FINAL ENVIRONMENTAL ASSESSMENT

LYTTON RESIDENTIAL DEVELOPMENT

VOLUME II

MAY 2011

Lead Agency:

U.S. Department of the Interior

Bureau of Indian Affairs

Pacific Region Office

2800 Cottage Way, Room W-2820

Sacramento, CA 95825-1846
FINAL ENVIRONMENTAL ASSESSMENT

LYTTON RESIDENTIAL DEVELOPMENT

VOLUME II

MAY 2011

Lead Agency:

U.S. Department of the Interior

Bureau of Indian Affairs

Pacific Region Office

2800 Cottage Way, Room W-2820

Sacramento, CA 95825-1846

Prepared By:

Analytical Environmental Services

1801 7th Street, Suite 100

Sacramento, CA 95811

(916) 447-3479

www.analyticalcorp.com
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TABLE OF CONTENTS 

LYTTON RESIDENTIAL DEVELOPMENT – VOLUME II 

FINAL ENVIRONMENTAL ASSESSMENT 

REVISED EA 

Executive Summary ................................................................................................................................ ES-1 

1.0 INTRODUCTION 

1.1 Introduction ...................................................................................................................... 1-1 

1.2 Location and Setting ........................................................................................................ 1-1 

1.3 Purpose and Need for the Proposed Action ..................................................................... 1-6 

1.4 Overview of the Environmental Process .......................................................................... 1-7 

1.5 Environmental Issues Addressed ..................................................................................... 1-7 

1.6 Regulatory Requirements and Approvals ........................................................................ 1-8 

2.0 PROPOSED PROJECT AND ALTERNATIVES 

2.1 Alternative A – Proposed Project .................................................................................... 2-1 

2.2 Alternative B – Onsite Water and Wastewater .............................................................. 2-10 

2.3 Alternative C – Reduced Intensity with Onsite Water and Wastewater ........................ 2-14 

2.4 Alternative D – No Action Alternative .......................................................................... 2-17 

2.5 Comparision of the Proposed Project and Alternatives ................................................. 2-17 

3.0 DESCRIPTION OF AFFECTED ENVIRONMENT 

3.1 Land Resources ................................................................................................................ 3-1 

3.2 Water Resources .............................................................................................................. 3-8 

3.3 Air Quality ..................................................................................................................... 3-15 

3.4 Biological Resources ..................................................................................................... 3-24 

3.5 Cultural Resources ......................................................................................................... 3-49 

3.6 Socioeconomic Conditions / Environmental Justice ...................................................... 3-59 

3.7 Transportation and Circulation ...................................................................................... 3-63 

3.8 Land Use ........................................................................................................................ 3-66 

3.9 Public Services ............................................................................................................... 3-74 

3.10 Noise .............................................................................................................................. 3-79 

3.11 Hazardous Materials ...................................................................................................... 3-82 

3.12 Visual Resources ............................................................................................................ 3-85 

 

4.0 ENVIRONMENTAL CONSEQUENCES 

4.1 Alternative A – Proposed Project .................................................................................... 4-1 

4.2 Alternative B – Onsite Water and Wastewater .............................................................. 4-27 

4.3 Alternative C – Reduced Intensity with Onsite Water and Wastewater ........................ 4-42 

4.4 Alternative D – No Action Alternative .......................................................................... 4-53 

4.5 Cumulative Effects ........................................................................................................ 4-55 

4.6 Indirect and Growth-Inducing Effects ........................................................................... 4-63 
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5.0 MITIGATION MEASURES 

5.1 Land Resources ................................................................................................................ 5-1 

5.2 Water Resources .............................................................................................................. 5-2 

5.3 Air Quality ....................................................................................................................... 5-3 

5.4 Biological Resources ....................................................................................................... 5-6 

5.5 Cultural Resources ......................................................................................................... 5-10 

5.6 Socioeconomic Conditions / Environmental Justice ...................................................... 5-11 

5.7 Transportation and Circulation ...................................................................................... 5-11 

5.8 Land Use ........................................................................................................................ 5-11 

5.9 Public Services ............................................................................................................... 5-12 

5.10 Noise .............................................................................................................................. 5-13 

5.11 Hazardous Materials ...................................................................................................... 5-13 

5.12 Visual Resources ............................................................................................................ 5-14 

6.0 CONSULTATION, COORDINATION AND LIST OF PREPARERS 

6.1 Federal Agencies Consulted ............................................................................................ 6-1

6.2 State Agencies Consulted ................................................................................................ 6-1 

6.3 Tribes Consulted .............................................................................................................. 6-1 

6.4 Local Agencies Consulted ............................................................................................... 6-2 

6.5 Preparers of Environmental Assessment ......................................................................... 6-2 

7.0 BIBLIOGRAPHY ............................................................................................................................ 7-1 

LIST OF TABLES 

ES-1 Summary of Potential Impacts, Mitigation Measures and Signficance ...................... ES-11 

1-1 Assessor’s Parcel Numbers within the Project Site (New Table) .................................... 1-5 

2-1 Summary of Development Alternatives ........................................................................... 2-2 

2-2 Tribal Community Development – Onsite Facilities ...................................................... 2-5 

3-1 Project Site Soils (Revised) ............................................................................................. 3-2 

3-2 Water Quality Objectives of Inland Surface Waters ...................................................... 3-12 

3-3 Water Quality Objectives for the Russian River (Revised) ........................................... 3-13 

3-4 Mark West Creek Flow Data (Revised) ......................................................................... 3-14 

3-5 National Ambient Air Quality Standards (Revised) ...................................................... 3-22 

3-6 Exceedances of NAAQS in the SFBAAB (Revised) ..................................................... 3-23 

3-7 Summary of Habitat Types Within the Project Site (Revised) ...................................... 3-35 

3-8 Summary of Arbor Survey Results (Revised)................................................................ 3-41 

3-9 Federal Special Status Species with Potential to Occur in Project Site (New Table) .... 3-42 

3-10 Regionally Occurring Non-Federal Special Status Species (Revised) .......................... 3-42 

3-11 Sonoma County Population 2000-2008 ......................................................................... 3-60 

3-12 Lytton Rancheria Population and Labor Force Estimates ............................................. 3-60 

3-13 Level of Service for Signalized Intersection .................................................................. 3-64 

3-14 Level of Service for Unsignalized Intersections ............................................................ 3-64 

3-15 Existing Level of Service and Average Delay of Study Intersections (Revised)........... 3-65 

3-16 Public Schools ................................................................................................................ 3-78 

3-17 Noise Level Performance Standards .............................................................................. 3-81 

4-1 Water Demand for the Proposed Project ......................................................................... 4-4 

4-2 Summary of Influent Flow and Load Projections (Revised) ........................................... 4-4 
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4-3 Mitigated (Unmitigated) Construction Emissions – Alternatives A and B (Revised) ..... 4-7 

4-4 Unmitigated Operational Emissions – Alternatives A and B (Revised) .......................... 4-7 

4-5 Greenhouse Gas CO2 Equivalent (New Table) ................................................................ 4-8 

4-6 Alternatives A and B GHG Emissions (New Table) ....................................................... 4-9 

4-7 Anticipated Impacts to Habitat Types – Alternative A (Revised) ................................. 4-11 

4-8 Tree Impact Summary for Each Project Alternative (Revised) ..................................... 4-12 

4-9 Proposed Project Trip Generation Estimates ................................................................. 4-17 

4-10 Level of Service Summary for Background Plus Project Conditions (Revised) ........... 4-19 

4-11 Typical Construction Noise Levels ................................................................................ 4-25 

4-12 Effluent Storage and Irrigation Estimates (New Table) ................................................. 4-31 

4-13 Anticipated Impacts to Habitat Types – Alternative B (New Table) ............................. 4-36 

4-14 Alternative B Trip Generation Estimate ........................................................................ 4-37 

4-15 Mitigated (Unmitigated) Construction Emissions- Alternative C (Revised) ................. 4-44 

4-16 Mitigated (Unmitigated) Operational Emissions: Reduced Intensity Alternative 

(Revised) ........................................................................................................................ 4-45 

4-17 Alternative C GHG Emissions (New Table) ................................................................. 4-46 

4-18 Anticipated Impacts to Habitat Types- Alternative C (New Table) .............................. 4-47 

4-19 Reduced-Intensity Alternative Trip Generation Estimate .............................................. 4-48 

4-20 Alternatives A, B, and C Cumulative Emissions ........................................................... 4-58 

4-21 Level of Service Summary for Cumulative Plus Project Conditions (Revised) ............ 4-61 

5-1 Estimated GHG Emissions and Quantification of Mitigation Reductions (New Table) . 5-5 

5-2 Summary of Mitigation Ratios for the Federally Listed Plants of the 

 Santa Rosa Plain .............................................................................................................. 5-9 

LIST OF FIGURES 

1-1 Regional Location ............................................................................................................ 1-2 

1-2 Site and Vicinity .............................................................................................................. 1-3 

1-3 Aerial Parcel Map ............................................................................................................ 1-4 

2-1 Site Plan – Alternative A ................................................................................................. 2-3 

2-2 Site Plan – Alternative B ............................................................................................... 2-11 

2-3 Site Plan – Alternative C ............................................................................................... 2-15 

3-1 Regional Fault Map ......................................................................................................... 3-3 

3-2 Ground Shaking Intensities Along the Healdsburg-Rodgers Creek Faults ...................... 3-4 

3-3 Soils Map ......................................................................................................................... 3-5 

3-4 FEMA Flood Zones ....................................................................................................... 3-11 

3-5 Air Management District Boundaries (New Figure) ...................................................... 3-16 

3-6 Sonoma County Land Use and Zoning Map .................................................................. 3-67 

3-7 Town of Windsor Land Use Designations ..................................................................... 3-69 

3-8 Williamson Act Map ...................................................................................................... 3-71 

3-9 Farmland Mapping & Monitoring Program (FMMP) Designations .............................. 3-73 

3-10 Site Photographs ............................................................................................................ 3-87 
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EXECUTIVE SUMMARY 

LYTTON RESIDENTIAL DEVELOPMENT – 

FINAL ENVIRONMENTAL ASSESSMENT

ES.1 INTRODUCTION 

The Environmental Assessment (EA) for the proposed Lytton Rancheria of California Fee-toTrust and Residential Development Project, dated July 2009 (SCH #2009074006) was submitted 

to the State Clearinghouse and released for public and agency review for a 30-day comment 

period beginning on July 30, 2009 and ending on August 31, 2009. Additional extensions to the 

30-day comment period were granted by the U.S. Bureau of Indian Affairs (BIA). This Final EA 

has been prepared for the BIA to support an application from the Lytton Rancheria of California 

(Tribe) for land to be placed into federal trust (Proposed Action). The BIA is the federal agency 

that is charged with reviewing and approving tribal applications to take land into federal trust 

status. This three-volume Final EA includes responses to comments received on the EA (Volume 

I), and a revised version of the EA to reflect the responses to comments received, with revised 

text shown in underline/strikeout format (Volume II) and supporting Appendices (Volume III). 

Note that the following Executive Summary is not shown in underline/strikeout format as it is a 

new section, unlike the remainder of Volume II. 

Since the public comment period, the Tribe has purchased an additional 32.12 acres (seven 

parcels) discussed in further detail in Section 1.0. These seven parcels were added to the fee-totrust application and housing project site plan alternatives (Section 2.0) to provide additional 

flexibility for reclaimed water reuse and mitigation of potential impacts in response to comments 

and concerns raised during the EA public comment period. The project site consists of 

approximately 124.12 acres in Sonoma County, California, which is intended to be used for 

residential housing, a community center, and associated facilities by the Tribe. The BIA will use 

this EA to determine if the Proposed Action would result in significant effects to the environment. 

This Final EA has been completed in accordance with the requirements set out in the National 

Environmental Policy Act (NEPA) of 1969 (42 U.S.C. §4321 et seq.), the Council on 

Environmental Quality (CEQ) Guidelines for Implementing NEPA, and the BIA’s NEPA 

handbook (59 IAM 3-H). This document provides a detailed description of the Proposed Action 

and an analysis of the potential environmental consequences associated with the action. This 

document also includes a discussion of alternatives, impact avoidance, and mitigation measures. 

Consistent with the requirements of NEPA, the BIA will review and analyze the environmental 
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consequences associated with the Proposed Action, and either determine that a Finding of No 

Significant Impact (FONSI) is appropriate, or request that an Environmental Impact Statement 

(EIS) be prepared. Volume II of this Final EA contains the full text of the original EA, with 

appropriate alterations based on comments received. New text is shown by underlining, with 

deletions shown in strikeout format. New tables in the Final are designated in the table name as 

“New Table;” revised tables are designated as “Revised” and new Appendices as “Added.” 

Volume III consists of supporting Appendices A through N. Appendices A through H and J

were revised for the Final EA. Appendix F (Cultural Resources Study and Addendum) is a 

confidential appendix bound under separate cover. Appendices K through N have been added 

with the Final EA, and Appendix I (Cooperative Fire Agreement) remains unchanged. 

ES.2 PURPOSE AND NEED 

Following the passage of the Rancheria Act (the Act of August 18, 1958, PL. 85-671, 72 Stat. 

619), the federal government terminated the Lytton Rancheria and distributed the tribal trust 

lands, which were located within the Alexander Valley, to individual members of the Lytton 

Rancheria. The Rancheria Act and distribution plan called for the federal government to provide 

certain improvements to the properties to make them habitable for the individuals to whom the 

property was distributed. The federal government failed to meet these obligations, however, and 

the Lytton Rancheria was restored as a tribe in 1991 through a stipulated judgment which 

acknowledged that the tribe was never legally terminated. There after, the Lytton Rancheria was 

again listed in the Federal Register as an Indian entity which is recognized and eligible to receive 

services from the BIA. Since then, the Tribe has attempted to secure land to re-establish a unified 

community in the vicinity of the Alexander Valley. Since the release of the EA for public review, 

the Tribe has purchased an additional 32.12 acres (seven parcels) of land proposed for trust status 

and revised housing alternatives analyzed for environmental impacts under the Final EA. The 

Tribe’s purpose for taking the 124.12 acres of land into trust is to provide additional flexibility for 

reclaimed water reuse and mitigation of potential impacts in response to comments and concerns 

raised during the EA public comment period and for the development of a residential community, 

a community center, and associated Tribal facilities. The construction of these facilities is 

important to the Tribe and provides a basis for taking the land into trust pursuant to 25 C.F.R. 

Part 151. Management and protection of the land and its natural resources, as well as the 

provision of social services to Tribal members, are essential functions of Tribal government. The 

Lytton Tribe consists of approximately 270 Tribal members, governed by a tribal council. Tribal 

members are currently dispersed throughout the County and State and do not have an identifiable 

physical community of their own. The proposed acquisition would bring together Tribal 

members into a unified location by providing adequate housing and associated facilities to 

improve the quality of life of the Tribal members. Taking the property into trust will allow the 

Tribe to foster their cultural identity, spiritual values, and traditional religion through construction 

of the roundhouse, retreat and community center. Providing housing in the fee-to-trust lands will 
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limit the geographic dispersion of Tribal members. Acceptance of the subject parcels into federal 

trust would assist the Tribe in meeting a long-term, viable, and sustainable solution to the Tribe’s 

lack of a tribal land base and provide a place to congregate for governmental, cultural, and social 

purposes. 

ES.3 ALTERNATIVES 

This document describes and analyzes four development alternatives plus the No Action 

Alternative. Three of the development alternatives include placing land into Federal trust. 

Development alternatives have been selected which potentially meet the Purpose and Need, 

although at varying degrees for each. The alternatives are described in detail in Section 2.0 of the 

Final EA and are summarized below. Section 3.0 of the Final EA provides relevant information 

about existing resources and other values that may be affected by the Proposed Action and 

alternatives. Section 4.0 of the EA describes environmental consequences associated with the 

Proposed Action and alternatives, while Section 5.0 presents mitigation measures. The 

alternatives are summarized below. 

ALTERNATIVE A – PROPOSED PROJECT

Alternative A consists of two components: The first is the fee simple conveyance of the 

approximately 124.14-acre site (fourteen Assessor’s Parcel Numbers [APNs]) into federal trust 

for the benefit of the Tribe: 

Original fee-to-trust parcels: 

066-300-028 

066-300-031 

066-300-033 

066-191-017 

066-191-018 

066-191-020 

066-191-022 

New parcels added: 

066-300-023 

066-300-017 

066-191-016 

066-191-019 

066-191-021 

066-050-040 

066-050-047 

The second component is the construction of 147 residential units and associated community 

facilities. The trust action would shift civil regulatory jurisdiction over the 124.14 acres from the 

State of California and Sonoma County to the Tribe and the federal government; the State and 

County would continue to exercise criminal jurisdiction under 18 U.S.C. §1162 and other federal 

laws pertaining to jurisdiction in Indian country. 

The Tribe would develop the project site to provide approximately 147 residential units. A site 

plan for Alternative A is shown in Figure 2-1. The residential units would include 95 singlefamily detached houses, 24 cottage-style houses, and 28 high-density housing units. A Tribal 

community center, retreat, and a roundhouse would be included as part of the project. The 

community center would be approximately 19,000 square feet (sf) in size and located in the 
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central southern portion of the project site. It would include a lounge area, bathroom facilities, 

and administrative offices. The roundhouse would be situated west of the community center and 

would include approximately 2,500 sf. The retreat would be located northwest of the roundhouse 

and would consist of approximately 2,700 sf. Signage would be included for all community 

facilities. 

The Town of Windsor’s Police Department (WPD) contracts with the Sonoma County Sheriff’s 

Department (SCSD) for law enforcement services. Both the WPD and the SCSD would serve the 

project site. Pursuant to the Cooperative Fire Protection Agreement between the BIA and State of 

California Department of Forestry and Fire Protection (CalFire), CalFire would provide fire 

protection and emergency medical services. Electric, telephone, and cable services would be 

extended to the site through contracts with the appropriate agency, if required. 

Water would be supplied from the Town of Windsor’s public water supply system, under an 

agreement to be negotiated between the parties. The primary water supply for the Windsor water 

system is wells located near the Russian River, northwest of the project site. Two large diameter 

water transmission mains transport water from the well field to the town for distribution. One of 

the two transmission mains is an 18-inch diameter main that parallels Windsor River Road, 

immediately north of the project site. Two connections would be made to this water main to 

serve the site. Each of these connections would include a meter and backflow prevention 

facilities, if required. The Tribe would install an onsite water distribution system and water 

quality standards would be adopted by the Tribe that would be no less stringent than Federal 

water quality and Federal Safe Drinking Water Act standards. Inspections of the water supply 

system and water quality by the United States Environmental Protection Agency (USEPA) would 

ensure compliance with applicable safe drinking water standards. 

Under this alternative, the Tribe would enter into an agreement with the Town of Windsor for 

sewer service. The Town is responsible for the treatment, storage, and disposal of the Town’s 

wastewater. A sewage lift station and approximately 3,200 feet of force main would be 

constructed to pump the wastewater from the proposed Tribal community to a manhole located 

near the intersection of Windsor River Road and Starr Road (approximately a half mile from site). 

The existing Windsor Wastewater Treatment, Reclamation, and Disposal Facility would have 

sufficient treatment and disposal capacity to serve the Proposed Project. The Tribe would adhere 

to local regulations for extending sewer mainlines to the project site, including the Town’s 

Sanitary Sewer Management Plan. 

Rural roadways would be constructed to provide access to onsite residences and facilities. Three 

main project access driveways from Windsor River Road are proposed. Stop signs would be 

installed at these three project access driveways. The rural roadways would be 24-feet wide twolane asphalt travel ways, with gravel shoulders consistent with Sonoma County Subdivision and 

Fire Safe Standards. Signage would be provided for the new roadways. 
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The project components would be constructed after the 124.12-acre property has been placed into 

federal trust. Construction would involve earthwork, placement of concrete foundations, steel 

and wood structural framing, masonry, electrical and mechanical work, building finishing, and 

paving, among other construction trades. A worksite safety plan would be prepared for 

construction. 

ALTERNATIVE B – ONSITE WATER AND WASTEWATER

As with Alternative A, Alternative B would include placing the 124.14-acre site into federal trust 

status for the benefit of the Tribe; however under Alternative B, onsite water, wastewater and 

reclamation facilities would be built. The Tribe would develop the site to provide 147 residential 

units including 95 single-family houses, 24 cottage style houses, and 28 high-density housing 

units, identical to Alternative A (Table 2-1). Alternative B would include the same associated 

community facilities as Alternative A. As with Alternative A, the same rural roadways would be 

constructed to provide access to the residences and community facilities. Signage would also be 

provided for streets and community facilities. With the exception of water and wastewater 

services, public service providers under Alternative B would be the same as those presented for 

Alternative A. 

Alternative B would include an onsite water supply obtained from the development of 

groundwater production wells. The primary production well would be located near the water 

storage tank located northwest of the roundhouse. Alternative B includes an onsite wastewater 

treatment and reclamation facility (WTRF) and is further broken into two options: 

 Under the first option, Alternative B would treat wastewater through the WTRF and reclaim 

treated water to the extent feasible within the site, then discharge any remaining treated 

effluent to local drainages at one of two proposed onsite locations. The WTRF would be 

located either in the northwest corner of the site (location #1) or in the southeast corner of the 

site (location #2) (Figure 2-2 of the Final EA). For wastewater treatment facility location #1, 

treated effluent would be discharged into an onsite drainage that flows into the roadside 

drainage ditch along Windsor River Road, which then flows to a former gravel pit adjacent to 

the Russian River. For wastewater treatment facility location #2, treated effluent would be 

discharged into an unnamed tributary located along the eastern boundary of the project site, 

which flows into Windsor Creek south of the project site. Windsor Creek connects to Mark 

West Creek, which eventually connects to the Russian River. Treated effluent would be used 

for irrigation during the summer and discharged during the winter pursuant to a National 

Pollutant Discharge Elimination System (NPDES) permit that would be issued by the 

USEPA. 

 Under the second option, Alternative B would utilize the WTRF and complete on-site 

effluent storage during winter and spring and summer and fall reclamation. This option under 
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Alternative B would utilize a storage basin for winter storage of recycled water and 

approximately 42 acres of landscaped area and sprayfields for recycled water irrigation 

during summer months. 

ALTERNATIVE C – REDUCED INTENSITY WITH ONSITE WATER AND 

WASTEWATER

Alternative C would include placing the 124.14-acre site into federal trust status for the benefit of 

the Tribe, as discussed under Alternative A. The Tribe would develop the site to provide 55 

residential units including 35 single-family homes, 12 cottage-style houses, and eight highdensity housing units (Figure 2-3). As with the other development alternatives, onsite features 

would include a community center, roundhouse, and retreat facilities. A breakdown of each 

community facility with the components and approximate sizes of each structure is included in 

Table 2-1. Alternative C would include the majority of the rural roadways proposed with 

Alternative A to provide access to the residences and community facilities. The water supply 

system would include similar facilities as described for Alternative B. Wastewater generated on 

the site would be treated at the Wastewater Treatment and Reclamation Facility (WTRF) 

described in Section 2.2, which would be located in the central southern portion of the project 

site. All treated effluent would be disposed of onsite using a combination of landscape irrigation 

and storage basins. No treated effluent would be discharged into surface water. 

ALTERNATIVE D – NO ACTION

Under the No-Action Alternative, the 124.12-acre site would not be placed into trust for the 

benefit of the Tribe and would not be developed as identified under the Proposed Project. 

Jurisdiction of the property would remain within Sonoma County. Ultimately, the 124.12-acre 

site could be developed by the Tribe with the property owned in fee, or by a private party, 

consistent with local zoning. However, for the purposes of the environmental analysis in this EA, 

it is assumed that the property would remain as rural residences and oak woodland habitat and 

would not be further developed. 

ES.4 COMPARISON OF THE PROPOSED PROJECT AND 

ALTERNATIVES 

Among the project alternatives evaluated in Section 4.0, the Proposed Project and Alternative B 

both include 147 housing units and the same associated community facilities. However, 

Alternative B would include onsite water and wastewater facilities (WTRF), whereas the 

Proposed Project (Alternative A) would connect to municipal water and sewer services. 

Alternative C would result in construction of only 55 housing units, with the same community 

facilities as the other two project alternatives, as well as a proportionally smaller on-site water 
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and wastewater facilities (WTRF). Under Alternative D, the No-Action Alternative, no 

development would occur on the property for the foreseeable future. 

Impacts to land resources would be proportionally greatest under Alternative B, due to the larger 

project footprint needed for construction of the WTRF. This would require additional site 

grading compared to the Proposed Project. Alternative C would require slightly less grading than 

the Proposed Project and substantially less than Alternative B. The No-Action Alternative would 

have no effect on land resources. 

Water resources would likewise potentially be impacted the most by Alternative B. This 

alternative would result in a greater area of impermeable surfaces than either the Proposed Project 

or Alternative C. Alternative B would have water demands identical to the Proposed Project; 

however, this alternative would obtain water from the local aquifer. Alternative C would also use 

groundwater, but the quantities would be substantially less due to the reduced number of housing 

units. The Proposed Project would use no groundwater. 

Under the first option for Alternative B, treated effluent would be used for irrigation during the 

summer and discharged to surface water during the winter, which would require a NPDES permit 

from USEPA. Under the second option for Alternative B, on-site treated wastewater storage and 

irrigation would occur year-round. Alternatives B and C require varying amounts of land to 

dispose of the effluent generated by these alternatives under varying climatic conditions. Because 

of the substantially reduced quantity of effluent that would result under Alternative C, all effluent 

would be utilized for on-site irrigation during summer and stored in a basin during the winter; 

therefore, a NPDES discharge permit would not be required. Potential impacts to groundwater 

and surface water quality associated with on-site effluent disposal would be proportionally greater 

for the second option for Alternative B than Alternative C, and much less for the first option of 

Alternative B (seasonal storage only). The Proposed Project, the second option under Alternative 

B and Alternative C would need no NPDES discharge permit, and would result in no impacts to 

surface water or groundwater quality due to on-site effluent discharge. No impacts to water 

resources would result from Alternative D. 

Construction and operational emissions of criteria air pollutants and greenhouse gases would be 

similar under both the Proposed Project and Alternative B; however, these emissions would be 

proportionally lower under Alternative C due to the reduced amount of construction and the 

reduction in residential vehicle trips generated. Operation of the WTRF under Alternatives B or 

C could result in objectionable odors; the Proposed Project would have no such potential effect. 

Under Alternative D, no impacts to air quality would occur. 

Due to the larger development footprint of Alternative B, as well as the operation of the WTRF, 

potential impacts to biological resources would be greatest under this alternative. Impacts to 
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sensitive habitats, potential jurisdictional waters of the U.S., native trees, and special-status 

species would all be slightly lessened under the Proposed Project, and would be proportionately 

less under the substantially reduced development area of Alternative C. No impacts to biological 

resources would occur under Alternative D. 

Potential impacts to cultural resources resulting from inadvertent discovery of previously 

unknown subsurface archaeological or paleontological sites would increase proportionally to the 

amount of ground disturbance; therefore, Alternative B would have the greatest potential for 

effects to cultural resources. The Proposed Project would involve less ground-disturbing 

construction work, thereby reducing the potential for these impacts. Alternative C has the 

smallest construction footprint, and would consequently have the least potential to affect cultural 

resources of the three project alternatives. The No-Action Alternative would not result in impacts 

to cultural resources. 

No significant impacts to socioeconomic conditions and environmental justice outside of the 

Tribe would result from the Proposed Project or Alternatives B, C, or D. The Tribe would benefit 

from creation of housing and associated facilities proposed under Alternatives A, B and C; 

however to the greatest extent under Alternatives A and B. 

Alternatives A and B would generate the same number of vehicle trips, due to the identical 

number of housing units. Impacts to the local transportation network from these two alternatives 

would therefore be similar. Alternative C includes fewer housing units and would therefore 

generate fewer vehicle trips. Impacts to the transportation system would be proportionally 

lessened under this alternative. Alternative D would generate no vehicle trips, and would 

therefore cause no impacts to transportation and circulation. 

Buildout of Alternatives A, B, and C would result in the construction of residences, a community 

center, a roundhouse, and a retreat. Alternatives B and C also include the addition of two 

groundwater wells and a WTRF. All three alternatives are compatible with the surrounding land 

uses, and similar residential densities currently occur in the project vicinity. Alternative C would 

have the least effect on land use as it would result in the lowest residential density. Alternative D 

would have no impact on local land use. 

Alternatives A and B would have equal impacts on solid waste, electricity, natural gas, 

telecommunications, law enforcement, fire protection and emergency medical services, public 

schools, and parks and recreation. Alternative C would have proportionally less impact on these 

services because of the reduced number of residents requiring these utilities and services. 

Alternative D would have no impact on public services and utilities. 
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Alternative A would have the greatest impact on municipal water supply and wastewater 

treatment facilities, as it is the only alternative that would connect to these facilities. This 

alternative would result in an increase of potable water demand and municipal wastewater 

treatment. Alternatives B, C, and D would not result in an increase in demand for municipal 

water supply or wastewater treatment. 

Impacts related to construction noise would be greatest under Alternative B, due to the larger 

development footprint. Alternative A would have a slightly lessened noise impact, as 

construction would take place in a somewhat smaller area and for a shorter duration of time. 

Operational noise would be similar under these two alternatives. Under Alternative C, 

construction activity would be reduced in duration and/or intensity when compared with 

Alternative A and B, and operational noise would be lessened due to the smaller number of 

residents. No noise-related impacts would occur under Alternative D. 

Impacts related to hazardous materials would be greatest under Alternatives B and C, due to the 

storage of hazardous materials (sodium hypochlorite, caustic soda and/ or citric acid) for the 

onsite wastewater facilities, whereas the Proposed Project would connect to the municipal water 

and sewer services and would not require the use of these chemicals. No hazardous material 

impacts would occur under Alternative D. 

Visual resource impacts would be greatest under Alternative B, due to the on-site water and 

wastewater facilities and maximum number of housing units. The Proposed Project would 

include an equal number of houses, but would not include the on-site water and wastewater 

facilities. Alternative C would include the on-site WTRF; however, it would include fewer than 

half of the housing units. No visual impacts would occur under Alternative D. 

While both Alternatives A and B meet the Tribe’s objectives of providing a cohesive residential 

community large enough to accommodate its members, Alternative A would result in fewer 

potential environmental impacts associated with the proposed development activities. Alternative 

C would result in proportionally fewer environmental impacts than the Proposed Project and 

Alternative B, but would not meet the project objectives since it would include fewer than half of 

the housing units, when compared to the two other development alternatives. While the NoAction alternative would not result in any of the environmental effects identified for the Proposed 

Project or Alternatives B and C, this alternative would not meet the Tribe’s objectives of 

providing a sufficient number of housing units for Tribal members, or community facilities for 

Tribal functions. 
Executive Summary 

Analytical Environmental Services ES-10 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

ES.5 ENVIRONMENTAL CONSEQUENCES, MITIGATION, AND 

SIGNIFICANCE CONCLUSIONS SUMMARY 

The environmental consequences of the alternatives analyzed within the Final EA are 

summarized in Table ES-1. Table ES-1 also serves to provide a brief, but comprehensive 

comparison of the environmental impacts of each Alternative. These measures and significance 

conclusions are summarized in Table ES-1. Abbreviations for alternatives and significance are 

identified at the bottom of the table. In the table, the level of significance of each environmental 

impact is indicated both before and after implementation of the recommended mitigation 

measure(s). Mitigation measures identified in the design process have been incorporated into the 

project description. Mitigation measures have been identified where feasible to address specific 

effects regardless of whether they are considered “significant.” In addition, measures have been 

identified to mitigate specific effects identified during the preparation of the Final EA. No new 

significant impacts that could not be mitigated to a less than significant level were identified, nor 

were substantial increases in the severity of environmental impacts identified as a result of 

comments received on the Draft EA. 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

Analytical Environmental Services ES-11 May 2011 

TABLE ES-1 

SUMMARY OF POTENTIAL ENVIRONMENTAL IMPACTS, MITIGATION MEASURES, AND SIGNIFICANCE 

IMPACT 

STATEMENT 

LEVEL OF 

SIGNIFICANCE 

IDENTIFIED MITIGATION 

MITIGATION MEASURE APPLICABLE 

ALTERNATIVE(

5.1 LAND RESOURCES 

Implementation of the Proposed Project could increase the potential for soil erosion due to soil content and construction activities. 

