-18. The Applicant does not intend to utilize this access road for the Project; however, the road is currently utilized and regularly maintained by Caltrans for accessing an off-site property to the east. In order to ensure regular maintenance activities, whether completed by the Applicant or others, are completed in a manner that ensures the long-term productivity of Baker’s meadowfoam or other CESA threatened or endangered species in this area, the Applicant intends to obtain a Scientific, Educational, or Management Permit (Management Permit) from CDFW pursuant to subdivision (a) or Section 2081 of Fish and Game Code. Additionally, as described in Mitigation Measure BIO-1, temporary fencing during

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construction would ensure that construction activities do not unintentionally encroach upon Baker’s meadowfoam.

North Coast semaphore grass (Pleuropogon hooverianus) is listed as a State Threatened species that is seriously endangered in California. A large population of North Coast semaphore grass was located during the field surveys near Ditch 5. Additionally, Davy’s semaphore grass (Pleuropogon californicus var. davyi) is listed as a State Candidate Threatened species that has limited distribution in California and was located adjacent to Ditch 5 and within the wetland area at the northern end of the Site. While the Project would not directly impact either species, the BRA recommends marking the limits of listed species and sensitive habitat with temporary fencing to prevent unintended impacts to the North Coast semaphore grass and Davy’s semaphore grass populations (Clifton, 2022). This has been included as Mitigation Measure BIO-1.

As the design of future projects is unknown, Mitigation Measure BIO-1 would be implemented during construction of other typical industrial facilities at the Site, as they occur, to ensure listed plant species are not impacted.

Operation of the Project or other typical industrial facilities may impact Baker’s meadowfoam, North Coast Semaphore grass, and Davy’s semaphore grass if employees are unaware of the locations of these listed plant species. Mitigation Measure BIO-2 would require that a barrier be installed around the limits of Baker’s meadowfoam, North Coast Semaphore grass, and Davy’s semaphore grass. This would prevent unintended encroachment during operations and ensure operations do not impact listed species.

Special Status Wildlife Species
White-tailed kites (Elanus leucurus) are classified as Fully Protected under the CESA. White-tailed kites are known to inhabit open grasslands, meadows, marshes, foothills, and valley margins adjacent to deciduous woodlands in California lowlands west of the Sierra Nevada range, and nest January through August. The approximately 11 acres of meadow and woodland plant communities of the Site may provide hunting and/or nesting habitat. During the field surveys in 2022, white-tailed kites were observed on the northeastern edge of the Site in a small stand of redwood and Douglas fir trees. Project construction has the potential to impact white-tailed kite nesting habitat in the Valley Oak Woodland and Valley Oak Riparian Woodland, and hunting habitat in the Meadow/Wetland communities in the form of vegetation disturbance and tree removal. To minimize impacts to white-tailed kites, the BRA recommends that a pre-construction nesting survey be conducted, with particular focus on trees within 500 feet of the Site if vegetation disturbance occurs during the nesting season, and buffers be maintained around active nests identified during the survey, if any. This has been included as Mitigation Measure BIO-3. This would ensure that white-tailed kites utilizing the Site for habitat are not impacted by vegetation disturbance and tree removal. Mitigation Measure BIO3 would also apply during construction of other typical industrial facilities that may occur at the Site to reduce impacts of potential construction and vegetation removal.

Yellow warbler (Dendroica petechia brewsteri) is classified as a Species of Special Concern by CDFW and a Bird of Conservation Concern by USFWS. Yellow warblers breed from April to late July and are known to frequent open- to medium-density woodlands and forests with a heavy brush understory during their breeding period. Deciduous riparian areas with cottonwood, alder, willow, and other miscellaneous small trees and shrubs are ideal breading habitat. Although no yellow warblers were identified within the BRA, the Valley Oak Riparian Woodland could potentially serve as habitat for this species during breeding season.

Project construction has the potential to impact yellow warbler nesting habitat. To minimize potential impacts to yellow warblers, the BRA recommends a nesting survey be conducted if vegetation disturbance occurs during its nesting season and buffers maintained around active nests identified during the survey, if

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any. This has been included as Mitigation Measure BIO-3. This would ensure that yellow warblers nesting at the Site are not impacted by vegetation disturbance and tree removal. Mitigation Measure BIO-3 would also apply during construction of other typical industrial facilities that may occur at the Site to reduce impacts of potential construction and vegetation removal.

American badger (Taxidea taxus) is classified as a Species of Special Concern by CDFW. They are most abundant in drier open stages of most shrub, forest, and herbaceous habitats, with friable soils, and mate in late summer or early autumn. While the Site may contain suitable habitat, no American badgers were observed on-site during field surveys, and there is a low likelihood that the species would use the Site as habitat. To minimize potential impacts to American badgers, if an American badger den is encountered during construction, works shall halt immediately in the vicinity of the den, and a qualified biologist shall evaluate the potential den site. If the hole is determined to be a potential American badger den, CDFW shall be notified, and an appropriate buffer shall be established around the den. This has been included as Mitigation Measure BIO-4. This would ensure that occupied maternity dens are avoided. Additionally, the implementation of passive den exclusion measures on occupied non-maternity dens would allow American badgers to move elsewhere prior to disturbance activities. Mitigation Measure Bio-4 would also apply during construction of other typical industrial facilities that may occur at the Site to reduce potential disturbance of American badgers.

Due to the high number of sensitive species and habitat within the Site, Mitigation Measure BIO-5, which requires construction personnel for the Project or other typical industrial facilities to undergo training by a qualified biologist prior to construction would be incorporated. With the incorporation of Mitigation Measures BIO-1 through BIO-5, a less than significant impact would occur.

IV.b) The BRA identified several natural communities of special concern by CDFW, including Blue Wildrye Prairie, Valley Oak Woodland, and Oak Riparian Woodland. Each natural community is described in further detail below:

While Valley Oak Woodland is considered a common natural community in the area, it is considered a natural community of special concern by CDFW. Approximately 1.3 acres of Valley Oak Woodland was observed at the Site (Clifton, 2022). Valley Oak Riparian Woodland, also a natural community of special concern by CDFW, approximately 2 acres was observed at the Site, primarily along drainages (Clifton, 2022).

Project construction would generally avoid permanent impacts to Valley Oak Woodland and Valley Oak Riparian Woodland communities. However, approximately seven (7) mature oak trees (considered to be 12 inches or greater DBH) throughout the Site would require removal. See Table 3 of this IS for a summary of the approximate size ranges in DBH of the of the seven (7) mature oaks proposed for removal. The Applicant shall offset the removal of mature oak trees through one or more of the oak woodland mitigation alternatives in PRC §21083.4, which may include conserving oak woodlands through the use of conservation easements, planting an appropriate number of trees, contributing funds to the Oak Woodlands Conservation Fund, or other mitigation measures developed by the City, if any. If the Applicant proposes to plant oak trees as part of mitigation, the Applicant shall prepare an Oak Mitigation and Monitoring Plan (MMP) that includes mitigation ratios for replanted trees, description and size of the area for replanting, planting techniques, maintenance and monitoring activities and schedule, and remediation measures. Mitigation for oak tree removal consistent with PRC §21083.4 has been included as Mitigation Measure BIO-6. This would ensure that oak tree removal is appropriately mitigated for in accordance with PRC §21083.4. Construction of other typical industrial facilities would have the potential to require the removal of oak trees. As such, Mitigation Measure BIO-6 would also apply during construction of other typical industrial facilities that may occur at the Site.

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Blue Wildrye Prairie is ranked as an “inexact” or “uncertain” natural community of special concern and occurs in three (3) patches across the property, totaling approximately 0.2 acre. Project construction, including construction of the proposed northern water storage pond and a water pipeline, would result in the permanent loss of Blue Wildrye Prairie (Clifton, 2022). Mitigation Measure BIO-7 would be incorporated to require that portions of the Site be revegetated with a native seed mix that includes Blue wildrye (Elymus glaucus) at a minimum ratio of 2.6 to 1. Construction of other typical industrial facilities would also have the potential to impact Blue Wildrye Prairie. As such, Mitigation Measure BIO-7 would also apply during construction of other typical industrial facilities that may occur at the Site. Mitigation Measure BIO-7 would ensure that Blue Wildrye Prairie is revegetated and maintained to compensate for areas of disturbed Blue Wildrye Prairie.

Operation of the Project or other typical industrial facilities may impact Blue Wildrye Prairie if employees are unaware of the locations of this sensitive habitat. Mitigation Measure BIO-2 would require that a barrier be installed around the limits of Blue Wildrye Prairie to prevent unintended encroachment during operations.

This would avoid impacts to Blue Wildrye Prairie.

Incorporation of Mitigation Measures BIO-1 and BIO-2, marking the limits of listed species and sensitive habitat with temporary fencing during construction and a barrier during operation, would ensure that construction and operation do not impact natural communities of special concern beyond those permitted by construction entitlements. Additionally, to mitigate the permanent loss of mature oak trees and Blue Wildrye Prairie, the Applicant shall mitigate removed mature oak trees pursuant to PRC §21083.4 and revegetate with native grasses that include blue wildrye, respectively. These mitigation measures have been included as Mitigation Measures BIO-6 and BIO-7.

