~ Summary ~

Currently, Lake Emily and Lake Ada Rose at Brooktrails provide sufficient domestic water supply for approximately 2,000 equivalent single-family dwelling units at Brooktrails. However, as currently subdivided, approximately 4,000 residential lots would not be supplied with water from existing sources. In 1981, the Township retained a consulting team to prepare an analysis of three alternative dam sites. Eight years later, the Township initiated preparation of the Willits Creek Reservoir Project Draft Environmental Impact Report (EIR). The Willits Creek Reservoir was a proposed 2,400 acre-foot impoundment, considered by the Township sufficient in size to allow buildout of the Township.

Through the process of addressing comments on the scope and content of the EIR by various regulatory agencies and the public, the Brooktrails Township Community Services District Board of Directors recognized that a community plan was necessary to address Township development potential, how many residential units would be appropriate for Township buildout, and land use and environmental concerns to allow for a better understanding of the costs and impacts associated with the proposed Willits Creek Reservoir project. Accordingly, after several years of effort, the Brooktrails Township obtained special legislation by the State legislature through Assembly Bill No. 266, and Township voter approval, authorizing the District to become the first special district in California to engage in land use planning decision-making. The Specific Plan is the result of that legislation and voter approval.

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1.2 SPECIFIC PLAN PROJECT
The purpose of the Brooktrails Township Specific Plan is to serve as a comprehensive planning document for the Township as it continues to grow. It includes development goals and policies, land use regulations, a capital improvement program and an overview of financing measures. It integrates land use controls that replace the existing Development Review Board Ordinance and Interim Site Development Standards.

The Specific Plan is not intended to be a rigid framework, but provides flexibility to respond to changes over time that are consistent with the Plan goals and policies. The Specific Plan may be updated at periodic intervals, for example every five years if warranted, to reflect changes in community standards, rate of Township growth, use of natural and man-made resources, and general community concerns regarding quality of life issues.

It should be noted that Brooktrails Township is an existing community. Thus the Specific Plan does not address a new community; rather, the Specific Plan addresses refinements to the existing subdivision as new information on growth and development of the Township has become available, and responds to changing physical conditions, community concerns and governmental regulations regarding Township growth and development.

1.3 PROJECT DESCRIPTION
At buildout, and as envisioned in the Specific Plan, the Brooktrails subdivision would contain 3,815 residential units (4,000 SFRs) supporting a resident population of about 9,919 individuals. New commercial development to augment existing commercial land uses would be expected to occur on land zoned for commercial uses, consistent with the needs and requirements of the local population. The predominant land use would remain singly-family residential with 2,817 acres devoted to Public Facilities open space. Various community services and infrastructure improvements and additions would be required to support the growing community as follows:

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Water: Water supply is the most immediate constraint facing Brooktrails, with the existing system reaching capacity at around 2,000 units. Water infrastructure consists of the development of additional water sources including a new dam and 1,600 acre-foot reservoir, plus added storage and treatment facilities to augment existing storage and treatment facilities commensurate with the level of demand.

Sewer: Development beyond 2,000 units will require the expansion of sewer capacity. Sewer improvements to serve up to 4,000 units consist of one main from Brooktrails to the Willits Wastewater Treatment Plant constructed in two stages.

Circulation: Two circulation projects are anticipated for the near future. The first project involves improvements to Sherwood Road, including shoulders, turn pockets, and signals. The second project is the second access route into the Township, established by the Brooktrails Board of Directors as the number one priority among infrastructure expansions. Traffic volumes generated by development of 4,000 units would require a third access route into the Township.

Fire: The Township plans to add one new fire station, including a fire engine and water tender, before reaching the 2,000 unit level of development. Development at 4,000 units would require a second additional station plus another engine and staff car. In addition to the two new fire stations noted above, the Brooktrails Township anticipates an additional station to serve development in the vicinity of the Ells Field Airport near the northeast quadrant of the Township.