PS A. All site preparation and earthwork construction in the field shall be 

performed by licensed contractors. 

A, B & C 

B. Suitability of earth and construction materials shall be determined 

by a licensed professional employing geotechnical/soils laboratory testing standards according to standard engineering practice. 

A, B & C 

C. All grading plans, subsurface investigations, and slope stability and 

seismic design calculations as well as all foundation, paving, and building design parameters shall be produced under the supervision of appropriate licensed professionals. 

A, B & C 

D. Construction on expansive soil shall be mitigated by using 

specialized grading techniques or designing structural foundations to withstand expansion pressures. 

A, B & C 

E. The effects of soil movement shall be mitigated by strengthening the 

soils during grading and/or designing and constructing satisfactory foundation support. 

A, B & C 

F. Prior to finalization of the grading and development plans for the 

property, design-level geotechnical specifications addressing the specific grading and development plans shall be developed. The specifications should include, but not be limited to, the following: 

1. Site, building and facility-specific grading 

recommendations regarding site preparation, clearing and grubbing. 

2. Select grading procedures, remedial grading procedures, 

material suitability and compaction criteria. 

3. Cut and fill slope stability analyses, recommended slope 

configurations and inclinations. 

4. Evaluation of soil expansion and corrosion potential. 5. Building-specific foundation design parameters. 6. Site-specific seismic design parameters. 7. Lateral earth pressure parameters for retaining wall design, 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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if any. 

8. Pavement design specifications.

5.2 WATER RESOURCES 

Construction of the Project would result in disturbance of the ground surface, which could lead to increased levels of erosion during storm events and a related decline in surface water quality. Operation of the Project could result in water quality impacts from the disposal of wastewater. 

PS A. The Tribe shall obtain a National Pollutant Discharge Elimination 

System permit (NPDES General Permit) from the USEPA for construction site runoff during the construction phase in compliance with the Clean Water Act (CWA). A Storm Water Pollution and Prevention Plan (SWPPP) shall be prepared, implemented, and maintained throughout the construction phase of the development, 

consistent with General Permit requirements. The SWPPP would 

detail the BMPs to be implemented during construction and postconstruction operation of the Proposed Project. The BMPs may include, but are not limited to, the following: 

1. Straw wattle placement on cut and fill slopes. 2. Straw wattle check dam installation within drainage swales. 3. Covering disturbed areas with plastic, hydro-seed 

applications, or straw. 

4. Construction entrance installation to reduce off-site 

sediment transport. 

5. Revegetation following construction activities.

A, B & C 

B. If Alternative B or C is chosen, the Tribe shall construct a tertiary 

wastewater treatment plant as described in Appendix B of the Final EA. Salt-based chemicals shall not be used whenever feasible in the wastewater treatment process. Water softeners that dispose of salt into the wastewater system shall be prohibited 

B & C 

C. Should Alternative B be chosen, the Tribe shall obtain a NPDES 

permit for surface discharge of treated effluent. An energy dissipater that does not result in any fill of waters of the U.S. shall 

be installed at the effluent discharge outfall. 

B 

D. Should Alternative B or C be chosen, wastewater effluent discharge 

shall be reduced or eliminated, if possible, during the issuance of a Urban and Small Streams Flood Advisory by the National Weather Service for the receiving waters into which project effluent is discharged. 

B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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E. Community Education programming will be conducted to educate 

residents of the importance of reducing chemical product use and disposal in the home and minimizing release of medicines and other contaminants into wastewater. 

A, B & C 

F. Should Alternative B or C be chosen, all effluent discharge basins 

shall maintain a minimum vertical distance of two feet freeboard between the high water level and pond levee crowns. Storage basins will also be gated to restrict access. All basins shall also be equipped with draining systems and level monitors. 

A, B & C 

G. Should Alternative B or C be chosen, spray drift from the spray 

disposal irrigation areas would be monitored daily during operation by qualified personnel. Spray drift shall not be allowed to migrate outside the irrigation area. Spray irrigation would cease when winds exceed 30 miles per hour. 

B &C 

H. Should Alternative B or C be chosen, the Tribe would adopt 

standards equivalent to the landscape irrigation standards contained in the State Water Resources Control Board (SWRCB) Recycled Water Policy (as referenced in Resolution No. 2009-0011. 

B &C 

I. Should Alternative B or C be chosen, a wastewater contingency 

plan shall be developed that ensures untreated wastewater is not discharged to the environment in the event of WTRF failure or malfunction. 

B &C 

Potential drawdown of groundwater levels in the vicinity of the project site is not assumed to occur with implementation of Alternative B or Alternative C due to the current aquifer thickness and the distance to the nearest well. 

LTS J. The nested monitoring well constructed for the hydrogeologic 

investigation shall be maintained and used for groundwater-level monitoring. 

B & C 

5.3 AIR QUALITY 

Construction of the Proposed Project would result in the emission of criteria air 

PS A. Construction vehicles, delivery, and commercial vehicles shall not 

idle for more than five minutes. 

A, B & C 

B. The Tribe shall designate an onsite Air Quality Construction BMP A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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pollutants from construction machinery, construction worker automobiles, and physical land disturbance. 

Manager (AQCBM) who shall be responsible for directing compliance with BMPs for the project construction heavy-duty equipment. 

C. Heavy, diesel-powered equipment idling shall be limited to two 

minutes. 

A, B & C 

D. The Tribe shall use heavy duty construction equipment equipped 

with a diesel particulate matter filter. 

A, B & C 

E. The Tribe shall fully fund a program to encourage and facilitate the 

use of ‘carpools’ by construction workers, including providing an offsite location for construction workers to park their vehicles and meet to carpool. 

A, B & C 

F. If possible, the Tribe shall use heavy duty construction equipment, 

which meets California Air Resources Board’s most recent certification standards. 

A, B & C 

G. The Tribe shall provide a storage area for recyclables and green 

waste during construction. 

A, B & C 

H. The Tribe shall recycle 50 percent or more of construction waste. A, B & C I. The Tribe shall use environmentally preferable materials to the 

extent practical for construction of facilities. Buildings will be designed to meet LEED or equivalent certification standards, except with respect to indoor smoking allowed in certain restricted areas. 

A, B & C 

J. The AQCBM shall be responsible for directing compliance with the 

following BMPs for fugitive dust control practices during project construction: 

1. For any earth moving which is more than 100 feet from all 

property lines, conduct watering as necessary to prevent visible dust emissions from exceeding 100 feet in length in any direction. 

2. For all disturbed surface areas apply dust suppression in a 

sufficient quantity and frequency to maintain a stabilized surface; any areas, which cannot be stabilized, as evidenced by wind driven dust, must have an application of water at least twice per day to at least 80 percent of the unstabilized area. 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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3. Establish a vegetative ground cover as soon as feasible 

after active operations have ceased. 

4. For all unpaved roads either water all roads used for any 

vehicular traffic as often as necessary to minimize dust; or apply chemical stabilizer to all unpaved road surfaces in sufficient quantity and frequency to maintain a stabilized surface. 

5. Provide track-out control to minimize tracking of soil onto 

neighboring roadways. 

6. For all off site haul vehicles, cover loads. 7. Grading activities shall not occur when winds exceed 25 

miles per hour (mph). 

8. Speed on unpaved roads shall be limited to 15 mph.

The Proposed Project could result in an increase in GHG emissions. 

PS K. For operation of the proposed project, the Tribe shall institute and 

fund an on-site waste composting program. Waste composting reduces GHG emissions from landfills. This mitigation measure would reduce GHG emissions from mobile sources by one percent. 

A, B & C 

L. For operation of the proposed project, the Tribe shall plant trees and 

other carbon-sequestering vegetation (as part of the Mitigation Measure outlined for native oak trees specified in Section 5.4.2 of the Final EA). The addition of photosynthesizing plants would reduce atmospheric carbon dioxide (CO2) because plants use CO2

for elemental carbon and energy production. Trees planted near buildings would result in additional benefits by providing shade to the buildings, reducing heat absorption and the need for air conditioning. According to the BAAQMD, implementation of this mitigation measure would reduce the project’s electricity consumption, thus lowering indirect GHG emissions in the residential air conditioning sector by up to 30 percent (per Table 5-1 of the Final EA). 

A, B & C 

M. The Tribe shall use solar hot water heaters where possible for all 

project components. The use of solar hot water heaters would reduce project’s energy usage, thus lowering indirect related GHG emissions by reducing natural gas and electricity usage. According to the BAAQMD, implementation of this mitigation measure would 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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reduce the project’s indirect GHG emissions in the residential natural gas water heating sector by up to 70 percent (per Table 5-1 of the Final EA). 

N. The Tribe shall seal all residential and other buildings heating, 

ventilation, and air conditioning ducts. According to the BAAQMD, implementation of this mitigation measure would reduce the project’s electricity consumption, thus lowering indirect GHG emissions in the residential air conditioning sector by up to 30 percent (per Table 5-1 of the Final EA). 

A, B & C 

O. If necessary, purchase GHG emissions credits in the amount 

specified in Table 5-1 on the Final EA in order to reduce the GHG emissions to below the BAAQMD threshold. 

A, B & C 

5.4 BIOLOGICAL RESOURCES 

Significant impacts could occur to aquatic habitat and jurisdictional waters of the US. 

PS A. A 50-foot setback, where possible, shall be established around each 

of the potentially jurisdictional wetland features within the project development and no development shall occur within the setback areas. 

A, B & C 

B. These wetland avoidance setbacks shall be established around 

jurisdictional wetland features using high-visibility fencing. A qualified biologist shall be present during construction activities that ensue within the vicinity of the wetland avoidance buffer zones. The qualified biologist shall monitor during construction to make sure that the fencing remains intact and that construction activities do not penetrate the wetland avoidance buffer zones. When project development is completed, the high-visibility fencing may be removed. 

A, B & C 

C. Temporary fencing shall be installed around riparian habitats. 

Fencing shall be in place prior to the initiation of any construction activities and no encroachment into the fenced areas shall be permitted. Fencing shall remain in place until all construction activities have ceased. 

A, B & C 

D. Any proposed construction activities that would occur within 50 feet 

of jurisdictional waters of the U.S. shall be conducted during the dry season (i.e., April 15 through October 15) to further reduce sedimentation within the watershed. 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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E. If complete avoidance of waters of the U.S. is not possible and 

impacts to wetland features cannot be avoided, authorization from the USACE is required. A Section 404 CWA permit shall be obtained from the USACE and mitigation ratios defined within the permit conditions shall be implemented. Typical Nationwide Permits (NWP) mitigation occurs at a ratio of 1:1 acres created versus impacted and 2:1 acres preserved versus impacted. Individual permit conditions may vary. A CWA Section 401 Water Quality Certification permit from the U.S. EPA would also be required. 

A, B & C 

The Proposed Project is likely to result in direct and/or indirect impacts (i.e., development) to native oak trees and oak habitats onsite. 

PS F. Trees of notable size (i.e. heritage trees exceeding 33 inches in 

diameter at breast height) shall be preserved to the greatest extent feasible. 

A, B & C 

G. Impacts to valley oak trees within the Valley Oak Habitat Combining 

District shall be avoided to the maximum extent feasible. 

A, B & C 

H. Protection of tree crowns and root zones shall be required for all 

trees planned for retention in the vicinity of the construction footprint. 

A, B & C 

I. Native oak trees permanently removed as a result of project 

construction will be mitigated through re-planting of removed trees at a 1:1 ratio as detailed below, or alternatively, preserving an equivalent area of oak woodland. 

1. Replacement oak trees will be planted on Tribally owned 

land and/or other parcels in the vicinity of the project site. 

2. Oak trees may be established by planting in replacement 

areas trees salvaged from construction impact zones, 15 gallon-sized trees, 24-inch boxes, 26-inch boxes, saplings, propagated seedlings, acorns, or any combination of these sizes or stages. 

3. To ensure the success of planted oak trees, the trees shall 

be monitored annually by a qualified biologist for a period of five years, with a survival target goal of 60 percent by the third year. If it is determined after the third year of monitoring that the 60 percent survival rate is not being met, additional trees shall be planted to meet a 80 percent 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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survival goal near the end of five years. 

4. Trees removed for construction shall be assessed by a 

qualified biologist to see if removed trees would be suitable for relocation in replacement areas.

The Proposed Project has the potential to result in direct impacts to special-status plant species should they occur within the project site. The Proposed Project could also result in indirect impacts to special-status plant species through loss of suitable habitat. 

PS J. The remaining floristic surveys for Sonoma sunshine, Sebastopol 

meadowfoam, Burke’s goldfields, and many-flowered navarretia shall be conducted within the required areas of the project site in accordance with the Santa Rosa Plain Conservation Strategy protocol prior to groundbreaking on those parcels. 

A, B & C 

K. If the protocol-level floristic survey results are positive, then formal 

consultation with USFWS must be initiated. Upon consultation, an appropriate course of action shall be established. 

A, B & C 

L. Prior to the onset of construction activities, an avoidance plan must 

be formulated, submitted, and approved by the USFWS. It is likely to entail the following basic principles: 

1. Prior to the onset of construction activities the areas where 

the plants occur shall be delineated with avoidance buffers via high visibility fencing. The avoidance buffers may be 50 feet in width, unless otherwise specified by USFWS. 

2. A qualified botanist shall be present during construction 

activities that ensue within the vicinity of the special-status plant avoidance buffer zones and monitored to ensure that the fencing remains intact and that construction activities do not penetrate the special-status plant avoidance buffer zones. 

3. When project development is completed, the high-visibility 

fencing may be removed. However, future development shall not occur within the setback buffer areas.

A, B & C 

M. If complete avoidance of the Santa Rosa Plain special-status plants 

is not feasible, the Tribe shall mitigate for impacts to the plants according to the mitigation ratios in Table 5-1 of the Final EA, which 

are outlined in the Programmatic Consultation for USACE 404 Permitted Projects that May Affect Four Endangered Plant Species on the Santa Rosa Plain, California (File Number 223420N) 

(USFWS, 2007). 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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The Proposed Project has potential to impact migratory nesting birds if construction activities occur during the nesting season (March 1 through September 15). 

PS N. If any construction activities are scheduled to occur during the 

nesting season (February 15 – August 31), pre-construction bird surveys shall be conducted. Pre-construction surveys for any nesting bird species shall be conducted by a qualified wildlife biologist, throughout all areas of suitable trees and habitat that are within 500 feet of any proposed construction activity, including oak trees slated for removal. The surveys shall occur no more than 14 days prior to the scheduled onset of construction activities. If construction is delayed or halted for more than 14 days, another pre-construction survey for nesting bird species shall be conducted. 

If no nesting birds are detected during the pre-construction surveys 

no additional surveys or mitigation measures are required. 

A, B & C 

O. If migratory nesting bird species are observed within 500 feet of the 

construction area during the surveys, appropriate avoidance setbacks shall be established by the qualified biologist. The size and scale of nesting bird avoidance setbacks is dependent upon the species of nesting bird observed and the habitat that the nest occurs. Avoidance setbacks shall be established around all active nest locations via stakes and high visibility fencing. The nesting bird setbacks shall be completely avoided during the duration of construction activities and the fencing must remain intact. The qualified biologist shall also determine an appropriate monitoring plan and shall decide if construction monitoring is necessary during the duration of construction activities. Again, monitoring requirements are dependent upon the species of nesting birds observed, the habitat in which the nests are contained, and the number of nests observed. The setback fencing may be removed when the qualified biologist confirms that the nest(s) are no longer occupied and all young have fledged. 

A, B & C 

P. If impacts (i.e., take) to migratory nesting bird species are 

unavoidable, consultation with USFWS shall be initiated. Through consultation, an appropriate and acceptable course of action shall be established. 

A, B & C 

5.5 CULTURAL RESOURCES The Proposed Project may PS A. Should any buried cultural materials (archaeological or A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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adversely affect previously unknown subsurface prehistoric or historic archaeological resources, including human remains. 

paleontological) be uncovered during ground-disturbing project activities, such activities shall cease within 100 feet of the find. Prehistoric archaeological indicators include: obsidian or chert flaked-stone tools and waste flakes (debitage) resulting from the tool making process; bedrock outcrops and boulders with mortar cups; ground stone implements (grinding slabs, mortars and pestles); and locally darkened midden soils containing any of the previously listed 

items plus fragments of faunal bone or shell, fire-affected rocks, 

and/or unusual amounts of charcoal. Historic period site indicators generally include: fragments of glass, ceramic and metal objects; milled and split lumber; and structural and feature remnants such as building foundations, privy pits, wells, irrigation ditches, and refuse dumps; and old trails. The Lytton Rancheria shall be notified of the discovery and a professional archeologist (or paleontologist, as appropriate) shall be retained to evaluate the find and recommend appropriate treatment measures in consultation with the Lytton Rancheria. Project-related activities shall not resume within 100 feet of the find until all mitigation measures have been approved and completed. 

B. If suspected human remains are encountered, work should halt in 

the vicinity and the Sonoma County Coroner should be notified immediately. At the same time, the Lead Agency and a qualified archaeologist should be contacted to evaluate the find. If human remains are determined to be of Native American origin, the Coroner must notify the NAHC within 24 hours of this identification. Construction activities shall not resume within 100 feet of the find until the NAHC-designated Most Likely Descendant (MLD) and the Tribe approves and implements a strategy for the appropriate disposition of the remains. 

A, B & C 

 C. Should paleontological resources be unearthed, a paleontological 

resource impact mitigation plan (PRIMP) shall be created prior to further earthmoving in the vicinity of the find. The PRIMP shall detail the procedures for collecting and preserving the discovered 

fossils. Any fossils discovered during construction shall be accessioned in an accredited scientific institution for future study. 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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5.6 SOCIOECONOMIC CONDITIONS 

The project would not result in any significant negative impacts to school districts or environmental justice issues. 

LTS None warranted. A, B & C 

5.7 TRANSPORTATION AND CIRCULATION The Proposed Project could result in increased traffic at the intersection of Windsor River Road and Bell Road. 

PS A. The Tribe shall pay a proportionate share for necessary intersection 

improvements at the intersection of Windsor River Road and Bell 

Road (Intersection #6). The improvements shall include, but not limited to, installation of a traffic signal if and when the Town of Windsor determines a signal is warranted. 

A, B & C 

The Proposed Project could potentially result in increased traffic at the intersection of Old Redwood Highway and Northbound U.S. 101 off-ramp at Lakewood Drive. 

PS B. The Tribe shall pay a proportionate share for intersection 

improvements at the intersection of Old Redwood Highway and the 

Northbound U.S. 101 Off-Ramp at Lakewood Drive (Intersection #9). Improvements would include the construction of an additional southbound left turn lane, an additional southbound right-turn lane, and restriping the northbound approach to include a shared through-left lane. It is assumed that the project’s equitable share of any planned improvements at this intersection would be calculated based on the methodology set forth in Appendix “B” of the 

California Department of Transportation “Guide for the Preparation 

of Traffic Impact Studies”. It is also assumed this will be determined in consultation with Sonoma County, the Town of Windsor and the Tribe. 

A, B & C 

5.8 LAND USE AND AGRICULTURE 

The project would not result in any significant impacts to land use and agriculture. 

LTS None warranted. A, B & C 

5.9 PUBLIC SERVICES Implementation of the Proposed Project could potentially result in an increased risk for wildfires. 

PS A. To minimize the risk of fire and the need for fire protection services 

during construction, any construction equipment that normally includes a spark arrester shall be equipped with a spark arrester in good working order. This includes, but is not limited to, vehicles, heavy equipment, and chainsaws. 

A, B & C 

B. During construction, staging areas, welding areas, or areas slated A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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for development using spark-producing equipment would be cleared of dried vegetation or other material that could serve as fire fuel. To the extent feasible, the contractor would keep these areas clear of combustible materials in order to maintain a firebreak 

C. Fire extinguishers shall be maintained onsite and inspected on a 

regular basis. 

A, B & C 

D. An evacuation plan shall be developed for the proposed 

development in the event of a fire emergency. 

A, B & C 

E. Fire hydrants shall be spaced no less than 500-feet apart 

throughout the developed portions of the site. 

A, B & C 

F. Fire alarm and suppression systems installed shall conform to 

design standards equivalent to the requirements of the California Building and Fire Codes as amended and adopted by Sonoma County. 

A, B & C 

G. On-site development shall be consistent with Sonoma County Fire 

Safe Standards Sections 13-54 through 13-59.

A, B & C 

H. A vegetation management plan shall be prepared by a qualified 

professional prior to occupation of any residences. The plan shall include, at a minimum, defensible space zones, identification of vegetation types, replacement of non-native flammable vegetation with fire resistive vegetation, and a maintenance program for all vegetation. The Tribe shall approve the plan and pass a resolution that requires that it will be implemented and maintained. Prior to approving the plan, the Tribe shall submit it to the County Fire Chief for review. 

A, B & C 

I. The Tribe shall arrange and coordinate with local law enforcement 

and emergency services if needed to assist with large events held at the proposed Community Center. 

A, B & C 

J. The Tribe and the Town of Windsor shall enter into a mutually 

agreeable binding service contract for the provision of water and sewer service to the project. 

A 

5.10 NOISE Implementation of the Proposed Project could potentially result in increased 

PS A. The Tribe shall restrict construction activities to normal daytime 

hours (7 a.m. to 7 p.m.), Monday through Saturday, with no work performed on Sundays.

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

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levels on noise in the vicinity of the project site during construction of project components and operation of the water reclamation facility. 

B. The Tribe shall ensure that construction equipment used at the 

project site shall be equipped with the best available noise reduction technology feasible, including the use of mufflers on motorized equipment according to the manufacturer’s specifications. 

A, B & C 

C. All existing residences within 200 feet of the project site shall be 

notified at least one day in advance of construction that is proposed to take place within 300 feet of the residence. 

A, B & C 

D. Stationary noise-producing equipment such as compressors and 

generators shall be placed as far as practical from homes, and shielding shall be provided between any such equipment and homes when it is necessary to operate the equipment closer than 200 feet from a home. 

A, B & C 

 E. On-site water reclamation facility equipment shall be shielded or 

enclosed. 

B & C 

5.11 HAZARDOUS MATERIALS Hazardous materials, such as gasoline, diesel fuel, and hydraulic fluid, would be brought on site during the construction phase. The storage of these hazardous materials on-site is therefore considered a potentially significant impact. 

PS A. Potentially hazardous materials, including fuels, shall be stored 

away from drainages and secondary containment shall be provided for all hazardous materials during construction.

A, B & C 

B. A spill prevention and countermeasure plan shall be developed 

which shall identify proper storage, collection, and disposal measures for potential pollutants (such as fuel storage tanks) used onsite, as well as the proper procedures for cleaning up and reporting of any spills. 

A, B & C 

C. Vehicles and equipment used during construction shall be provided 

proper and timely maintenance to reduce potential for mechanical breakdowns leading to a spill of materials into water bodies. Maintenance and fueling shall be conducted in an area that meets the criteria set forth in the spill prevention plan.

A, B & C 

D. Before the parcels are taken into trust, all items of non-hazardous 

debris shall be removed for the site and properly disposed of or recycled an appropriate off-site facility. 

A, B & C 

E. A hazardous materials storage and disposal plan shall be prepared 

that contains an inventory of hazardous materials stored and used on site, maintains an emergency response plan for a release and 

A, B & C 
Less than Significant = LTS Potentially Significant = PS No Impact = NI Alternative A = A Alternative B = B 

Analytical Environmental Services ES-24 May 2011 

IMPACT 

STATEMENT 

LEVEL OF 

SIGNIFICANCE 

IDENTIFIED MITIGATION 

MITIGATION MEASURE APPLICABLE 

ALTERNATIVE(

disposal of unused hazardous materials, and provides provisions specifying employee training in safety and emergency response procedures. 

5.12 VISUAL RESOURCES 

The project will not result in any significant impacts to visual resources. 

LTS None warranted. A, B & C 
SECTION 1.0 

INTRODUCTION
Analytical Environmental Services 1-1 Lytton Property Residential Development

May 2011 Final Environmental Assessment

SECTION 1.0 

INTRODUCTION 

1.1 INTRODUCTION 

This Environmental Assessment (EA) has been prepared for the U.S. Bureau of Indian Affairs 

(BIA) to support an application from the Lytton Rancheria of California (hereafter, “Tribe”) for 

land to be placed into federal trust (Proposed Action). The BIA is the federal agency that is 

charged with reviewing and approving tribal applications to take land into federal trust status. 

This land, known as the “Lytton Property,” consists of approximately 92 124.12 acres in Sonoma 

County, California, which is intended to be used for residential housing, a community center, and 

associated facilities by the Tribe. The BIA will use this EA to determine if the Proposed Action 

would result in adverse effects to the environment. 

This document has been completed in accordance with the requirements set out in the National 

Environmental Policy Act (NEPA) of 1969 (42 U.S.C. §4321 et seq.); the Council on 

Environmental Quality (CEQ) Guidelines for Implementing NEPA; and the BIA’s NEPA 

handbook (59 IAM 3-H). This document provides a detailed description of the Proposed Action 

and an analysis of the potential environmental consequences associated with the development of 

this project. This document also includes a discussion of alternatives, impact avoidance, and 

mitigation measures. Consistent with the requirements of NEPA, the BIA will review and 

analyze the environmental consequences associated with the Proposed Action, and either 

determine that a Finding of No Significant Impact (FONSI) is appropriate, or request that an 

Environmental Impact Statement (EIS) be prepared. 

1.2 LOCATION AND SETTING 

The proposed trust parcels addressed in this EA are located approximately two miles west of 

Highway 101 near the Town of Windsor, California, one mile east of the Russian River, and 

approximately ten miles north of the City of Santa Rosa. The project site is within the 

“Healdsburg and Environs” sub-County Planning Area of Sonoma County and occurs in Sections

14, 15, and unsectioned areas of Molinos, Township 8 North, Range 9 West, on the 

“Healdsburg,” California U.S. Geological Survey (USGS) 7.5-Minute Topographic Quadrangle 

(USGS, 1993). Figure 1-1 shows the regional vicinity and Figure 1-2 shows the project site 

vicinity and location. Figure 1-3 shows an aerial photograph of the entire project site, which 
^_

PROJECT SITE

Sonoma County

Lake County

Napa County

Marin County

Mendocino County

Santa Rosa

Petaluma

Windsor

Rohnert Park

Cobb

Bodega Bay

Lower Lake

Hidden Valley Lake

Deer Park

Occidental

St. Helena

Forestville

Healdsburg

Cotati

Sonoma

Guerneville

Calistoga

Dillon Beach

Cloverdale

Middletown

Graton

Temelec

Glen Ellen

Sebastopol

Monte Rio

El Verano

Roseland

Eldridge

Boyes Hot Springs

Tomales

£¤101

£¤101

UV1

UV116

UV128 UV29

UV175

UV12

UV121

UV116

UV29

UV29

UV116

UV12

UV12

Figure 1-1

Regional Location

SOURCE: StreetMap North America, 2009; AES 2011

^_

0 3 6

Miles

SCALE

^_ Project Site

Sonoma County

Lytton Residential Development Final EA / 207513
Starr Rd

Eastside Rd

Windsor Rd

Windsor River Rd

£¤101

Old Redwood Hwy

Herb Rd

Los Amigos Rd

Arata Ln

Gumview Rd

Fontana Rd

Reiman Ln

Starr View Dr

Richardson Rd

Cooper Way

Kloer Rd

Oak Way

Jones Rd

Rio Ruso Dr

RUSSIAN RIVER

Erika Dr

Russian River Gravel Company Rd

Rockstrech Rd

Grapevine Ln

Ashley Dr

Figure 1-2

Site and Vicinity

SOURCE: "Healdsburg, CA” USGS 7.5 Topographic Quadrangle,

T8N, R9W, Sections 14, 15, and unsectioned areas of Molinos, 

Mt. Diablo Baseline & Merdian; Sonoma County GIS, 2/9/2007;

AES, 2011

LEGEND

0 990 1,980

Feet

!¢NO

ÐR TH

Lytton Residential Development Final EA / 207513

Project Site Boundary

Windsor Sphere of Influence

Windsor Urban Growth

Windsor City Limits
Windso r River Rd

Eastside R d

APN

066-300-028

(5.0 Acres)

APN

066-300-033

(12.51 Acres)

APN

066-300-031

(50.47 Acres)

APN

066-300-017

(3.60ac)

APN

066-300-023

(1.22ac)

APN

066-191-017

(9.27 Acres)

APN

066-191-018

(0.002 Acres)

APN

066-191-016

(4.11 Acres)

APN

066-191-019

(2.28ac)

APN

066-050-040

(9.86ac)

APN

066-050-047

(10.14ac)

APN

066-191-021

(1.248ac)

APN

066-191-020

(2.45 Acres)

APN

066-191-022

(11.96 Acres)

Figure 1-3

Aerial Parcel Map

SOURCE: AEX Aerial Photograph, 11/1/2008; AES, 2011 Lytton Residential Development Final EA / 207513

LEGEND

0 250 500

Feet

!¢NO

ÐR TH New Proposed Trust Parcels

Original Proposed Trust Parcels
1.0 Introduction 

Analytical Environmental Services 1-5 Lytton Property Residential Development

May 2011 Final Environmental Assessment

consists of seven fourteen separate parcels totaling approximately 92 124.12 acres, all owned in 

fee by the Tribe. The seven fourteen parcels are identified by the following Assessor Parcel 

Numbers (APNs) in Table 1-1. 

TABLE 1-1 (NEW TABLE)

ASSESSOR’S PARCEL NUMBERS WITHIN THE PROJECT SITE 

APN Acreage Town of Windsor Sonoma County Zoning/

Land Use 

066-300-028 5.00 N/A AR/ RR 

066-300-033 12.51 N/A AR/ RR 

066-300-031 50.47 N/A AR/ RR 

066-300-023 a 1.22 N/A AR/ RR 

066-300-017 a 3.60 N/A AR/ RR 

066-191-016 a 4.11 N/A AR/ RR 

066-191-019 a 2.28 N/A AR/ RR 

066-191-021 a 1.25 N/A AR/ RR 

066-191-020 2.45 N/A AR/ RR 

066-191-022 11.96 LDR/ E AR/ RR 

066-191-018 0.002 LDR AR/ RR 

066-191-017 9.27 LDR/ E AR/ RR 

066-050-040 a 9.86 LDR/ E AR/ RR 

066-050-047 a b 10.14 LDR AR/ RR 

Total 124.12 

Town of Windsor: 

N/A: Not applicable; parcels located outside Town of Windsor Sphere of Influence/ Urban Growth Boundary 

LDR (Zoning): Low-Density Residential 

E (Land Use): Special Planning Area E 

a

 Parcel added to fee-to-trust application and site plan alternatives under this Final EA. b

 Parcel located within Town of Windsor limits 

Sonoma County: 

AR (Zoning): Agriculture and Residential District 

RR (Land Use): Rural Residential 

SOURCE: Sonoma County Permit and Resource Planning Department, 2010: Town of Windsor, 2005. 