Implementation of Mitigation Measures BIO-1, BIO-2, BIO-6, and BIO-7 would enhance existing on-site habitat for sensitive natural communities. With mitigation incorporated, a less than significant impact would occur.

IV.c) Six (6) seasonal wetlands were observed at the Site that may be considered jurisdictional features regulated under Section 401 and Section 404 of the CWA. Construction-related impacts are estimated to cause temporary impacts to 0.01 acre of seasonal wetlands and result in the permanent loss of approximately 0.02 acre of seasonal wetlands. Additionally, Ditch 2 and 4 would be impacted by fill, construction of new truck road drainage crossings, minor road reconstruction impacts, and pipeline construction. Approximately 0.01 acre of ditch in Ditches 2, 5, and 6 would be temporarily disturbed due to Project construction and an estimated 0.06 acre in Ditches 2, 3, 4, and 5 would be permanently impacted (Clifton, 2022). As the design of future projects is unknown, construction of other typical industrial facilities may have the potential to impact wetlands and drainages.

Due to the proposed impacts to potentially jurisdictional waters, a Section 404 CWA permit through the U.S.

Army Corps of Engineers (USACE) and a Section 401 Water Quality Certification (WQC) from the North Coast Regional Water Quality Control Board (NCRWQCB) shall be obtained from the respective agencies, as required by Mitigation Measure BIO-8 below prior to the issuance of grading permits for construction activities within or adjacent to these resources. This would ensure that impacts to jurisdictional waters are compensated for to the satisfaction of permitting agencies. Mitigation Measure BIO-8 would be required for both the Project and other typical industrial facilities. Additionally, Mitigation Measure BIO-1, marking the limits of listed species and sensitive habitats with temporary fencing, would ensure that construction does not impact seasonal wetland beyond those permitted by construction entitlements. Through implementation of Mitigation Measure BIO-2, installing barriers around the limits of listed species and sensitive habitats to protect

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them from unintended encroachment, impacts to wetlands would be avoided during operation of the Project and other typical industrial facilities. With mitigation incorporated, a less than significant impact would occur.

IV.d) The Project and other typical industrial facilities would not be anticipated to substantially interfere with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites. Although the Project and other typical industrial facilities would involve new development at the Site, wildlife movement would continue to be unimpeded on the undeveloped land north, east, and west of the Site. Additionally, although habitat on and adjacent to the Site provides potential nesting habitat for white-tailed kites and yellow warblers, Mitigation Measure BIO-3, which requires pre-construction nesting bird surveys if construction is to occur within the nesting seasons for these species, would ensure that white tailed kites and yellow warblers nesting at the Site are not impacted by vegetation disturbance and tree removal, reduce the potential impact to these species to a less than significant level. With mitigation incorporated, a less than significant impact would occur.

IV.e) The proposed Project and other typical industrial facilities would not conflict with any local policies or ordinances protecting biological resources. Although natural communities of special concern and habitat for special status species may be present on-site (Clifton, 2022), Mitigation Measures BIO-1 through BIO-8 would reduce potential impacts to less than significant. With mitigation incorporated, a less than significant impact would occur.

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

MITIGATION MEASURES
BIO-1: Prior to the start of construction, areas of the Site associated with listed species and sensitive habitats and that are not proposed to be impacted shall be identified and designated as Environmentally Sensitive Areas (ESAs) using flagging, high-visibility orange fencing, and/or silt fencing. This applies specifically to areas with Baker’s meadowfoam, North Coast semaphore grass, Davy’s semaphore grass, Blue Wildrye Prairie, Valley Oak Woodland, Valley Oak Riparian Woodland, and wetlands. ESAs shall be shown on design plans or maps for the proposed project, to be provided to construction personnel. The ESA flagging/fencing shall remain in place throughout the duration of construction activities to prevent the encroachment of construction equipment/personnel into sensitive areas. To the extent feasible, construction activities shall be located outside of any designated ESA.

BIO-2: Barriers shall be installed around the limits of listed species and sensitive habitats that may be impacted by unintended encroachment during operation of the proposed project and that are not easily identified, including Baker’s meadowfoam, North Coast semaphore grass, Davy’s semaphore grass, Blue Wildrye Prairie, and wetlands. These barriers shall be installed in a way that would be clearly identified by employees but would not interfere with wildlife movement.

BIO-3: Construction activities for the proposed project shall be conducted, if possible, outside of the nesting seasons for white-tailed kite (January 15 to August 15) and yellow warblers (March 15 to August 15) to avoid impacts to these species. If construction activities begin during the nesting season, a qualified biologist shall conduct a pre-construction survey for active nests in suitable nesting habitat within 500 feet of the construction area no more than seven (7) days prior to the initiation of construction. If no active nests are identified during the pre-construction survey, no further mitigation is necessary. If at any time during the

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nesting season construction stops for a period of seven (7) days or longer, a supplemental pre-construction survey shall be conducted prior to construction resuming.

If active nests are found within the construction footprint or immediately adjacent to construction activities within the project area, the biologist shall establish a species-appropriate buffer or exclusion zone around the nest (approximately 500 feet for white-tailed kites and 100 feet for yellow warblers) and/or operational restrictions within the buffer in consultation with the California Department of Fish and Wildlife (CDFW).

Construction activities shall avoid nest buffers until the qualified biologist determines that the birds have fledged and are no longer reliant upon the nest or parental care for survival. The qualified biologist may modify these buffers, in consultation with CDFW, depending upon the species, nest location, and existing visual buffers.

If construction activity is required within the established buffer, the qualified biologist shall be consulted prior to beginning construction activities within this area. If the qualified biologist determines that the activity would impact the nest, the qualified biologist shall have the authority to stop work. If the qualified biologist determines that the activity would not disturb the nest, construction may continue under supervision of the qualified biologist or designee.

BIO-4: In the unlikely event that an American badger den (evidenced by a large mound of dirt piled outside an excavated den) is encountered during construction of the proposed project, construction work shall halt in the vicinity of the den, a qualified biologist shall evaluate the potential den site, and CDFW shall be notified if the hole is determined to be a potential American badger den. A 100-foot no-work buffer shall be established around occupied maternity dens throughout the puprearing season (February 15 through July 1) and a 15-foot no-work buffer around occupied dens during other times of the year. If non-maternity dens are found and cannot be avoided during construction activities, they shall be monitored by a qualified biologist for badger activity. If the qualified biologist determines that dens may be occupied, passive den exclusion measures shall be implemented for three (3) to five (5) days to discourage the use of these dens prior to disturbance activities during construction.

BIO-5: Before construction activities begin, a qualified biologist shall conduct an education program for all construction personnel. The training shall include a description of special status species, including State-listed species and associated habitats with potential to occur in the study area; an explanation of the status of these species and their protection under the California Endangered Species Act; the measures to conserve listed species and their habitats as they relate to the work being done; and Environmentally Sensitive Areas (ESAs) to be avoided during construction. A fact sheet conveying this information will be prepared and distributed to all construction crews. Upon completion of the program, personnel shall sign a form stating that they attended the program and understand the mitigation measures.

BIO-6: The project proponent shall offset the removal of mature oak trees, defined as trees greater than 12 inches in diameter at DBH, through one or more of the oak woodland mitigation alternatives in PRC §21083.4, which may include conserving oak woodlands through the use of conservation easements, planting an appropriate number of trees, removing invasive species encroaching upon oak tress to be retained, contributing funds to the Oak Woodlands Conservation Fund, or other mitigation measures developed by the City, if any.

Prior to the issuance of a building and/or grading permit by the City and the start of construction, an Oak Mitigation and Monitoring Plan (Oak MMP) shall be prepared by a certified arborist, registered professional forester, botanist, or landscape architect. The Oak MMP shall be prepared to satisfy the standards of PRC

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§21083.4 and shall include the following elements, at a minimum: selected mitigation alternative(s) pursuant to PRC §21083.4; a map showing the location of all oak trees 5 inches or more DBH and all oak trees 12 inches or more DBH planned for removal; oak tree protection measures for oak trees to be retained with 20 feet of the construction area; and details related to on-site mitigation, if proposed. For on-site mitigation, the following information shall be provided: proposed mitigation ratio; description and size of the area for replanting; planting techniques; maintenance and monitoring activities and schedule; irrigation requirements; success criteria; reporting plan and schedule; and remediation measures. Success criteria may consider factors such as relative cover of established oak woodland habitat, height of planted trees, and/or other relevant criteria as determined in the Oak MMP. The Oak MMP shall be submitted for review and approval by the City’s Community Development Director or his/her designee.