1.4 REQUIRED APPROVALS
The Specific Plan EIR must be certified as complete and adequate under CEQA by the Mendocino County Board of Supervisors prior to considering a General Plan amendment, rezoning and approving and adopting the Specific Plan. A General Plan amendment is needed to reflect the Specific Plan's greater level of specificity applying to the Township proper, while rezoning of specified commercial and multiple-residential unit parcels is called for in the Specific Plan.

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1.5 AREAS OF CONTROVERSY
Several areas of potential environmental impact controversy currently affect, but are not necessarily affected by, the Brooktrails Township Specific Plan. Those issues of environmental impact controversy that are discussed in the EIR are as noted below. The issues of controversy known at this time include:

1) Caltrans' proposals for a U.S. 101 freeway bypass, that routes freeway traffic around rather than through the City of Willits, and the effect of the proposed bypass on circulation patterns and intersection service levels within the City of Willits. The bypass would also have importance on decisions regarding a third access route into Brooktrails Township. This subject is discussed in Section 3.1.2, Traffic and Circulation.

2) The timing of constructing a future Caltrans' U.S. 101 bypass around the City of willits. This project is not currently listed in the State Transportation Improvement Program (STIP), and funding for the project could be delayed in future years while congestion along U.S. 101 gets progressively worse with area growth.

3) Potential impacts of residential construction on steep and/or unstable slopes areas, and in geologically seismically active areas. This subject is discussed in Section 3.2.2, Soils, Geology and Seismicity.

4) The level of proposed development. Although the Township, through an extensive community involvement program to promote consensus regarding preparation of the Specific Plan to accommodate 4,000 equivalent single-family dwellings, this reduces potential Township buildout from 6,000 residential units as envisioned when Brooktrails was initially conceived. This issue generated some controversy, particularly with respect to individuals in the real estate community. The choice among alternatives, including buildout of Brooktrails Township as envisioned in the Specific Plan, relates to a careful balancing of the need for maintaining a community character desired by Township property owners, environmental protection and fiscal responsibility.

The alternatives studied include the following:

1. No Project (no Specific Plan)
2. Alternative Development Scenarios

Fixed Growth Scenario #1: 2,000 units
Low Growth Scenario #2: 2,500 units
Medium Growth Scenario #3: 3,500 to 4,000 units
Medium-High Growth Scenario #4: 5,000 units
High Growth Scenario #5: 6,000 units

3. Environmentally Superior Alternative

Other areas of controversy may include impacts on the providers of public services and utilities, pedestrian safety (especially school children), potential air quality and noise impacts, and the potential for growth inducing impacts. These subjects are discussed in the respective technical sections of this EIR.

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1.6 MAJOR EIR CONCLUSIONS
The following presents the major conclusions and findings of the EIR. A table that summarizes the environmental impacts and mitigation measures as contained in the body of the EIR is provided. The description of some impacts and mitigation measures has been abbreviated consistent with the format of a summary section, and the reader is referred to the main EIR text for a complete discussion of environmental impacts and mitigation measures (refer to the numbering sequence for location). A summary description of each Specific Plan alternative studied is also provided.

Alternatives
The purpose of the discussion of alternatives is to focus on alternatives capable of eliminating any significant adverse environmental effects or reducing them to a level of insignificance, even if these alternatives would impede to some degree the attainment of project objectives or would be more costly.

No Project
For purposes of definition, the No Specific Plan Alternative is synonymous with the description of the No Project Alternative. Alternative Development Scenario #1 described below is analogous to the No-Project (no Specific Plan) Alternative because the existing Township water supply can provide up to about 2,000 residences, and no Specific Plan would be prepared without the need for a new reservoir due to circumstances surrounding the issue of growth within Brooktrails Township.

The Township with 6,000 residential units as originally envisioned when the land was subdivided is not feasible without environmental evaluation because of the determination of need for the Specific Plan. Therefore, development not exceeding 2,000 residences is the respective limit of growth within the Township without the Specific Plan.