 066-300-028 (5.0 acres)

 066-300-031 (50.47 acres)

 066-300-033 (12.51 acres)

 066-191-017 (9.27 acres)

 066-191-018 (0.002 acres)

 066-191-020 (2.45 acres)

 066-191-022 (11.96 acres)

Except for parcel APN 066-050-047, which falls within the limits of the Town of Windsor, The 

the site is located approximately 150 feet south of the Windsor city town limits (Figure 1-2). 

APNs 066-191-017, 066-191-018, 066-050-040, 066-050-047 and 066-191-022 are 
1.0 Introduction 

Analytical Environmental Services 1-6 Lytton Property Residential Development

May 2011 Final Environmental Assessment

locatedcomprise approximately 41.23 acres within the Town of Windsor’s Sphere of Influence, 

Urban Growth Boundary, and all fall within Special Planning Area E except parcel 066-050-047. 

Regional access is provided by Highway 101, which runs in a general north-south direction and is 

located approximately two miles to the east of the project site. Local access to the Proposed 

Project site from Highway 101 is provided by the Old Redwood Highway/Windsor River Road 

exit, which to the westeast of Highway 101 is a two-lane road that runs adjacent to the north side 

of the project site. The only other roadway in the immediate vicinity is Eastside Road, which 

runs perpendicular to Windsor River Road and is west of the project site (Figure 1-3). A 

partially unpaved road is located between APNs 066-300-031 and 066-191-017, which leads to 

agricultural fields to the south of the project site. Another partially paved road is located between 

066-191-022 and 066-191-020, which leads to an existing residence.

SixTwelve existing single-family homes are located within the project site’s boundaries. Two 

homes are located on APNs 066-300-028 and 066-050-040. Each of the following four eight

parcels contains existing residences: APNs 066-300-017, 066-191-016, 066-191-019, 066-191-

021, 066-300-033, 066-300-031, 066-191-0187, and 066-191-020. Surrounding land uses include 

private residential, agricultural, and undeveloped parcels. 

The majority of the project site is undeveloped and uncultivated over a gently rolling terrain, 

comprised of five vegetation community types: mixed oak woodland, annual grassland, oak 

savannah, mixed riparian, and pasture. Access to all residences is from Windsor River Road. 

The topography of the site ranges in elevations of 100 to 200 feet above mean sea level. 

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION 

Following the passage of the Rancheria Act (the Act of August 18, 1958, PL. 85-671, 72 Stat. 

619), the federal government terminated the Lytton Rancheria and distributed the tribal trust 

lands, which were located within the Alexander Valley, to individual members of the Lytton 

Rancheria. The Rancheria Act and distribution plan called for the federal government to provide 

certain improvements to the properties to make them habitable for the individuals to whom the 

property was distributed. The federal government failed to meet these obligations, however, and 

the Lytton Rancheria was restored as a tribe in 1991 through a stipulated judgment which 

acknowledged that the tribe was never legally terminated. There after, the Lytton Rancheria was 

again listed in the Federal Register as an Indian entity which is recognized and eligible to receive 

services from the United States Bureau of Indian Affairs. Since then, the Tribe has attempted to 

secure land to re-establish a unified community in the vicinity of the Alexander Valley. The 

Tribe’s purpose for taking the 124.1292 acres of land into trust is for the development of a 

residential community, a community center, and associated Tribal facilities. The construction of 

these facilities is important to the Tribe and provides a basis for taking the land into trust pursuant 
1.0 Introduction 

Analytical Environmental Services 1-7 Lytton Property Residential Development

May 2011 Final Environmental Assessment

to 25 C.F.R. Part 151. Management and protection of the land and its natural resources, as well 

as the provision of social services to Tribal members, are essential functions of Tribal 

government. The Lytton Tribe consists of approximately 270 Tribal members, governed by a 

tribal council of five members. Tribal members are currently dispersed throughout the County 

and State and do not have an identifiable physical community of their own. The proposed 

acquisition would bring together Tribal members into a unified community location by providing 

adequate housing and associated facilities to improve the quality of life of the Tribal members. 

Taking the property into trust will allow the Tribe to foster its cultural identity, spiritual values, 

and traditional religion through construction of the roundhouse, retreat and community center. 

Providing housing in the fee-to-trust lands will limit the geographic dispersion of Tribal 

members. Acceptance of the subject parcels into federal trust would assist the Tribe in meeting a 

long-term, viable, and sustainable solution to the Tribe’s lack of a tribal land base and provide a 

place to congregate for governmental, cultural, and social purposes. 

1.4 OVERVIEW OF THE ENVIRONMENTAL PROCESS 

The BIA and the Tribe will use the EA to determine whether the Proposed Action will result in 

adverse effects on the environment and whether a Finding of No Significant Impact (FONSI) or 

an Environmental Impact Statement should be prepared, pursuant to NEPA and the BIA’s NEPA 

Handbook (59 IAM 3-H; BIA, 2005). 

The EA is first released for a 30-day comment period. Comments will be considered by the BIA, 

and either a FONSI will be prepared, or additional environmental analysis will be conducted. 

After the NEPA process is complete, the BIA may issue a determination on the Tribe’s fee-totrust application. 

1.5 ENVIRONMENTAL ISSUES ADDRESSED 

In accordance with NEPA, and based on a review of the 124.1292-acre project site, the following 

environmental issue areas are evaluated in this EA: 

 Land Resources; 

 Water Resources; 

 Air Quality; 

 Biological Resources; 

 Cultural Resources; 

 Socioeconomic Conditions/Environmental Justice; 

 Transportation and Circulation; 

 Land Use; 

 Public Services; 
1.0 Introduction 

Analytical Environmental Services 1-8 Lytton Property Residential Development

May 2011 Final Environmental Assessment

 Noise; 

 Hazardous Materials; and 

 Visual Resources. 

1.6 REGULATORY REQUIREMENTS AND APPROVALS 

The following direct and indirect approvals and actions may occur as a result of the Proposed 

Action: 

 Transfer of the 124.1292-acre site into Federal trust status for the Tribe by the 

Secretary of the Interior. 

 Compliance with the National Pollutant Discharge Elimination System (NPDES) 

General Permit for Storm Water Discharges Associated with Construction Activity. 

 NPDES permit for discharge of treated effluent into waters of the U.S., if the 

seasonal surface water discharge option for Alternative B is chosen. 

 Consultation with the U.S. Fish and Wildlife Service (USFWS) under Section 7 of 

the Federal Endangered Species Act (FESA), if endangered species may be impacted 

by the Proposed Action. 

 Consultation with the State Historic Preservation Office (SHPO) under Section 106 

of the National Historic Preservation Act (NHPA), if historic properties may be 

impacted by the project. 

 Consultation with the U.S. Army Corps of Engineers (USACE) under Section 404 of 

the Clean Water Act (CWA), if any waters of the U.S. may be impacted by the 

project. 

 Encroachment permit for construction of offsite water and wastewater infrastructure 

and associated pipeline, if Alternative A is chosen. 
SECTION 2.0 

PROPOSED PROJECT AND ALTERNATIVES
Analytical Environmental Services 2-1 Lytton Property Residential Development

May 2011 Final Environmental Assessment

SECTION 2.0 

PROPOSED PROJECT AND ALTERNATIVES 

The Proposed Project and project alternatives are described in this section. This section also 

summarizes the potential environmental consequences associated with each alternative as well as 

the protective measures and Best Management Practices (BMPs) incorporated into the project to 

reduce potential adverse impacts to environmental resources. A summary of each development 

alternative and associated components is included in Table 2-1. The project alternatives 

evaluated in the Environmental Assessment (EA) include: 

 Alternative A - 147 residences and community facilities with municipal water and 

wastewater service from the Town of Windsor (Proposed Project); 

 Alternative B - 147 residences and community facilities with onsite water supply and 

wastewater treatment under one of two options; 

o Under the first option, effluent storage/ reclamation on-site to the extent feasible, 

and surface water discharge of any remaining treated effluent during winter, or

o Under the second option, complete on-site effluent storage/ reclamation (storage 

during winter and spring) and subsequent reclamation during drier months;

 Alternative C - 55 residences and community facilities with onsite water supply and 

wastewater treatment with effluent storage/ reclamation; and 

 Alternative D - No-Action Alternative. 

2.1 ALTERNATIVE A - PROPOSED PROJECT 

Alternative A consists of two main components: (1) placing seven fourteen parcels that roughly 

total 92 124.14 acres (APNs 066-300-028, 066-300-031, 066-300-023, 066-300-017, 066-300-

033, 066-191-016, 066-191-017, 066-191-019, 066-191-018, 066-191-020, 066-191-020, 066-

050-040, 066-050-047 and 066-191-022) into Federal trust status for the Tribe, and (2) 

construction of 147 residential units and associated facilities. Alternative A is described in more 

detail below. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-2 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

TABLE 2-1 (REVISED)

SUMMARY OF DEVELOPMENT ALTERNATIVES 

Project Components Alternatives

A B C 

Single-family (low-density) 

houses 95 95 35 

Cottages (Townhouses) 24 24 12 

High-density units 28 28 8 

Total Units 147 147 55 

Community Center 18,809 SF 18,809 SF 18,809 SF 

Roundhouse 2,500 SF 2,500 SF 2,500 SF 

Retreat 2,707 SF 2,707 SF 2,707 SF 

Water Source Municipal Onsite wells Onsite wells 

Wastewater Option Municipal 

Onsite wastewater treatment and 

reclamation facility (WTRF), seasonal 

reclamation and surface water 

disposal (first option) or all-year onsite reclamation (second option) 

Onsite wastewater 

treatment plant, onsite 

reclamation 

Note: Square Feet (SF) 

SOURCE: Williams and Paddon, 2009; Eco:Logic, 2010a 

2.1.1 LAND TRUST ACTION

Alternative A consists of the fee simple conveyance of the approximately 92124.14-acre site into 

Federal trust status for the benefit of the Tribe. This trust action would shift civil regulatory 

jurisdiction over the 124.1492 acres from the State of California and Sonoma County to the Tribe 

and the federal government; the State and County would continue to exercise criminal jurisdiction 

under 18 U.S.C. §1162 and other federal laws pertaining to jurisdiction in Indian country. 

2.1.2 RESIDENTIAL COMPONENT

The Tribe would develop the project site to provide approximately 147 residential units. A site 

plan for Alternative A is shown in Figure 2-1. The residential units would include 95 singlefamily detached houses, 24 cottage-style houses, and 28 high-density housing units (Table 2-1). 

Rural roadways would be constructed to provide access to the residences. Sample design features 

for the single-family residential houses, including sample floorplans and a demonstration of 

green-building features is contained in Appendix K.

2.1.3 ASSOCIATED FACILITIES 

As shown in Figure 2-1, a Tribal community center, retreat, and a roundhouse would be included 

as part of the proposed development. These facilities would be open only to Tribal members and 

their guests for tribal events, functions, and ceremonies. The facilities would also be open to 

Tribal residents of the site as a gathering place for socializing and recreation. The facilities 
Proposed Retreat Facility

Proposed Backup Well

Primary Water Storage Tank

Proposed Roundhouse

Proposed Ceremonial 

Dance Circle

Proposed 

Community Center

Proposed Park

WINDSOR RIVER ROAD

WELL NI GTON

CIRCLE

KENS NI GTON LANE

EASTSIDE ROAD

LEGEND

Figure 2-1

Site Plan - Alternative A

SOURCE: Adobe Associates, 2010; Aerial Express aerial photograph, 11/2008; AES, 2011 Lytton Residential Development Final EA / 207513

Property Boundaries

Proposed Trail

Cottage Housing

High Density Housing

Low Density Housing

Parking

Proposed Backup Well - Primary Water Storage

Proposed Retreat Facility

Proposed Ceremonial Dance Circle

Proposed Community Center

Proposed Park

Proposed Roadway

Proposed Roundhouse !¢NO

ÐR TH

0 175 350

Feet
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-4 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

would not be open to the public for the purposes of hosting business meetings, conferences, 

events, or gaming. The community center would be approximately 19,000 square feet (sf) in size 

and located in the central southern portion of the project site. It would include a lounge area, 

bathroom facilities, and administrative offices. The roundhouse would be situated west of the 

community center and would include approximately 2,500 sf. The retreat would be located 

northwest of the roundhouse and would consist of approximately 2,700 sf. Signage would be 

included for all community facilities. A detailed breakdown of each facility, including the 

components and approximate sizes of each facility, are displayed in Table 2-2. An architectural 

rendition of the community center and retreat is contained in Appendix K. 

2.1.4 PUBLIC SERVICES 

The Town of Windsor’s Police Department (WPD) contracts with the Sonoma County Sheriff’s 

Department Office (SCSOD) for law enforcement services. Both the WPD and the SCSOD

would serve the project site. Pursuant to the Cooperative Fire Protection Agreement (Appendix 

I) between the Bureau of Indian Affairs (BIA) and State of California Department of Forestry and 

Fire Protection (CAL alFIREire), CAL alFIREire would provide fire protection and emergency 

medical services. Electric, telephone, and cable services would be extended to the site through 

contracts with the appropriate agency, if required. 

2.1.5 WATER SUPPLY

Water would be supplied from the Town of Windsor’s public water supply system, under an 

agreement to be negotiated between the parties. The primary water supply for the Windsor water 

system is wells located near the Russian River, northwest of the project site. Two large diameter 

water transmission mains transport water from the well field to the town for distribution. One of 

the two transmission mains is an 18-inch diameter main that parallels Windsor River Road, 

immediately north of the project site. Two connections would be made to this water main to 

serve the site. Each of these connections would include a meter and backflow prevention 

facilities, if required. Common area landscaping areas are proposed to be irrigated with 

reclaimed water supplied by the Town of Windsor. The closest reclaimed water pipeline is 

located at the intersection of Windsor River Road and Windsor Road, approximately 6,000 feet 

east of proposed landscaped areas under Alternative A. The Tribe would install an onsite water 

distribution system and water quality standards would be adopted by the Tribe that would be no 

less stringent than Federal water quality and Federal Safe Drinking Water Act standards. 

Inspections of the water supply system and water quality by the U.S. Environmental Protection 

Agency (USEPA) would ensure compliance with applicable safe drinking water standards. The 

proposed water connection is discussed in more detail in Appendix B. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-5 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

TABLE 2-2 

TRIBAL COMMUNITY DEVELOPMENT — ONSITE FACILITIES 

Structure Usage Room Square Footage (sf) 

Community 

Center 

Social Entry Lobby 400 

Banquet Pre-function 750 

Banquet Hall 4,250 

Catering Kitchen 450 

Banquet Storage 250 

Multi-Purpose (3 room each at 625 sq ft) 1,875 

Restrooms 480 

Electrical and Telephones 250 

Janitorial 75 

Subtotal 8,780 

Administrative Entry/Reception 175 

Private Offices (15 rooms each at 144 sq ft) 2,160 

Open Office 750 

Work Room 200 

Break Room 200 

Conference Room 375 

Storage 250 

Restrooms 350 

Subtotal 4,460 

Wellness Entry/Reception 200 

Treatment Room (3 rooms each at 120 sq ft) 360 

Private Office 144 

Work Room 225 

Storage 150 

Restrooms 150 

Subtotal 1,229 

Amenity Subtotal 14,469 

Circulation, Misc. at 30% 4,340 

Total Community Subtotal 18,809 

Roundhouse Spiritual Round House Ceremonial Space 2,500 

Retreat Social Entry Lobby 150 

Pre-function Lounge 350 

Banquet Room 1,000 

Catering Kitchen 250 

Restrooms 250 

Storage 100 

Subtotal 2,100 

Circulation, Misc. at 30% 607 

Total Retreat Subtotal 2,707 

Combined Total of Amenities 24,016 sq ft

Source: Williams and Paddon, 2009
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-6 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

2.1.6 WASTEWATER TREATMENT AND DISPOSAL

Under this alternative, the Tribe would enter into an agreement with the Town of Windsor for 

sewer service. The Town is responsible for the treatment, storage, and disposal of the Town’s 

wastewater. A sewage lift station and approximately 3,200 feet of force main would be 

constructed to pump the wastewater from the proposed Tribal community to a manhole located 

near the intersection of Windsor River Road and Starr Road (approximately a half mile from site). 

The existing Windsor Wastewater Treatment, Reclamation, and Disposal Facility would have 

sufficient treatment and disposal capacity to serve the Proposed Project (ECO:Logic, 2010a: 

Appendix B). The Tribe would adhere to local regulations for extending sewer mainlines to the 

project site, including the Town’s Sanitary Sewer Management Plan. 

2.1.7 ROADWAYS

As shown in Figure 2-1, rural roadways would be constructed to provide access to onsite 

residences and facilities. Three main project access driveways from Windsor River Road are 

proposed. Stop signs would be installed at these three project access driveways. The rural 

roadways would be 24-feet wide two-lane asphalt travel ways, with gravel shoulders consistent 

with Sonoma County Subdivision and Fire Safe Standards. Signage would be provided for the 

new roadways. 

2.1.8 PROJECT CONSTRUCTION

The project components would be constructed after the 92-acre propertyproject site has been 

placed into federal trust. Construction would involve earthwork, placement of concrete 

foundations, steel and wood structural framing, masonry, electrical and mechanical work, 

building finishing, and paving, among other construction trades. Construction of the project is 

anticipated to begin in 20120 and end in 20153. A worksite safety plan would be prepared for 

construction. 

2.1.9 PROTECTIVE MEASURES AND BEST MANAGEMENT PRACTICES

Protective measures and BMPs have been incorporated into the project design to eliminate or 

substantially reduce environmental impacts from the project. These measures and BMPs are 

discussed below. 

Land Resources 

 All structures would meet design standards equivalent to the California Building Code 

(CBC) requirements for the site, including the seismic design criteria of the most recent 

edition of the Uniform Building Code (UBC) for Seismic Zone 4. 

 Protective coatings for buried steel facilities would be used for construction on corrosive 

soil. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-7 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

Water Resources 

 Areas outside of buildings and roads would be kept as permeable surfaces to the extent 

practicable; either as vegetation or high infiltration cover, such as mulch, gravel, or turf 

block. Pedestrian pathways would use a permeable surface where possible, such as 

crushed aggregate or stone with sufficient permeable joints (areas between stone or brick 

if used). 

 Existing native vegetation would be retained where possible. 

 Roof down spouts would be directed to splash blocks and not to underground stormdrain 

systems. 

 Runoff from rooftops, and other impervious areas would be directed to vegetated areas to 

help treat and infiltrate stormwater prior to leaving the site. 

 Runoff from roadways would filter though rock-lined swales and bio-swales. 

 All storm drains would be equipped with silt and grease traps to remove oils, debris, and 

other pollutants. Storm drain inlets would also be labeled “No Dumping – Drains to 

Streams and Rivers.” 

 Permanent energy dissipaters would be included for drainage outlets. 

 Rock rip-rap energy dissipaters would be installed at the point of release of concentrated 

flow. 

 High water-demand plants would be minimized in landscaping plans. Native and 

drought-tolerant plant species (trees, shrubs, and ground cover) landscaping would be 

emphasized. 

 Water-efficient fixtures and appliances would be installed in residences and community 

facilities. 

 Water conservation standards at least equivalent to Sonoma County design standards

would be implemented in the residential and community buildings. 

 Implementation of check dams, rain gardens, and bio-swales would be used to reduce 

stormwater velocities as recommended in the preliminary drainage plan in Appendix A. 

Air Quality 

The following measures would reduce project related greenhouse gas emissions related to climate 

change: 

 Buildings would be sited to take advantage of aspect, shade, prevailing winds, and sun 

screens to reduce energy use. 

 Buildings would be designed to include efficient lighting and lighting control systems. 

 Energy efficient heating and cooling systems as well as appliances would be installed in 

residences and community facilities. 

 Solar or wind power systems would be utilized where feasible. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-8 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

Biological Resources 

 All identified heritage trees would be preserved to the maximum extent feasible. 

 Native trees with greater than nine inches diameter at breast height (DBH) within the 

Sonoma County valley oak habitat (VOH) Combining District would be preserved to the 

maximum extent feasible. 

 Native trees with greater than nine inches DBH within mixed riparian habitats would be 

preserved to the maximum extent feasible. 

 Avoidance of mixed riparian habitat, as well as wetlands and drainages to the maximum 

extent feasible.

Public Services 

 Structural fire protection would be provided through compliance with Uniform Fire Code 

requirements for commercial structures of this size. The Tribe would ensure that 

appropriate water supply and pressure is available for emergency fire flows. 

 The community center would be equipped with an early detection system that ensures an 

initial response to any fire alarm (automatic, local, or report). This would rely on 

automatic sprinkler systems in the occupied areas and smoke detection, along with 

automatic sprinkler systems, in the areas of the facility that are normally unoccupied, 

such as storerooms and mechanical areas. 

 All structures would be constructed in accordance with design standards equivalent to all 

Uniform Building Codes, as adopted or supplemented by Sonoma County. 

Noise 

 Houses would be designed to locate outdoor spaces away from the sound path of travel in 

order to minimize noise levels for existing offsite houses in the vicinity of the project site. 

Visual Resources 

 Signage for all streets and community facilities would be subtly incorporated into the 

landscape. 

 Lighting would only occur at street intersections and parking areas for the community 

facilities. The lighting would consist of pole mounted lights limited to 18 feet and would 

be required to have cut-off lenses. 

Green Building

The Tribe proposes to incorporate the “Build it Green” 2005 Green Building Guidelines for New 

Home Construction along with the Leadership in Energy and Environmental Design (LEED) for 

Homes criteria for all the residential units on the project site (U.S. Green Building Council, 

2010). In addition, LEED certification is proposed for the community center and retreat 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-9 Lytton Property Residential Development

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buildings. The above-noted BMPs and protective measures would aid the Tribe in achieving 

these standards. In addition, the following measures would be implemented:

 Roadways will be generally designed as narrow country lanes with surface runoff 

diverted into vegetated bioswales.

 Individual homes would have limited personal planting areas with a portion of the 

watering needs satisfied from captured rainwater or reclaimed water.

 Indoor plumbing would use the highest efficiency fixtures and fittings available.

 All homes would be designed for efficient use of energy and natural resources and would 

be sized below the median standard based on the LEED for Homes rating system. Each 

plan would be oriented to maximize access to solar energy and natural daylight. 

Operable windows would be placed to provide efficient natural ventilation, taking 

advantage of prevailing breezes.

 All appliances and heating, ventilation, and air conditioning (HVAC) equipment would 

be Energy Star Certified for optimal performance.

 During construction, all waste material would be separated and sorted into individual bins 

for recycling.

 Upon completion, the community center would have trash enclosures for separation of 

recyclable materials and newspapers.

 The communal buildings would meet all Americans with Disabilities Act (ADA) 

accessibility requirements. Pathways would meet required slopes and roadway crossings

would include textured paving and indicators for the visually impaired.

 At least 75 percent of the residences built would be single story to minimize visual 

effects.

 The single story retreat building would be located on the site of an existing two-story 

home.

 Building envelopes would be designed to maximize performance of HVAC, lighting, and 

other energy systems. Equipment and appliances would meet or exceed California state, 

Title 24 energy requirements.

 HVAC equipment would have no chlorofluorocarbon (CFC) refrigerants.

 To the extent possible, building materials with recycled content would be specified for 

use during construction. 

 Building and landscape elements would be designed to give preference to materials that 

are produced regionally or with in 500 miles of the project.

 Wood materials and products used in construction would be specified to be Forest 

Stewardship Council (FSC) certified from suppliers who practice responsible and 

sustainable forest management.

 During construction, on-site absorptive materials would be protected from moisture 

damage.
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 All paints, coatings, adhesives and sealants used on the interiors of buildings would have 

a low Volatile Organic Compound (VOC) limits to reduce odor and harmful indoor air 

contaminants.

 Carpets, cabinets, and other interior finishes would be selected, in part, on minimizing 

their potential to off-gas or adversely affect indoor air quality.

2.2 ALTERNATIVE B - ONSITE WATER AND WASTEWATER 

As with Alternative A, Alternative B would include placing the 92124.14-acre site into federal 

trust status for the benefit of the Tribe; however under Alternative B, an onsite water and,

wastewater and reclamation facilities facility would be built. The Tribe would develop the site to 

provide 147 residential units including 95 single-family houses, 24 cottage style houses, and 28 

high-density housing units, identical to Alternative A (Table 2-1). Alternative B would include 

the same associated community facilities as Alternative A. These facilities include a Tribal 

community center, roundhouse, and retreat facility (Figure 2-2). A detailed breakdown of each 

facility, including the components and approximate sizes of each facility, are displayed in Table 

2-2. As with Alternative A, the same rural roadways would be constructed to provide access to 

the residences and community facilities. Signage would also be provided for streets and 

community facilities. With the construction of an onsite water, wastewater and reclamation 

facility, Alternative B includes two options. Under the first option, Alternative B would involve 

on-site tertiary treatment and seasonal reclamation with surface water discharge to one of two 

locations (described in Section 2.2.3) when permitted (October 1-May 14), or when waste 

discharge flows is greater than one percent of the receiving stream’s flow. Under the second 

option for Alternative B, complete on-site tertiary treatment and reclamation would occur. 

2.2.1 PUBLIC SERVICES 

Public service providers under Alternative B would be the same as those presented for Alternative 

A, with the exception of water and wastewater services, which would be provided onsite. 

2.2.2 WATER SUPPLY 

Alternative B would include an onsite water supply obtained from the development of 

groundwater production wells. The primary production well would be located southeast of the 

planned retreat facility, as shown in Figure 2-2. A secondary well would be located near the 

water storage tank located northwest of the roundhouse (Figure 2-2). A small groundwater 

treatment plant with a capacity greater than the maximum day system demand would be located 

near the water storage tank, which would have a 400,000-gallon capacity for emergency fire 

flows. The treatment plant would ensure concentrations of arsenic and manganese are treated to 

levels at least meeting Federal Safe Drinking Water Act standards. 
!R

Proposed Retreat Facility

Proposed Backup Well

Primary Water Storage Tank

Proposed Roundhouse

Proposed Ceremonial 

Dance Circle

Proposed 

Community Center

Primary Well Location

Proposed Optional Wastewater

Treatment Facilities Location 1

Proposed Wastewater

Treatment Facilities Location 2

Proposed Effluent Storage Basin

Proposed Park

WINDSOR RIVER ROAD

WELL NI GTON

CIRCLE

KENS NI GTON LANE

EASTSIDE ROAD

RIVER OAKS LN

LEGEND

Figure 2-2

Site Plan - Alternative B

Property Boundaries

!R Primary Well Location

Proposed Trail

Cottage Housing, 24 units

High Density Housing, 28 units

Low Density Housing, 95 units

Proposed Backup Well - Primary Water Storage Tank

Proposed Retreat Facility

Proposed Ceremonial Dance Circle

Proposed Community Center

Proposed Effluent Storage Basin

Proposed Optional Wastewater Treatment Facilities

Proposed Park

Proposed Parking

Proposed Roadway

Proposed Roundhouse

SOURCE: Adobe Associates, 2010; Aerial Express aerial photograph, 11/2008; AES, 2011 Lytton Residential Development Final EA / 207513

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2.2.3 WASTEWATER TREATMENT AND DISPOSAL

Under the first option of Alternative B, includes an onsite wastewater treatment and reclamation 

facility and approximately 30 11.75 acres of landscaped or other areas for recycled water 

irrigation (spray fields) would be used during summer months (May 15-September 30) or when 

surface water discharge is not feasible. Treated water would otherwise be disposed of via 

discharge to one of two drainage locations, as shown in Figure 2-2. Under the second option of 

Alternative B, the wastewater treatment and reclamation facility would be used for year-round 

reclamation and approximately 42.1 acres of landscaped or other area for year-round recycled 

water irrigation would be required. 

As shown in Figure 2-2, the treatment plant for Alternative B would be located either in the 

northwest corner of the site (option location #1) or in the southeast corner of the site (option 

location #2). Under the first option for Alternative B, Ttreated effluent would be used for 

irrigation during the summer and discharged during the winter pursuant to an National Pollutant 

Discharge Elimination System (NPDES) permit that would be issued by the USEPA. For 

wastewater treatment facility option location #1, treated effluent would be discharged into an 

onsite drainage that flows into the roadside drainage ditch along Windsor River Road, which then 

flows to a former gravel pit adjacent to the Russian River (Figure 5 of Appendix EAppendix L). 

For wastewater treatment facility option location #2, treated effluent would be discharged into an 

unnamed tributary located along the eastern boundary of the project site, which flows into 

Windsor Creek south of the project site. Windsor Creek connects to Mark West Creek, which 

eventually connects to the Russian River. 

Wastewater Treatment and Reclamation Facility (WTRF)

The proposed wastewater treatment and reclamation facility (WTRF) for Alternatives B and C

would treat wastewater to or exceeding tertiary standards under Chapter 3, Division 4, Title 22, 

California Code of Regulations (CCR), Section 60304, et seq. (Title 22). Treated effluent would 

be utilized for irrigation of landscaping and crops (reclamation) during dry periods and stored 

during wet periods when irrigation is not needed. Between one and 2.5 acres of land would be 

required for construction of the WTRF in one of the two locations under Alternative B (Figure 2-

2) and in the southeastern location for Alternative C (Figure 2-3). Planned WTRF features 

include the following:

 Headworks components to remove particulate matter larger than two millimeters from 

incoming wastewater;

 Influent flow equalization and emergency storage facilities,

 Biological treatment and filtration facilities by membrane bioreactor (MBR) or other 

similar treatment methods,

 Ultra-violet (UV) disinfection system, and
2.0 Proposed Project and Alternatives 

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 Supporting systems such as chemical storage systems, plant water systems, stormwater 

detention, biosolids handling system and emergency power generator.

Effluent Storage Facilities

Effluent storage amount is dependent on monthly irrigation needs under typical and worst-case 

design conditions. The 100-year rainfall scenario is modeled for worst-case design. The 100-

year rainfall design conditions for effluent storage are 1.01 million gallons (Mgal) (under the first 

option for Alternative B) and 23.49 Mgal (under the second option for Alternative B)

(ECO:Logic, 2010a: Appendix B). The first option of Alternative B will utilize winter surface 

water disposal of treated wastewater, with summer storage in a closed tank or in an effluent 

storage basin in the northern parcels, north of Windsor River Road (Figure 2-2). The second 

option for Alternative B would utilize one or more open-topped, earthen basins designed to hold 

effluent and 100-year event precipitation. All reservoirs would be lined with 60 millimeter high 

density polyethylene (HDPE) liner to prevent effluent percolation. 

2.2.4 ROADWAYS

As with Alternative A, rural roadways would be constructed to provide access to onsite 

residences and facilities (Figure 2-2). If wastewater treatment facilityWTRF option location #1 

is chosen, access to the facility would be provided from a nearby existing driveway off Windsor 

River Road. 

2.2.5 PROJECT CONSTRUCTION

Project construction measures would be similar to those described for Alternative A. 

2.2.6 PROTECTIVE MEASURES AND BEST MANAGEMENT PRACTICES

Protective measures and BMPs would be similar to those described for Alternative A. However, 

the following additional measures to accommodate for the WTRF reclamation and surface water 

discharge would be implemented: 

 Sodium hypochlorite, caustic soda and/or citric acid would be stored in the chemical 

room of the wastewater treatment facilityWTRF. The storage and metering facilities 

would be located inside a chemical spill containment area, sized to contain 150 percent 

of the storage volume in case of an unintentional release. 

 The sodium hypochlorite would be stored in a 55-gallon drum and the citric acid would 

be stored as dry material and then in a 50-gallon mixing tank when needed. 

 The wastewater treatment facilityWTRF would incorporate an active odor control 

system, consisting of a packaged biofilter with an active carbon absorption unit. 

