~ Introduction ~

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PURPOSE OF EIR

This Environmental Impact Report (EIR) for the Brooktrails Township Specific Plan (the "project"), has been prepared in conformance with the provisions of the California Environmental Quality Act (CEQA) Guidelines as amended. The purpose of this EIR is to provide the County of Mendocino (Lead Agency), public agencies and the public in general with detailed information about the environmental effects of implementing the Brooktrails Township Specific Plan, and to examine and institute methods of mitigating any adverse environmental impacts should the Specific Plan be adopted by the Mendocino County Board of Supervisors for implementation, and to consider alternatives to the Specific Plan as proposed. CEQA provides that public agencies should not approve projects as proposed (in this case the Brooktrails Township Specific Plan), until all feasible means available have been employed to substantially lessen the significant effects of such projects. "Feasible" means capable of being accomplished in a successful manner within a reasonable period of time.

The EIR will be considered at public hearings by officials of the County of Mendocino, including the Planning Commission and Board of Supervisors, and the Brooktrails Township Community Services District Board of Directors prior to any decisions being made on modifying and/or adopting the Brooktrails Township Specific Plan. Certification of the Final EIR by the County of Mendocino as complete and adequate in conformance with CEQA does not grant any approvals to the Specific Plan. The merits of the Brooktrails Township Specific Plan will be considered separately by the Mendocino County Planning Commission and Board of Supervisors after certification of the EIR.

The Brooktrails Township Specific Plan is available for public inspection and review at the Mendocino County Department of Planning and Building Services, Courthouse, Ukiah, Calif., 95482, the Brooktrails Township Community Services District office, 24860 Birch Street, Willits, Calif., 95490, and County libraries in Ukiah (105 North Main Street) and Willits (390 East Commercial Street).

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EIR SCOPING

In October of 1995, the County of Mendocino, Department of Planning and Building Services, issued a Notice of Preparation that an EIR would be prepared for the Brooktrails Township Specific Plan. The Notice was submitted to Federal agencies (i.e., U.S. Army Corps of Engineers, U.S. Department of the Interior Geological Survey and Fish and Wildlife Service, local agencies (i.e., Mendocino County Water Agency, Mendocino County Department of Public Works, City of Willits), and the State Office of Planning and Research. The State Office of Planning and Research in turn forwarded the Notice of Preparation on to Responsible State agencies including the California Department of Fish and Game, Department of Transportation, Department of Water Resources and other State agencies. The purpose of the Notice was to allow these and other public agencies to transmit their concerns and comments on the scope and content of the EIR, focusing on specific information related to their own statutory responsibility early in the environmental review process.

In response to the Notice, letters of comment were received from the following:

In addition, an agency/public EIR scoping meeting was held at the Brooktrails Township Community Center on the morning of October 24, 1995 at 10:00 AM. The meeting was noticed by the County of Mendocino and Brooktrails Township in advance of the scoping meeting. The purpose of the scoping meeting was to allow agency representatives, organizations, individuals and the public at large to express the environmental concerns that should be addressed in the EIR. There were no attendees.

In response to letters received as a result of the Notice of Preparation, all correspondence was passed on to the EIR preparers for their consideration in preparing the Draft EIR for the Brooktrails Township Specific Plan, and it was determined that a full EIR would be prepared for the Specific Plan. Major EIR issues were determined to be the following:

• Land Use;
• Traffic and Circulation;
• Visual Quality and Community Character;
• Utilities;
• Public Services;
• Cultural Resources;
• Soils, Geology and Seismicity;
• Hydrology and Water Quality;

• Vegetation and Wildlife;
• Air Quality;
• Noise; and
• Growth Inducements.

The environmental effects of implementing the Brooktrails Township Specific Plan are analyzed under each major topic categories as listed above. The CEQA Guidelines define the effects of a project as changes from the environmental setting (existing conditions), that are attributable to the project. Short-term construction impacts as well as the long-term operational impacts are described as appropriate for each topic.

PROGRAM EIR
Because of the complex nature of the Brooktrails Township Specific Plan, this EIR presents the environmental setting and findings of impacts and mitigation measures in a consistent format for comprehension.

The Specific Plan itself is treated as the "project". The Specific Plan is addressed in a general way, similar to the way an EIR would address a City or County General Plan. This is because the Specific Plan is not specific to any single project that would be proposed for construction by the Brooktrails Township Community Services District or an individual (for example a water impoundment feature for domestic water supply or a commercial development). This is consistent with CEQA Guidelines Section 15146 which provides that the degree of specificity required in an EIR should correspond to the degree of specificity involved in the underlying activity which is described in the EIR.