The No Project alternative includes maintenance of the existing environment at the 2,000 unit level as a basis for comparison of the other alternatives considered.

Alternative Development Scenarios

The Brooktrails Township Community Services District initiated the process of forming a Specific Plan Advisory Committee consisting of Brooktrails property owners. In working with the Advisory Committee, the first step was to prepare and present for review a series of potential growth scenarios for Brooktrails Township, up to and including Township buildout as originally envisioned when Brooktrails was

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TABLE 1-1

SUMMARY OF ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

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established. Five Alternative Development Scenarios were developed and presented for review and discussion, together with the criteria and considerations documenting the origin of each Scenario.

The ultimate objective was for the Advisory Committee and District Board of Directors to agree on a series of Development Scenarios for testing in terms of environmental practicality, consistency with the Proposed Goals and Objectives of the Community Vision Focus Group Report as adopted by the Township Board of Directors, and to assess each Scenario for economic feasibility.

The following is a summary review of the potential environmental implications of initiating either of the five Alternative Development Scenarios. Potential risk of adverse environmental impact by subject area is provided to facilitate evaluation of the alternative development scenarios. Generally, order of magnitude of impact risk is provided.

Fixed Growth Scenario #1: 2,000 Units (No Specific Plan Project)

• Land Use - Scenario #1 would create the least risk of land use impact of all the development scenarios. New Development would be infill development and primarily residential in character (there could be some locally-serving commercial uses), with no discernable land use conflicts.

• Traffic and Circulation - Circulation improvements are currently warranted, including a second access road, regardless of additional development in the Township.

• Visual Quality - Of all the Alternative Development Scenarios, alternative #1 would create the least risk of altering existing visual resources or changing the semi-rural character of the Township.

• Utilities and Public Services - Additional demands would be placed on utilities and public services, but, Fixed Growth Scenario #1 would be the least intense of the development scenarios. There would be no new dam construction.

• Soils and Seismicity - Alternative #1 would afford the greatest opportunity to avoid development on steep slopes or within unstable soils, areas of high constraint to development.

• Drainage and Water Quality - Scenario #1 would generate the least increase in stormwater runoff of all the alternatives, and present the least risk to water quality.

• Vegetation and Wildlife - Scenario #1 would minimize disturbance to forest habitat because of reduced development.

• Air Quality - Scenario #1 would minimize potential air quality impacts because of the reduced development profile as compared with the other alternatives.

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• Noise - Scenario #1 would minimize adverse noise impacts because of reduced development density and population.

Low Growth Scenario #2: 2,500 Units

• Land Use - New development would be infill development in a random lot selection pattern, and primarily residential in character, consistent with existing residential land use.

• Traffic and Circulation - Circulation improvements are currently warranted, including a second access road. Increased development over Fixed Growth Scenario #1 would create an increased need for circulation improvements.

• Visual Quality - Under Low Growth Scenario #2, there would be a low risk of altering visual resources or changing the existing community character because of scattered infill development throughout an established lotting pattern.

• Utilities and Public Services - Under Scenario #2. there would be additional demands placed on utilities and public services, but there would correspondingly be less demand than under the increased Development Scenarios #3, #4 and #5. There would be no new dam construction.

• Soils and Seismicity - Alternative #2 would afford significant opportunities to avoid development on steep slopes or within unstable soils.

• Drainage and Water Quality - Scenario #2 would provide an increase in the amount of stormwater runoff over Fixed Growth Scenario #1 because of the increased area of construction, but the increase in intensity and amount of runoff would be less than development scenarios #3, #4 and #5.

• Vegetation and Wildlife - Scenario #2 would require more disturbance to forest habitat than Fixed Growth Scenario #1 because of increased development.

• Air Quality - Alternative #2 would generate more vehicular traffic than Fixed Growth Scenario #1 because of the greater population base, potentially adversely affecting air quality due to increased vehicular, heating, cooling and fireplace emissions.

• Noise - Alternative #2 would generate more vehicular traffic and bring more people into the Township than Fixed Growth Scenario #1, increasing noise levels over what would be generated under Scenario #1.