BIO-7: Permanent impacts to the Blue Wildrye Prairie community shall be compensated for through on-site revegetation, invasive species removal from within the Blue Wildrye Prairie community to be maintained, and/or other measures as deemed appropriate in consultation with CDFW. Should on-site revegetation be proposed, portions of the Site shall be revegetated with a native seed mix that includes Blue wildrye (Elymus glaucus). Revegetation shall occur at a minimum ratio of 2.6 to 1, or as otherwise required by CDFW, to compensate for permanent impacts. Revegetation shall occur within areas of the Site deemed appropriate for Blue wildrye (Elymus glaucus).
- Commercially available native grasses shall be used to revegetate. These grasses include but are not limited to: Blue wildrye (Elymus glaucus), California brome (Bromus sitchensis var. carinatus), California fescue (Festuca californica), Pine bluegrass (Poa secunda), and California oatgrass (Danthonia californica).
- A native grass seed blend such as Holdfast Native Blend from LeBallister’s can be purchased and used as a viable option for revegetation plans. This mix consists of California brome, Blue wild rye (Elymus glaucus), three weeks fescue (Festuca microstachys), California poppy (Eschscholzia californica), and California native lupines (Lupinus spp.). This seed mix conforms to the standard practice of using grasses, legumes, and wildflowers in combination for erosion control and revegetation plans.
- A qualified botanist or landscape architect shall advise the field crew on seeding rate and dispersal technique. Broadcast seeding is an effective way to reclaim bare areas and should be done just prior to the autumn rains. If insufficient rain is in the forecast when seeding can occur, irrigation must be used to gently water in the seeds for the first season.

BIO-8: Due to the proposed impacts to on-site wetlands and drainage ditches, the project proponent shall obtain a Section 404 CWA permit through USACE for impacts to waters of the United States and a Section 401 WQC from the NCRWQCB, if deemed necessary by these resource agencies. If required, these permits shall be obtained prior to issuance of grading permits for construction activities in or adjacent to the on-site wetlands and drainage ditches, as determined through consultation with the USACE and NCRWQCB.

The project proponent shall ensure that the design of the proposed project would not result in a loss of functions and values of waters of the United States or State through impact avoidance, impact minimization, and/or compensatory mitigation for the impact, as determined by the resource agencies. The project proponent shall design the proposed project to limit the obstruction of and human intrusion into the riparian area of the on-site wetlands and drainage ditches, to the extent feasible. If it is determined, through obtaining an Approved Jurisdictional Determination through the USACE, that the aquatic resource features at the Site are not jurisdictional under the CWA, then the Section 404 CWA permit and Section 401 WQC may not be required.

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Compensatory mitigation may consist of:

1. Providing on-site compensatory mitigation through an aquatic resource restoration (which may include removal of invasive species and/or native species planting), establishment, enhancement, and/or preservation activity in a location at or adjacent to the impact site;

2. Providing off-site compensatory mitigation through an aquatic resource restoration, establishment, enhancement, and/or preservation activity at another location, usually within the same watershed as the permitted impact;

3. Obtaining credits from a mitigation bank; and/or

4. Making a payment to an in-lieu fee program that would conduct wetland, stream, or other aquatic resource restoration, creation, enhancement, or preservation activities. The project proponent retains responsibility for the implementation and success of the mitigation project.

Evidence of compliance with this mitigation measure shall be provided to the City’s Community Development Department prior to initiating construction activities in or adjacent to the on-site wetlands and drainage ditches.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact with Mitigation Incorporated on Biological Resources.

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V. CULTURAL RESOURCES. Would the project: Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
§15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to §15064.5?
c) Disturb any human remains, including those interred
outside of formal cemeteries?

DISCUSSION
According to the Development Element of the Mendocino County General Plan (2020), ten (10) Native American tribes historically had territory in what is now Mendocino County. Native American tribes known to inhabit Mendocino County concentrated mainly along the coast and along major rivers and streams, while some tribes seasonally occupied mountainous areas and redwood groves. The first permanent non-native settlers came to Mendocino County in the middle of the 16th century, exploring and establishing small outposts. It was almost 300 years before the first permanent non-Spanish settlements in Mendocino County were established in April of 1852 on the coast north of Big River. As European-American settlement expanded in Mendocino County, most of the tribes known to inhabit the land were restricted to reservations and rancherias. During the 19th century, other tribes from the interior of California were forced to settle on the Round Valley Reservation in the northeastern portion of Mendocino County (County of Mendocino, 2020).

Settlement in the vicinity of the City began in the mid-1880s (City of Willits, 1992, pg. III-27).

Various County and City policies exist related to the protection and preservation of cultural and historical resources, including but not limited to: Development Element of the Mendocino County General Plan (2020), pages 3-94 through 3-95; Chapter 22.12 of the Mendocino County Code (1991); the City of Willits General Plan Revision EIR (1992), page III-27; and Chapter 17.48 of the City Code (1991). Specifically, within the City of Willits, mitigation measures 4.931 and 4.932 of the City of Willits General Plan Revision EIR (1992) and Chapter 17.48 – Historical Resources of the City Code (2021) include provisions for the protection, enhancement, perpetuation or use of places, buildings, structures, and other objects having a special character or special historical or aesthetic interest or value to the City. Several historical resources have been identified in the County and within, or in close proximity to, the City, many of which have been placed on various federal and state historic registries; however, no historical sites or buildings have been designated by the County or the City and none are with the current vicinity of the Site.

Cultural Resources Inventories (Cultural Studies) were completed for Quail Meadows and APN 108-040-18 by Browning Cultural Resources, Inc. (BCR) in August 2020 and March 2021, respectively. Please note that due to the confidential nature of Cultural Studies, copies of the Cultural Studies are not provided as appendices to the Initial Study.

As noted in the Cultural Studies performed for the two parcels, BCR’s investigations included pre-field research and a records search obtained from the Northwest Information Center (NWIC), as well as reviewing internal records and data within a 0.25-mile buffer around the Area of Potential Impacts (API). The inventory also included background research, examining the ethnographic and historic use of the Project vicinity, and an intensive pedestrian survey of the entire API on both parcels (which included the entirety of the parcels) (BCR, 2020 and 2021).

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As noted in the Cultural Studies, as a result of the pre-field research, eight (8) resources were identified within

0.25-miles of the Site; however, none are located within the API (BCR, 2020 and 2021). Although no resources were identified within the API, one (1) isolated artifact (a Franciscan chert flake) was observed near the western edge of Quail Meadows (BCR, 2020) and two (2) isolated artifacts (two Franciscan chert flakes) were observed near the northwest corner of the parcel identified by APN 108-040-18 (BCR, 2021). Additionally, “a buried site sensitivity analysis suggests that the potential for buried prehistoric resources in the vicinity is high” (BCR, 2020 and 2021). As such, proper protocol is provided in the Cultural Studies in the event of inadvertent discovery of archaeological resources, including remains (see Mitigation Measures CUL-1 through CUL-3, below).

In addition, outreach and correspondence with the Native American Heritage Commission (NAHC) occurred during preparation of the August 2020 Cultural Study. In July 2020, a Sacred Lands File (SLF) Search was requested from the NAHC. On July 3, 2020, the NAHC provided a response that indicated the results of the SLF Search were negative. The NAHC additionally provided a list of Native American tribes that may have knowledge of cultural resources in the Project area. On December 14, 2022, in compliance with Assembly Bill (AB) 52 and Senate Bill (SB) 18, the City of Willits sent consultation letters to the Tribal Historic Preservation Officer (THPO) or appropriate representative for each of the following 15 Native American tribes: Coyote Valley Band or Pomo Indians, Guidiville Indian Rancheria, Hopland Band of Pomo Indians, Cahto Tribe, Manchester Band of Pomo Indians of the Manchester Rancheria, Middletown Rancheria of Pomo Indians, Noyo River Indian Community, Pinoleville Pomo Nation, Potter Valley Tribe, Redwood Valley or Little River Band of Pomo Indians, Robinson Rancheria of Pomo Indians, Round Valley Reservation/Covelo Indian Community, Scotts Valley Band of Pomo, Sherwood Valley Rancheria of Pomo, Yokayo Tribe, and Torres Martinez Desert Cahuilla Indians. Two Native American tribes, the Manchester Band of Pomo Indians of the Manchester Rancheria and the Sherwood Valley Rancheria of Pomo, responded to request additional information. No Native American tribes responded with concerns regarding the proposed Project. Copies of the NWIC response letter and the NAHC Native American Contacts List are included in Appendix F.

V.a) The Project and other typical industrial facilities are not anticipated to have a significant impact on historical resources. No historical resources are identified at or near the Site, per Figure 10-1 of the City of Willits General Plan (City of Willits, 1992).

The property identified by APN: 108-040-18 has been utilized as pastureland and does not contain any development (BCR, 2021). However, Quail Meadows is noted to contain existing development, which are proposed to be demolished and hauled off-site to appropriate waste disposal facilities (BCR, 2020). Although Quail Meadows contains existing development proposed for demolition, the Cultural Studies note the structures are “modern” (BCR, 2020) and are therefore not historically significant nor eligible for listing on the California Register of Historic Resources (CRHR) or National Register of Historic Places (NRHP). As a result, no impact would occur.