 All treated effluent storage dimensions have been calculated to hold 100-year rainfall 

event precipitation amounts, which is approximately 1.5 times greater than that 

estimated to be required for normal rainfall years. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-14 Lytton Property Residential Development

May 2011 Final Environmental Assessment 

 Spray drift from the spray disposal irrigation areas would be monitored daily during 

operation by qualified personnel. Spray drift shall not be allowed to migrate outside of 

the irrigation area.

 Spray irrigation would cease when winds exceed 30 miles per hour.

 Disposal of treated wastewater to irrigation areas shall be adjusted based on weather 

conditions in order to prevent surface runoff.

 The Tribe would adopt standards equivalent to the landscape irrigation standards in the 

State Water Resources Control Board Recycled Water Policy (as referenced in 

Resolution No. 2009-0011).

 Potential groundwater impacts from irrigation and effluent storage will be minimized 

through treatment of effluent through nitrogen and salinity reduction processes. 

 Operation and maintenance of the wastewater utility from house service laterals,

through the wastewater and effluent system, to treatment and disposal will be by the 

Tribe utilizing contract services. Individual residents will have no responsibility

regarding operation and maintenance of any aspect of the wastewater treatment and 

conveyance systems. The residents’ sole responsibility would be to follow Tribal 

guidance on what should and should not be flushed down sinks and toilets. Community 

education shall be promoted to reduce needless contaminants to wastewater.

 The effluent storage basins and irrigation areas would be located and designed so that 

they are well-drained and readily accessible.

 Implementation of the following measures would be incorporated during design and 

operation of the wastewater and effluent system to minimize chances of system failures:

o Solvent welded plastic house services;

o Above grade cleanouts;

o Dual (redundant) discharge pumps;

o High water alarms;

o Adherence to recommended septic tank pump-out frequency;

o Maintaining records of pumping, inspections, and other maintenance activities;

o Flushing of solvent, paint, paper towels, diapers, feminine hygiene products, 

cigarette butts, pesticides, and fertilizer would be discouraged by recurring 

outreach notices to the residents. The frequency of the noticing would be based 

on the results of ongoing system inspections.

2.3 ALTERNATIVE C - REDUCED INTENSITY WITH ONSITE 

WATER AND WASTEWATER 

Alternative C would include placing the 92124.14-acre site into federal trust status for the benefit 

of the Tribe, as discussed under Alternative A. The Tribe would develop the site to provide 55 

residential units including 35 single-family homes, 12 cottage-style houses, and eight highdensity housing units (Figure 2-3). As with the other development alternatives, onsite features 
!R

Proposed Retreat Facility

Primary Well Location

Proposed Backup Well

Primary Water Storage Tank

Proposed Roundhouse

Proposed Ceremonial 

Dance Circle

Proposed 

Community Center

Proposed Playfields

Proposed Winter

Storage Basin

Proposed Park

Proposed Wastewater

Treatment Facilities Location

WINDSOR RIVER ROAD

WELL NI GTON

CIRCLE

KENS NI GTON LANE

EASTSIDE ROAD

LEGEND

Figure 2-3

Site Plan - Alternative C

Property Boundaries

!R Primary Well Location

Proposed Trail

Cottage Housing, 12 units

High Density Housing, 8 units

Low Density Housing, 35 units

Proposed Backup Well

Water Storage Tank

Proposed Retreat Facility

Proposed Ceremonial

Dance Circle

Proposed Community Center 

Proposed Detention Basin

Proposed Optional Wastewater Treatment Facilities 

Proposed Park 

Proposed Parking 

Proposed Playfields

Proposed Roadway 

Proposed Roundhouse 

Proposed Winter

Storage Basin 

SOURCE: Adobe Associates, 2010; Aerial Express aerial photograph, 11/2008; AES, 2011 Lytton Residential Development Final EA / 207513

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would include a community center, roundhouse, and retreat facilities. A breakdown of each 

community facility with the components and approximate sizes of each structure is included in 

Table 2-1. Alternative C would include the majority of the same rural roadways to provide 

access to the residences and community facilities. The water supply system would include 

similar facilities as described for Alternative B. Wastewater generated on the site would be 

treated at an onsite water reclamation facility (WRF) the WTRF described in Section 2.2, which 

would be located in the central southern southeastern portion of the project site (Figure 2-3). All 

treated effluent would be disposed of onsite using a combination of landscape irrigation and 

storage basins. No treated effluent would be discharged into surface water. 

2.3.1 PUBLIC SERVICES 

Public service providers under Alternative C would be similar to those presented for Alternative 

A. 

 

2.3.2 WATER SUPPLY 

Alternative C would include a similar but proportionately smaller water supply system as 

Alternative B. The water supply system would be located in the same location as for Alternative

B.

2.3.3 WASTEWATER FACILITIES 

As with Alternative B, wastewater would be treated at an onsite wastewater treatment facilitythe 

WTRF; however, under Alternative C, only 11.717.6 acres of irrigation land is required, and a 

large treated effluent storage basin would be constructed (Figure 2-3). As with the second option 

for Alternative B, all treated effluent would be disposed of onsite using a combination of 

landscape irrigation and storage basins. No surface water discharge would occur under this 

alternative. The treatment plant would be located in the central southeast portion of the project 

site and the storage basin would be located in the southeast corner of the project site. During the 

winter months, treated effluent would be stored in the storage basin; while in the summer months, 

treated effluent would be used for landscape irrigation throughout the property. 

2.3.4 ROADWAYS

As with Alternative A, rural roadways would be constructed to provide access to onsite 

residences and facilities. Three main project access driveways from Windsor River Road are 

proposed, as shown in Figure 2-3. 

2.3.5 PROJECT CONSTRUCTION

Project construction would be similar to what is described for the Alternative A. 
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2.3.6 PROTECTIVE MEASURES AND BEST MANAGEMENT PRACTICES

Protective measures and BMPs would be similar to those described for Alternatives A and B. 

However, the following additional measures for the effluent storage basin would be implemented: 

 

 The storage basin would be lined using 60 millimeter high density polyethylene HDPE 

liner, equipped with draining systems and level monitors. 

 The storage basin would be fenced and gated for vehicular access. 

 A minimum of two feet would be maintained between the high groundwater level and 

the basin bottom. 

2.4 ALTERNATIVE D - NO-ACTION ALTERNATIVE 

Under the No-Action Alternative, the 92124.12-acre site would not be placed into trust for the 

benefit of the Tribe and would not be developed as identified under the Proposed Project. 

Jurisdiction of the property would remain within Sonoma County. Ultimately, the 92124.12-acre 

site could be developed by the Tribe with the property owned in fee, or by a private party, 

consistent with local zoning. However, for the purposes of the environmental analysis in this EA, 

it is assumed that the property would remain as rural residences and oak woodland habitat and 

would not be further developed. 

2.5 COMPARISON OF THE PROPOSED PROJECT AND 

ALTERNATIVES 

Among the project alternatives evaluated in Section 4.0, the Proposed Project and Alternative B 

both include 147 housing units and the same associated community facilities. However, 

Alternative B would include onsite water and wastewater facilities, whereas the Proposed Project 

(Alternative A) would connect to municipal water and sewer services. Alternative C would result 

in construction of only 55 housing units, with the same community facilities as the other two 

project alternatives, as well as proportionally smaller on-site water and wastewater facilities 

(WTRF). Under Alternative D, the No-Action Alternative, no development would occur on the 

property for the foreseeable future. 

Impacts to land resources would be proportionally greatest under Alternative B, due to the larger 

project footprint needed for construction of the water and wastewater facilities. This would 

require additional site grading compared to the Proposed Project. Alternative C would require 

slightly less grading than the Proposed Project, and substantially less than Alternative B. The 

No-Action Alternative would have no effect on land resources. 

Water resources would likewise be impacted the most by Alternative B. This alternative would 

result in a greater area of impermeable surfaces than either the Proposed Project or Alternative C. 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-18 Lytton Property Residential Development

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Alternative B would have water demands identical to the Proposed Project; however, this 

alternative would obtain water from the local aquifer. Alternative C would also use groundwater, 

but the quantities would be substantially less due to the reduced number of housing units. The 

Proposed Project would use no groundwater. 

Under the first option for Alternative B, treated effluent would be used for irrigation during the 

summer and discharged to surface water during the winter, which would require a NPDES permit 

from USEPA. Under the second option for Alternative B, on-site treated wastewater storage and 

irrigation would occur year-round. Alternatives B and C require varying amounts of land to 

dispose of the effluent generated by these alternatives under varying climatic conditions. Because 

of the substantially reduced quantity of effluent that would result under Alternative C, all effluent 

would be utilized for on-site irrigation during summer and stored in a basin during the winter; 

therefore, a NPDES discharge permit would not be required. Potential impacts to groundwater 

and surface water quality associated with on-site effluent disposal would be proportionally greater 

for the second option for Alternative B than Alternative C, and much less for the first option of 

Alternative B (seasonal storage only). The Proposed Project, the second option under Alternative 

B and Alternative C would need no NPDES discharge permit, and would result in no impacts to 

surface water or groundwater quality due to on-site effluent discharge. No impacts to water 

resources would result from Alternative D. 

Construction and operational emissions of criteria air pollutants and greenhouse gases would be 

similar under both the Proposed Project and Alternative B; however, these emissions would be 

proportionally lower under Alternative C due to the reduced amount of construction and the 

reduction in residential vehicle trips generated. Operation of the WTRF under Alternatives B or 

C could result in objectionable odors; the Proposed Project would have no such potential effect. 

Under Alternative D, no impacts to air quality would occur. 

Due to the larger development footprint of Alternative B, as well as the operation of the WTtRF, 

potential impacts to biological resources would be greatest under this alternative. Impacts to 

sensitive habitats, potential jurisdictional waters of the U.S., native trees, and special-status 

species would all be slightly lessened under the Proposed Project, and would be proportionately 

less still under the substantially reduced development area of Alternative C. No impacts to 

biological resources would occur under Alternative D. 

Potential impacts to cultural resources resulting from inadvertent discovery of previously 

unknown subsurface archaeological or paleontological sites would increase proportionally to the 

amount of ground disturbance; therefore, Alternative B would have the greatest potential for 

adverse effects to cultural resources. The Proposed Project would involve less ground-disturbing 

construction work, thereby reducing the potential for these impacts. Alternative C has the 

smallest construction footprint, and would consequently have the least potential to affect cultural 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-19 Lytton Property Residential Development

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resources of the three project alternatives. The No-Action Alternative would not result in impacts 

to cultural resources. 

No significant impacts to socioeconomic conditions and environmental justice outside of the 

Tribe would result from the Proposed Project or Alternatives B, C, or D. The Tribe would benefit 

from creation of housing and associated facilities proposed under Alternatives A, B and C; 

however to the greatest extent under Alternatives A and B. 

Alternatives A and B would generate the same number of vehicle trips, due to the identical 

number of housing units. Impacts to the local transportation network from these two alternatives 

would therefore be similar. Alternative C includes fewer housing units and would therefore 

generate fewer vehicle trips. Impacts to the transportation system would be proportionally 

lessened under this alternative. Alternative D would generate no vehicle trips, and would 

therefore cause no impacts to transportation and circulation. 

Buildout of Alternatives A, B, and C would result in the construction of residences, a community 

center, a roundhouse, and a retreat. Alternatives B and C also include the addition of two 

groundwater wells and a wastewater treatment facilityWTRF. All three alternatives are 

compatible with the surrounding land uses, and similar residential densities currently occur in the 

project vicinity. Alternative C would have the least effect on land use as it would result in the 

lowest residential density. Alternative D would have no impact on local land use. 

Alternatives A and B would have equal impacts on solid waste, electricity, natural gas, 

telecommunications, law enforcement, fire protection and emergency medical services, public 

schools, and parks and recreation. Alternative C would have proportionally less impact on these 

services because of the reduced number of residents requiring these utilities and services. 

Alternative D would have no impact on public services and utilities. 

Alternative A would have the greatest impact on municipal water supply and wastewater 

treatment facilities, as it is the only alternative that would connect to these facilities. This 

alternative would result in an increase of potable water demand and municipal wastewater 

treatment. Alternatives B, C, and D would not result in an increase in demand for municipal 

water supply or wastewater treatment. 

Impacts related to construction noise would be greatest under Alternative B, due to the larger 

development footprint. Alternative A would have a slightly lessened noise impact, as 

construction would take place in a somewhat smaller area and for a shorter duration of time. 

Operational noise would be similar under these two alternatives. Under Alternative C, 

construction activity would be reduced in duration and/or intensity when compared with 
2.0 Proposed Project and Alternatives 

Analytical Environmental Services 2-20 Lytton Property Residential Development

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Alternative A and B, and operational noise would be lessened due to the smaller number of 

residents. No noise-related impacts would occur under Alternative D. 

Impacts related to hazardous materials would be greatest under Alternatives B and C, due to the 

storage of hazardous materials (sodium hypochlorite, caustic soda and/ or citric acid) for the 

onsite wastewater facilities, whereas the Proposed Project would connect to the municipal water 

and sewer services and would not require the use of these chemicals. No hazardous material 

impacts would occur under Alternative D. 

Visual resource impacts would be greatest under Alternative B, due to the on-site water and 

wastewater facilities and maximum number of housing units, which would be partially visible to 

local sensitive receptors and drivers on Eastside and Windsor River Roads. The Proposed Project 

would include an equal number of houses, but would not include the on-site water and wastewater 

facilities. Alternative C would include the on-site water and wastewater facilitiesWTRF; 

however, it would include fewer than half of the housing units. No visual impacts would occur 

under Alternative D. 

While both Alternatives A and B meet the Tribe’s objectives of providing a cohesive residential 

community large enough to accommodate its members, Alternative A would result in fewer 

potential environmental impacts associated with the proposed development activities. Alternative 

C would result in proportionally fewer environmental impacts than the Proposed Project and 

Alternative B, but would not meet the project objectives since it would include fewer than half of 

the housing units, when compared to the two other development alternatives. While the NoAction alternative would not result in any of the environmental effects identified for the Proposed 

Project or Alternatives B and C, this alternative would not meet the Tribe’s objectives of 

providing a sufficient number of housing units for Tribal members, or community facilities for 

Tribal functions. 
SECTION 3.0 

AFFECTED ENVIRONMENT
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SECTION 3.0 

DESCRIPTION OF AFFECTED ENVIRONMENT 

This section presents relevant information about existing resources and other values that may be 

affected by the Proposed Project and alternatives. In accordance with the National Environmental 

Policy Act (NEPA) and the Bureau of Indian Affairs’ (BIA) implementing guidelines (59 IAM 3-

H), the existing conditions described herein provide the base line for determining the 

environmental effects identified in Section 4.0. Descriptions include the following resource and 

issue areas: 

 Land Resources 

 Water Resources 

 Air Quality 

 Biological Resources 

 Cultural Resources 

 Socioeconomic Conditions / Environmental Justice 

 Transportation and Circulation 

 Land Use 

 Public Services 

 Noise 

 Hazardous Materials 

 Visual Resources 

 

3.1 LAND RESOURCES 

3.1.1 GEOLOGICAL SETTING

The project site is located within the California Coast Range geologic region. Extensive folding 

and thrust faulting during the late Cretaceous through early Tertiary geologic time created the 

geologically complex region consisting of northwest-trending faults and mountain ranges that 

characterize the California Coast Range. The property is underlain by quaternary age Pleistocene 

alluvial fan deposits comprised of materials that include claystone, siltstone, lithic sandstone, and 

pebbly mudstone and sandstone (RGH Consultants, 2008). 

3.1.2 TOPOGRAPHY

The topography of the project site consists of rolling hills covered with grasses and is 

characterized by mixed oak woodland habitat. Slopes within the project site range between five 

and thirty percent. The eastern half of the property has a moderately sloped terrain, while the 
3.0 Affected Environment

Analytical Environmental Services 3-2 Lytton Property Residential Development

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western half consists of steep hills which flatten out in the northwest corner of the site. 

Elevations on the project site range between approximately 100 and 200 feet above mean sea 

level (amsl). A topographic map of the project site is provided in Figure 1-2. 

3.1.3 SEISMIC CONDITIONS

Three fault zones classified by the California Division of Mines and Geology transect the general 

region of the Town of Windsor. These include the Healdsburg-Rodgers Creek Fault, the San 

Andreas Fault, and the Maacama Fault. The closest of the three faults to the project site is the 

Healdsburg-Rodgers Creek Fault, which runs in a general north-south direction, approximately 

two and a half miles east of the project site (U.S. Geological Survey [USGS], 2007). Figure 3-1 

shows regionally active faults and their relative distances to the project site. 

As shown in Figure 3-2, a portion of the project site is within the area associated with the 

Healdsburg-Rodgers Creek Fault Modified Mercalli Intensity (MMI) rating of VIII. This MMI 

rating indicates the potential for slight damage to specially designed structures; considerable 

damage to ordinary substantial buildings; immense damage to poorly built structures; the collapse 

of chimneys, factory stacks, columns, monuments, and walls; and the overturning of heavy 

furniture (USGS, 1989). 

3.1.4 SOIL TYPES AND CHARACTERISTICS

The 124.1292-acre project site contains six seven well drained soils that are derived from either a 

form of alluvium or residuum (Natural Resources Conservation Service [NRCS], 2008a, 2010). 

Table 3-1 summarizes the characteristics for each soil type, while Figure 3-3 shows the location 

of each soil type on the project site. 

TABLE 3-1 (REVISED)

PROJECT SITE SOILS 

Map Unit 

Symbol Map Unit Name Slope Range 

Hydraulic 

Conductivity Class Erosion Hazard 

Percent of 

Project 

Site 

AeA Alluval Land, Clayey 0-2% Very High Slight 1.7% 

AgE Arbuckle gravelly 

sandy loam 15-30% Moderately High Moderate 10.0% 

CgC Clough gravelly loam 2-9% Moderately High Slight 0.4% 

FaD Felta very gravelly 

loam 5-15% Moderately High Slight 29.1% 

FaF Felta very gravelly 

loam 30-50% Moderately High Severe 3.5% 

HtC Huichica loam 2-9% Moderately High Slight 31.5% 

SkD Spreckels loam 9-15% Moderately High Moderate 23.8% 

Source: NCRS, 2008a, 2010 
"

"

"

" "

"

"

"

"

"

Maacama fault zone, southern section

Ge

" 

yser Peak fault zone

Geyser Peak fault zone

Rodgers Creek fault

Rodgers Creek fault

Collayomi fault zone

ing fault zone

Hunting Creek-Berryessa fault system, Wilsonsection

Hunting Creek-Berryessa 

San Andreas fault zone, North Coast section

San Andreas fault zone, North Coast section

Wight Way fault

Healdsburg fault

Maacama fault zone, southern section

Bennett Valley fault zone

Healdsburg fault

Project Site

UV116

UV12

UV29

UV128

UV29 UV1

UV1

Maacamafault zone, southern section

Bloomfield fault

Americano Creek fault

Joy Woods fault

Alexander-RedwoodHill fault zone

Maacama fault zone, southern section

Chianti fault

Chianti fault

Big Valley fault

17.52 Miles

3.21 Miles

1.73 Miles

2.65 Miles

1.99 Miles

Sonoma

County

Lake

County

Napa

County

Mendocino

County

Marin

County

Cobb

Sonoma

Angwin

Cotati

Graton

Lytton

Jenner

Temelec

Windsor

Hobergs

Petaluma

Eldridge

Roseland

El Verano

Deer Park

Calistoga

Monte Rio

Clearlake

Glen Ellen

Sebastopol

Santa Rosa

Occidental

Healdsburg

Middletown

Lower Lake

Cloverdale

Bodega Bay

Pope Valley

Forestville

Guerneville

Geyserville

Saint Helena

Rohnert Park

Dillon Beach

Agua Caliente

South Santa Rosa

Boyes Hot Springs

Hidden Valley Lake

Clearlake Highlands

£¤101

Figure 3-1

Regional Fault Map

SOURCE: USGS Earthquake Hazards Program, 2007; AES 2011

Historic

<15,000 - latest Quaternary

<100,000 - late Quaternary

<1.600,000 Quaternary

Other Faults

Other Quaternary Faults

LEGEND

0 3 6

Miles

Lytton Residential Development Final EA / 207513
Rodgers Creek fault

Healdsburg fault

Lytton Resi

Ground Shaking Intensities Along the Heald

SOURCE: Town of Windsor, 1995; AES, 2011

LEGEND

0 1,500 3,000

Feet

Property Boundary
AgE

FaD

SkD

SkD

HtC

HtC

AgE

AeA

FaF

FaF

HtC

CgC

AgE

Eastside Rd

Windsor River Rd

Figure 3-3

Soils Map

SOURCE:USDA Natural Resources Conservation Service, 12/13/2006; DigitalGlobe Aerial Photograph, 9/20/2003; AES, 2011

SOIL TYPES

!¢ON

ÐRTH

0 250 500

Feet

Soil Types

Lytton Residential Development Final EA / 207513

Approximate Property Boundary

PROJECT AREA SOILS

AeA - ALLUVIAL LAND, CLAYEY

AgE - ARBUCKLE GRAVELLY SANDY LOAM, 15 TO 30 PERCENT SLOPES

FaD - FELTA VERY GRAVELLY LOAM, 5 TO 15 PERCENT SLOPES

FaF - FELTA VERY GRAVELLY LOAM, 30 TO 50 PERCENT SLOPES

HtC - HUICHICA LOAM, 2 TO 9 PERCENT SLOPES

SkD - SPRECKELS LOAM, 9 TO 15 PERCENT SLOPES

CgC - CLOUGH GRAVELLY LOAM, 2 TO 9 PERCENT SLOPES
3.0 Affected Environment

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May 2011 Final Environmental Assessment

A description of the six seven soil types is included below: 

 Alluvial land, clayey soils (AeA) – These soils are found at elevations between 200 to 

800 feet. AeA has moderate shrink-swell potential. No information on the depth to 

restrictive feature or water table is reported by NRCS; however, the landform is classified 

as floodplains. Although not corrosive to concrete, AeA is highly corrosive to steel 

(NRCS, 2008a) 

 Arbuckle gravelly sandy loam (AgE) – This soil type commonly occurs in elevations 

between 100 and 1,600 feet amsl and is located on both hills and terraces. Parent 

material for AgE is alluvium derived from sedimentary rock. The depth restrictive 

feature and water table for this soil is more than 80 inches. AgE is characterized as 

moderately corrosive to concrete and steel (NRCS, 2008a). 

 Clough gravelly loam (CgC) – This soil type commonly occurs in elevations between 200 

and 1,000 feet amsl and is located on both terraces and slightly sloped areas (generally 

two to nine percent slopes). Parent material for CgC is gravelly alluvium derived from 

sedimentary rock. The depth restrictive feature and water table for the soil is more than 

80 inches. CgC is characterized as highly corrosive to concrete and steel (NRCS, 2010).

 Two types of Felta loams are found within the project site: FaD and FaF - Both Felta 

soils typically occur in elevations between 100 and 1,500 feet amsl and are commonly 

found on terraces. The parent material for Felta soils is alluvium derived from igneous, 

metamorphic, and sedimentary rock. The depth to restrictive feature and water table of 

this type of soil is more than 80 inches. Both FaD and FaF are characterized as 

moderately corrosive to concrete and steel (NRCS, 2008a). 

 Huichica loam (HtC) - occurs in elevations between 100 and 300 feet amsl and is found 

on terraces. The parent material of HtC is alluvium, which was derived from igneous, 

metamorphic, and sedimentary rock. This soil type has a restrictive feature at a depth of 

20-40 inches. The depth to the water table is greater than 80 inches. HtC is characterized 

as highly corrosive to both concrete and steel (NRCS, 2008a). 

 Spreckels loam (SkD) – This soil typically occurs at elevations between 100 and 800 feet 

amsl and is commonly located on hillsides. The parent material for SkD soils is residuum 

weathered from metavolcanics. As with the other soils, the depth to the water table is 

also greater than 80 inches. SkD is characterized as moderately corrosive to concrete and 

steel with moderate shrink-swell potential (NRCS, 2008a). 
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SOIL HAZARDS

Soil Erosion 

Soil erosion is the wearing and removal of soil materials from the ground surface and the 

transportation of these soil materials resulting in deposition elsewhere. Mechanisms of soil 

erosion include storm water runoff and wind, as well as human activities, such as changes in 

drainage patterns and removal of vegetation. Factors that influence erosion include physical 

properties of the soil, topography (slope), and annual rainfall and peak intensity. The United 

States Department of Agriculture (USDA) rates the erosion potential of a map unit by taking all 

of the above into consideration. The ratings range from “slight” to “very severe.” The erosion 

ratings of the six seven soils within the project site are provided in Table 3-1. All of the soils on 

the project site are considered to have “moderately high” to “very high” hydraulic conductivity 

(Table 3-1). The hydraulic conductivity class describes the rate at which water flows though the 

soil; a high hydraulic conductivity refers to soils that can absorb a lot of water quickly, fast 

enough that only a moderate percentage of storm water becomes runoff. 

Liquefaction 

Liquefaction involves soils that become highly saturated and lose their cohesive strength and 

subsequently act as a liquid, rather than a solid mass. Soils comprised of sands and inland fill in 

areas with high groundwater tables or rainfall are subject to liquefaction during intense seismic 

shaking events. The project site has a low percentage of sandy soils, making the risk of 

liquefaction minimal. 

 

Landslides 

Areas susceptible to landslides are comprised of weak soils on sloping terrain. Landslides can be 

induced by weather, such as heavy rains or strong seismic shaking events. The majority of the 

project site is located within an area designated as having low incidence of landslides (USGS, 

1982). The western portion of the project site has relatively unstable rock and soil units, with 

slopes greater than 15 percent, containing abundant landslides. Two landslides were observed 

during the geotechnical study (RGH Consultants, 2008). One landslide, located on the northern 

edge of APN 066-300-033 is characterized as a recently active earthflow with an estimated 

thickness of landslide deposits of 5 five to 20 feet. The second landslide, located near the 

existing well on APN 066-300-033, is characterized as a recently active earthflow with an 

estimated landslide deposit thickness of less than 5 five feet. 

3.1.5 MINERAL RESOURCES

The most predominantly mined mineral in Sonoma County is aggregate for the processing of 

rock, sand, and earth products used for landscaping purposes (Sonoma County, 2008). In 

California, local agencies must adopt a mineral management plan that recognizes important 

mineral resources to the State and assist in the management of such resources. Sonoma County 
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May 2011 Final Environmental Assessment

has adopted the Aggregate Resources Management (ARM) Plan, which recognizes aggregate 

resources classified as Mineral Resource Zone 2 (MRZ-2) by State geologists (Draft 187). 

According to the Sonoma County General Plan 2020 (General Plan; Sonoma County, 2008), there 

are no mineral resources located within the project site boundaries. However, such aggregate 

mineral resources inherent to the County are located approximately one mile to the west along the 

edges of the Russian River. 

3.2 WATER RESOURCES 

The following section describes the existing surface water, drainage, flooding, water supply, 

groundwater, water quality, and wastewater treatment and disposal conditions in the area 

surrounding the project site. 

3.2.1 SURFACE WATER, DRAINAGE, AND FLOODING

Watersheds and Hydrology 

The project site is located within the Russian Watershed, Hydrologic Unit Code #18010110 

(USGS, 1978) and is bisected from north to south by the Guerneville and Mark West Hydrologic 

Sub Areas (HSA). The project site is located within the Russian River Basin (Basin), Hydrologic 

Unit Code No. 18010110, and is split between the Guerneville and Mark West sub basins. The 

Russian River Basin follows the Russian River from initiates approximately 16 miles north of 

Ukiah and drains to the Pacific Ocean, draining an area of 1,485 square miles. Altitudes in the 

Basin range from approximately 4,500 feet in the north to sea level in the southwest. Over 95 

percent of the total precipitation in the Russian River Basin occurs during November through 

April. Precipitation in the Basin is highly variable by year and location; precipitation in general 

can range in amount from 15 to 85 inches and in addition coastal precipitation is greater than 

inland precipitation (RRWC, 2006b). 

The Russian River is located approximately one mile west of the project site. The principal 

tributaries to the Russian River include East Fork, Sulphur Creek, Maacama Creek, Dry Creek, 

and Mark West Creek (RRWC, 2006a). A natural hydrologic break runs north to south down the 

center of the projects boundary. While the unnamed stream tributary to Windsor Creek along the 

eastern boundary is located within the Lower Russian River hydrologic area (HA), the unnamed 

stream tributary to the Russian River located in the northwest corner of the project site is part of

the Middle Russian River HA. Eventually, most surface waters onsite drain to the Russian River. 

Drainage on the west of the project site occurs via drainage ditches that are part of the Town of 

Windsor’s roadside stormwater drainage system, which flow to an old gravel quarry that is 

adjacent to the Russian River. Drainage on the east of the project site occurs via an ephemeral 

drainage that outlets into an unnamed tributary to Windsor Creek and flows to Mark West Creek 

before joining the Russian River.
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Over 95 percent of the total precipitation in the Russian River Basin occurs during November 

through April. Precipitation in the Basin is highly variable by year and location; precipitation in 

general can range in amount from 15 to 85 inches and in addition coastal precipitation is greater 

than inland precipitation (RRWC, 2006b).

Drainage 

Slopes on the project site range from 2 two to 50 percent. The Guerneville hydrologic sub area 

(HSA) drains the western portion of the property, while the Mark West HSA drains the eastern 

portion. Runoff from the western portion of the project site runs northeast into an unnamed 

drainage channel that flows west along Windsor River Road. This water (proposed discharge 

location #1 under Alternative B, Figure 2-2) crosses under Eastside Road and continues to flow 

south along the roadside drainage prior to terminating in the large abandoned gravel quarry 

adjacent the Russian River located west of the project site. The average width of the unnamed 

drainage channel is 2.4 meters while the average maximum depth is 15 centimeters. The 

unnamed drainage is only influenced by one ephemeral drainage from the project site and one 

other drainage to the north. The two drainages meet where the onsite drainage enters the roadside 

ditch along Windsor River Road. Bank stability is weak at this point, but improves at the location 

where the flow is culverted under the residential driveway downstream of the Windsor River 

Road crossing. As it reaches the point where it flows west into a large abandoned gravel quarry, 

the drainage becomes choked with emergent wetland species and transitions into a seasonal 

wetland. Once in the quarry, water evaporates or exchanges through underflow influence with 

the Russian River (AES, 2009b2010b; Stream Characterization: Appendix L). The path of the 

unnamed drainage channel is shown on Figure 5 of Appendix E and photographs of the drainage 

are provided in Figure 13 of Appendix EAppendix L. 

 

Surface runoff from the eastern half of the property collects in one significant ephemeral channel 

that flows west to east, initiating flow in the roadside drainage ditch along Windsor River Road. 

The average width of the unnamed tributary drainage is 2.0 meters, while the average maximum 

depth is 18 centimeters. This drainage cuts southeast from Windsor River road and then 

meanders east as it slowly transitions into a seasonal wetland through the annual 

grasslandspasture onsite. This drainage enters a drop inlet which connects to the storm drain 

system from the housing development to the north. This storm drainage system flows directly 

into the unnamed tributary to Windsor Creek (proposed discharge location #2 under Alternative 

B, Figure 2-2). The exit point of this storm drainage system is just west of the stream channel, 

along the eastern property boundary. Two large concrete storm drain culverts empty into the 

unnamed tributary from this location. From this point downstream, the hydrology of the channel 

is significantly altered since the influence from point source storm drainage flows during heavy 

runoff events has evidently altered the character of the channel as noted in the channel 

dimensions at the southern property boundary (AES, 20092010b; Appendix L). The path of the 

unnamed tributary to Windsor Creek is shown on Figure 5 4 of Appendix EL, while 
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May 2011 Final Environmental Assessment

photographs are provided in Figures 12 6 and 14 7 of Appendix EL. 