Medium Growth Scenario #3: 3,500 to 4,000 Units

• Land Use - New development would be infill development, and primarily residential, consistent with existing land uses. At this level of development, it would be expected that most of the more easily developable lots (lots that are not steeply sloping or heavily forested), would be developed and other lots that are in high constraint areas or without sewer hookups would remain for development.

• Traffic and Circulation - Circulation improvements are currently warranted, including a second access road. Increased development above Low Growth Scenario #2 would create an increased need for circulation improvements.

• Visual Quality - Scenario #3 would pose an increased risk of altering visual resources or changing the existing community character because of increased, more dense, suburban infill development throughout an established lotting pattern.

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• Utilities and Public Services - Additional demands would be placed on utilities and public services under Alternative #3, but these demands would be the less than for Alternative Development Scenarios #4 and #5. Scenario #3A at 3,500 units would require additional water for domestic use through increasing the capacity of Lake Ada Rose and/or Lake Emily in conjunction with the use of wells and conservation efforts.
  Alternative #3B, at 4,000 units, would trigger a major threshold decision since Alternative #3B would involve the construction of a new minimum-size reservoir that, together with existing water supplies, could support up to 4,000 units and provide water for fish flows.

• Soils and Seismicity - Alternative #3 would afford opportunities to avoid development on steep slopes or within unstable soils.

• Drainage and Water Quality - Scenario #3 would generate an increase in the amount of stormwater runoff over Low Growth Scenario #2, but the increase in intensity and amount of runoff would be less than for Scenarios #4 and #5.

• Vegetation and Wildlife - Scenario #3 would generate more disturbance to forest habitat because of increased development as compared to Alternative Development Scenarios #1 and #2.

• Air Quality - Scenario #3 would generate more vehicular traffic than Fixed Growth Scenario #1 or Low Growth Scenario #2, potentially adversely affecting air quality.

• Noise - Scenario #3 would generate more vehicular traffic and bring more people into the Township than Fixed Growth Scenario #1 or Low Growth Scenario #2, increasing noise levels over what would be generated under Scenario #1 and #2.

Medium-High Growth Scenario #4: 5,000 Units

• Land Use - New development would be infill development, and primarily residential, consistent with existing land uses. As with Medium Growth Scenario #3, under Scenario #4 at this higher level of development potential, it would be expected that most of the more easily developable lots (lots that are not steeply sloping or heavily forested), would be developed and other lots that are in high constraint areas or without sewer hookups would remain available for development.

• Traffic and Circulation - Circulation improvements are currently warranted, including a second access road. Increased development over Medium Growth Scenario #3 would create increased need for circulation improvements. There would be increased risk of peak hour congestion under this growth scenario.

• Visual Quality - There would be a substantially increased risk of altering visual resources or changing the existing community character because of increased development under Scenario #4, even though the development would be infill development.

• Utilities and Public Services - Scenario #4 would require the construction of a new dam on Willits Creek to provide a new source of municipal water supply to enable increased development and provide water for required fish flows.

• Soils and Seismicity - Scenario #4 would afford fewer opportunities to reassemble lots into larger developable parcels in the effort to avoid development on steep slopes or within unstable soils.

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• Drainage and Water Quality - Scenario #4 would provide an increase in the amount of runoff over Alternative Development Scenarios #1, #2 and #3, but would be less than full buildout of the Township. There would be an increased potential for adverse water quality impacts because of the higher level of construction and additional stormwater runoff under this alternative.

• Vegetation and Wildlife - Scenario #4 would generate increased disturbance to forest habitat because of increased development in comparison to Alternative Development Scenarios #1, #2 and #3. There would be increased risk to maintaining existing open space conditions, wetlands and riparian habitat because of the greater local population base.

• Air Quality - Scenario #4 would generate more vehicular traffic than Scenarios #1, #2 and #3. The larger population could potentially adversely affect air quality due to increased vehicular, heating, cooling and fireplace emissions.