V.b-c) The Project and other typical industrial facilities are not anticipated to cause a substantial adverse change in the significance of an archaeological resource or disturb any human remains. According to the Cultural Studies (BCR, 2020 and 2021), eight (8) resources are known within 0.25-miles of the Site; however, none are located within the API. Further, although the Cultural Studies note that there is a high potential for buried prehistoric resources in the vicinity, the Cultural Studies conclude the Project would not have a significant impact on cultural resources, provided the prescribed measures in the Cultural Studies are implemented in the event of inadvertent discovery of resources. Such measures include stopping grounddisturbing activity; notifying a qualified archaeologist; assessing of the significance and extent of the

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
resource; subsequent recordation based upon the results of the assessment; and following the procedures identified in CHSC 7050.5 and PRC 5097.98, should human remains be encountered (BCR, 2020 and 2021), which have been incorporated as Mitigation Measures CUL-1 through CUL-3, below. The Project, and development of other typical industrial facilities, would be required to comply with Measures CUL-1 through CUL-3. With mitigation incorporated, a less than significant impact would occur.

MITIGATION MEASURES
CUL-1: In the event archaeological resources or cultural resources, including human remains, are inadvertently unearthed or discovered during construction, the contractor shall immediately halt all grading/land-clearing activities and contact a qualified archaeologist. Project personnel shall not collect the potential resources. All activity in the vicinity of the resources shall cease until a qualified archaeologist can evaluate it. If the qualified archaeologist determines that the resources may be significant, they shall notify the City’s Community Development Department and develop an appropriate treatment plan for the resources. The archaeologist shall consult with Native American representatives in determining appropriate treatment for prehistoric or Native American cultural resources. In considering any suggested mitigation proposed by the archaeologist, and Native American representative where applicable, the City’s Community Development Department will determine whether avoidance is necessary and feasible in light of factors such as the nature of the find, project design, costs, and other considerations. If avoidance is infeasible, other appropriate measures (e.g., data recovery) will be instituted. Work may proceed in other parts of the project area while mitigation for cultural resources is being carried out.

CUL-2: If human remains are encountered on-site, all work must stop in the immediate vicinity of the discovered remains and the Mendocino County Coroner and a qualified archaeologist shall be notified immediately so that an evaluation can be performed. If the remains are deemed to be Native American and prehistoric, the NAHC shall be contacted by the Coroner so that a “Most Likely Descendant” can be designated and further recommendations regarding treatment of the remains can be provided.

CUL-3: Any identified cultural resources shall be recorded on DPR 523 historic resource recordation forms by a qualified archaeologist, available online from the Office of Historic Preservation’s website:
http://ohp.parks.ca.gov/default.asp?page_id=1069.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact with Mitigation Incorporated on Cultural Resources.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
VI. ENERGY. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy, or wasteful use of energy
resources, during project construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?

DISCUSSION
On October 7, 2015, Governor Edmund G. Brown, Jr. signed into law Senate Bill (SB) 350, known as the Clean Energy and Pollution Reduction Act of 2015, which sets ambitious annual targets for energy efficiency and renewable electricity aimed at reducing greenhouse gas (GHG) emissions. According to the Final Commission Report of the California Energy Commission (CEC), dated October 2017, SB 350 requires the CEC to establish annual energy efficiency targets that will achieve a cumulative doubling of statewide energy efficiency savings and demand reductions in electricity and natural gas final end uses by January 1, 2030.

This mandate is one of the primary measures to help the state achieve its long-term climate goal of reducing GHG emissions to 40 percent below 1990 levels by 2030. The proposed SB 350 doubling target for electricity increases from 7,286 gigawatt hours (GWh) in 2015 up to 82,870 GWh in 2029. For natural gas, the proposed SB 350 doubling target increases from 42 million therms (MM) in 2015 up to 1,174 MM in 2029 (CEC, 2017).

Improvements proposed for the Project generally include vegetation removal, grading, and reuse or removal of existing structures. Vegetation removal and grading activities would facilitate the construction of rocked log storage areas, internal access roads, and access points between the existing log yard and the Site, parking near the office, and two (2) water storage ponds. Daily operations would be consistent with the existing operations of the existing log yard and would include: the storage and sale of non-retail logs; log and lumber trucks transporting logs to and from the Site; log clean-up (including periodic chainsaw work to logs to cut into shorter lengths, flush knots (limb ends) and clean up and flush the ends of the logs to remove any unevenness, splinters, or other log defects); loading of bark and other byproducts; lumber trailer staging; and site maintenance, including minor grading, resurfacing, and watering.

Operation of a typical industrial facility would be subject to Code Chapter 17.50 – Performance Standards.

Pursuant to Code Section 17.50.040 – Locations where determinations are made for enforcement of performance standards (1982), compliance with performance standards would generally be enforced within five hundred (500) feet of the Project Area. Operations would be anticipated to generally occur between 7:00am and 7:00pm up to six (6) days per week. Typical operational activities would be anticipated to include employee trips to the typical industrial facility, operation of heavy equipment within and outside of structures, heavy truck traffic to/from the facility for materials transfers, and use of machinery within structures.

VI.a) The proposed Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy, or wasteful use of energy resources, during Project construction or operation. The consumption of energy would occur during construction through the use of

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
fossil fuels and electricity for construction equipment and vehicles. Construction would be temporary in nature. The use of general construction equipment would be required during construction activities. The contractor would keep all construction equipment in good working order and would comply with California Code of Regulations, Title 13, Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the CARB. In addition, the contractor would comply with Rule-1-430 (Fugitive Dust Emissions) of Chapter IV (Prohibitions) of Regulation 1 (Air Pollution Control Rules) of the MCAQMD’s Rules and Regulations (February 2011), which suppresses fugitive dust during construction and operation and would maintain all construction equipment in good working order such that exhaust and fugitive dust emissions are minimized. Therefore, it is anticipated that the construction phase of the Project would not result in wasteful, inefficient, and unnecessary consumption of energy. Construction of other typical industrial facilities would also be temporary in nature and would be required to comply with the abovementioned regulations, and as such, would also not result in wasteful, inefficient, and unnecessary consumption of energy.

Operation of the Project and other typical industrial facilities would not require a significant increase in energy above the current usage for operation of the existing log yard due to wasteful, inefficient, or unnecessary consumption of energy. Although the office, which was not previously utilized, would increase energy usage at the Site, the office and any other development to occur at the Site for the Project or other typical industrial uses would be subject to Part 6 (California Energy Code) of Title 24 of the California Code of Regulations, which contains energy conservation standards applicable to residential and non-residential buildings throughout California to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality (CEC, 2021). A less than significant impact would occur.

VI.b) The proposed Project and other typical industrial facilities would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. As noted above, the Project and other industrial facilities would comply with Part 6 (California Energy Code) of Title 24 of the California Code of Regulations, which contains energy conservation standards applicable to residential and non-residential buildings throughout California to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality (CEC, 2021). Therefore, a less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Energy.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
VII. GEOLOGY AND SOILS. Would the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer
to Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction
or collapse?
d) Be located on expansive soil, as defined in Table 18-1- B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property? e) Have soils incapable of adequately supporting the
use of septic tanks or alternative wastewater disposal
systems where sewers are not available for the
disposal of wastewater?
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

DISCUSSION
The Site is relatively flat and at an elevation of approximately 1,350 feet above sea level. The City of Willits and the general region experiences cool winters and hot summers, with occasional snow each year due to the mountains to the west. The City of Willits is located in the western portion of Little Lake Valley. Little Lake Valley is characterized by the coast range province known as Mendocino Highlands. The Mendocino Highlands are known by discontinuous and independent ridges and isolated valleys with a general northnorthwest trend, sub parallel to the coastline farther west.

As noted in the Public Review Draft 2019 Safety Element of the City of Willits General Plan [2019 (a)], seismic and geologic hazards in and around the City include surface fault rupture, seismic shaking, liquefaction, and landslides. The City is located within a seismically active region and in close proximity to active faults. These faults include the Maacama fault, considered an active fault by the California Geological Survey (CGS), which runs through the center of the City, and the San Andreas Fault Zone and the Bartlett Springs Fault, which run through the surrounding Mendocino County region to the east of the City [City of Willits, 2019 (a)].

As shown on the Alquist-Priolo Special Study Zones map of the Public Review Draft 2019 Safety Element of the City of Willits General Plan [2019 (a)], Figure S-2, there are no fault lines located at the Site, and the Site is not within the Alquist-Priolo Special Study Zone. However, according to the Faulting and Seismicity map, Figure S-1, the Site is located within an area of very high earthquake shaking potential [City of Willits, 2019 (a)]. The

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Site is located in the California Coast Ranges Geomorphic Province, a seismically active and geologically complex province due to historic and ongoing tectonic deformation that is characterized by northwest trending faults and topographic and geologic features (DOC, 2002). As evidenced by the flat topography of the Site and surrounding area, the Site is not in an area subject to landslides. According to the Earthquake Zones of Required Investigation [2016 (b)] and the Fault Activity Map of California [2015 (a)] of the Department of Conservation (DOC), the Maacama fault is located approximately 0.5 mile west of the Site.