A number of other ephemeral drainages and seasonal wetlands are located on the project site. 

These are discussed in Section 3.4 as well as the Biological Assessment, included as Appendix 

E. 

Flooding 

Executive Order 11988 pertaining to floodplain management states that each federal agency shall 

“provide leadership and shall take action to reduce the risk of flood loss.” In order for each 

agency to carry out its responsibility, the order requires that each agency determine whether a 

project is located within a floodplain and consider alternatives to a project’s location within a 

floodplain. If the project must reside on a floodplain, the agency must minimize any potential 

impacts. 

The Federal Emergency Management Agency (FEMA) is responsible for predicting the potential 

for flooding in most areas. FEMA routinely performs this function through the update and 

issuance of Flood Insurance Rate Maps (FIRMs), which depict various levels of predicted 

inundation. Map numbers 06097C0561E and 06097C0562E show that the majority of the project 

site is classified as Zone X. Zone X is designated for those lands that are outside the 100-year 

floodplains (FEMA, 2008). As shown in Figure 3-4, a small portion of the project site, located in 

the northwest corner of APN 066-300-028, is within the 500 year floodplain of the Russian River. 

In the vicinity of the project site, the nearest areas in the 100-year flood zone are approximately 

one mile west of the project site (Figure 3-4). 

3.2.2 GROUNDWATER

The project site is located within the Santa Rosa Plain ground water sub basin (sub basin). The 

California Department of Water Resources’ (DWR) Bulletin 118 (2004) describes the sub basin 

as part of the larger Santa Rosa Valley Basin, which occupies the southern part of the Coast 

Ranges of Northern California. The sub basin has a surface area of 80,000 acres and is drained 

principally by Santa Rosa and Mark West Creeks, which flow westward into the Laguna de Santa 

Rosa. The principal aquifer in the vicinity of the project site is the Glen Ellen Formation. The 

Glen Ellen Formation overlies the Merced Formation in most places and the two formations are 

continuous in some locations (DWR, 2004). On average, wells drilled in the Glen Ellen 

Formation yield between one and 140 gallons per minute (gpm) (ECO:Logic, 2009a2010a,; 20-

092010b; Appendix C). 
Eastside Rd

Starr Rd

Windsor River Rd

Richardson Rd

A St A St

Springfield Ct Springfield Ct

Ventnor Ave

Dorthea Ct Dorthea Ct

Indiana Ave

Stellar Ct

Sirius Dr Sirius Dr

Windsor River Rd

Starr Rd Starr Rd Starr Rd

WINDSOR RIVER

RUSSIAN RIVER

Figure 3-4

FEMA Flood Zones

SOURCE: FEMA Q3 Flood Data, 1996; AES 2011

Project Boundary

FEMA FLOOD ZONES

100 Year Flood Zone

Outside of Flood Zone

500 Year Flood Zone

LEGEND

!¢NO

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0 500 1,000

Feet

Lytton Residential Development Final EA / 207513
3.0 Affected Environment

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May 2011 Final Environmental Assessment

Pumping tests were completed in December 2008 for a test well located on APN 066-300-033. 

The results of these tests are included in the Hydrogeologic Investigation Report (ECO:Logic, 

2010b) in Appendix C. The step test was completed at rates up to 272 gpm, while the constant 

discharge test was completed at 150.3 gpm. Analysis of the test data indicates that a production 

well could sustain a continuous pumping rate of 75 gpm without excessive drawdown. Based on 

the test well program the aquifer is approximately 300 feet thick in the vicinity of the project site 

(ECO:Logic, 2009a2010a; , 2009b2010b; Appendix C). 

3.2.4 WATER QUALITY

Surface Water Quality 

Section 303(d) of the Clean Water Act (CWA) requires that each State identify those waters 

within its boundaries that do not meet the water quality standards that have been set for them. 

Impaired water bodies occur where industrial and technological waste limits, or other legal 

mechanisms for pollution control, are not enough to meet water quality standards. When 

identified, a priority schedule for the development of total maximum daily loads (TMDLs) for 

each contaminant or “stressor” impacting the water body. Both the Mark West Creek and 

Guerneville HSAs are listed as impaired by the United States Environmental Protection Agency 

(USEPA). The Mark West Creek HSA is impaired due to sedimentation/siltation and 

temperature; the TMDL is scheduled to be completed in 2019 (USEPA, 2008a). The Guerneville 

HSA is impaired due to pathogens, pH, sedimentation/siltation, and temperature; the TMDL for 

pathogens was scheduled to be completed September 2008 while the others are scheduled to be 

completed by 2019 (USEPA, 2008b). 

The 2008 2007 Water Quality Control Plan for the North Coast Region (Basin Plan) provides 

water quality objectives of inland surface waters for the North Coast Region, including the Basin. 

Table 3-2 lists the general water quality objectives by parameter according to the Basin Plan. 

Specific water quality objectives are listed for certain water bodies, including the Russian River 

(Table 3-3). 

TABLE 3-2 

WATER QUALITY OBJECTIVES OF INLAND SURFACE WATERS 

Parameter Description 

Color Waters shall be free of coloration that causes nuisance or adversely affects beneficial 

uses 

Tastes and 

Odors 

Waters shall not contain taste or odor producing substances in concentrations that 

impart undesirable tastes or odors to fish flesh or other edible products of aquatic 

origin, or that cause nuisance of adversely affect beneficial uses. 

Floating Material Waters shall not contain floating material in concentrations that could cause nuisance 

or adversely affect beneficial uses. 

Suspended and 

Settleable 

Material 

Waters shall not contain suspended or settleable material in concentrations that could 

cause nuisance or adversely affect beneficial uses. 
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Parameter Description 

Oil and Grease 

Waters shall not contain oils, greases, waxes, or other materials in concentrations 

that result in a visible film or coating on the surface of the water or on objects in the 

water, that cause nuisance, or that otherwise adversely affect beneficial uses. 

Biostimulatory 

Substances 

Waters shall not contain biostimulatroy substances in concentrations that promote 

aquatic growths to the extent that such growths cause nuisance or adversely affect 

beneficial uses. 

Turbidity 

Turbidity shall not be increased more than 20 percent above naturally occurring 

background levels. Allowable zones of dilution within which higher percentages can 

be tolerated may be defined for specific discharges upon the issuance of discharge 

permits or waiver thereof. 

pH Some waters have specific pH limits listed within the Basin Plan. For waters not 

listed, the pH shall not be reduced below 6.5 nor raised above 8.5. 

Dissolved 

Oxygen 

Some waters have specific dissolved oxygen concentrations listed within the Basin 

Plan. For waters not listed, dissolved oxygen concentration limitations are based on 

the water’s designation. 

Bacteria 

The Bacteriological quality of waters of the North Coast Region shall not be degraded 

beyond natural background levels. Specific limits have been set for coliform in 

waters designated for contact recreation or where shellfish may be harvested for 

human consumption. 

Temperature 

The natural receiving water temperature of intrastate waters shall not be altered 

unless it can be demonstrated to the satisfaction of the Regional Water Board that 

such alteration in temperature does not adversely affect beneficial uses. 

Toxicity 

All waters shall be maintained free of toxic substances in concentrations that are toxic 

to, or that produce detrimental physiological responses in human, plant, animal, or 

aquatic life. 

Pesticides 

No individual pesticide or combination of pesticides shall be present in concentrations 

that adversely affect beneficial uses. There shall be no bioaccumulation of pesticide 

concentrations found in bottom sediments or aquatic life. 

Radio Activity 

Radionuclides shall not be present in concentrations which are deleterious to human, 

plant, animal or aquatic life nor which result in the accumulation of radionuclides in 

the food web to an extent which presents a hazard to human, plant, animal, or 

indigenous aquatic life. 

Source: NCRWQCB, 2007a 

TABLE 3-3 (REVISED)

WATER QUALITY OBJECTIVES FOR THE RUSSIAN RIVER 

 CND (micromhos) TDS (mg/l) DO (mg/l) pH 

Russian River 

90% 

Upper 

Limit3

50% 

Upper 

Limit4

90% 

Upper 

Limit3

50% 

Upper 

Limit4 Min 

90% 

Lower 

Limit3

50% 

Lower 

Limit4 Max Min 

Upstream1 320 250 170 150 7 7.5 10 8.5 6.5 

Downstream2 375 286 200 170 7 7.5 10 8.5 6.5 

Notes: 

CND= Conductivity 

TDS = Total Dissolved Solids 

DO= Dissolved oxygen 

1=Upstream of Laguna De Santa Rosa 

2=Downstream of Laguna De Santa Rosa 

3=90% upper and lower limits represent the 90 percentile values for a calendar year. 

4=50% upper and lower limits represent the 50 percentile values of the monthly means for a calendar year. 

Source: NCRWQCB, 2007a
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The Russian River watershed is listed under Section 303(d) as sediment and temperature impaired 

waterbody. In addition, two sections of the Russian River are listed as impaired for pathogen 

contamination. The segments are from Fifes Creed in Guerneville to Dutch Bill Creek in Monte 

Rio and upstream from Healdsburg Memorial Beach to Highway 101. TMDLs regarding 

temperature and sediment are scheduled to be completed by 2010. The North Coast Regional 

Water Quality Control Board (NCRWQCB), in cooperation with researchers at the University of 

California, Davis, has begun initial studies of the Russian River in order to establish a TMDL for 

pathogens (NCWQCB, 2007b). TMDLs regarding temperature and sediment are scheduled to be 

completed by 2019 (USEPA, 2008b). The Basin Plan places limitations on wastewater discharge 

into the Russian River and its tributaries. Wastewater discharge is prohibited during the period 

between May 15 and September 30 and all other periods when the wastewater discharge flow is 

greater than one percent of the receiving stream’s flow. Discharge during October 1 through May 

14 must be advanced treated wastewater in accordance with effluent limitations contained in 

National Pollutant Discharge Elimination System (NPDES) permits for each affected discharger, 

and must meet a median coliform level of 2.2 mpn/100 ml2 (NCWQCB, 2007a). USGS gauging 

station #11466800 11464000 near Healdsburg has measuredrecorded the stream flow of the 

Russian RiverMark West Creek since 1939from October 2005 to October 2008. Table 3-4 shows 

the mean monthly flow as well as one percent of the mean monthly flow, average from October 

2005 to September 20081939 to September 2007, and mean daily flow for 2006. 

TABLE 3-4 (REVISED)

MARK WEST CREEK FLOW DATA 

Mark West Creek Gauge #11466800, discharge (cfs) 

Monthly mean in cfs (Calculation Period: 2005-10-01 to 2008-09-30)

Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

2005 ~ ~ ~ ~ ~ ~ ~ ~ ~ 14.1 37.1 1,516 

2006 1,317 486.6 1,585 1,282 82.6 28.7 11.8 7.02 4.33 9.65 51.7 315.4 

2007 71.8 814.6 194 88.3 34.9 9.44 3.13 2.12 1.76 25.8 16.3 159 

2008 1,369 719 100.9 35.2 13.5 4.98 1.6 0.444 0.16 ~ ~ ~ 

Mean 919 673 627 469 44 14 5.5 3.2 2.1 17 35 663 

Notes: 

Cfs = Cubic Feet per Second 

** No Incomplete data have been used for statistical calculation 

Source: USGS, 2010 

The NPDES program established pursuant to the Clean Water Act (33 USC §§ 1251 to 1387) is a 

national program for regulating and administering permits for discharges to receiving waters. 

Under the Federal Clean Water Act, Indian Tribes can be treated as states for the purposes of the 

NPDES program [33 USC § 1377(e)]. However, the USEPA maintains regulatory authority over 

discharges to surface waters on Tribal lands. The Town of Windsor has a NPDES permit that 

allows discharge for treated municipal wastewater from the Windsor Wastewater Treatment, 

Reclamation, and Disposal Facility (WWTRDF) into Mark West Creek (USEPA, 2008c). The 

location of the discharge is shown on Figure 5 4 of Appendix EL. Because Mark West Creek is 
3.0 Affected Environment

Analytical Environmental Services 3-15 Lytton Property Residential Development

May 2011 Final Environmental Assessment

a tributary of the Russian River, discharge is prohibited during the summer months or anytime 

where the discharge would exceed one percent of river flows. In addition, no more than 17 μg/L 

of copper is allowed to be discharged monthly (NPDES permit No. CA0023345; USEPA 

2007d). The WWTRDF is discussed in more detail in Section 3.9.2. 

Groundwater Quality 

In order to protect drinking water supplies under the mandate of the Safe Drinking Water Act of 

1974, the USEPA defines National Primary Drinking Water Regulations (primary standards). 

These are legally enforceable standards that apply to public water systems. These standards are 

established to protect human health by limiting the levels of contaminants in drinking water. The 

USEPA also defines National Secondary Drinking Water Regulations (secondary standards). 

Near the Town of Windsor, magnesium chloride is present in the aquifer to a depth of 

approximately 100 feet. Many private well owners in the area have complained about the color 

and/or taste of the water. However, the overall quality of the groundwater in the Santa Rosa Plain 

is good (DWR, 2004). 

A water quality analysis was completed from a sample of water taken from the test well on the 

project site. The results of the analysis show that the total dissolved solids (TDS) concentrations 

were 270 mg/L. The analysis also found levels of arsenic and manganese that did not meet 

California or Federal drinking water standards, therefore on-site treatment of groundwater will be 

required (ECO:Logic, 2009a2010a; 2009b2010b: Appendix C). 

 

3.3 AIR QUALITY 

3.3.1 PROJECT AREA AND VICINITY

The project area is located largely in the Bay Area Air Quality Management District 

(BAAQMD), which includes Marin, San Francisco, San Mateo, Santa Clara, Alameda, Contra 

Costa, Napa, and part of Sonoma and Solano counties. A small western portion of the project site 

is located within the Northern Sonoma Air Pollution Control District (NSAPCD )Coast Unified 

Air Quality Management District (NCUAQMD), which includes northern Sonoma County. The 

NSAPCD is part of the North Coast Air Basin (NCAB), along withwhich includes northern 

Sonoma, Del Norte, Humboldt, Trinity and Mendocino counties. The smaller western portion of 

the project site is located within the North Coast Air Basin (NCAB), while the larger eastern 

portion of the project site is located in the San Francisco Bay Area Air Basin (SFBAAB) (Figure 

3-5). The residential development, community center, and related Tribal facilities will be 

primarily located on the larger eastern portion of the project site; therefore, impacts will be 

analyzed in Section 4.0 using information from the SFBAAB and the BAAQMD. 
£¤101

Eastside Rd

Windsor Rd

Windsor River Rd

Old Redwood Hwy

Arata Ln

Los Amigos Rd

Shiloh Rd

North Coast

Air Basin

San Francisco Bay Area

Air Basin

Figure 3-5

Air Management District Boundaries

SOURCE: State of California, Air Resources Board, 2010; AES, 2011

0 1,000 2,000

Feet

!¢NO

ÐR TH

Lytton Residential Development Final EA / 207513

Property Boundaries

Air Basin Boundary

Air Quality Management District

Northern Sonoma

San Francisco Bay Area

LEGEND
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Marine winds and coastal fogs characterize the regional climate of the project site. Temperature 

inversions (warm air trapping cooler air near the ground surface) occur frequently in the region, 

particularly during fall and winter seasons. Winds typically originate from the south during 

spring, summer, and fall, and out of the northwest during winter. Wind speeds are highest during 

spring and lowest during fall. The regional temperature averages in the low 70s (degrees 

Fahrenheit) for highs and the mid-40s for lows. Precipitation averaged approximately 30 inches 

per year during the period between 1931 and 2005 [(Western Regional Climate Center (WRCC), 

2008]). 

3.3.2 REGULATORY CONTEXT

The Federal Clean Air Act (CAA) was enacted for the purposes of protecting and enhancing the 

quality of the nation’s air resources to benefit public health, welfare, and productivity. Basic 

components of the CAA and its amendments include national ambient air quality standards 

(NAAQS) for major air pollutants and state implementation plans (SIPs) to ensure these standards 

are met. Regulation of air pollution is achieved through both the NAAQS and emission limits for 

individual sources of air pollutants. The USEPA is the federal agency responsible for identifying 

criteria air pollutants (CAPs), establishing NAAQS, and approving and overseeing SIPs as they 

relate to the CAA. 

3.3.3 CLIMATE CHANGE

Federal 

In 1997 the Council on Environmental Quality (CEQ) circulated an internal draft memorandum 

(CEQ, 1997a) on how global climate change should be treated for the purposes of NEPA. The 

CEQ draft memorandum advised federal lead agencies to consider how proposed actions subject 

to NEPA would affect sources and sinks of green house gases (GHGs). During the same year, 

CEQ released guidance on the assessment of cumulative effects in NEPA documents (CEQ, 

1997b). Consistent with the CEQ draft memorandum, climate change impacts were offered as 

one example of a cumulative effect.

The following are recent regulatory actions taken by the USEPA:

 On July 23, 2009, USEPA published a rule which proposes to establish the criteria for 

including sources or sites in a Registry of Recoverable Waste Energy Sources (Registry), 

as required by Energy Independence and Security Act of 2007. Waste energy can be

used to produce clean electricity. The clean electricity produced by waste energy would 

reduce the need for non-renewable forms of electricity production; thus, reducing GHG 

emissions. 
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 On September 15, 2009, USEPA and the Department of Transportation’s National 

Highway Traffic Safety Administration (NHTSA) proposed a new national program that 

would reduce greenhouse gas emissions and improve fuel economy for all new cars and 

trucks sold in the United States. USEPA proposed the first-ever national greenhouse gas 

(GHG) emissions standards under the Clean Air Act, and NHTSA proposed an increase 

in the Corporate Average Fuel Economy (CAFE) standards under the Energy Policy and 

Conservation Act. 

 In response to the Fiscal Year 2008 Consolidated Appropriations Act (H.R. 2764; Public 

Law 110–161), USEPA has issued the Final Mandatory Reporting of Greenhouse Gases 

Rule. Signed by the Administrator on September 22, 2009, the rule requires in general 

that suppliers of fossil fuels and industrial GHGs, manufacturers of vehicles and engines 

outside of the light duty sector, and facilities that emit 25,000 metric tons or more of 

GHGs per year to submit annual reports to USEPA. The rule is intended to collect 

accurate and timely emissions data to guide future policy decisions on climate change. 

 On September 30, 2009 USEPA proposed new thresholds for GHG emissions that define 

when CAA permits under the New Source Review and title V operating permits 

programs would be required.

State

California has been a leader among the states in outlining and aggressively implementing a 

comprehensive climate change strategy that is designed to result in a substantial reduction in total 

statewide GHG emissions in the future. California’s climate change strategy is multifaceted and 

involves a number of state agencies implementing a variety of state laws and policies. These 

laws and policies are briefly summarized below.

Assembly Bill 1493 (AB 1493)

Signed by the Governor in 2002, AB 1493 requires that the CARB adopt regulations requiring a 

reduction in GHG emissions emitted by cars in the state. AB 1493 is intended to apply to 2009 

and later vehicles. On June 30, 2009 the USEPA granted a CAA waiver, which the state needs in 

order to implement AB 1493. 

Executive Order S-3-05 (EO S-3-05)

EO S-3-05 was signed by the Governor on June 1, 2005. EO S-3-05 established the following 

statewide emission reduction targets:

 Reduce GHG emissions to 2000 levels by 2010,

 Reduce GHG emissions to 1990 levels by 2020, and

 Reduce GHG emissions to 80 percent below 1990 levels by 2050.
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Assembly Bill 32 (AB 32)

Signed by the Governor on September 27, 2006, AB 32 codifies a key requirement of EO S-3-05, 

specifically the requirement to reduce statewide GHG emissions to 1990 levels by 2020. AB 32 

tasks CARB with monitoring state sources of GHGs and designing emission reduction measures 

to comply with the law’s emission reduction requirements. .

AB 32 required that CARB prepare a comprehensive “scoping plan” that identifies all strategies 

necessary to fully achieve the required 2020 emissions reductions. Consequently in early 

December 2008 CARB released its scoping plan to the public and approved by CARB board on 

December 12, 2008.

The scoping plan calls for an achievable reduction in California’s carbon footprint. Reduction of 

GHGs emissions to 1990 levels are proposed, which equates to cutting approximately 30 percent 

from “business-as-usual GHG emission levels projected for 2020, or about 15 percent from 

today’s levels. The scoping plan relies on existing technologies and improving energy efficiency 

to achieve the 30 percent reduction in GHG emission levels by 2020. The scoping plan provides 

the following key recommendation to reduce GHG emissions: 

 Expanding and strengthening existing energy efficiency programs as well as building and 

appliance standards: 

 Achieving a statewide renewable energy mix of 33 percent; 

 Developing a California cap-and-trade program that links with other Western Climate 

Initiative partner programs to create a regional market system; 

 Establishing targets for transportation-related GHG emissions for regions throughout 

California, and pursuing policies and incentives to achieve those targets; 

 Adopting and implementing measures pursuant to existing State laws and policies, 

including California’s clean car standards, goods movement measures, and the Low 

Carbon Fuel Standard; and 

 Creating targeted fees, including a public goods charge on water use, fees on high global 

warming potential gases, and a fee to fund the administrative costs of the State’s long 

term commitment to AB 32 implementation. 

Executive Order S-01-07 (EO S-01-07)

EO S-01-07 was signed by the Governor on January 18, 2007. It mandates a statewide goal to 

reduce the carbon intensity of transportation fuels by at least 10 percent by 2020. 

Senate Bill 97 

Signed by the governor on August 24, 2007, Senate Bill (SB) 97 required that the Governor’s 

Office of Planning and Research (OPR) prepare California Environmental Quality Act (CEQA) 
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guidelines for evaluating the effects of GHG emissions and for mitigating such effects. The 

Natural Resources Agency adopted these guidelines on December 31, 2009. 

The Governor’s Office of Planning and Research (OPR) released a Technical Advisory on June 

19, 2008, titled CEQA and Climate Change: Addressing Climate Change Through California 

Environmental Quality Act Review. The Technical Advisory provides informal, interim guidance 

for analyzing climate change impacts in advance of comprehensive amendments to the CEQA 

Guidelines to be prepared pursuant to SB 97. The CEQA Guidelines was released to the public 

on July 3, 2009. The Technical Advisory provides the following guidance when providing 

climate change analyses in a CEQA document:

 Each lead agency needs to develop its own approach to performing climate change 

analyses. 

 Lead agencies should determine whether GHGs are generated by the project and, if they 

are, they must be quantified.

 A project’s impact can either be cumulatively or individually significant, but climate 

change is "ultimately a cumulative issue." 

 A lead agency must provide mitigation measures to avoid, reduce, or otherwise mitigate 

the impacts of GHG emissions. 

 There is no standard format for including the analysis in a CEQA document. 

 A less than significant impact can be presented using mitigation measures.

 The Technical Advisory outlines mitigation measures.

In April 2009, OPR released the CEQA Guidelines Section Proposed to be Added or Amended, 

which included guidelines for evaluating the effects of GHG emissions and for mitigating such 

effects. On December 31, 2009, the Natural Resources Agency delivered its rulemaking package 

to the Office of Administrative Law for their review pursuant to the Administrative Procedure 

Act. The Adopted Amendments will not become effective until after the Office of Administrative 

Law completes its review of the Adopted Amendments and rulemaking file, and transmits the 

Adopted Amendments to the Secretary of State for inclusion in the California Code of 

Regulations. The CEQA Guidelines Section Proposed to be Added or Amended provides the 

following direction for consideration of climate change impacts in a CEQA document:

 The determination of significance of GHG emissions calls for a careful judgment by the 

lead agency.

 A model or methodology shall be used to quantify GHG emissions resulting from a 

CEQA project. 

 Significance may rely on qualitative analysis or performance based standards.

 The CEQA document shall discuss regional and/or local GHG reduction plans.

 A CEQA document shall analyze GHG emissions if they are cumulatively considerable.
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 A description of the effects of climate change on the environment shall be included in 

CEQA documents.

 A CEQA document shall contain mitigation measures, which feasibly reduce GHG 

emissions.

 GHG analysis in a CEQA document may be Tiered or Streamlined. 

Senate Bill 375 

SB 375 was approved by the Governor on September 30, 2008. SB 375 provides for the creation 

of a new regional planning document called a “sustainable communities strategy” (SCS). An 

SCS is a blueprint for regional transportation infrastructure and development that is designed to 

reduce GHG emission from cars and light trucks to target levels that will be set by CARB for 18 

regions throughout California. Each of the various metropolitan planning organizations and the 

Association of Bay Area Governments (ABAG) must prepare an SCS and include it in that 

region’s regional transportation plan. The SCS would influence transportation, housing, and land 

use planning. CARB will determine whether the SCS will achieve the region’s GHG emissions 

reduction goals. CARB has not approved any SCS plans as of January 28, 2010. Under SB 375 

certain qualifying in-fill residential and mixed-use projects would be eligible for streamlined 

CEQA review.

Local

Bay Area Air Quality Management District CEQA Guidelines

The current approved BAAQMD CEQA Guidelines were released in December, 1999; it does not 

include any guidance for the evaluation of GHG project-level emissions, GHG threshold 

recommendations, or recommendation for the determination of significance of project-level GHG 

emissions. On October 9, 2009 the BAAQMD released its draft CEQA thresholds, which 

included thresholds for criteria pollutants and GHGs (BAAQMD, 2009). On November 9, 2009 

the BAAQMD released new draft CEQA guidelines, which included the October 9, 2009 draft 

CEQA threshold. Revised draft CEQA guidelines were issued on December 9, 2009. The 

BAAQMD adopted the 2009 draft guidelines on June 2, 2010. All GHG thresholds and 

methodologies from the draft guidelines were adopted without change. 

In 1997 the Council on Environmental Quality (CEQ) circulated an internal draft memorandum 

(CEQ, 1997a) on how global climate change should be treated for the purposes of NEPA. The 

CEQ draft memorandum advised federal lead agencies to consider how proposed actions subject 

to NEPA would affect sources and sinks of green house gases (GHGs). During the same year, 

CEQ released guidance on the assessment of cumulative effects in NEPA documents (CEQ, 

1997b). Consistent with the CEQ draft memorandum, climate change impacts were offered as 

one example of a cumulative effect. 
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3.3.4 POLLUTANTS OF CONCERN 

The USEPA has identified six CAPs that are both common and detrimental to human health. 

These CAPs are used as indicators of regional air quality. The six CAPs include: ozone (O3), 

carbon monoxide (CO), particulate matter ≤ 10 microns and ≤ 2.5 microns in diameter (PM10 and 

PM2.5), nitrogen dioxide (NO2), and sulfur dioxide (SO2). Pollutants of concern are CAPs that are 

present in quantities exceeding the NAAQS in the applicable air quality management district. In 

the area monitored by the BAAQMD, ozone has been designated as a pollutant of concern. 

Because the District has exceeded the NAAQS for ozone on more than three days within three 

consecutive years, the BAAQMD is said to be in nonattainment for this CAP (see Table 3-5). 

TABLE 3-5 (REVISED)

NATIONAL AMBIENT AIR QUALITY STANDARDS 

Pollutant Averaging 

Time 

NAAQS

SFBAAB 

Attainment Status 

Standard in 

parts per 

million (ppm) 

Standard in 

micrograms per cubic 

meter (μg/m3

) 

Violation Criteria 

O3 8 hours 0.075 157 If exceeded on more 

than 3 days in 3 years Nonattainment 

CO 8 hours 9 10,000 If exceeded on more 

than 1 day per year Attainment 

PM10 24-hour N/A 150 If exceeded on more 

than 1 day per year Unclassified 

PM2.5 24-hour N/A 35 If exceeded on more 

than 1 day per year Nonattainment1

NO2 Annual N/A 100 If exceeded Attainment 

SO2 1-hour 0.03 80 If exceeded on more 

than 1 day per year Attainment 

1

 On October 8, 2009 the SFBAAB was redesignated nonattainment by the EPA for PM2.5, this designation takes effect 90 days 

after noticed of the redesignation appears in the Federal Registry. 

Source: CARB, 2008a, BAAQMD, 2008 

Ozone 

The largest source of ground-level ozone is the incomplete combustion of fossil fuels, which 

results in emissions of reactive organic gases (ROG) and oxides of nitrogen (NOX). These ozone

precursors react in the atmosphere in the presence of sunlight to form ozone. Because the rate of 

this photochemical reaction depends on air temperature and the intensity of ultraviolet light, 

ozone is primarily a summer air pollution problem. Often the effects of the emitted ROG and 

NOX are observed at a distance downwind of the emission sources. Ozone is subsequently 

considered a regional pollutant, as the reactions forming it take place over time and downwind 

from the sources of the emissions. As a photochemical pollutant, ozone is formed only during 

daylight hours under appropriate conditions, but is destroyed throughout the day and night. Thus, 
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ozone concentrations vary depending upon both time of day and location. 

Particulate Matter (PM2.5)

Particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. This 

pollution, also known as particulate matter, is made up of a number of components, including 

acids (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles, and 

allergens (such as fragments of pollen or mold spores). The size of particles is directly linked to 

their potential for causing health problems. Particulate matter less 2.5 m in diameter (PM2.5) 

pose the greatest public health concerns, because they are small enough to enter the bloodstream. 

Hazardous Air Pollutants 

In addition to the criteria air pollutants, another group of airborne substances, called Hazardous 

Air Pollutants (HAPs) are known to be hazardous to human health. HAPs are airborne substances 

capable of causing short-term (acute) and/or long-term (chronic or carcinogenic) adverse human 

health effects. HAPs can be emitted from a variety of common sources, including fueling 

stations, vehicles, dry cleaners, industrial operations, and painting operations. Farms, 

construction sites, and residential areas can also potentially contribute to toxic air emissions. 

HAPs are regulated under the National Emission Standards for Hazardous Air Pollutants 

(NESHAP) regulations. 

3.3.5 MONITORING DATA

Monitors that collect air quality data are located at stations throughout the SFBAAB and 

California. Some monitoring stations collect data on all six federal CAPs, while others are 

specialized and only collect data for certain CAPs. Table 3-6 shows data on the BAAQMD 

pollutant of concern (ozone) collected at the Santa Rosa-5th Street Monitoring Station, which is 

the closest monitoring station to the project site. 

TABLE 3-6 (REVISED)

EXCEEDANCES OF NAAQS IN THE SFBAAB 

Pollutant 2007 2008 2009 

Ozone (8-hour averaging time)1

Highest (ppm) 0.059 0.064 0.065 

Days >0.075 ppm 0 0 0 

PM2.5 (24-hour)

Highest (μg/m3) 36.6 48.5 * 

Days >35 μg/m3 0 0 0 

1 Data provided by the Santa Rosa-5th Street monitoring station. 

* There was insufficient (or no) data available to determine the value. 

Source: CARB, 2008c. 

3.3.6 SENSITIVE RECEPTORS

Sensitive receptors are generally defined as land uses that house or attract people who are 
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susceptible to experience adverse impacts from air pollution emissions and, as such, should be 

given special consideration when evaluating air quality impacts from projects. Sensitive 

receptors include facilities that house or attract children, the elderly, people with illnesses, or 

others who are especially sensitive to the effects of air pollutants. Hospitals, schools, 

convalescent homes, parks and recreational facilities, and residential areas are examples of 

sensitive receptors. 

Sensitive receptors in the vicinity of the project site primarily include primarily nearby 

residences. The closest of these are located approximately 50100 feet east north of APN 066-

191-01622 and approximately 100 feet east west of APN 066-191-01920. AnOother nearby 

residences is are located approximately 50 feet north of APN 066-300-017 south of Windsor 

River Road and 150 feet north of APN 066-300-031, on the north side of Windsor River Road. 