• Noise - Scenario #4 would generate more vehicular traffic and bring more people into the Township than Scenarios #1, #2 and #3, increasing noise levels over what would be generated under either alternative of less intense development.

High Growth Scenario #5: 6,000 Units

• Land Use - New development under Scenario #5 would be infill development coinciding with the existing lotting pattern. The overall level of density and intensity of land use would be greater than all other Alternative Development Scenarios because of community buildout.

• Traffic and Circulation - Circulation improvements are currently warranted, including a second access road. Community buildout would create a correspondingly increased need for circulation improvements within the Township and possibly the City of Willits. There would be a substantially increased risk of peak hour congestion under this long-term growth scenario.

• Visual Quality - Under buildout, there would be a significantly increased risk of altering existing visual resources or changing the existing community character because of increased development, even though the development would be infill development over an existing lotting pattern. This would be because of increased density and intensity of development throughout the Township.

• Utilities and Public Services - Buildout would place additional demands on utility systems and public services. As with Medium-High Growth Scenario #4 at 5,000 units, under Scenario #5, a new dam would need to be constructed on Willits Creek to provide an additional source of domestic water supply.

• Soils and Seismicity - Scenario #5 would afford fewer opportunities to avoid development on steep slopes, areas of high constraint to development. Owners of currently unimproved lots in high constraint areas would either not be able to build because of the costs to mitigate existing conditions, or be forced to acquire whatever remaining adjacent parcels may be developable, if they continue to desire to build.

• Drainage and Water Quality - Buildout would generate an increase in the amount of stormwater runoff above all other Alternative Development Scenarios. There would be increased potential for localized flooding, erosion, sedimentation and adverse water quality impacts. The ability of the existing drainage system and local creeks to adequately handle increased stormwater runoff would need to be determined.

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• Vegetation and Wildlife - Buildout would require increased disturbance to forest habitat because of increased development over all other Alternative Development Scenarios. There would be significantly increased risk to maintaining existing open space conditions, and increased risk of adverse impact to existing wetlands, riparian habitat and wildlife migration corridors.

• Air Quality - Buildout would generate more vehicular traffic than the other Alternative Development Scenarios because of the increased population. Accordingly, there would be increased risk of adversely affecting existing air quality because of vehicular, heating, cooling and fireplace emissions.

• Noise - Buildout would generate more vehicular traffic and bring more people into the Township than Alternatives #1, #2, #3 and #4, increasing noise levels over what would otherwise be generated under reduced development. It would be expected that under buildout conditions, traffic noise would become objectionable to area residents, particularly residents living in more hilly areas where traffic would be accelerating up steep grades generating higher engine noise.

Conclusion

Fixed Growth Scenario #1 with 2,000 residential units would provide the least risk of environmental impact. However, as explained previously, Scenario #1 is analogous to the No-Project alternative because the existing Township water supply can provide up to about 2,000 units.

The economic analysis conducted for the Alternative Development Scenarios indicated no development rights acquisition may be required under Scenario #4 at 5,000 units or Scenario #5 at 6,000 units. The economic analysis also indicated development upwards of 4,000 units under Scenario #3B would create less pressure to acquire development rights and have a lower order-of-magnitude economic impact on property values than the lower growth scenarios. Although infrastructure costs of Scenario #3B would be higher than Scenarios #1, #2 or #3A, this would be more than offset by a reduction in development rights acquisition costs.

It was concluded that the optimum community size would be Medium Growth Scenario #3B with 4,000 units. Scenario #3B was determined to provide an optimum balance between the need for environmental protection and the economic costs of expanding infrastructure and/or limiting growth.

Environmentally Superior Alternative
Of all the Alternative Development Scenarios, Low Growth Scenario #2 at 2,500 units (excludes Scenario #1 as the No Project Alternative), would appear to be the Environmentally Superior Alternative and would be most consistent with the proposed goals and objectives of the Brooktrails Township Focus Group Report recommendations.