Soil types in the City vary from well drained to poorly drained, including clays, silty, sand, and gravel.

According to the Natural Resources Conservation Service (NRCS, 2019), APN: 108-040-18 is comprised of 96.9 percent of Soil Unit #115 — Cole silty clay loam, 0 to 1 percent slopes, and 3.1 percent of Soil Unit #128 — Gielow sandy loam, located on the northwest corner of the parcel. Quail Meadows is comprised of 98 percent of Soil Unit #115 and 0.2 percent of Soil Unit #210—Urban land, located within the southwest portion of the parcel.

VII.a.i.) As noted above, the City is located within a seismically active region and in close proximity to active faults including the Maacama fault, , which runs through the center of the City and is considered an active fault by the CGS, and the San Andreas Fault Zone and the Bartlett Springs Fault, which run through the surrounding Mendocino County region to the east of the City [City of Willits, 2019 (a)]. As shown on the AlquistPriolo Special Study Zones map of the Public Review Draft 2019 Safety Element of the City of Willits General Plan [2019 (a)], Figure S-2, there are no fault lines located at the Site, and the Site is not within the AlquistPriolo Special Study Zone. However, according to the Faulting and Seismicity map, Figure S-1, the Site is located within an area of very high earthquake shaking potential [City of Willits, 2019 (a)]. According to the Earthquake Zones of Required Investigation [2016 (b)] and the Fault Activity Map of California [2015 (a)] of the Department of Conservation (DOC), the Maacama fault is located approximately 0.5 mile west of the Site.

As the Site is not located in an Alquist-Priolo Special Study Zone, neither the Project nor other typical industrial facilities would directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to the rupture of a known earthquake fault and a less than significant impact would occur.

VII.a.ii) As noted above, there are no mapped faults or Alquist-Priolo Special Study Zones traversing the Site.

However, since the Site is situated within a seismically active region and given the proximity of significant active faults to the Site, the Site will likely experience strong ground shaking during the economic life span of any development on the Site. Improvements at the Site due to the Project would include grading, vegetation removal, and removal of the storage units and tennis courts. Improvements would also include installation of twelve (12) log storage decks, two (2) ponds, on-site parking, internal access roads, and drainage ditches.

As required by the Fire Marshal of the Little Lake Fire District, pursuant to the 2019 CFC, the log decks at the existing log yard are a maximum of 300 feet by 500 feet (150,000 square feet). The maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshall and incorporation of sprinkled log decks. Site design of other typical industrial facilities is unknown at this time. However, construction of the proposed Project and other typical industrial facilities at the Site would be subject to the requirements of the latest version of the California Building Code (CBC). As such, a less than significant impact would occur.

VII.a.iii) According to the Public Review Draft 2019 Safety Element of the City of Willits General Plan, liquefaction occurs when intense vibrations from an earthquake cause saturated soil to lose stability and act more like a liquid than a solid. Additionally, areas near the City where groundwater is shallower than 50 feet may be prone to liquefaction; however, no historic impacts associated with liquefaction have occurred within the City [City of Willits, 2019 (a)].

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
As shown in Table 4 of this IS, the Project would require an average of up to 80,000 gpd of water, at peak use, to wet the log decks using the proposed recirculated log irrigation system. The increase of water output from the rainbird sprinklers would cause ground saturation and overland flow; however, the proposed drainage ditches would direct water flow back to the holding ponds to minimize ground saturation and prevent stagnant water. As such, the Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to seismic-related ground failure, including liquefaction. A less than significant impact would occur.

Water usage proposed under other typical industrial facilities that may be proposed in the future is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage. Details on the specific locations, capacities, and dimensions of the ponds and/or other water storage facilities would be subject to grading and/or building permits through the City. As such, it is not anticipated that other typical industrial facilities would directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to seismic-related ground failure, including liquefaction. A less than significant impact would occur.

VII.a.iv) As shown on the Landslide Susceptibility Classes figure, Figure S-3a, of the Public Review Draft 2019 Safety Element of the City of Willits General Plan, landslides present risk to portions of the City of Willits, mainly along the southern and western portion of the City. However, the Site is located within the northern portion of the City, and the majority of the Site is characterized as “low landslide susceptibility” [City of Willits, 2019 (a)]. Furthermore, the Site is relatively flat (approximately 1 percent slope) and is located at an elevation between 1,342 and 1,349 feet above mean sea level. Given the relatively low slopes, both on and adjacent to the Site, the Project and other typical industrial facilities would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death due to landslides and no impact would occur.

VII.b) The Site is relatively flat, with approximately 1 percent slope, generally draining from the southwest to the northwest. The proposed Project involves minimal grading and drainage since the Site is primarily flat.

While the proposed grading would have the potential to temporarily create erosion and loss of topsoil, the Project is proposed in an area that has been previously disturbed for the prior use as an RV park, and standard BMPs, such as straw bales, fiber rolls, and/or silt fences, would be employed to limit the potential for erosion resulting from construction and to avoid runoff into sensitive habitat areas. In addition, construction would occur during the dry season [typically May 30 through October 15] when rainfall and runoff potential would be low. Upon completion of construction, all disturbed soil would be stabilized, and bare soil vegetated, as needed, with native vegetation and/or native seed mixes for soil stabilization as soon as feasible.

Furthermore, due to the size of the Site and the nature of industrial uses, it can be assumed that construction activities of other typical industrial facilities would cause disturbance to greater than 1 acre of land and would therefore be required to comply with the CGP, which would ensure that BMPs would be implemented in accordance with a project-specific SWPPP to reduce the risk of soil erosion and loss of topsoil. The Project would also be required to comply with the CGP. As a result, the proposed Project and other typical industrial uses would not result in substantial soil erosion or the loss of topsoil, and a less than significant impact would occur.

VII.c) A landslide can occur when masses of rock, earth, or debris move down a slope and can be accompanied by heavy rains or following a drought, earthquakes, or volcanic eruptions. Majority of the Site is characterized as “low landslide susceptibility,” according to Figure S-3a, Landslide Susceptibility Classes,

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
per the Public Review Draft 2019 Safety Element of the City of Willits General Plan. The eastern portion of the Site may be subject to flooding as it is within the 100-year flood hazard zone, according to Figure S-4, FEMA Flood Zones [City of Willits, 2019 (a)]. Additionally, although the Site is not located within a mapped AlquistPriolo Special Study Zone, the Site is located within a seismically active region and would likely experience ground shaking during the economic lifespan of the Project. However, given the relatively low slopes, both on and adjacent to the Site, neither the Project nor other typical industrial facilities would directly or indirectly cause potential substantial adverse effects. As such, a less than significant impact would occur.

VII.d) Expansive soils generally consist of cohesive fine-grained clay soils and represent a significant structural hazard to buildings constructed on them as they have a tendency to undergo volume changes (shrink or swell) with changes in moisture content. According to NRCS (2019), as previously discussed, APN: 108-040-18 is comprised of 96.9 percent of Soil Unit #115 — Cole silty clay loam, 0 to 1 percent slopes, and 3.1 percent of Soil Unit #128 — Gielow sandy loam, located on the northwest corner of the parcel. Quail Meadows is comprised of 98 percent of Soil Unit #115 and 0.2 percent of Soil Unit #210—Urban land, located on the southwest portion of the parcel. No known expansive soils are located at the Site. The increased water output from the rainbird sprinklers would cause ground saturation and overland flow but would be captured by a series of drainage ditches to direct flow back to the holding ponds. The subsurface soils are unlikely to be affected by the proposed increased water output and, therefore, a less than significant impact would occur.

The water usage proposed under other typical industrial facilities that may be proposed in the future is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage. Additionally, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the Statewide General Permit for Stormwater Discharges Associated with Industrial Activities, Order 2014-0057-DWQ (IGP), administered by the SWRCB. As increased water output from the Project would not be anticipated to affect subsurface soils in a way that would cause substantial direct or indirect risks to life or property, other typical industrial facilities would also have a less than significant impact.

VII.e) A sewage pumping station exists near the office structure. Sewer lines run to the pumping station from the office and old infrastructure from the previous RV park. The sewage pumping station connects to the main line, which is serviced by the City of Willits. Additionally, a recirculating log irrigation system is anticipated to be utilized to wet the log decks. The proposed system would utilize the 1.0 ac-ft and 0.85 ac-ft holding ponds and series of return ditches to collect and transport the water back to the holding ponds rather than disposing the water into the sewer system. As such, no impact would occur.

Other typical industrial facilities would have the potential to increase wastewater generation at the Site.

However, details on Site development for a typical industrial facility, including wastewater improvements, would be subject to grading and/or building permits through the City. As such, a less than significant impact would occur.

VII.f) The potential exists for unique paleontological resources or unique geological features to be encountered at the Site during ground-disturbing construction activities, including excavation for grading and installation of the irrigation pond; however, the potential is low as the Site has been previously disturbed for former uses, including an RV park. In the event that any archaeological or paleontological resources are discovered during Site preparation or other earth-disturbing construction activities, either for the Project or other typical industrial uses, the contractor would immediately halt all work and contact the City’s

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Community Development Department and a qualified paleontologist, as required by Mitigation Measure GEO-1. With Mitigation Measure GEO-1 incorporated, a less than significant impact would occur.