Approximately seven fifteen residences are located on large individual parcels within 0.25 miles 

of the proposed project site. A high-density residential development is located directly north of 

APN 066-191-022 and east of APN 066-050-047; approximately 10 35 houses in this 

development are located along Windsor River Road in the vicinity of the Proposed Project’s 

northeast corner (bordering APNs066-050-047, 0666-191-021 and 066-191-022). The nearest 

schools are the Windsor Cooperative Nursery and the Cali Calmecac Charter School, both of 

which are located approximately 0.50 miles from the project site. 

3.4 BIOLOGICAL RESOURCES 

This section describes the existing biological resources that occur within the project site and 

general vicinity. The assessment of the existing biological resources is based upon the results of 

biological field surveys, which were conducted to document the existing habitat types onsite and 

to assess the potential for occurrence and/or presence of federally listed species and/or their 

habitats. The following discussion of existing biological resources provides the basis from which 

potential environmental consequences were identified and measured. More detailed information 

is provided in the Biological Assessment (AES, 2009b2010a) included as Appendix E. 

3.4.1 ENVIRONMENTAL SETTING

The project site is located in central Sonoma County, within the Russian River Valley. Sonoma 

County has a Mediterranean climate regime characterized by hot, dry, sunny summers and cool, 

rainy winters. Offshore winds and fog from the Pacific Ocean are common and these factors tend 

to moderate the climate in Sonoma County. Evening temperatures are frequently much cooler 

than midday temperatures and mornings are prone to coastal fog. The mean annual temperature 

range near the Town of Healdsburg is approximately 46 to 74 Fahrenheit (F). The average 

annual precipitation near the Town of Healdsburg is approximately 42 inches, with a maximum 

of approximately 8.81 inches during the month of January. This climate data was collected from 

1931 to 2007 (WRCC, 2007). 
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The project site is composed of gently rolling terrain and is situated at elevations that range from 

approximately 95 feet to 220 feet (29 to 67 meters) above mean sea level. An unnamed tributary 

to Windsor Creek is located along the eastern boundary and the Russian River is located 

approximately 1,071 meters (3,515 feet) west of the project site. The Russian River Valley falls 

within climate Zone 14 “Ocean-influenced Northern and Central California.” Climate Zone 14 

includes inland areas with oceanic or other cold air influence. This climate zone is a linear region 

that runs from Humboldt County to Santa Barbara County. The local and regional geology is 

within the Outer North Coast Range (NCoRO) geomorphic province, and is characterized by 

redwood, mixed-evergreen, and mixed-hardwood forests and by very high rainfall. This 

geomorphic province occurs within the greater California Floristic Province (Ca-FP), thus is 

equivalent to “cismontane” as often cited in other scientific texts (Hickman, 1993).

The project site is situated in a rural residential/agricultural setting near the Town of Windsor, 

approximately one mile west of the town center. APNs 066-191-017, 066-191-018, 066-191-022, 

066-050-040 and 066-050-047, which comprise approximately 41.23 acres of the project site, are 

within the sphere of influence of the Town of Windsor (Table 1-1). Specific surrounding land 

uses include rural residences, agriculture (vineyards and pastures), and undeveloped parcels. The 

project site is predominantly undeveloped and uncultivated. However, several abandoned and/or 

occupied residences and associated structures are located on-site. Twelve existing residences and 

other associated buildings are located within APNs 066-300-031, 066-300-028, 066-191-020, 

066-191-017, 066-300-023, 066-300-017, 066-191-016, 066-191-019, 066-191-021 and 066-050-

040. 

The project site is situated within the North Coast Ranges, on the west side of State Highway 101, 

just west of the Town of Windsor and south of the Town of Healdsburg, in Sonoma County, 

California. It is located within the Russian Watershed, Hydrologic Unit Code #18010110 (USGS, 

1978). The majority of the project site is currently undeveloped and uncultivated. 

The Russian River Valley falls within climate Zone 14 “Ocean-influenced Northern and Central 

California.” Climate Zone 14 includes inland areas with oceanic or other cold air influence. This 

climate zone is a linear region that runs from Humboldt County to Santa Barbara County 

(Hickman 1993). The local and regional geology is within the Outer North Coast Range 

(NCoRo) geographic subdivision of California. The NCoRo is characterized by redwood, mixedever-green, and mixed-hardwood forests and by very high rainfall. The NCoRo subdivision is 

part of the larger Northwestern (NW) geographic division, which is a component of the larger 

California Floristic Province (Ca-FP); thus is equivalent to “cismontane” as often cited in other 

scientific texts (Hickman, 1993).
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3.4.2 REGULATORY SETTING

Federal Endangered Species Act 

The United States Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service 

(NMFS) implement the Federal Endangered Species Act (FESA) of 1973 (16 USC Section 1531 

et seq.). Under the FESA, threatened and endangered species on the federal list and their habitats 

(50 CFR Subsection 17.11, 17.12) are protected from “take” (i.e., activities that harass, harm, 

pursue, hunt, shoot, wound, kill, trap, capture, or collect) as well as any attempt to engage in any 

such conduct, unless a Section 10 Permit is granted to an individual or a Section 7 consultation 

and a Biological Opinion with incidental take provisions are rendered from the lead federal 

agency. Pursuant to the requirements of FESA, an agency reviewing a Proposed Project within 

its jurisdiction must determine whether any federally listed species may be present within the 

project site and vicinity and determine whether the Proposed Project will have a potentially 

significant impact upon such species. Under FESA, habitat loss is considered to be an impact to 

the species. In addition, the agency is required to determine whether the project is likely to 

jeopardize the continued existence of any species proposed to be listed under FESA or result in 

the destruction or adverse modification of critical habitat proposed to be designated for such 

species (16 USC Section 1536[3], [4]). Therefore, project-related impacts to these species, or 

their habitats, would be considered significant and require mitigation. 

Under FESA, critical habitat may be designated by the Secretary of the Interior for any listed 

species. The term "critical habitat" for a threatened or endangered species refers to the following: 

specific areas within the geographical range of the species at the time it is listed that contain 

suitable habitat for the species, which may require special management considerations or 

protection; and specific areas outside the geographical range of the species at the time it is listed 

that contain suitable habitat for the species and is determined to be essential for the conservation 

of the species. Under Section 7 of the FESA, all federal agencies (including USFWS and NMFS) 

are required to ensure that any action they authorize, fund, or carry out will not likely jeopardize 

the continued existence of a listed species or modify their critical habitat. 

Santa Rosa Plain Conservation Strategy 

The USFWS, in cooperation with the USEPA, U.S. Army Corps of Engineers (USACE), 

California Department of Fish and Game (CDFG), North Coast Regional Water Quality Control 

Board (NC-RWQCB), and other local jurisdictions and interests, has developed a strategy to 

conserve and contribute to the recovery of several federally-listed species of the Santa Rosa Plain 

and their habitats. This document is titled The Santa Rosa Plain Conservation Strategy 

(Conservation Strategy) and identifies potential habitat and survey guidelines for the five listed 

species that are known to occur within the Santa Rosa Plain area that reaches from the City of 

Cotati north to the Town of Windsor (and encompasses the project site) (USFWS, 2005a). These 

species include the federally endangered California Tiger Salamander (CTS) (Ambystoma 
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californiense), federally endangered Sonoma sunshine (Blennosperma bakeri), federally 

endangered Burke’s goldfields (Lasthenia burkei), federally endangered Sebastopol meadowfoam 

(Limnanthes vinculans), and federally endangered many-flowered navarretia (Navarretia 

leucocephala ssp. plieantha). 

The project site falls outside the known range of CTS (USFWS, 2005a). However, it is within the 

range of the four listed plant species that are known to occur on the Santa Rosa Plain (four listed 

plant species). As such, determinant-level protocol surveys are required. In order to substantiate 

negative findings for the four listed plant species, the Conservation Strategy requires a minimum 

of two years of negative protocol survey results for future permitted actions. The protocol 

requires that at least three separate floristic surveys be conducted during the duration of the 

growing season within the project site for two consecutive years and that each one of these three 

floristic surveys be conducted at a time when at least one of the four listed plant species is 

identifiable (i.e., blooming) at a local reference site. Should these criteria not be met, USFWS 

will assume presence for all four listed plant species. 

Additional information regarding permitting requirements is available in a Programmatic 

Consultation for USACE 404 Permitted Projects that May Affect Four Endangered Plant Species 

on the Santa Rosa Plain, California (File Number 223420N) (USFWS, 2007). USFWS requires 

mitigation for impacted aquatic features that constitute suitable habitat for the four listed plant 

species (i.e., wetland features that are not occupied by the four listed plant species) and the 

mitigation ratios vary according to whether or not presence of these plant species is documented, 

assumed, or substantiated-negative. By definition, suitable habitat for the four listed plant species 

includes suitable vegetative conditions in combination with specified topographic and hydrologic 

conditions. The following vegetative conditions must be present: areas that support vernal pool 

indicator species and seasonal wetland areas where weedy grasses contribute less than 90 percent 

of the relative vegetation cover (CH2M Hill, 1998). The vegetative conditions must occur in 

combination with one or more of the following topographic and hydrologic conditions: the 

wetland area has not been entirely filled such that the wetland no longer floods or ponds and the 

original topography no longer exists, the wetland has an outlet barrier or occurs in depressional 

terrain, or the wetland contains surface water during the rainy season in a normal rainfall year for 

seven or more consecutive days (CH2M Hill, 1998). 

Migratory Bird Treaty Act 

Most bird species, (especially those that are breeding, migrating, or of limited distribution) are 

protected under federal and/or state regulations. Under the Migratory Bird Treaty Act of 1918 

(16 USC Subsection 703-712), migratory bird species, their nests, and their eggs are protected 

from injury or death, and any project-related disturbances during the nesting cycle. As such, 

project-related disturbances must be reduced or eliminated during the nesting cycle. 
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Bald and Golden Eagle Protection Act 

The Bald Eagle Protection Act was originally enacted in 1940 to protect bald eagles and was later 

amended to include golden eagles (16 USC Subsection 668-668). This act prohibits the taking or 

possession of and commerce in bald and golden eagles, parts, feathers, nests, or eggs with limited 

exceptions. The definition of take includes pursue, shoot, shoot at, poison, wound, kill, capture, 

trap, collect, molest or disturb. Bald eagles may not be taken for any purpose unless a permit is 

issued prior to the taking. Activities which can be authorized by permit are: scientific 

collecting/research, exhibition, tribal religious, depredation, falconry, and the taking of inactive 

golden eagle nests, which interfere with resource development or recovery operations. The 

statute imposes criminal and civil sanctions as well as an enhanced penalty provision for 

subsequent offenses. 

Wetlands and Waters of the U.S. 

The USACE has primary federal responsibility for administering regulations that concern Waters 

of the U.S. (including wetlands), under Section 404 of the Clean Water Act (CWA). Section 404 

of the CWA regulates the discharge of dredged or fill material into waters of the U.S. The 

USACE requires that a permit be obtained if a project proposes the placement of structures 

within, over, or under navigable waters and/or discharging dredged or fill material into waters 

below the ordinary high-water mark (OHWM). The USACE has established a series of 

nationwide permits (NWP) that authorize certain activities in waters of the U.S. 

Waters of the U.S. are defined as “All waters used in interstate or foreign commerce; all 

interstate waters including interstate wetlands; all other waters such as intrastate lakes, rivers, 

streams (including intermittent and ephemeral streams), mudflats, sand flats, wetlands, sloughs, 

prairie potholes, wet meadows, playa lakes or natural ponds, where the use, degradation, or 

destruction of which could affect interstate commerce; impoundments of these waters; tributaries 

of these waters; or wetlands adjacent to these waters” (Section 404 of the CWA; 33 CFR Part 

328). The limit of USACE jurisdiction for non-tidal waters (including non-tidal perennial and 

intermittent watercourses and tributaries to such watercourses) in the absence of adjacent 

wetlands is defined by the OHWM.

The OHWM is defined as “The line on the shore established by the fluctuations of water and 

indicated by physical characteristics such as a clear, natural line impressed on the bank, 

shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of 

litter and debris, or other appropriate means that consider the characteristics of the surrounding 

areas” (Section 404 of the CWA; 33 CFR Part 328). 

Wetlands are defined as “Those areas that are inundated or saturated by surface or ground water 

at a frequency and duration sufficient to support, and that under normal circumstances do 

support, a prevalence of vegetation typically adapted for life in saturated soil conditions” 
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(Section 404 of the CWA; 33 CFR Part 328). 

In addition, a Section 401 Water Quality Certification Permit was established to comply with 

CWA Sections 301, 302, 303, 306 and 307 and is typically regulated by the Regional Water 

Quality Control Board (RWQCB). Anyone that proposes to conduct a project that may result in a 

discharge to U.S. surface wasters and/or “waters of the state” including wetlands (all types) year 

round and seasonal streams, lakes and all other surface waters would require a federal permit. At 

a minimum, any beneficial uses lost must be replaced by a mitigation project of at least equal 

function, value and area. Waste Discharge Requirements Permits are required pursuant to 

California Water Code Section 13260 for any persons discharging or proposing to discharge 

waste, including dredge/fill, that could affect the quality of the waters of the state. 

Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act (MSFA) conserves and 

manages the fishery resources found off the coasts of the United States, the anadromous species, 

and the Continental Shelf fishery resources of the United States, including the conservation and 

management of highly migratory species through the implementation and enforcement of 

international fishery agreements. The NMFS enforces the MSFA and regulates commercial and 

recreational fishing and the management of fisheries resources. The Sustainable Fisheries Act of 

1996 amended the MSFA to include new fisheries conservation provisions by emphasizing the 

importance of fish habitat in regards to the overall productivity and sustainability of U.S. marine 

fisheries (Public Law 104-267). 

Under the MSFA, NMFS identifies, conserves, and enhances Essential Fish Habitat (EFH) for 

those species regulated under a federal Fisheries Management Plan (FMP). EFH is defined as 

“those waters and substrates necessary to fish for spawning, breeding, feeding, or growth to 

maturity.” The EFH Regulatory Guidelines (50 CFR 600.110) further interpret this definition as:

 Waters include aquatic areas and their associated physical, chemical, and biological 

properties that are used by fish and may include aquatic areas historically used by fish 

where appropriate.

 Substrate includes sediment, hard bottom, structures underlying the waters, and 

associated biological communities.

 Necessary means the habitat required to support a sustainable fishery and the managed 

species’ contribution to a healthy ecosystem.

 “Spawning, breeding, feeding, or growth to maturity” covers a species’ full life cycle. 

Federal agencies are required to consult with NMFS on all actions or proposed actions 

authorized, funded, or undertaken by the agency, which may adversely affect EFH (MSFA 

305.b.2). Adverse affects are any impacts that reduce the quality and/or quantity of EFH. 
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Adverse affects can include direct (e.g., contamination or physical disruption), indirect (e.g., loss 

of prey or reduction in species fecundity), site-specific or habitat-wide impacts, including 

individual, cumulative, or synergistic consequences of actions (50 CFR 600.810). 

There are four FMPs in California, Oregon, and Washington that identify EFH for groundfish, 

coastal pelagic species, Pacific salmon, and Pacific highly migratory fisheries. The Pacific Coast 

groundfish FMP manages over 82 species (e.g., rockfish, sablefish, flatfish, and Pacific whiting). 

Species considered pursuant under this FMP often, though not exclusively, occur on or near the 

ocean floor or other structures. The coastal pelagic species FMP manages finfish such as sardine, 

mackerel, anchovy, and the market squid. Species addressed in this FMP tend to occur nearer to 

the surface and EFH for these species is based on temperature range, life history cycles, and 

geographic distributions of these species. The Pacific salmon FMP includes both marine and 

freshwater EFH because of the unique biology of these species. As such, lakes, rivers, streams, 

ponds, wetlands, and other bodies of water that were historically accessible to salmon are 

considered EFH, including certain areas above artificial barriers. The FMP for highly migratory 

species manages mobile fishes such as tuna, swordfish, and sharks. EFH identified in this FMP is 

highly variable. It typically is defined in terms of area, depth, temperature, salinity, oxygen 

levels, currents, and topography. 

Sonoma County Tree Ordinance

State and local laws and ordinances addressing the protection of oaks and other trees are not 

applicable to trust lands, however, the standards and recommended requirements for tree 

preservation within the Sonoma County Tree Ordinance (Article 02: §26-02-140, Article 67: 

§26-67-005 through §26-67-050, and Article 88: §26-88-010 and §26-88-140) have been 

considered. The trees within the project site are not protected under federal law. The Sonoma 

County Code provides a level of protection for several native tree species, including: big leaf 

maple (Acer macrophyllum), black oak (Quercus kelloggii), blue oak (Quercus douglasii), coast 

live oak (Quercus agrifolia), interior live oak (Quercus wislizenii), madrone (Arbutus menziesii), 

oracle oak (Quercus morehus), Oregon oak (Quercus garryana), redwood (Sequoia 

sempervirens), valley oak (Quercus lobata), California bay (Umbellularia california), and their 

hybrids with DBH greater than nine inches. In addition, the Sonoma County Tree Ordinance 

(Ordinance) mandates additional protection for valley oak trees and valley oak woodlands that 

occur within a designated Valley Oak Habitat (VOH) Combining District as defined in the Open 

Space and Resource Conservation Element in the Sonoma County General Plan 2020 (Policy 

OSRC-7m: Sonoma County, 2008). The Ordinance requires that valley oak trees within the 

VOH Combining District with single trunks over 20 inches diameter at breast height (DBH), or 

multiple trunks with cumulative DBH exceed 60 inches be preserved to the maximum extent 

feasible and replaced if preservation is not feasible. 
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Tertiary Treated Discharge 

The proposed wastewater treatment and reclamation facilities facility (WTRF) and potential 

surface water discharge points locations for the first option under Alternative B (Figure 2-2) 

would be on trust land under the jurisdiction of the USEPA, which would require a USEPA 

Region 9 issued NPDES permit. Although the jurisdiction and regulatory obligations fall under 

federal authority for this project, the general Basin Plan water quality standards and beneficial use 

designations that have been established by the RWQCB would be considered by the USEPA. 

Beneficial uses specific to water bodies within Sonoma County are identified within the Water 

Quality Control Plan, North Coast Region (Basin Plan; (NCWQCB, 2007a). The Basin Plan 

identifies beneficial uses specific to the Guerneville and Mark West Creek HSAs of the Russian 

River Watershed. Each beneficial use requires different chemical or physical criteria for its 

protection. 

The following have been designated by the NCWQCB (2007a) as existing beneficial uses for the 

Guerneville* and Mark West Creek HSAs: 

 Municipal and Domestic Supply 

 Agricultural Supply 

 Industrial Service Supply 

 Groundwater Recharge 

 Freshwater Replenishment 

 Navigation 

 Water Contact Recreation 

 Non-Water Contact Recreation 

 Commercial and Sport Fishing 

 Warm Freshwater Habitat 

 Cold Freshwater Habitat 

 Wildlife Habitat 

 Rare, Threatened, or Endangered Species 

 Migration of Aquatic Organisms 

 Spawning, Reproduction, and/or Early Development 

 Estuarine*(Guerneville HSA only) 

3.4.3 METHODOLOGY

Preliminary Research and Data Gathering 

Prior to conducting the biological field surveys AES staff reviewed the following resources: 

 Aerial photographs of the project site, 

 USGS “Healdsburg, CA” 7.5-minute topographic quadrangle (USGS, 1993), 

 Online Soil Survey of Sonoma County, California (NRCS, 2008, 2010), 
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 A USFWS list of federally listed special-status species with potential to occur within 

Sonoma County and the “Healdsburg, CA” 7.5-minute topographic quadrangle and 

within the eight surrounding quadrangles (“Jimtown,” “Mount Saint Helena,” “Mark 

West Springs,” “Santa Rosa,” “Sebastopol,” “Camp Meeker,” “Guerneville,” and 

“Geyserville”)Sonoma County (USFWS, 2009; query date December 24, 2009), 

 A California Natural Diversity Database (CNDDB) list of state and federally listed 

special-status species with potential to occur within the “Healdsburg, CA” 7.5-minute 

topographic quadrangle and the surrounding eight quadrangles (Jimtown, Mount Saint 

Helena, Mark West Springs, Santa Rosa, Sebastopol, Camp Meeker, Guerneville, and 

Geyserville) (CDFG, 2003; query date December 24, 2009), 

 A CNDDB map of state and federally listed special-status species that have been 

documented within a five-mile radius of the project site (CDFG, 2003; mapped June 

2010), 

 A California Native Plant Society (CNPS) list of special-status plant species with 

potential to occur within the “Healdsburg, CA” 7.5-minute topographic quadrangle and 

the surrounding eight quadrangles (CNPS, 2009; query date December 24, 2009), and 

 A search of CDFG Anadromous Fish Passage Database (Cal Fish, 2009CDFG, 2010). 

State and/or CNPS-listed species typically do not receive specific protection on Indian trust lands 

and are not necessarily afforded protection under the FESA. However, State and CNPS listed 

species were evaluated in terms of their overall contribution to the biodiversity of the project site 

and for the purpose of providing general information that is pertinent to the Proposed Project. 

The USFWS, CNDDB, and CNPS database research lists of regionally occurring special-status 

species are included for reference purposes in Appendix E. 

A complete list of all of the regionally occurring special-status species reported in the scientific 

database queries was compiled for the project site (Attachment B to Appendix E). An analysis to 

determine which of these special-status species have the potential to occur within the project site 

was conducted. The habitat requirements for each regionally occurring special-status species 

were assessed and compared to the type and quality of habitats observed onsite during the field 

surveys. Several regionally occurring special-status species were eliminated due to lack of 

suitable habitat within the project site, elevation range, lack of suitable soil/substrate, and/or 

distribution. The analysis was also based on reviews of resource agency materials, pertinent 

scientific literature, aerial photography of the project site, topographic maps of the project site, 

and other local information. Special-status species determined to have the potential to occur 

within the project site are discussed in Section 3.4.5. 

Biological Field Surveys 

AES staff conducted numerous biological field surveys throughout the project site over a period 

of several years. These surveys were conducted on April 5 and 30, May 1 and 30, July 31, 
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August 1, November 27, 2007 and March 3, 4, 5, and 27, April 18, May 23, May 27, and October 

16 and 17, 2008. Additional surveys were conducted on March 11 and 24, April 20, May 14, and 

June 29, 2009 and April 9, May 10, June 8, 14 and July 8, 2010. The surveys were conducted on 

foot and the entire project site has been evaluated extensively. During the surveys, the habitat 

types onsite were classified and further evaluated for the occurrence of and the overall potential 

to support special-status plant and animal species. Habitat classification was based on the 

classification systems presented in A Manual of California Vegetation (MCV) (Sawyer and 

Keeler-Wolf, 19952009), Preliminary Descriptions of the Terrestrial Communities of California

(Holland, 1986), and A Guide to Wildlife Habitats of California (Mayer and Laudenslayer, Jr., 

1988), but have been modified to reflect the existing site conditions. All visible plant and wildlife 

species were noted and identified to the lowest possible taxonomic level, which is required for 

accurate identification and reporting. All tracks, scat, etc. observed onsite were also noted. Plant 

species identification, nomenclature, and taxonomy followed The Jepson Manual: Higher Plants 

of California (Hickman, 1993) and A Flora of Sonoma County (Best et al[ed]., 1996). Wildlife 

identification, nomenclature, and taxonomy followed standard reference texts including: Sibley 

Field Guide to Birds of Western North America (Sibley, 2003), Field Guide to Western Reptiles 

and Amphibians (Stebbins, 2003), and Mammals of California (Jameson and Peeters, 2004). 

These visits also included in-depth surveys for the species considered under the Conservation 

Strategy. The floristic survey efforts were conducted according to the Conservation Strategy 

protocol (USFWS, 2005a) and occurred within the appropriate bloom periods for all potentially 

occurring special-status plant species (AES, 2009g2010c; Attachment E to Appendix E). 

AES staff conducted a formal wetland delineation within the project site to identify potentially 

jurisdictional waters of the U.S (AES, 2009f2010d). The wetland delineation survey efforts were 

conducted in accordance with the Sacramento District of the USACE’s Minimum Standards for 

Acceptance of Preliminary Wetland Delineations (USACE, 2001), the Corps of Engineers 

Wetland Delineation Manual (Wetland Training Institute, Inc., 1995), and the Regional 

Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 

2.0) (USACE, 2008).Interim Regional Supplement to the Corps of Engineers Wetland 

Delineation Manual: Arid West Region (Arid West Region Supplement) (USACE, 2006). A 

stream characterization was conducted for the perennial drainage bordering the eastern edge of 

the property using the methods outlined in the RWQCB’s Surface Water Ambient Monitoring 

Programs 2007 Bioassessment Protocol Manual (Ode, 2007); a modified version of the physical 

habitat methodology was also used to characterize the unnamed drainage along the northwestern 

corner of the property (Appendix L, summarized in Appendix E). 

In addition, AES staff conducted an arbor survey of the project site, and used the collected data to 

estimate the total number of native oak and other trees onsite (AES, 2009a2010e). 
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3.4.4 RESULTS

This section summarizes the results of the field surveys that were conducted within the project 

site and provides further analysis of the data collected in the field. 

Habitat Types 

The project site contains a variety of terrestrial and aquatic habitat types. Six terrestrial habitats 

were identified onsite: annual grassland, mixed oak woodland, oak savannah, mixed riparian, 

pasture, and ruderal/developed. Five Six aquatic habitat types were observed onsite: ephemeral 

drainage, perennial drainage, isolated pit, seasonal wetland, and seasonal wetland swale. A 

summary of the terrestrial and aquatic habitat types identified within the project site and the 

approximate acreages of each type is provided in Table 3-7. A map that illustrates terrestrial and 

aquatic habitat types within the project site is presented as Figure 8 of Appendix E and 

representative photographs of each habitat type are shown in Figures 9 and 10 of Appendix E. 

TERRESTRIAL HABITATS

Annual Grassland 

Approximately 5.488 acres of annual grassland habitat was mapped within the project site, which 

represents approximately 4.416.1 percent. Annual grassland habitat is scattered in small patches 

throughout the mixed oak woodland and oak savannah habitats on the project site, as well as a 

grassy hillside within APN 066-300-023 of approximately one acre. Trees are largely absent 

within this community type and it is generally dominated by non-native annual grasses and forbs. 

Native grasses found commonly in these areas included California oatgrass (Danthonia 

californica), blue wildrye (Elymus glaucus), and purple needlegrass (Nassella pulchra). Nonnative grasses common within this habitat type included vernal grass (Anthoxanthum aristatum), 

wild oat (Avena fatua), quaking grass (Briza maxima), hedgehog dog-tail grass (Cynosurus 

echinatus), annual rabbit-foot grass (Polypogon monspeliensis), small patches of medusa-head 

grass (Taeniatherum caput-medusae), and rat-tail vulpia (Vulpia myuros). Non-native brome 

grasses (Bromus species) were notably uncommon in these areas. Native forbs commonly 

observed were harvest brodiaea (Brodiaea elegans), soap plant (Chlorogalum pomeridianum var. 

pomeridianum), blue dicks (Dichelostemma capitatum), plantain (Plantago erecta), mules ears 

(Wyethia glabra), Ithuriel’s spear (Triteleia laxa), sun cup (Camissonia ovata), buttercup 

(Ranunculus californicus) and butter and eggs (Triphysaria eriantha). Non-native forbs 

commonly observed were bur chervil (Anthriscus caucalis), filaree (Erodium botrys), Klamath 

weed (Hypericum perforatum), sanicle (Sanicula crassicaulis), common sow thistle (Sonchus 

oleraceous), torilis (Torilis arvensis), and vetch species (Vicia sativa and V. villosa).

Small patches of this habitat type are scattered throughout the mixed oak woodland habitat onsite. 

Areas classified as annual grassland habitat within the project site are simply openings within the 

mixed oak woodland habitat. Trees are largely absent within this community type and it is 

dominated by non-native annual grasses and forbs. Plant species observed within this habitat 
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type include: annual vernal grass, ripgut brome, soft brome, medusa-head grass, rat-tail vulpia 

(Vulpia myuros), blue dicks (Dichelostemma capitatum), mules ears (Wyethia glabra), Ithuriel’s 

spear (Triteleia laxa), sun cup (Camissonia ovata), winter vetch (Vicia villosa), and buttercup 

(Ranunculus californicus).

TABLE 3-7 (REVISED)

SUMMARY OF HABITAT TYPES WITHIN THE PROJECT SITE 

 

Mixed Oak Woodland 

Approximately 50.45153.59 acres of mixed oak woodland habitat was mapped within the project 

site, which represents approximately 56.043.14 percent of the total property. The overstory of 

this community is composed of mature trees species including: Blue oak (Quercus douglasii), 

black oak (Quercus kellogii), coast live oak (Quercus agrifolia), and madrone (Arbutus 

menziesii). More specifically, Black Oak Forest Alliance (Sawyer et al., 2009) is found on 

ridgetops and slopes in the northwest quadrant of APN 066-300-031, as well as APNs 066-300-

033 and 066-300-028. The Black Oak Forest Alliance is dominated by black oak (> 50 percent) 

in the canopy, with madrone and coast live oak as subdominants. Non-riparian woodlands 

elsewhere on the project site are Blue Oak Woodland Alliance (Sawyer et al., 2009), where blue 

oak is dominant (> 50 percent) in the tree canopy, with coast live oak subdominant. Shrub and 

vine species observed within the oak woodlands on the project site include: poison oak 

(Toxicodendron diversilobum), Himalayan blackberry (Rubus armeniacus), coyote brush 

(Baccharis pilularis), scotch broom (Cytisus scoparius), pipevine (Aristolochia californica), and 

honeysuckle (Lonicera hispidula). The understory of this community is dominated by annual 

grasses and forbs, observed species included annual vernal grass, wild oat, quaking grass, 

hedgehog dog-tail grass, soap plant, filaree (Erodium botrys), Klamath weed, skunkweed 

(Navarretia squarrosa), blue-eyed grass (Sisyrinchium bellum), torilis, rose clover (Trifolium 

hirtum), and bird’s beak (Cordylanthus pilosus). Shrub and vine species observed within the 

mixed oak woodland habitat onsite include: poison oak (Toxicodendron diversilobum), 

Habitat Type Acres Percent Area 

Terrestrial Habitats 

Annual Grassland 5.48 4.41 

Mixed Oak Woodland 53.59 43.14 

Oak Savannah 8.21 6.61 

Mixed Riparian 1.56 1.26 

Pasture 36.78 29.61 

Ruderal/Developed 16.99 13.68 

Aquatic Habitats 

Ephemeral Drainage 0.379 0.31 

Isolated Pit 0.022 0.02 

Seasonal Wetland 0.624 0.50 

Seasonal Wetland Swale 0.273 0.22 

Stock Pond 0.266 0.21 

Perennial Drainage 0.036 0.03 

TOTAL 124.12 100% 

Source: AES 2010a (Appendix E) 
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Himalayan blackberry (Rubus armeniacus), manzanita (Arctostaphylos sp.), coyote brush 

(Baccharis pilularis), scotch broom (Cytisus scoparius), pipevine (Aristolochia californica), and 

honeysuckle (Lonicera sp.). The understory of this community is dominated by annual grasses 

and forbs including annual vernal grass (Anthoxanthum aristatum), ripgut brome (Bromus 

diandrus), soft brome (Bromus hordeaceus), cheat grass (Bromus tectorum), medusa-head grass 

(Taeniatherum caput-medusae), quaking grass (Briza maxima), ryegrass (Lolium multiflorum), 

wild oat (Avena fatua), hedgehog dog-tail grass (Cynosurus echinatus), soap plant (Chlorogalum 

pomeridianum), filaree (Erodium botrys), Klamath weed (Hypericum perforatum), skunkweed 

(Navarretia squarrosa), blue-eyed grass (Sisyrinchium bellum), torilis (Torilis arvensis), rose 

clover (Trifolium hirtum), and bird’s beak (Cordylanthus pilosus). This habitat is considered a 

sensitive biological community by the State of California and Sonoma County. The majority of 

the woodland stands within the mixed oak woodland habitat consist of a monoculture of trees that 

appear to have become established within the same time period, probably following a clearing 

event within the project site. It appears that the woodland stands on site have not been managed, 

thinned, or otherwise altered in any way and this lack of management has resulted in severe 

overcrowding, competition, and a majority of specimens with multiple suppressed boles. 