In addition, the EIR analysis of the Specific Plan addresses cumulative development. This means that buildout of the Specific Plan Area is addressed in the assessment of environmental impacts, rather than addressing only a portion of the Specific Plan. This EIR that addresses the Specific Plan is developed as a "Program" EIR under CEQA. A "Program" EIR is an EIR which is prepared on a series of actions that can be characterized as one large project that are geographically related.

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There are basic advantages to the Program EIR level of analysis. For example, a Program EIR provides for a more exhaustive consideration of the effects and alternatives than would be practical for an EIR on an individual action (such as an individual project comprising only a part of the Specific Plan area development). In addition, a Program EIR ensures the consideration of cumulative impacts that otherwise could be overlooked on a case-by-case basis, avoids duplicative reconsideration of basic policy issues, and allows the Lead Agency under CEQA (the County of Mendocino), to consider broad policy alternatives and area wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts. Subsequent activities in the program, for example new access roads, may be later examined in the light of the Program EIR in order to provide additional environmental documentation.

STANDARD FOR ADEQUACY
Section 15151 of the CEQA Guidelines specifies that an EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information that enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Where a particular project effect is too speculative for evaluation, discussion of the effect is ended. What is desired is completeness and a good faith effort at full disclosure.

SIGNIFICANT EFFECT ON THE ENVIRONMENT
In accordance with Section 15143 of the CEQA Guidelines, this EIR focuses on the significant effects on the environment. Each major topic (i.e., Hydrology, Vegetation and Wildlife), provides criteria for evaluating whether an environmental impact is significant or insignificant. As explained in Section 15002 (g) of the CEQA Guidelines, a significant effect on the environment is defined as a substantial adverse change in the physical conditions which exist in the area affected by the proposed project.

The definition of impact using terms such as "beneficial" or "insignificant" is not defined in the CEQA Guidelines, but for purposes of this EIR a beneficial environmental impact is one in which an environmental condition is enhanced or improved, while an insignificant environmental impact is one in which there is no long or short-term significant adverse change in environmental conditions.

Determining that a mitigation measure reduces an impact's significant level to a level of insignificance

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rests with understanding the criteria for determining a significant impact. If the criteria for determining a significant impact is not met, the impact is considered insignificant. For one or more significant unavoidable impacts that cannot be substantially mitigated, the Lead Agency (County of Mendocino), under CEQA must prepare a Statement of Overriding Considerations in which the Lead Agency sets forth its views in writing on the ultimate balancing of the merits of approving a project despite the environmental impacts which may result from project implementation. This process requires consideration of the decision maker (the Lead Agency), to balance the benefits of a proposed project against its potential unavoidable environmental impacts in determining whether to approve a project. The Statement is preserved in the record of project approval (if a project is approved), and is prepared after the Final EIR has been completed and certified as complete and adequate.

In the discussion of environmental impacts and mitigation measures in this EIR, a code is used to convey information regarding the significance of impacts before and after mitigation. The codes and their meanings are as follows:

(S) = Significant adverse impact
(PS)= Potentially Significant adverse impact
(B) = Beneficial impact
(I) = Insignificant impact

In Section 3, Environmental Setting, Impacts and Mitigation Measures, the impacts for each environmental topic are numbered, with one of the above codes following the discussion of impact. In addition, each mitigation measure for an environmental impact is similarly numbered with one of the above codes following the discussion of a mitigation measure. Cumulative impacts resulting from growth, inclusive of regional growth, that would affect the Township are specified in each technical section of the EIR where such cumulative impacts have been identified.

MITIGATION MONITORING AND REPORTING
The California Environmental Quality Act (CEQA) requires public agencies to adopt mitigation monitoring and reporting programs, for changes to a project to mitigate or avoid significant effects on the environment.

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CEQA requires that a monitoring and reporting program be adopted "When making findings required by
subdivision (a) of Section 21081 (Public Resources Code), or when adopting a (mitigated)
Negative Declaration -." The monitoring and reporting program need not be a component of the EIR. The
program is part of the project approval process, not necessarily part of the impact analysis process.

A Draft Mitigation Monitoring and Reporting Program has been prepared for the Specific Plan project
(Appendix C). The mitigation monitoring and reporting program is intended to identify each mitigation
measure for a significant environmental impact and indicate the responsible party or agency to conduct the
monitoring and reporting program.