MITIGATION MEASURES
GEO-1: In the event that paleontological resources, including individual fossils or assemblages of fossils, are encountered during construction activities all ground disturbing activities shall halt, and the City’s Community Development Department shall be contacted. Additionally, a qualified paleontologist shall be procured to evaluate the discovery and make treatment recommendations.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact With Mitigation Incorporated on Geology and Soils.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
VIII.GREENHOUSE GAS EMISSIONS. Would the
project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Generate greenhouse gas emissions (GHG), either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?

DISCUSSION
The Global Warming Solutions Act of 2006, also known as Assembly Bill (AB) 32, is a State law that establishes a comprehensive program to reduce GHG emissions from all sources throughout the State. AB 32 requires the State to reduce its total GHG emissions to 1990 levels by 2020, a reduction of approximately 15 percent below emissions expected under a “business as usual” scenario. Pursuant to the AB 32 Scoping Plan (last reviewed in 2018), the CARB must adopt regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. The following major GHGs and groups of GHGs being emitted into the atmosphere are included under AB 32: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3).

The 2020 GHG emissions statewide limit set by AB 32, equal to the 1990 level, is 431 million metric tons of carbon dioxide equivalent (MMTCO2e). In addition, in 2016, SB 32 was signed into law to codify the reduction target to reduce GHG emissions to 40 percent below the 1990 levels by 2030 (CARB, 2018).

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

The Site is located within the NCAB and is subject to the requirements of the MCAQMD. The MCAQMD is responsible for monitoring and enforcing federal, state, and local air quality standards in the Mendocino County. As noted in the Resource Management Element of the Mendocino County General Plan (2020), due to the rural nature of Mendocino County, the amount of GHG generated by human activities (primarily the burning of fossil fuels for vehicles, heating, and other uses) is small as compared to other, more urban counties and miniscule in statewide or global terms. However, GHG emissions in Mendocino County are higher per capita due to the distances involved in traveling around the county.

Improvements proposed for the Project generally include vegetation removal, grading, and reuse or removal of existing structures. Vegetation removal and grading activities would facilitate the construction of rocked log storage areas, internal access roads, and access points between the existing log yard and the Site, parking near the office, and two (2) water storage ponds. The Site would be leveled and surfaced with compacted base rock, sufficient to withstand log storage and truck traffic. Gravel access roads would be maintained, upgraded, and/or constructed, as needed, to facilitate on-site circulation and to connect the existing log yard and the Site. General construction equipment would be utilized during and would be maintained in working condition throughout Project construction. One (1) new employee is anticipated to be required to serve the Project, supporting four (4) full-time staff and one (1) seasonal employee at the existing log yard.

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Development of the Site for a typical industrial facility would generally include vegetation removal; grading for access roads, building pads, and parking areas; landscaping; installation of water storage facilities such as water tanks and/or ponds to serve as back-up water supplies and for fire suppression needs; reuse and/or removal of existing structures; infrastructure improvements related to water supply, wastewater, solid waste, and storm drainage; regular maintenance activities; and in many cases, construction of new structures.

Operation of a typical industrial facility would be subject to Code Chapter 17.50 – Performance Standards.

Pursuant to Code Section 17.50.040 – Locations where determinations are made for enforcement of performance standards (1982), compliance with performance standards would generally be enforced within five hundred (500) feet of the Project Area. Operations would be anticipated to generally occur between 7:00am and 7:00pm up to six (6) days per week. Typical operational activities would be anticipated to include employee trips to the typical industrial facility, operation of heavy equipment within and outside of structures, heavy truck traffic to/from the facility for materials transfers, and use of machinery within structures.

A Focused Traffic Study was prepared by W-Trans on November 29, 2023 (Appendix E), to assess the potential transportation related impacts associated with the proposed Project and other typical industrial facilities.

VIII.a) The Project and other typical industrial facilities would not generate GHG emissions either directly or indirectly, that may have a significant impact on the environment, as construction would not generate significant amounts of GHG emissions above the baseline conditions. A limited amount of GHG emissions would be anticipated to occur during construction activities; however, it is anticipated that construction would be temporary and would not result in wasteful, inefficient, and unnecessary consumption of energy.

To reduce the potential for GHG emissions during construction, the contractor would keep all construction equipment in good working order and comply with California Code of Regulations, Title 13, Section 2485:

Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (adopted 2005), which limits idling from both on-road and off-road diesel-powered equipment and is enforced by the CARB.

Once construction is complete, Project operations would not generate an increase in GHG emissions from the Site, as the overall Project VMT is expected to be reduced. The Project is expected to reduce heavytruck trips between Eureka and Willits, which would lower the overall VMT due to the Project. Additionally, operation of the Project would not require a significant increase in energy above the current usage for operation of the existing log yard. Although the office structure, which has not been utilized for regulation operations since operation of the RV park, would increase energy usage at the Site, the office and any other development to occur at the Site in the future would be subject to Part 6 (California Energy Code) of Title 24 of the California Code of Regulations, which contains energy conservation standards applicable to residential and non-residential buildings throughout California to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality (CEC, 2021).

Operation of other typical industrial facilities would not generate a significant increase in GHG emissions from the Site. The Focused Traffic Study used standard trip generation rates for various uses to analyze potential trip generation of other typical industrial facilities. Table 1 of the Focused Traffic Study (Appendix E) shows

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
that trip generation for light industrial uses are substantially lower than those for typical commercial uses, such as office, retail, or service uses (W-Trans, 2023). The proposed Rezone is for MH, heavy industrial, rather than light industrial. However, commercial uses tend to generate a higher number of trips, as commercial uses are often utilized by the public. Light and heavy industrial uses are not utilized by the public to the same level as commercial uses. Based on a review of the uses permitted in C1, C2, and MH in Table 2 of this IS, it appears that uses permitted in C1 and C2 tend to involve more interaction with the public than uses permitted in MH.

Based on the substantially lower trip generation of light industrial uses than typical commercial uses and the nature of public utilization of commercial uses, it is reasonable to anticipate that other typical industrial facilities permitted by the GPA and Rezone would result in lower trip generation than would be anticipated with the existing zoning designation of C1 and C2. Furthermore, other typical industrial development at the Site would be subject to Part 6 (California Energy Code) of Title 24 of the California Code of Regulations, which contains energy conservation standards applicable to residential and non-residential buildings throughout California to ensure new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality (CEC, 2021).

As the Project and other typical industrial facilities would only generate minimal GHG emissions during construction, would not result in wasteful, inefficient, and unnecessary consumption of energy, and would not be anticipated to increase VMT during operation, a less than significant impact would occur.

VIII.b) The proposed Project and other typical industrial facilities would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Action Item RM-50.2 in the Resource Management Element of the Mendocino County General Plan (2020) requires the County to “create a greenhouse gas reduction plan for the unincorporated areas of the county that sets specific reduction strategies and targets to meet.” Although the County has not yet prepared and adopted this plan, a significant amount of GHG emissions is not anticipated under the Project or other typical industrial facilities, as described above. In addition, the proposed Project and other typical industrial facilities would not conflict with local, MCAQMD, State, or federal regulations pertaining to GHG emissions, since the proposed Project and other typical industrial facilities would have a negligible impact on the current GHG emissions from the Site. A less than significant impact would occur.

MITIGATION MEASURES
No mitigation required.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Greenhouse Gas Emissions.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
IX. HAZARDS AND HAZARDOUS MATERIALS. Would
the project:

Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project result in a safety hazard or excessive noise for people residing or working in the project
area?
f) Impair implementation of, or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?

DISCUSSION
A material is considered hazardous if it appears on a list of hazardous materials prepared by a federal, state, or local agency, or has characteristics defined as hazardous by a federal, state, or local agency. Chemical and physical properties such as toxicity, ignitability, corrosiveness, and reactivity cause a substance to be considered hazardous. These properties are defined in the California Code of Regulations, Title 22, Article 3:

Characteristics of Hazardous Waste (effective July 1, 1991). A “hazardous waste” includes any hazardous material that is discarded, abandoned, or will be recycled. The criteria that render a material hazardous also cause a waste to be classified as hazardous, according to the California Health and Safety Code, Chapter

6.5, Section 25117 (effective January 1, 1997).

Mendocino County has adopted numerous plans related to hazard management and mitigation including, but not limited to: Community Wildfire Protection Plan (2005), Hazardous Waste Management Plan, Emergency Operations Plan, and Multi-Jurisdictional Hazard Mitigation Plan (2021), in which the City is a participant (County of Mendocino, 2020). In addition, in October 2019, the City released a Public Review Draft of the 2019 Safety Element of the City of Willits General Plan to identify safety risks the City faces and develop goals, policies, and implementation programs to better address the issues.