Circumstances of this nature often result in dead limbs, higher rates of disease, insect infestation, 

parasites, build-up of woody debris (i.e., fuel), and a thick, jagged, and impenetrable overstory. 

This is the case within some sections of the project site. The overall lack of management has 

resulted in severe fuel build-up, and such extreme overcrowding poses a dangerous fire threat. 

Oak Savannah 

Approximately 8.019 21 acres of oak savannah habitat was mapped within the project site, which 

represents approximately 8.96.61 percent. The mixed oak savannah habitat type within the 

project site is very similar to the mixed oak woodland habitat type, except for the density of trees 

within it. The mixed oak savannah habitat type has fewer trees within it and they are spaced at 

much greater distances. The plant species composition is the same as described for mixed oak 

woodland above, with the exception of the shrub/vine layer. This The shrub/vine stratum is 

largely absent within this community. 

Mixed Riparian 

Approximately 1.205 56 acres of mixed riparian habitat was mapped within the project site, 

which represents approximately 1.3 26 percent. Mixed riparian habitat occurs along several of 

the drainages that were mapped within the project site. Plant species observed in the tree layer of 

this community include Valley oak (Quercus lobata), willows (Salix sp.), and Fremont’s 

cottonwood (Populus fremontii). The dominant plant species observed within the shrub/vine 

layer of this community are Himalayan blackberry and poison oak. Other plant species observed 

within the herbaceous layer of this community include: ryegrass, little quaking grass (Briza 

minor), and blue wild-rye (Elymus glaucus). 
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Pasture 

Pasture and developed areas dominate the eastern portion of the project site. Approximately 

13.60536.78 acres of pasture habitat occurs within the southeastern region of the project site, 

which represents approximately 15.129.61 percent. Pasture south of Windsor River Road appears 

to be used primarily for horses, and pasture north of Windsor Road has been used primarily for 

cattle in recent years. Trees and shrubs are sparse within this community, although, remnant 

stands of blue oak woodland persist and there are a few stands of planted non-native shade trees. 

Pasture differs from annual grassland habitat in overall plant species composition and the 

distribution of native species, which reflects more intensive management through periodic 

plowing and seeding. Occasional natives observed on-site included California oatgrass and 

purple needlegrass in pastures on the north side of Windsor River Road. Pastures on the south 

side of Windsor River Road contained a greater cover of weedy forbs and non-native grasses. 

Dominant non-native grasses included: wild oat, quaking grass, ripgut brome, soft brome, barley 

(Hordeum murinum), ryegrass, medusa-head grass, and rat-tail vulpia. Non-native forbs that 

were common in the pasture included filaree, bur chervil, torilis, prickly sow thistle (Sonchus 

asper), Shamrock clover (Trifolium dubium), rose clover, vicia species, pineapple weed 

(Chamomilla suaveolens), field mustard (Brassica rapa), black mustard (Brassica nigra), 

Shepard’s purse (Capsella bursa-pastoris), bindweed/morning glory (Convolvulus arvensis), cutleaved geranium (Geranium dissectum), shortpod mustard (Hirschfeldia incana), perennial/rough 

cat’s ear (Hypochaeris radicata), Spanish clover (Lotus purshianus), yellow wild radish 

(Raphanus raphanistrum) and sheep sorrel (Rumex acetosella). The following native forbs 

observed within pasture habitat include: soap plant, buttercup, sun cup, butter and eggs 

(Triphysaria eriantha), dove weed (Eremocarpus setigerus), bicolored lupine (Lupinus bicolor), 

and bracted popcorn flower (Plagiobothrys bracteatus).

Various sections of the pasture habitat on-site are fenced and horses were observed within this 

habitat type during the field surveys. Trees and shrubs are largely absent within this community

and it is dominated by non-native annual grasses and forbs. Plant species observed within this 

habitat type include: soap plant, buttercup, sun cup, filaree, yellow wild radish (Raphanus 

raphanistrum), ripgut brome, soft brome, medusa-head grass, rat-tail vulpia, and barley 

(Hordeum murinum).

Ruderal/Developed 

Approximately 10.40316.99 acres of ruderal/developed habitat was mapped within the project 

site, which represents approximately 11.513.68 percent. The areas classified as 

ruderal/developed habitat within the project site include all existing buildings and structures, any 

landscaped areas, roads, and parking areas, and otherwise disturbed regions. Non-native 

landscape plants observed in these areas included English walnut (Juglans regia), London plane 

tree (Platanus x acerifolia), Eucalyptus (Eucalytpus species), fig (Ficus carica), pomegranate 

(Punica granatum), apple (Malus species), plum (Prunus species), heavenly bamboo (Nandina 

domestica), periwinkle (Vinca major), and English ivy (Hedera helix). Most of the species 
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observed within this habitat type are weedy, non-native species including fennel (Foeniculum 

vulgare), bindweed, mayweed (Anthemis cotula), morning glory (Convolvulus arvense), bristly 

oxtongue (Picris echioides), shortpod mustard (Hirschfeldia incana), bur clover (Medicago 

polymorpha), filaree, English plantain (Plantago lanceolata), prostrate knotweed (Polygonum 

arenastrum), ripgut brome, wild oat, and harding grass (Phalaris aquatica) and various lawn 

grasses. 

AQUATIC HABITATS

Approximately 1.297 acres of wetlands and waters that were mapped within the project site are 

likely to be considered jurisdictional features by the USACE pursuant to the CWA. These 

include one stock pond, five seasonal wetlands, two seasonal wetland swales, nine ephemeral 

drainages and one perennial drainage (AES, 2010d). All the remaining wetlands and waters that 

were mapped within the project site are likely to be considered non-jurisdictional features by the 

USACE. One stock pond, two seasonal wetlands, one seasonal wetland swale and two isolated 

pits within the project site are likely to be considered non-jurisdictional pursuant to the Rapanos 

and Solid Waste Agency of Northern Cook County (SWANCC) decisions (totaling 0.287 acres) 

(AES, 2010d). 

Ephemeral Drainage 

Ephemeral drainages are linear features that exhibit an ordinary high water mark (OHWM). They 

are seasonal features that typically convey rainwater and surface runoff flows seasonally and for 

short time periods. Unlike intermittent drainages, ephemeral drainages are not typically 

influenced by groundwater. Nine ephemeral drainages (approximately 0.167 379 acre or 

3,618.738,270.10 linear feet) were mapped within the project site and this habitat type composes 

approximately 0.2 31 percent of the habitats on-site (AES, 2009b2010d). A few plant species 

were observed within the ephemeral drainages. However, they were predominantly unvegetated 

due to the scouring effects of flowing water. If plants do occur within ephemeral drainages, they 

tend to occur within the upper limits of the drainage or in areas where sediment has deposited that 

can function as a plant substrate. This habitat type comprises approximately 0.31 percent of the 

habitats on-site. Plant species observed within these feature types include: blue oak, coast live 

oak, madrone, ryegrass, torilis, tall flatsedge (Cyperus eragrostis), pennyroyal (Mentha 

pulegium), poverty rush (Juncus tenuis), ryegrass, fiddle dock (Rumex pulcher), sedge (Carex 

densa), torilis, Klamath weed, hedge nettle (Stachys ajugoides) and shortpod mustard 

(Hirschfeldia incana). 

Isolated Pit 

The isolated pits within the project site are relatively deep manmade holes that were excavated 

within uplands. These constructed features are round to rectangular in shape and the excavated 

dirt is piled right beside them. Two isolated pits (approximately 0.022 acre) were mapped within 
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the project site (AES, 2009b2010d). This habitat type comprises approximately 0.02 percent of 

the habitats on-site. The two isolated pits may have functioned as watering holes for cattle, test 

percolation pits, or potential sites for trash disposal. Creeping spikerush (Eleocharis 

macrostachya) was the dominant plant species observed within the isolated pits on-site. 

Seasonal Wetland 

Seasonal wetlands are typically closed, depressional features that are ephemerally wet due to the 

accumulation of surface runoff and rainwater collection within low-lying areas. The length of 

inundation tends to be relatively short and seasonal wetlands are typically dominated by nonnative, hydrophytic plant species. Six Seven seasonal wetlands (approximately 0.476 624 acre) 

were mapped within the project site and this habitat type composes approximately 0.5 percent of 

the habitats on-site (AES, 2009b2010d). Plant species observed within the seasonal wetlands 

include blue oak, ryegrass, fiddle dock, quaking grass, poverty rush, hedgehog dog-tail grass, 

pennyroyal, tall flatsedge, Bermuda grass (Cynodon dactylon), annual vernal grass, curly dock 

(Rumex crispus), soft brome, Mediterranean barley (Hordeum marinum), white water buttercup 

(Ranunculus aquatilis),and little quaking grass. 

Seasonal Wetland Swale 

Seasonal wetland swales are typically linear-shaped features that lack a clearly defined bed and 

bank and do not exhibit an OHWM. The length of inundation within seasonal wetland swales is 

relatively short and seasonal. These features primarily carry surface runoff and rainwater from 

areas of higher elevation to areas of lower elevation. Two Three seasonal wetland swales (0.260

273 acre) were mapped within the project site and this habitat type composes approximately 0.3

22 percent of the habitats on-site (AES, 2009b2010d). Plant species observed within these 

seasonal wetland swales include: Valley oak, pennyroyal, tall flatsedge, ryegrass, cut-leaved 

geranium (Geranium dissectum), and curly dock. 

Stock Pond

Stock ponds are typically man-made pond features which usually have a clearly defined bed and 

bank and OHWM. Two stock ponds (approximately 0.266 acre) occur within the northern two 

parcels of the project site (AES, 2010d). This habitat type comprises approximately 0.21 percent 

of the habitats on-site. Dominant plant species observed within the stock ponds include spikerush 

and semaphore grass (Pleuropogon californicus); rye grass and wild oats were dominant along 

upland slopes. 

Perennial Drainage 

Perennial drainages are linear features that exhibit an OHWM, have a clearly defined bed and 

bank, are typically inundated year-round, and have some degree of ground water contribution. A 

single perennial drainage (approximately 0.036 acre) was mapped within the project site for a 
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total of 0.040 acre along the eastern boundary. This feature is an unnamed tributary to Windsor 

Creek and is shown as a blue-line stream on the “Healdsburg, CA” USGS quad (Figure 2, 

Appendix E). An OHWM was observed along the entire reach and this feature was inundated 

during the field surveys. Mixed riparian habitat surrounds the perennial drainage and the density 

and width of this corridor varies. Plant species observed within the riparian corridor associated 

with the perennial drainage on-site include Valley oak, blue oak, black oak, willows, Himalayan 

blackberry and poison oak. Plant species were largely absent within the actual channel due to the 

scouring effect of flowing water. A representative photograph of the perennial drainage is shown 

in Figure 12, Photo 1 of Appendix E.

Waters of the U.S. 

A formal wetland delineation of the project site was conducted (Figure 11, Appendix E). The 

wetland delineation report identified a total of 0.9651.297 acre of potentially jurisdictional 

wetland features onsite (AES, 2009f2010d). Of this acreage, it is likely that Another 0.109 287

acre of wetland features (i.e., one stock pond, two seasonal wetlands, one ephemeral 

drainageseasonal wetland swale and the two isolated pits) will not be considered jurisdictional 

waters of the U.S. This wetland delineation is subject to USACE verification under Section 404 

of the CWA. If the USACE agrees that the previously mentioned features are not jurisdictional, 

then 0.8561.297 acres of wetlands and waters within the project site would be subject to USACE 

jurisdiction under the CWA. The wetland features are also depicted on the habitat map (Figure 

8, Appendix E). 

Total Number of Trees Within The Project Site 

Although none of the trees present on the site are protected under federal law, an arbor survey 

was conducted within the project site (AES, 2009a2010e). A total of 4,123 528 native trees are 

estimated to occur within the project site. The species composition of the native trees onsite 

includes (in order of abundance): blue oak, black oak, madrone, blue oak, Valley oakcoast live 

oak, madrone, and coast live oak Valley oak. Table 3-8 summarizes the results of the arbor 

survey (AES, 2009a2010e). 

Plant and Wildlife Observed Within the Project Site 

A variety of wildlife species were observed within the project site during the field surveys (AES, 

2009bAppendix E). Several of the species observed onsite include: pipevine swallowtail (Battus 

philenor), bullfrog (Rana catesbiana), Pacific chorus frog (Pseudacris regilla), gopher snake 

(Pituophis catenifer), ring-necked snake (Diadophis punctatus), western fence lizard (Sceloporus 

occidentalis), red-shouldered hawk (Buteo lineatus), turkey vulture (Cathartes aura), mourning 

dove (Zenaida macroura), violet-green swallow (Tachycineta thalassina), and black-tailed deer 

(Odocoileus hemionus). A complete list of wildlife species observed within the project site is 

included in Appendix E. 
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TABLE 3-8 (REVISED)

SUMMARY OF ARBOR SURVEY RESULTS 

Size Class Number of Surveyed 

Trees in Each Size Class 

Percentage of 

Surveyed Trees in 

Each Size Class 

Number of Trees in 

Each Size Class 

A 

6 ≤ DBH < 24 381 65.24% 2,954 

B 

24 ≤ DBH < 36 132 22.60% 1,023 

C 

DBH ≥ 36 71 12.16% 550 

Total 584 100% 4,528 

Source: AES, 2010e. 

Fisheries 

As detailed in the BA (Appendix E) and Stream Characterization (Appendix L) reports, the 

aquatic habitats onsite do not provide enough habitat complexity to support a diverse assemblage 

of aquatic organisms. In addition, the upper limit to anadromy lies downstream, south of the 

project site, at the confluence of Mark West Creek and Windsor Creek (Figure 5 4 of Appendix 

EL).

Special-Status Species 

For the purposes of this assessment, special-status has been defined to include those species that 

are listed as endangered or threatened under the FESA (or formally proposed and/or candidates 

for listing). While other state and/or CNPS-listed species may have potential to occur within the 

project site and its vicinity (and have been included in the baseline research that was conducted 

for the Proposed Project), these species generally receive no specific protection on Tribal trust 

land and are not necessarily afforded protection by the FESA. As discussed in Section 3.4.3, the 

results of the USFWS, CNDDB, and CNPS database research queries of regionally occurring 

species are included in Appendix E. 

An analysis was conducted to determine which of these regionally occurring species has the 

potential to occur within the project site. As shown in Table 3-9, 14 six federal special-status 

plant species were determined to have potential to occur within the project site. An additional 19

non-federal species were identified as having potential to occur within the project site. The name, 

regulatory status, distribution, habitat requirements, and period of identification for all of these 

species are identified in Tables 3-9 and 3-10. No federal special-status animal species were 

found to have potential to occur within the project site. Of the 14 species identified as having 

potential to occur within the project site, only six of them are listed as threatened or endangered

under the FESA. None of these the federal special-status plant species have been observed on the 

project site during years of surveys, as outlined in the Technical Memorandum (Attachment E to 

Appendix E). However, two CNPS List 4 species have been observed within the wetlands of the 

project site (Harlequin lotus and Lobb’s aquatic buttercup; see Attachment E to Appendix E). 
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More detailed descriptions of these six federally-listed species (identified as having potential to 

occur within the project site) are provided under Species Descriptions below. Federal or other 

species determined to have no potential to occur within the project site are not further discussed 

within this document. 

TABLE 3-9 (NEW TABLE)

FEDERAL SPECIAL-STATUS PLANTS WITH POTENTIAL TO OCCUR IN PROJECT SITE 

SCIENTIFIC 

NAME, 

COMMON 

NAME 

FEDERAL/ 

STATE/ 

CNPS 

STATUS 

DISTRIBUTION HABITAT 

REQUIREMENTS 

PERIOD OF 

IDENTIFICATION

Alopecurus 

aequalis var.

sonomensis 

Sonoma 

alopecurus

FE/--/1B Known to occur in Marin and Sonoma 

counties. 

Occurs in marshes and 

swamps (freshwater) and 

Riparian scrub. Elevations; 

5-365 meters. 

May-July 

Blennosperma 

bakeri 

Sonoma 

sunshine * 

FE/CE/1B Known to occur in Sonoma County. Occurs in Valley and foothill 

grassland (mesic) and 

vernal pools. Elevations; 

10-110 meters. 

March-May 

Lasthenia 

burkei 

Burke’s 

goldfields * 

FE/CE/1B Known to occur in Lake, Mendocino, 

Napa, and Sonoma counties. 

Occurs in meadows and 

seeps (mesic) and vernal 

pools. Elevations; 15-600 

meters. 

April-June 

Lilium 

pardalinum 

ssp. pitkinense 

Pitkin Marsh 

lily 

FE/CE/1B Known to occur in Sonoma County. Cismontane woodland, 

meadows and seeps, and 

marshes and swamps 

(freshwater, mesic, sandy). 

Elevations: 35-65 meters. 

June - July 

Limnanthes 

vinculans 

Sebastopol 

meadowfoam * 

FE/CE/1B Known to occur in Napa and Sonoma 

counties. 

Occurs in meadows and 

seeps, Valley and foothill 

grassland, and vernal pools 

(vernally mesic). 

Elevations; 15-305 meters. 

April-May 

Navarretia 

leucocephala 

ssp. plieantha 

many-flowered 

navarretia * 

FE/CE/1B Known to occur in Lake and Sonoma 

counties. 

Occurs in vernal pools 

(volcanic ash flow). 

Elevations; 30-950 meters. 

May-June 

* denotes Species covered under the Santa Rosa Plain Conservation Strategy (USFWS, 2005a) 

TABLE 3-109 (REVISED)

REGIONALLY OCCURRING NON-FEDERAL SPECIAL STATUS SPECIES 

SCIENTIFIC 

NAME, 

COMMON 

NAME 

FEDERAL/ 

STATE/ 

CNPS 

STATUS 

DISTRIBUTION HABITAT 

REQUIREMENTS 

PERIOD OF 

IDENTIFICATION

Plants 

Castilleja 

ambigua ssp. 

ambigua 

Johnny-nip

--/--/4.21

 Known to occur in Alameda, Contra Costa, 

Del Norte, Humboldt, Mendocino, Marin, 

Napa, Santa Cruz , San Francisco 

(unverified), San Luis Obispo, San Mateo, 

Sonoma, as well as Oregon and 

Washington. 

Coastal bluff scrub, coastal 

prairie, coastal scrub, 

marshes and swamps, 

Valley and foothill 

grassland, vernal pool 

margins. Elevations: 0 to 

435 meters. 

March - August 
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SCIENTIFIC 

NAME, 

COMMON 

NAME 

FEDERAL/ 

STATE/ 

CNPS 

STATUS 

DISTRIBUTION HABITAT 

REQUIREMENTS 

PERIOD OF 

IDENTIFICATION

Centromadia 

parryi ssp. 

parryi 

pappose 

tarplant

--/--/1B.2 Known to occur in Butte, Colusa, Glenn, 

Lake, Napa, San Mateo, Solano, and 

Sonoma counties. 

Chaparral, coastal prairie, 

meadows and seeps, 

marshes and swamps 

(coastal salt), and Valley 

and foothill grassland 

(vernally mesic/often 

alkaline). Elevations: 2 to 

420 meters. 

May - November 

Downingia 

pusilla 

dwarf 

downingia 

--/--/2.2 Known to occur in Fresno, Merced, Napa, 

Placer, Sacramento, San Joaquin, Solano, 

Sonoma, Stanislaus, Tehama, and Yuba 

counties. Also occurs in South America. 

Occurs in Valley and foothill 

grassland (mesic) and 

vernal pools. Elevations: 1-

445 meters. 

March-May 

Elymus 

californicus 

California 

bottlebrush 

grass 

--/--/4.31

 Known to occur in Marin, Santa Cruz, San 

Mateo, Sonoma counties. 

Broadleaf upland forest, 

cismontane woodland, 

North Coast coniferous 

forest, riparian woodland. 

Elevations: 15 to 470 

meters. 

May - August 

Fritillaria 

liliacea 

fragrant 

fritillary

--/--/1B.2 Known to occur in Alameda, Contra Costa, 

Monterey, Marin, San Benito, Santa Clara, 

San Francisco, San Mateo, Solano, and 

Sonoma counties. 

Occurs in cismontane 

woodland, coastal prairie, 

coastal scrub, and Valley 

and foothill grassland/often 

serpentinite. Elevations; :

3-410 meters. 

February-April 

Hemizonia 

congesta ssp. 

congesta 

seaside 

tarplant/pale 

yellow hayfield 

tarplant 

--/--/1B.2 Known to occur in Marin, Mendocino, San 

Francisco, and Sonoma counties. 

Valley and foothill 

grasslands (sometimes 

roadsides). Elevations: 

20-560 meters. 

April - November 

Legenere 

limosa 

Legenere 

--/--/1B.1 Known to occur in Alameda, Lake, Napa, 

Placer, Sacramento, Santa Clara, Shasta, 

San Joaquin, San Mateo, Solano, 

Sonoma, Stanislaus Tehama, and Yuba 

counties. 

Vernal pools, sloughs 

ephemeral stock ponds 

(CDFG, 2003). Elevations: 

1 to 880 meters. 

April - June 

Leptosiphon 

acicularis 

Bristly 

leptosiphon 

--/--/4.21 Known to occur in Alameda, Butte, Contra 

Costa (unverified), Fresno, Humboldt, 

Lake, Mendocino, Marin, Napa, Santa 

Clara, San Mateo, and Sonoma counties. 

Chaparral, cismontane 

woodland, coastal prairie, 

and Valley and foothill 

grassland. Elevations: 55 to 

1,500 meters. 

April - July 

Lilium 

rubescens 

Redwood lily

--/--/4.21

 Known to occur in Del Norte, Glenn, 

Humboldt, Lake, Mendocino, Napa, Santa 

Cruz*, Shasta, Siskiyou, Sonoma, and 

Trinity counties. 

Broadleaf upland forest, 

chaparral, lower montane 

coniferous forest, North 

Coast coniferous forest, 

upper montane coniferous 

forest/sometimes 

serpentinite, sometimes 

roadsides. Elevations: 30 to 

1,750 meters. 

April - August 
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SCIENTIFIC 

NAME, 

COMMON 

NAME 

FEDERAL/ 

STATE/ 

CNPS 

STATUS 

DISTRIBUTION HABITAT 

REQUIREMENTS 

PERIOD OF 

IDENTIFICATION

Lotus 

formosissimus 

Harlequin lotus

--/--/4.21

 Known to occur in Del Norte, Humboldt, 

Mendocino, Monterey, Marin, San Benito, 

Santa Cruz, San Francisco, San Luis 

Obispo, San Mateo, and Sonoma 

counties, as well as Oregon and 

Washington. 

Broadleaf upland forest, 

coastal bluff scrub, closed 

cone coniferous forest, 

cismontane woodland, 

coastal prairie, coastal 

scrub, meadows and seeps, 

marshes and swamps, 

North Coast coniferous 

forest, Valley and foothill 

grassland/wetlands, 

roadsides. Elevations: 0 to 

700 meters. This species 

was observed within a 

wetland area of parcels 

surveyed prior to 2010. 

March - July 

Microseris 

paludosa 

marsh 

microseris 

--/--/1B.2 Known to occur in Mendocino, Monterey, 

Marin, San Benito, Santa Cruz, San 

Francisco (though may be extirpated), San 

Luis Obispo, San Mateo (though may be 

extirpated), and Sonoma counties. 

Occurs in closed-cone 

coniferous forest, 

cismontane woodland, 

coastal scrub, and Valley 

and foothill grassland. 

Elevations; : 5-300 meters. 

April-June (July) 

Navarretia 

leucocephala 

ssp. bakeri 

Baker’s 

navarretia 

--/--/1B.2 Known to occur in Colusa, Glenn, Lake, 

Mendocino, Marin, Napa, Solano, 

Sonoma, Sutter, Tehama, and Yolo 

Counties. 

Occurs in cismontane 

woodland, lower montane 

coniferous forest, meadows 

and seeps, Valley and 

foothill grassland, and 

vernal pools (mesic). 

Elevations: 5-1,740 meters. 

April-July 

Perideridia 

gairdneri ssp. 

gairdneri 

Gairdner’s 

perideridia 

--/--/4.21

 Known to occur in Contra Costa , Kern, 

Los Angeles (may be extirpated), 

Mendocino, Monterey, Marin, Napa, 

Orange (may be extirpated), San Benito, 

Santa Clara, Santa Cruz, San Diego (may 

be extirpated), San Luis Obispo, San 

Mateo (may be extirpated)(unverified), 

Solano, and Sonoma counties. 

Broadleaf upland forest, 

chaparral, coastal prairie, 

Valley and foothill 

grassland, vernal pools/ 

vernally mesic areas. 

Elevations: 0 to 365 

meters. 

June - October 

Ranunculus 

lobbii 

Lobb’s aquatic 

buttercup

--/--/4.21 Known to occur in Alameda, Contra 

Costa, Mendocino, Marin, Napa, Santa 

Cruz (may be extirpated)(unverified), San 

Mateo (may be extirpated)(unverified), 

Solano, and Sonoma counties, as well as 

Oregon 

Cismontane woodland, 

North Coast coniferous 

forest, Valley and foothill 

grassland, Vernal 

pools/mesic areas. 

Elevations: 15 to 470 

meters. This species was 

observed within a wetland 

area of parcels surveyed 

prior to 2010.

February - May

Reptiles 

Actinemys 

marmorata 

marmorata 

northwestern 

pond turtle 

--/CSC/-- In California, primarily north of the San 

Francisco Bay Area and west of the Sierra 

Nevada Range. 

Ponds, marshes, rivers, 

streams, and irrigation 

ditches with aquatic 

vegetation. Requires 

basking sites and suitable 

upland habitat for egg 

laying. Nest sites most 

often characterized as 

having gentle slopes 

(<15%) with little vegetation 

or sandy banks. Elevations 

range from 0 to 

approximately 1,525 

meters. 

March - October

Birds 
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SCIENTIFIC 

NAME, 

COMMON 

NAME 

FEDERAL/ 

STATE/ 

CNPS 

STATUS 

DISTRIBUTION HABITAT 

REQUIREMENTS 

PERIOD OF 

IDENTIFICATION

Ardea 

herodias 

great blue 

heron

--/--/-- Range extends from Alaska through 

Canada and into northern South America. 

In California, occurs in northern, central 

and southern counties across the state. 

Shallow estuaries, ponds, 

roadside ditches, fresh and 

saline emergent wetlands 

and other wetland areas. 

Less common along riverine 

and rocky marine shores, in 

croplands, pastures, and in 

mountains above foothills. 

Year round 

Elanus 

leucurus 

white-tailed 

kite 

--/CFP/-- Permanent resident of coastal and valley 

lowlands. 

Habitats include savannahh, 

open woodland, marshes, 

partially cleared lands and 

cultivated fields, mostly in 

lowland situations. Nesting 

occurs in trees. 

Year round 

Mammals 

Antrozous 

pallidus 

pallid bat 

--/CSC/-- Locally common species at low elevations. 

It occurs throughout California except for 

the high Sierra Nevada from Shasta to 

Kern cos., and the northwestern corner of 

the state from Del Norte and western 

Siskiyou cos. to northern Mendocino Co. 

Habitats occupied include 

grasslands, shrublands, 

woodlands, and forests from 

sea level up through mixed 

conifer forests, generally 

below 2,000 meters. The 

species is most common in 

open, dry habitats with 

rocky areas for roosting. 

Roosts also include cliffs, 

abandoned buildings, bird 

boxes, and under bridges. 

Year Round 

Taxidea taxus 

American 

badger

--/CSC/-- Found throughout most of California in 

suitable habitat. 

Suitable habitat occurs in 

the drier open stages of 

most shrub, forest, and 

herbaceous habitats with 

friable soils. Badgers are 

generally associated with 

treeless regions, prairies, 

parklands, and cold desert 

areas. Cultivated lands 

have been reported to 

provide little usable habitat 

for this species. 

Year Round 

1

This species is not documented within the CNDDB because it is not listed pursuant through the CEQA review process. Though it is not 

required for the NEPA review process, CNPS recommends that List 3 and List 4 plant species also be considered. AES considered CNPS 

List 3 and 4 species during plant surveys; see Appendix E for more detail. 

STATUS CODES 

FEDERAL: United States Fish and Wildlife Service 

FE Federally Endangered 

STATE: California Department of Fish and Game 

CE California Listed Endangered 

CSC California Species of Special Concern 

CFP California Fully Protected Species 

CNPS: California Native Plant Society 

List 1B Plants Rare, Threatened, or Endangered in California and Elsewhere 

List 2 Plants Rare, Threatened, or Endangered in California (But More Common Elsewhere) 

List 3 Plants About Which More Information is Needed 

List 4 Plants of limited distribution 

Months in parenthesis are uncommon. 

SOURCE: USFWS, 2009; CDFG 2003; CNPS, 2009. 
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SPECIES DESCRIPTIONS

Sonoma Alopecurus (Alopecurus aequalis var. sonomensis) 

Poaceae Family 

Federal Status – Endangered 

State Status – None 

Other – CNPS List 1B 

Sonoma alopecurus is a perennial grass that occurs in freshwater marshes and swamps and 

riparian scrub habitats. This species occurs at elevations that range from five to 365 meters above 

mean sea level. Sonoma alopecurus blooms from May through July. The known range of this 

species includes Marin and Sonoma counties. This species is known for having spikelets 

(excluding the awns) that are less than four millimeters (mm) long and straight (as opposed to 

bent) awns that barely exceed the body of the lemmas by zero to two mm. Critical habitat has not 

been designated for this species and it does not have a recovery plan. The nearest documented 

occurrence of this species is located 4.85 miles southwest of the site (CDFG, 2003). The aquatic 

features and the mixed riparian habitat within the project site were considered marginally suitable 

habitat for this species. Sonoma alopecurus was not observed onsite during the floristic surveys 

between 2007 and 2010, which were conducted within the appropriate bloom period for this 

species. 

Sonoma Sunshine (Blennosperma bakeri) 

Asteraceae Family 

Federal Status – Endangered 

State Status – Endangered 

Other – CNPS List 1B 

Sonoma sunshine is an annual herb that occurs in mesic areas within Valley and foothill grassland 

and vernal pool habitats at elevations that range from ten to 110 meters above mean sea level. In 

the northern portions of the Santa Rosa Plain (i.e., north of Highway 12), this species is known to 

occur on soils within the Huichica loam series. In the southern portions of the Santa Rosa Plain 

(i.e., south of Highway 12), Sonoma sunshine is likely to occur on soils within the Wright loam 

or Clear Lake clay series (USFWS, 2007). This species blooms from March through May. 

Sonoma sunshine is endemic to Sonoma County and this is the only region where this species 

occurs. It is known for having entire lower leaves, one to three lobed upper leaves, and ray 

flowers that have dark red stigmas. Critical habitat has not been designated for this species and it 

does not have a recovery plan. The nearest documented occurrence of this species is located 4.91 

miles southeast of the project site (CDFG, 2003). Prior to conducting the floristic surveys, a 

reference population of this species was observed at the Todd Road location (Attachment E to 

Appendix E). The aquatic features and the annual grassland habitat within the project site were 

considered suitable habitat for this species. Sonoma sunshine was not observed onsite during the 
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floristic surveys between 2007 and 2010, which were conducted within the appropriate bloom 

window for this species. 