GeoTracker is an online database that provides state-wide data of authorized or unauthorized discharges of waste to land, or unauthorized releases of hazardous substances from underground storage tanks. This

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
system consists of a relational database, on-line compliance reporting features, a geographical information system (GIS) interface, and other features that are utilized by the SWRCB, regional boards, local agencies, regulated industry, and the public to input, manage, or access compliance and regulatory tracking data.

Additionally, EnviroStor, managed by the Department of Toxic Substances Control (DTSC), is an online database for tracking cleanup, permitting, enforcement, and investigation efforts at hazardous waste sites with known or suspected contamination. Both these databases were queried, and three (3) sites were listed within the general vicinity of the Site, approximately 15 feet west, 514 feet west, and 525 feet north of the Site. All three (3) sites were caused by leaking underground storage tanks and the clean-up of all three sites was completed in 1996, 1997, and 2008, respectively. However, no active sites were listed at the Site. See Appendix G for maps depicting the Site in relation to active sites on these databases.

The Project, as well as other typical industrial facilities, would require the transport, use, storage, and disposal of small quantities of hazardous materials common for construction, equipment, site maintenance, and operation, such as gasoline, diesel fuel, hydraulic fluids, oils, lubricants, and cleaning solvents and supplies.

However, all hazardous materials would be utilized and disposed of in accordance with all applicable federal and state regulations. The existing log yard contains a mobile self-contained 1,000-gallon fuel tank, located near the main gate to the log yard. If needed on the Site in the future, it may be placed in the southwestern corner of the Site, near the Quail Meadows entrance; however, for the foreseeable future it is anticipated that the fuel tank would stay in its current location on the existing log yard. For reference, the possible location on the Site is shown on Figure 5: Site Plan. All other chemical storage is located within the two (2), 450-square-foot shipping containers in the southwest portion of the existing log yard. The approximate location of these shipping containers is shown on Figure 5: Site Plan.

IX.a-b) In Mendocino County, the transport, storage, and use of hazardous materials is regulated by the Office of Hazardous Materials Safety of the United States Department of Transportation (USDOT), Title 49 of the Code of Federal Regulation (CFR), Resource Conservation Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Occupational Safety and Health Administration (OSHA),Title 13 of the California Code of Regulations (CCR) California Health and Safety Code Sections 25100 et seq., California Division of Safety and Health (DOSH), and Mendocino County Environmental Health. Chapter 6.95 of the California Health and Safety Code requires businesses that handle more than a specified amount of hazardous materials on-site to submit a Hazardous Materials Business Plan (HMBP) to firefighters, health officials, planners, public safety officers, health care providers, regulatory agencies, and other interested persons. The HMBP must include an inventory of hazardous materials handled, facility floor plans showing where hazardous materials are stored, an emergency response plan, and provisions for employee safety and emergency response training.

The proposed Project would not cause the transport, use, emission, or disposal of significant amounts of hazardous materials, nor create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. During the construction phase, small quantities of hazardous materials common to equipment maintenance and operation, such as gasoline, diesel fuel, hydraulic fluids, oils, and lubricants, may be required. Once constructed, the Project would be anticipated to utilize small quantities of hazardous materials for operations, such as fuels, lubricants, solvents, and chemicals used for routine log yard operations. Equipment used for the operation of the Project would include but not be limited to two (2) Caterpillar 966 front end loaders, or equivalent, two (2) Caterpillar 568 Heel Boom Log Loader, or equivalent, and one (1) water truck. As described above, a mobile self-contained 1,000-gallon fuel tank, maybe relocated from near the main gate to the existing log yard to the southwestern corner of the Site; however, for the foreseeable future it is anticipated that the fuel tank would stay in its current location on the existing

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
log yard. All other chemical storage is located within the two (2), 450-square-foot shipping containers in the southwest portion of the existing log yard. The types and quantities of materials to be used are not expected to pose a significant risk to the public and/or environment and would be managed in accordance with the abovementioned federal, state, and local regulations.

Operation of other typical industrial facilities may require transport, use, emission, or disposal of various hazardous materials. However, if a future typical industrial facility at the Site requires more hazardous materials than the amount specified in Chapter 6.95 of the California Health and Safety Code, preparation of a HMBP would be required. Since the transport, use, and storage of any hazardous materials at the Site for the Project or other typical industrial facilities would be required to be conducted in accordance with federal, state, and local regulations, a less than significant impact would occur.

IX.c) The Site is located approximately 600 feet (0.11 mile) north of Willits High School. The Project would be anticipated to utilize small quantities of hazardous materials for operations, such as fuels, lubricants, solvents, and chemicals used for routine log yard operations. As described above, a mobile self-contained 1,000- gallon fuel tank, maybe relocated from near the main gate to the existing log yard to the southwestern corner of the Site; however, for the foreseeable future it is anticipated that the fuel tank would stay in its current location on the existing log yard. If the fuel tank were to be relocated, it would be moved further from Willits High School. The fuel tank and other hazardous materials utilized for the Project or other typical industrial facilities would be managed in accordance with the abovementioned federal, state, and local regulations. As such, the quantity or application of hazardous materials would not be expected to impact Willits High School, and a less than significant impact would occur.

IX.d) Review of the SWRCB’s GeoTracker and DTSC’s EnviroStor databases indicates that the Site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. As discussed above, any hazardous materials to be used on-site would be utilized, stored, transported, and disposed of in accordance with federal, state, and local regulations. No impact would occur.

IX.e) The nearest airport to the Site is the Ells Field (Willits Municipal Airport), located approximately 1.88 miles northwest of the Site at its closest point. According to the Mendocino County Airport Comprehensive Land Use Plan (ACLUP, 1996), the Site is not located within the compatibility boundary of the Ells Field (Willits Municipal Airport) (County of Mendocino, 1996). As such, a less than significant impact would occur.

IX.f.) There are no components of the Project that would impair or interfere with emergency response or evacuation. The proposed expansion of the existing log yard operation would be constructed in accordance with State and local standards, including safety and emergency access requirements. The proposed Project would comply with all requirements of the Little Lake Fire District, including a maximum log deck size of 300 feet by 500 feet, a 100-foot separation from other log decks and exposures, and maintaining vehicle access to all log decks, ponds, and on-site hydrants. Additionally, the maximum deck height has been expanded from 20 feet to 30 feet with approval from the Fire Marshall and incorporation of sprinkled log decks. Since the Site is designed for large logging trucks, it is anticipated that all types of vehicles, including emergency responders, would be able to adequately navigate the Site. As such, the proposed Project would not have a significant impact on emergency response or evacuation at the Site, and there are no components of the Project that would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Other typical industrial facilities would not be anticipated to impair or interfere with emergency response or evacuation. Building permit applications for a typical industrial facility would be subject to review by the

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Little Lake Fire District for compliance with the version of the CFC in place at the time of building permit application submittal, and conditions would be implemented to ensure the project does not impair or interfere with emergency response or evacuation. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed. Therefore, a less than significant impact would occur.

IX.g) As described above, the Site is located north of the City center on two (2) parcels that are not currently utilized and are predominately undeveloped. Both parcels are within the Local Responsibility Area (LRA).

According to the California Department of Forestry and Fire Protection (CAL FIRE) LRA Fire Hazard Severity Zone Maps (2024), the majority of the Site is located within a “Moderate” fire hazard severity zone.

The proposed Project components may cause increased exposure of people or structures to a significant risk of loss, injury or death involving wildland fires. However, as required by the Fire Marshal of the Little Lake Fire District, pursuant to the 2019 CFC, the log decks at the existing log yard are a maximum of 300 feet by 500 feet (150,000 square feet), with an approved 30-foot deck height, and a similar design is proposed on the subject Site. The proposed Project would comply with all requirements of the Little Lake Fire District, including the maximum log deck size, a 100-foot separation from other log decks and exposures, and maintaining vehicle access to all log decks, ponds, and on-site hydrants. The Site contains four (4) existing wells in addition to the proposed irrigation ponds, which would be available for fire suppression needs. As required by Mitigation Measure HAZ-1, an EAP would be prepared prior to operation of the expanded log yard, which would include fire prevention, mitigation, and response strategies. The EAP would include, but not be limited to access requirements, evacuation routes and procedures, employee trainings, deck orientation maps, adequate water supply, on-site firefighting equipment, and fire prevention and mitigation. By complying with conditions of the Little Lake Fire District and Mitigation Measure HAZ-1, a less than significant impact would occur.

Other typical industrial facilities may also expose people or structures to a significant risk of loss, injury, or death involving wildland fires. However, building permit applications for a typical industrial facility would be subject to review by the Little Lake Fire District for compliance with the current version of the CFC at the time of building permit application submittal, and conditions would be implemented to ensure a project does not impair or interfere with emergency response or evacuation. Typical conditions would be anticipated to be related to maintaining site access and circulation for emergency equipment, emergency water supply, property signage, flammable materials storage, and other conditions as required by the Fire Marshal in accordance with the current CFC at the time a project is proposed. Additionally, Mitigation Measure HAZ-1 would require the preparation of an EAP, which would include fire prevention, mitigation, and response strategies. With mitigation incorporated, a less than significant impact would occur.

MITIGATION MEASURES
HAZ-1: Prior to operation of the project and future proposed projects, the project proponent shall prepare an EAP to the satisfaction of the Little Lake Fire District. The EAP shall describe plans and preparedness for emergency response. This includes a list of emergency contacts, access requirements, evacuation routes and procedures, employee trainings, deck orientation maps, adequate water supply, and on-site firefighting equipment. Firefighting equipment to keep on-site for use in emergencies may include but not be limited to a water truck, fire extinguishers, fire tools, and a portable foaming fire suppression system. The EAP shall also include fire prevention and mitigation strategies, including identification of potential fire hazards, general housekeeping, and required training. Implementation of the EAP shall provide employees with the ability to put out a 10-foot by 10-foot, or equivalent, spot fire should the need arise. For uses involving bark storage, a

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
Bark Management Plan shall be included as part of the EAP. The Bark Management Plan shall include general management techniques, strategies to reduce the risk of bark piles catching on fire, response protocols, and other details as required by the Little Lake Fire District.

FINDINGS
The proposed Project and other typical industrial facilities would have a Less Than Significant Impact on Hazards or Hazardous Materials.

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City of Willits
Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
X. HYDROLOGY AND WATER QUALITY. Would the
project:

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

DISCUSSION
The National Pollutant Discharge Elimination System (NPDES) permit program of the EPA addresses water pollution by regulating point sources that discharge pollutants to waters of the United States. Created in 1972 by the CWA, the NPDES permit program grants authority to state governments to perform a portion of the permitting, administrative, and enforcement aspects of the program. Within California, the NPDES permit program is administered by the SWRCB and the Regional Water Quality Control Boards. Construction projects that would disturb more than 1 acre of land, such as the proposed Project, would be subject to the requirements of the CGP, which requires operators of such construction sites to implement stormwater controls and develop a SWPPP identifying specific BMPs to be implemented to minimize the amount of sediment and other pollutants associated with construction sites from being discharged in stormwater runoff.

Construction within the City is subject to the 100% Draft City of Willits Design and Construction Standards (City Standards), updated November 12, 2011. The City Standards requires that contractors prepare and implement a program to control water pollution on construction projects that result in 1 acre or more of soil disturbance, in accordance with the CGP of the SWRCB, as described above.

According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) panel number 06045C1111G, effective September 1, 2022, the majority of the Site is designated as Zone X (unshaded), which is defined as an area of minimal flood hazard (Appendix H). However, the eastern portion of the Site is designated as Zone AE and Zone X (shaded). Zone AE, or the Special Flood Hazard Area (SFHA),

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
is defined as the area that will be inundated by the flood event having a 1-percent chance of being equaled or exceeded in any given year. The 1-percent annual chance flood is also referred to as the base flood or 100-year flood. The portion of the Site that is designated as Zone AE has a base flood elevation (BFE) of 1,342 feet to 1,349 feet. Zone X (shaded), or the moderate flood hazard area, is defined as the area that will be inundated by the flood event having a 0.2-percent chance of being equaled or exceeded in a given year.

The 0.2-percent annual chance flood is also referred to as the 500-year flood.

The Site is located within the Little Lake Valley Groundwater Basin (Basin). The Little Lake Valley Groundwater Management Plan (LLVGMP) represents “the initial effort on the part of the City of Willits to develop a plan for sustainable management of groundwater in the Little Lake Valley” (LACO, 2020). The LLVGMP is a voluntary and non-regulatory document. The main source of groundwater recharge in the Basin is precipitation, and while groundwater levels in the Basin fluctuate in response to pumping and precipitation, long-term groundwater levels have been observed to be relatively flat to slowly recovering from heavy well pumping and drought. Furthermore, Chart 4-1 of the LLVGMP shows that groundwater levels in the Basin recover quickly from declines in groundwater levels due to heavy pumping and drought. The LLVGMP did not identify any overdraft issues in the Basin, and as such, did not recommend any mitigation or actions to manage overdraft conditions (LACO, 2020).

Six (6) seasonal wetlands, totaling approximately 1 acre, exist within the Site that may be considered jurisdictional features regulated under Section 401 and Section 404 of the CWA. Additionally, there are seven (7) drainage ditches at the Site, as described in Section IV (Biological Resources). The ephemeral and intermittent ditches throughout the Site drain into an unnamed tributary to Mill Creek, east of the Site, which is mapped as a Water of the U.S. The unnamed tributary to Mill Creek flows under the Highway 101 bypass into Mill Creek, approximately 0.3 miles north of the Site (Clifton, 2022).

Water sources and storage would be required for sprinkling log decks and emergency fire suppression.

Existing water sources consist of three (3) wells on the Site, each of which provides an existing yield of 5 to 35 gallons per minute (gpm), and an additional well and water tank on the existing log yard. Four (4) City fire hydrants are located within the vicinity of the Site, with the closest hydrant located approximately 200 feet southwest of the existing office structure. The Applicant intends to install up to three (3) additional log-yard fire hydrants such that no log deck is greater than 600 feet from a City or log-yard fire hydrant. It is anticipated that the two (2) proposed irrigation ponds would store water for use in the log-yard fire hydrant system, when needed.

A recirculating log irrigation system is proposed for wetting the log decks. The proposed system would generally consist of up to two (2) holding ponds and series of return ditches to collect and transport the water back to the ponds. A pump station at the end of the ponds would charge an approximately 12-inch PVC manifold that would run to the ends of the log decks. From there a 2-inch poly line would be run across the top of the decks from one end to the other and a series of rainbird sprinkler heads would be installed at intervals needed for sufficient coverage. The increased water output from the rainbird sprinklers would cause ground saturation and overland flow, which would be captured by a series of drainage ditches to direct flow back to the ponds. To combat evaporation, the wells would be plumbed to the pond to supply make-up water, as needed, to keep the pond full and pumps primed. It is anticipated that an average of up to 80,000 gallons per day (gpd), peak usage (accounting for evaporation and dust abatement uses) could be required from July through October. During the months of May, June, and November, the estimated water usage would be approximately 40,000 gpd and little to no water would be anticipated to be required for the remainder of the year (December through April, which generally coincides with the rainy season). This would equate to approximately 41.5 acre-feet per year, as shown in Table 4 of this IS. The Applicant

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Sanhedrin Timber Company General Plan Amendment, Rezone, and Boundary Line Adjustment May 2025 ~ Revised September 2025
anticipates that the four (4) existing wells plus the up to three (3) proposed wells would be sufficient for meeting the needs of the current and expanded log yards, with the proposed ponds available for irrigation water storage and fire suppression needs.

In a typical industrial facility, water sources and storage would be required for daily operation and emergency fire suppression. The water usage proposed under typical industrial facilities principally permitted within the MH zoning district that may be proposed in the future is anticipated to be comparable to, and possibly less than, the Project due to the importance of water in the log yard for keeping logs wet during storage. Details on the specific locations, capacities, and dimensions of the ponds and/or other water storage facilities would be subject to grading and/or building permits through the City.

X.a) The proposed Project and other typical industrial facilities would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. As discussed above, construction activities associated with the Project and typical industrial facilities would be subject to the standards of the CGP, which requires the preparation of a SWPPP with BMPs designed to prevent, at a minimum, erosion resulting from construction activities and minimize the discharge of sediment and other pollutants associated with construction sites. Adherence to the post-construction requirements of the CGP would ensure that the proposed Project and other typical industrial facilities would comply with applicable water quality standards post-construction. Additionally, industrial facilities such as manufacturers, landfills, mining, steam generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities would also be subject to coverage under the IGP, administered by the SWRCB.

Through proper implementation of appropriate BMPs and compliance with the aforementioned regulations, the proposed Project would not violate any water quality standards or waste discharge requirements, and a less than significant impact would occur.

X.b) As discussed above, the proposed Project is anticipated to use approximately 41.5 ac-ft annually, primarily between the months May through November. However, the Project is not expected to substantially decrease groundwater supplies or interfere with groundwater recharge such that the Project may impede sustainable groundwater management of the basin. Groundwater usage in the area is expected to be fairly low, as most water users in the area obtain water services through the City of Willits. Figure 3-6 of the LLVGMP shows that well density is low in the area surrounding the Site, as there were only 5 to 10 wells located in the section of Figure 3-6 that includes the Site as of 2020. Additionally, the LLVGMP found that the Basin recovers quickly from declines in groundwater levels and did not identify any overdraft issues in the Basin.

A Well Impact Report prepared by VESTRA Resources and dated October 5, 2023, determined that each of the three (3) proposed wells for the Project would have a drawdown of less than one foot at the nearest structure, nearest off-site well, and within a one-mile radius (Appendix I). Based on these results, the extraction of groundwater from the proposed wells and the nearby adjacent existing wells is not likely to interfere with the production and function of existing nearby wells and are not likely to cause subsidence that would adversely impact or damage nearby infrastructure. As such, water usage for the Project is not anticipated to substantially decrease groundwater supplies or interfere with groundwater recharge, and a less than significant impact would occur.

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Willits City CouncilOctober 8, 2025

Willits City Council
October 8, 2025