Burke’s Goldfields (Lasthenia burkei)

Asteraceae Family 

Federal Status – Endangered 

State Status – Endangered 

Other – CNPS List 1B 

Burke’s goldfields are annual herbs that occur in a variety of mesic habitats including meadows, 

seeps, swales, and vernal pools at elevations that range from 15 to 600 meters above mean sea 

level. In the northern portions of the Santa Rosa Plain (i.e., north of Highway 12), this species is 

known to occur on soils within the Huichica loam series. In the southern portions of the Santa 

Rosa Plain (i.e., south of Highway 12), Burke’s goldfields are likely to occur on soils within the 

Wright loam or Clear Lake clay series (USFWS, 2007). This species blooms from April through 

June. The known range of Burke’s goldfields includes Lake, Mendocino, Napa, and Sonoma 

counties. This species is known for having an unusual pappus that is composed of one long awn 

and several short scales. Critical habitat has not been designated for this species and it does not 

have a recovery plan. The nearest documented occurrence of this species is located 0.09 mile east 

of the project site (CDFG, 2003). Prior to conducting the floristic surveys, a reference population 

of this species was observed at the Alton Road Vernal Pool Preserve (Attachment E to Appendix 

E). The aquatic features within the project site are considered suitable habitat for this species. 

Burke’s goldfields were not observed onsite during the floristic surveys between 2007 and 2010, 

which were conducted within the appropriate bloom period for this species. 

Pitkin Marsh lily (Lilium pardalinum ssp. pitkinense) 

Liliaceae Family 

Federal Status – Endangered 

Stat Status – Endangered 

Other – CNPS List 1B 

Pitkin Marsh lily is a bulbiferous herb that occurs in cismontane woodland, meadows and seeps, 

and in freshwater marshes and swamps on substrates that are mesic and sandy. It is found in 

elevations ranging from 35 to 65 meters above mean sea level. The Pitkin Marsh lily blooms 

from June through July. Its known range is restricted to Sonoma County. This species is known 

for having a pendant, nodding inflorescence, whorled leaves, and for occurring in moist habitats. 

It has two-toned perianth segments that are typically yellow toward the center and darker red at 

the tips. The anthers tend to be between six and 11 mm long and magenta colored and the pollen 

is red or brownish-orange. The bulb scales of this species typically have two segments. Critical 

habitat has not been designated for this species but it will be included in the recovery plan for 

coastal plants, which is under development. The nearest documented occurrence of this species is 
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located 3.02 miles from the project site (CDFG, 2003). Prior to conducting the floristic surveys, a 

reference population was observed (Attachment E to Appendix E). The cismontane woodland 

and aquatic features within the project site are suitable habitat for this species. Pitkin Marsh lily 

was not observed within the project site during floristic surveys between 2007 and 2010, which 

were conducted within the appropriate bloom period for this species. 

Sebastopol Meadowfoam (Limnanthes vinculans)

Limnanthaceae Family 

Federal Status – Endangered 

State Status – Endangered 

Other – CNPS List 1B 

Sebastopol meadowfoam is an annual herb that occurs in meadows and seeps, Valley and foothill 

grassland, vernal pools, and other mesic areas at elevations that range from 15 to 305 meters 

above mean sea level. Most of the known occurrences of Sebastopol meadowfoam within the 

Santa Rosa Plain occur on Wright loam or Clear Lake clay soil series. A few other documented 

occurrences of this species within the Santa Rosa Plain are on other soil types including: Pajaro 

clay loam, Cotati fine sandy loam, Haire clay loam, and Blucher fine sandy loam series (USFWS, 

2007). Sebastopol meadowfoam blooms from April through May. The known range of 

Sebastopol meadowfoam includes Napa and Sonoma counties. However, the occurrence and 

status of this species within Napa County is considered uncertain. Sebastopol meadowfoam is 

differentiated from other species in the genus by its stamens, petals, and leaflets. The stamens of 

this species are approximately five to eight millimeters long and the petals are approximately ten 

to 18 millimeters long. The petals of this species reflex (i.e., fall out as opposed to in) as the fruit 

matures. Sebastopol meadowfoam tends to have between three to five leaflets that are entire (as 

opposed to toothed or lobed). Critical habitat has not been designated for this species and it does 

not have a recovery plan. The nearest documented occurrence of this species is located 

approximately 2.15 miles southeast of the project site (CDFG, 2003). Prior to conducting the 

floristic surveys, a reference population of this species was observed at both the Todd Road site 

and the Alton Road Vernal Pool Preserve (Attachment E to Appendix E). The aquatic features 

and the annual grassland within the project site are considered suitable habitats for this species. 

Sebastopol meadowfoam was not observed within the project site during the floristic surveys 

between 2007 and 2010, which were conducted within the appropriate bloom period for this 

species. 

Many-flowered Navarretia (Navarretia leucocephala ssp. plieantha)

Polemoniaceae Family 

Federal Status – Endangered 

State Status – Endangered 

Other – CNPS List 1B 
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Many flowered navarretia is an annual herb that occurs in vernal pool habitats. This species has 

an affinity for substrates that originated from volcanic ash flows. It occurs at elevations that 

range from approximately 30 to 650 meters above mean sea level and it blooms from May 

through June. Many-flowered navarretia (like Baker’s navarretia) is differentiated from the other 

subspecies because it has a corolla that is greater than or equal to the calyx and calyx lobes that 

are generally entire (as opposed to toothed). However, this species (ssp. plieantha) has low, 

spreading branches (as opposed to erect and ascending), and blue-tinged corollas. Critical habitat 

has not been designated for this species. However, it is included in the Recovery Plan for Vernal 

Pool Ecosystems of California and Oregon (USFWS, 2005b). The nearest documented 

occurrence of this species is located 2.04 miles southeast of the project site (CDFG, 2003). The 

aquatic features (i.e., seasonal wetlands) within the project site are considered marginally suitable 

habitat for this species. Many-flowered navarretia was not observed within the project site during 

the floristic surveys between 2007 and 2010, which were conducted within the appropriate bloom 

period for this species (Attachment E to Appendix E). 

3.5 CULTURAL RESOURCES 

An archaeological survey of APN 066-300-031 was conducted by AES in August 2007. 

Additional surveys of the remainder of the project site were conducted in October 2008 and,

March 2009, July 2010, and October 2010. The cultural resources study and addendum (AES, 

2009c 2009a and 2010f) is are bound under separate cover as Confidential Appendix F. The 

cultural resources study and addendum included a literature search, field surveys, and Native 

American consultation to identify and evaluate any prehistoric and historic-period resources 

within or adjacent to the project site that may be impacted by the proposed undertaking. 

Following is a summary of applicable sections of the cultural resources study. 

3.5.1 REGULATORY SETTING

National Historic Preservation Act 

Section 106 of the National Historic Preservation Act (NHPA) as amended, and its implementing 

regulations found in 36 Code of Federal Regulations (CFR) Part 800, require federal agencies to 

identify cultural resources that may be affected by actions involving federal lands, funds, or 

permitting. The significance of the resources must be evaluated using established criteria 

outlined 36 CFR 60.4, as described below. 

If a resource is determined to be a historic property, Section 106 of the NHPA requires that 

effects of the development on the resource be determined. A historic property is defined as: 

“...any prehistoric or historic district, site, building, structure or object included in, or eligible for 

inclusion in the National Register of Historic Places, including artifacts, records, and material 

remains related to such a property.” (NHPA Sec. 301[5]). 
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The criteria for listing on the National Register of Historic Places (NRHP), defined in 36 CFR 

60.4, are as follows: 

The quality of significance in American history, architecture, archaeology, and culture is present 

in districts, sites, buildings, structures, and objects of state and local importance that possess 

integrity of location, design, setting, materials, workmanship, feeling, association, and: 

A. That are associated with events that have made a significant contribution to the 

broad patterns of our history; 

B. That are associated with the lives of persons significant in our past; 

C. That embody the distinctive characteristics of a type, period, or method of 

construction, or that represent the work of a master, or that possess high artistic 

values, or that represent a significant and distinguishable entity whose 

components may lack individual distinction; or 

D. That have yielded, or may be likely to yield, information important to 

prehistory or history. 

Sites younger than 50 years, unless of exceptional importance, are not eligible for listing in the 

NRHP. 

National Environmental Policy Act (NEPA) 

NEPA requires that federal agencies take all practical measures to “preserve important historic, 

cultural, and natural aspects of our national heritage” (NHPA, Section 800.8(a)). NEPA’s 

mandate for considering the impacts of a federal project on important historic and cultural 

resources is similar to that of Section 106 of the NHPA, and the two processes are generally 

coordinated when applicable. Section 800.8(a) of NHPA’s implementing regulations provides 

guidance on coordination with NEPA. 

Antiquities Act 

Passed in 1906, the Antiquities Act prohibits the collection, destruction, injury, or excavation of 

“any historic or prehistoric ruin or monument, or any object of antiquity” that is situated on 

federal land without permission of the appropriate land management agency. The Antiquities Act 

also provides for the criminal prosecution, including fines and imprisonment, for individuals who 

commit one or more of the acts described above. 

3.5.2 CULTURAL RESOURCES SETTING

The following discussion of the cultural setting of the project area is condensed from the 

information presented in the cultural resources study (AES, 2009e) and addendum (AES, 2010f), 

provided referenced as Appendix F of this document. 
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Prehistory 

An analytic framework for the interpretation of central Sonoma County prehistory is provided by 

Frederickson (1974), who divided human history in California into three broad periods: the PaleoIndian period, the Archaic period and the Emergent period. This scheme used sociopolitical 

complexity, trade networks, population, and the introduction and variations of artifact types to 

differentiate between cultural units; the scheme remains the dominant framework for this region’s 

prehistoric archaeological research. 

The Paleo-Indian period (10,000-6,000 BC) was characterized by small, highly mobile groups 

occupying broad geographic areas. During the Archaic period, consisting of the Lower Archaic 

period (6,000-3,000 BC), Middle Archaic period (3,000-1,000 BC) and Upper Archaic period 

(1,000 BC–AD 500), geographic mobility may have continued, although groups began to 

establish longer-term base camps in localities from which a more diverse range of resources could 

be exploited. By the Upper Archaic, mobility was being replaced by a more sedentary adaptation 

in the development of numerous small villages, and the beginnings of a more complex society 

and economy began to emerge. During the Emergent period (AD 500-1,800), social complexity 

developed toward the ethnographic pattern of large, central villages where political leaders 

resided, with associated hamlets and specialized activity sites. 

Ethnography 

Ethnographic literature indicates that at the time of historic contact, the project area was within 

the territory of Southern Pomo-speaking people (Bean and Theodoratus, 1978:289; Kroeber, 

1976:222). According to Kroeber, the greater Pomo were the second most populous ethnohistoric 

group in California, having about 1,200 people as of the 1910 census, but it has been estimated 

that pre-contact population estimates may have been as many as 8,000 (Kroeber, 1976:237). 

Pomo communities were scattered across the landscape from the present-day City of Willits in 

northern Mendocino County, to the south near the present-day city of Santa Rosa in Sonoma 

County, and from the coastal shorelines in the west to the eastern shores of Clear Lake in Lake 

County. Ethnographic literature indicates that at the time of historic contact, the project area was 

part of lands of the Southern Pomo-speaking tribelet, or village, community of tsōlika’wiī, which 

occupied the area near the Russian River at a point about one-half mile east of “old Windsor” 

(Barrett, 1908:222; McLendon and Oswalt, 1978:284). 

The Pomo economy was based on a seasonal round of fishing, hunting, and the collection of a 

variety of plants for food, tools, structures and trade (Barrett, 1908; Kroeber, 1953; Powers, 

1877). Beads (also called Po or Pol) were also an important part of the Pomo economy. They 

were made from magnesite and could be 1-3 inches long. The beads were of such high value that 

they were traded individually rather than in a necklace like the Pomo did with the clamshell coins 

they made. The Pomo were also known for their expertise in basket making (Kroeber, 1976). 
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Typical weapons used in hunting were the bow and arrow for larger game, club for bear, and 

spears for sea lions and seals. Smaller animals were captured with low brush fences, nets, snares 

and basketry traps. Lake, stream, and ocean fish were caught in traps, with lines or weirs. The 

traditional mortar and pestle were used for processing of acorns, Buckeye nuts and other seeds, 

grasses, and roots (Powers, 1877). The stone mortars were natural shapes and were used with 

bottomless basketry hoppers. Knives were made from obsidian or chert and could be attached to 

handles and used as axes. Bone was not used often for tools and was most notably used for awls 

and fishhooks (Bean and Theodoratus, 1978:291). 

History 

Many of the traditional lifeways and land-use patterns that served the Pomoan peoples for 

centuries changed abruptly with the establishment of the Spanish missions in the Bay Area. 

Native Americans were brought into the missions, both willingly and by force, to be converted to 

Christianity, to learn farming and other “civilized” skills, and to serve as laborers. Large numbers 

of the mission inhabitants died of diseases introduced by foreign settlers and from malnutrition. 

By the mid-1800s, settlement within the Sonoma County region had not only displaced the native 

people from their villages and land-based resources, but had also disrupted culturally and 

economically significant seasonal gathering strategies and trade (McLendon and Oswalt 

1978:279, 414). 

The project area is sited on lands that once were part of the Rancho El Molino, granted in 1834 to 

Juan Bautista Rogers Cooper, brother-in-law of Mariano Vallejo, after the secularization of the 

mission system in 1833. Rancho El Molino had been sold and parceled by 1851 when the first 

residents of what would become the Town of Windsor arrived. The project area is located on 

land that belonged to J.W. Calhoun, one of the area’s first settlers. He and his descendents 

maintained approximately 360 acres from at least 1867 through 1939. 

The town of Windsor was officially laid out in 1858, and continued to grow (Alley et al., 1880: 

360-361). By the end of the nineteenth century, a foundry, two brickyards, a distillery, six 

saloons, seven wineries, three grocery stores, three livery stables, one blacksmith, three hotels, a 

photo shop, a drugstore, a barber shop, two wheelwrights, an undertaker, and dance and lodge 

halls, had been built to the west—all a result of the 1872 extension of the California Northwestern 

Railroad (CNRR) west of the town (Beedie, 1978: 50; Fray, 2004: 39; Robertson, 1998: 90-91). 

The outskirts of the Town of Windsor remained much the same throughout all these changes. 

The rural area was predominately agricultural, primarily growing hops, wine grapes, prunes, 

pears, apples, and hay. In the early 1900s, poultry farming was popular in the area, with about 

twenty ranches with flocks averaging 4,000 hens (Fray, 2004: 70). While the housing boom of 

the 1980s and the town’s incorporation in 1992 sped the growth and expansion of the urban areas, 

the surrounding area, including the project area, remains largely rural. 
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3.5.3 RESULTS OF CULTURAL STUDIES

Documentation of cultural resources within the project site was achieved through review of 

pertinent anthropological literature, historic documents and maps, a records search at the 

Northwest Information Center (NWIC), Native American consultation, and a field examination of 

the project site by archaeologists who meet the Secretary of the Interior’s professional standards. 

Records and Literature Search 

A records search for the project area was conducted by AES staff at the NWIC of the California 

Historical Resources Information System in July of 2007 (NWIC File #07-0075). The record 

search area included all the additional parcels that were added to the project area subsequent to 

2007. The records search and literature review were done to: (1) determine whether known 

cultural resources had been recorded within or adjacent to the study area and to determine if the 

project site was subject to cultural resources surveys in the past; (2) assess the likelihood of 

unrecorded cultural resources based on archaeological, ethnographic, and historical documents 

and literature; and (3) to review the distribution of nearby archaeological sites in relation to their 

environmental setting. 

The records search found that no prehistoric or historic cultural resources have been recorded 

within the project area, and no previous archaeological surveys have been conducted within its 

boundaries. However, the records search did identify two prehistoric archaeological resources 

and seven previous archaeological surveys located within approximately 1⁄4 mile of the project 

boundaries. 

Native American Consultation 

On March 5, 2007, the State of California Native American Heritage Commission (NAHC) was 

asked to review the Sacred Lands file for information on Native American cultural resources on 

the project site (see Appendix F). On March 23, 2007, the NAHC responded indicating that they 

have no knowledge of Native American resources within the project site. A second review was 

requested on October 7, 2008. On October 17, 2008, the NAHC responded again indicating they 

had no knowledge of Native American resources within or adjacent to the project site. However, 

they did provide a list of individuals and groups to further consult with. Consultation letters to 

these individuals and groups were sent on October 17, 2008. The BIA will consult with these 

individuals and the State Historical Preservation Officer (SHPO), pursuant to Section 106 of the 

NHPA, prior to approval of the proposed action. 

Field Surveys 

Damon Haydu, AES archaeologist conducted a cultural resources field survey of APN 066-300-

028 on August 16, 2007, on October 9, 2008, and March 6, 2009. Additional surveys of the 

remaining project parcels were conducted by Melinda McCrary, MA on June 24, 2010 and July 6 
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and 8, 2010. These studies included an on-foot intensive survey in 10-to-15-meter-wide transects 

within the proposed APE. Surface visibility varied between little or no visible ground surface due 

to dense grasses (undeveloped areas), to complete surface visibility in areas of bare soil. The 

ground surface was examined for archaeological remains. In addition rodent burrow backdirt 

piles, cutbanks along seasonal drainages, and road cuts were examined for indicators of buried 

archaeological deposits. Additionally, AES architectural historian Laura Brown, M.A. visited the 

project area on October 26, 2010 to inspect several historical structures. As a result of the field 

surveys, three five historic-period residential structures were identified, recorded, mapped, and 

photographed. These resources are described below. Completed State of California Department 

of Parks and Recreation (DPR) Site Forms are provided in Appendix F. 

9624 Eastside Road. APN 066-300-028 contains two residential structures. The primary 

residence was built in 1910, and a secondary residence was built after 1982. The primary 

structure is a single-story, single-family residence with modest Craftsman elements. The 

secondary structure is a two-story single-family barn style residence, and does not meet the age 

criteria for consideration as a historic property. Both houses are currently vacant.

The single story primary residence is wood framed with a basement. Wood shingles clad the 

exterior walls and a low-pitched cross-gabled roof with gabled dormers caps the building. Wide 

concrete steps set into the hillside lead up to the entrance where they meet a raised wood porch 

accessed by wood steps enclosed by a wood railing with close-set balusters. Three entrances are 

located along the porch including a wood and glass door with decorative detailing sheltered by 

the porch roof, a wood framed glass door, and a paneled wood door. Bay windows extend from 

both the east and west sides and multi-light ribbon window spans the enclosed porch on the south 

side of the residence. A front-gabled detached garage clad with vertical wood panels sits north 

of, and adjacent to, the residence. 

Review of historical maps, aerial photographs, record search materials, and a thorough literature 

review failed to indicate a connection between the parcel and any events or individuals important 

in history (criteria A and B). The primary residence appears to meet the minimum age 

requirements, but does not embody distinctive characteristics of a type, represent the work of a 

master, or possess high artistic values (criterion C). Furthermore, the site has not yielded, and is 

not likely to yield, information important to prehistory or history (criterion D). With regard to 

integrity, the primary residence has been visibly altered over the past ninety years. Many of the 

Craftsman-inspired elements of the residence have been altered, changing the appearance of the 

building: the porch on the south side of the residence has been enclosed, the majority of the 

windows and doors have been replaced, and additional living space has been added to the 

residence on the northeast side. With the above considerations in mind, it is recommended that 

the historic building at 9624 Eastside Road is ineligible for listing on the NRHP. 
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1290 Windsor River Road. APN 066-191-017 contains a primary residence and barn built in 

1935. The primary structure is a single story residence with Hall-and-Parlor Family and simple 

Folk farmhouse elements. The secondary structure is a single-story barn. The residence is 

currently occupied.

The single story primary residence is wood framed with one bedroom and one bathroom. 

Wooden horizontal-channeled board-and-batten clad the exterior walls and a low-pitched sidegabled roof slightly overhung with brackets caps the building. Contemporary wood steps lead up 

to the entrance and a raised one –story, full width wood porch enclosed by wood railing and metal 

screening is located on the north side of the structure. The centrally placed brick fireplace has 

had its top replaced with modern metal stove pipe materials. The roof was originally simple 

wood shingles which has been replaced with composite tar paper sheets. The windows have been 

replaced with modern single-hung metal windows and the front door appears to be a modern as 

well. The south side of the structure has witnessed the addition of a laundry room and car port. 

Review of historical maps, aerial photographs, record search materials, and a thorough literature 

review failed to indicate a connection between the parcel and any events or individuals important 

in history (criteria A and B). Built in 1935, the primary structure and associated barn meet the 

minimum age requirements, but do not embody distinctive characteristics of a type, represent the 

work of a master, or possess high artistic values (criterion C). The simple vernacular 

architectural style is common throughout Sonoma County and has been significantly altered since 

its initial construction. Furthermore, the site has not yielded, and is not likely to yield, 

information important to prehistory or history (criterion D). While the primary structure under 

consideration at 1290 Windsor River Road retains the general form recognizable as Hall-andParlor Family simple Folk vernacular architecture, it has undergone extensive modifications, 

which have severely diminished the architectural integrity of the structure. With the above 

considerations in mind, it is recommended that the house at 1290 Windsor River Road is 

ineligible for listing on the NRHP. 

1296 Windsor River Road. APN 066-191-020 contains a primary residence built in 1961. The 

structure is a single story, single family residence with contemporary ranch-style elements 

(McAlester and McAlester, 2002). The structure includes an attached garage and concrete 

foundation. The low pitch, side gabled structure is clad with a lapped board-on-board siding. The 

roof is clad in modern composite shingles and the windows are a mix of contemporary sliding 

two-pane and single pane fixed lights. Built in 1961, this residence will reach the minimum age 

requirements for listing on the NRHP in 2011, and therefore is evaluated in the following section. 

Review of historical maps, aerial photographs, record search materials, and a thorough literature 

review failed to indicate a connection between the parcel and any events or individuals important 

in history (criteria A and B). Moreover, it does not embody distinctive characteristics of a type, 
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represent the work of a master, or possess high artistic values (criterion C). Finally, the site has 

not yielded, and is not likely to yield, information important to prehistory or history (criterion D). 

The residence at 1296 Windsor River Road is a common example of the contemporary Ranch 

design. The Ranch style was originated in California in the mid 1930s and became the dominate 

style of architecture around the country by the 1960s (McAlisterMcAlester and 

McAlisterMcAlester, 2002). Though this residence appears to retain most of its original 

elements, therefore retaining sufficient integrity, it is one of the most ubiquitous styles of 

architecture in California and grander examples of the Ranch style can be found throughout 

Sonoma County. With the above considerations in mind, it is recommended that the house at 

1296 Windsor River Road is ineligible for listing on the NRHP. 

1390 Windsor River Road 

The historical ranch complex located at 1390 Windsor River Road (APN 066-191-016) includes a 

main residence, barn and carport, and shed. The main residence is classified as a simplified 

Queen Anne (McAlester and McAlester, 2009). Likely built in the late nineteenth century, this 

residence meets the minimum age requirements for listing on the NRHP in 2010. 

Review of historical maps, aerial photographs, archival records, and a thorough literature review 

failed to indicate a connection between the parcel and any events or individuals important in 

history (criteria A and B). The Queen Anne and vernacular architectural styles are common 

throughout Sonoma County. These particular structures do not embody distinctive characteristics 

of a type, represent the work of a master, or possess high artistic values, nor are these structures 

the best example of a Queen Anne style residence in Sonoma County (criterion C). There were 

no observations made during the pedestrian survey that the ranch complex will yield or is likely 

to yield, information important to prehistory or history (criterion D). Therefore, the historical 

ranch complex Windsor River Road is ineligible for listing on the CRHR or NRHP. 

1270 Windsor River Road 

The extant structures located at 1270 Windsor River road (APN 066-191-021) are described as a 

water tower and Contemporary Folk style residence (McAlester and McAlester, 2009). The 

structures are depicted on the 1955 “Healdsburg, California”. USGS topographic map and 

therefore meet the minimum age requirement for listing on the CRHR or NRHP. 

Review of historical maps, aerial photographs, archival records, and a thorough literature review 

failed to indicate a connection between the parcel and any events or individuals important in 

history (criteria A and B). Contemporary folk and vernacular architectural styles are common 

throughout Sonoma County and these particular structures do not embody distinctive 

characteristics of a type, represent the work of a master, or possess high artistic values, nor are 

these structures the best example of a Contemporary folk or vernacular utilitarian architecture in 

Sonoma County (criterion C). There were no observations made during the pedestrian survey 
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that the residence and water tower will yield, or are likely to yield, information important to 

prehistory or history (criterion D). Therefore, the residence and water tower at 1270 Windsor 

River Road is ineligible for listing on the CRHR or NRHP. 

3.5.4 PALEONTOLOGICAL SETTING

Paleontological resources are defined as the traces or remains of prehistoric plants and animals. 

Such remains often appear as fossilized or petrified skeletal matter, imprints or endocasts, and 

reside in sedimentary rock layers. Fossils are important resources, due to their scientific and 

educational value. Fossil resources are non-renewable. 

This section presents documentation on reported paleontological deposits on the Lytton property 

and surrounding region, as well as an analysis on the potential for unreported paleontological 

resources to be present on the project site. 

Regulatory Background 

The Antiquities Act of 1906 (PL 59-209; 16 United States Code 431 et seq.; 34 Stat. 225) calls 

for the protection of historic landmarks, historic and prehistoric structures, and other objects of 

historic or scientific interest on Federal land. While neither the Antiquities Act nor its 

implementing regulations (found at 43 CFR 3) explicitly mention fossils or paleontology, the 

inclusion of “object[s] of antiquity” in the Act has been interpreted to extend to paleontological 

resources by many federal agencies. As such, projects involving federal lands require permits for 

paleontological resource evaluation and mitigation efforts that involve excavation, collection, etc. 

Additional provisions appear in the Archaeological and Historic Data Preservation Act of 1974, 

as amended, for the survey, recovery, and preservation of significant scientific, prehistoric, 

historic, archaeological, or paleontological data, in such cases wherein this type of data might be 

otherwise destroyed or irrecoverably lost as a result of Federal projects. 

Typologies and Formation Processes 

The processes involved in the preservation of paleontological resources result in several types of 

remains. It is noted that only a small percentage of ancient life forms and their traces have been 

exposed to conditions favorable to preservation. Factors affecting the persistence of 

paleontological resources vary between species, and broadly include geological formation 

processes, climate, soil and rock chemistry, and organism morphology. Paleontological resources 

are discussed here as fossil remains, although other types of remains occur elsewhere. 

Fossils are the remains of plants and animals embedded in layers of rock, which have retained 

some degree of their original characteristics over a long period of time. Remains are buried under 

layers of sediment, which under building pressure become sedimentary rock. Paleontological 

remains can be those of organism structure, such as skeletal parts, shell, tree trunks, pollen, 
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endocasts or imprints, or they can be remnants of activity, such as footprints or tunnels of 

burrowing organisms. Soft tissues are less frequently fossilized, because they usually decay 

before fossilization processes take place. Since fossil remains occur in sedimentary rock 

formations, they tend to persist unless the rock has undergone significant changes. Fossils, 

therefore, do not occur in metamorphic rock formations. 

Fossils of considerable age may be subject to varying degrees of mineralization, at times resulting 

in the total replacement of original, organic matter by minerals. The agents of mineralization are 

most commonly comprised of calcium carbonates, such as calcite and aragonite, and silicates, 

such as quartz, opal and chalcedony. Less common materials are iron disulfides such as pyrite 

and marcasite; limonite; sulphates such as gypsum; phosphates such as calcium phosphate and 

vivianite; and glauconite. These minerals are typically transported in minute quantities by 

seeping water, with aggregation over time. 

Plant fossils, shell fossils, pollen and microfossils are generally more frequent than fossils of 

vertebrates. Thus, vertebrate fossils are considered significant. Invertebrate fossils are 

considered significant if they are scarce or diagnostic of date range, or if they constitute a 

segment of a unique paleoenvironmental framework. Paleontologists may additionally determine 

significance on a case-by case basis. 

All surficial geologic deposits on the Lytton property are Pleistocene to Recent in age. Weaver 

(1949) completed initial mapping of these deposits. He classified all deposits as Quaternary 

alluvium. Chapman and Bishop (1988) mapped almost the entire Windsor area as younger 

Quaternary alluvium and Miller (1972) mapped this alluvium as Yolo Silt Loam overlying the 

Franciscan Formation. Weaver (1949) and Chapman and Bishop (1988) mention no fossil 

localities in these deposits. 

A search of the University of California Museum of Paleontology (UCMP) database indicates 

that 503 paleontological specimens have been reported in Sonoma County (UCMP, 2008). Areas 

along the eastern edge of the Russian River Valley and adjacent North Coast Range have the 

highest frequency of fossils in the County. Within Sonoma County, the vast majority of fossil 

specimens have been documented within five major geologic formations, none of which occur in 

proximity to the project site. These formations include: Merced, Gualala, Glen Ellen, Petaluma, 

and Sonoma Tuff (UCMP, 2008). The project area is underlain by the Glen Ellen formation 

(RGH Consultants, 2008). Regionally, significant fossil discoveries have been made within the 

Sonoma Tuff formation in the eastern hills of the North Coast Range near Calistoga. Of 

particular importance is the Calistoga Petrified Forest I and II localities, located roughly 13 miles 

east of the project area. 
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Potential for Fossil Discovery 

The depositional environments of the sediments underlying the Lytton property were alluvial fans 

and marshes associated with the Russian River drainage. Fossil occurrences are not usually 

common in alluvial fan deposits because of the high probability of reworking and damage of any 

skeletal and plant material as it is transported and deposited. 

In addition, indicators of significant paleontological resources within the project site and 

immediate vicinity are absent in the sources consulted, and no such resources were observed in 

the course of surface reconnaissance surveys by AES in 2007, 2008, and 2009between 2007 and 

2010. The geologic formation upon which the project site is located has not produced significant 

paleontological specimens of scientific consequence and is unlikely to do so in the future. 

3.6 SOCIOECONOMIC CONDITIONS / ENVIRONMENTAL 

JUSTICE 

3.6.1 SONOMA COUNTY

Demographics 

Sonoma County is located 35 miles from the San Francisco Bay Area and lies in the North Coast 

Ranges of northwestern California. Additionally, Sonoma County is adjacent to Marin, 

Mendocino, Lake, Napa, Solano and Contra Costa counties. Sonoma County is home to nine 

incorporated cities and to seventeen unincorporated areas. As shown in Table 3-1011, the county 

had an estimated population of 485,000 people in 2008. The largest city in Sonoma County is 

Santa Rosa. The cities of Petaluma and Rohnert Park are the next most populated. The Sonoma 

County General Plan assumes that 73 percent of the population growth experienced in the County 

through the year 2020 will be directed to incorporated cities and 27 percent will be absorbed in 

the unincorporated area (Sonoma County, 2008). 

Community of Windsor 

Demographic data for the Windsor area (zip code 95492) is representative of the population 

within the project area. As shown in Table 3-1011, the estimated 2008 population of Windsor 

was approximately 26,564 persons. 

The 2000 U.S. Census reported that there were roughly 8,060 housing units in the community of 

Windsor with approximately 7,872 units occupied (U.S. Census Bureau, 2000a). Owneroccupied housing units made up 79.6 percent (6,266 units) of the housing stock and renteroccupied housing 20.4 percent (1,606 units), with a 2.3 percent vacancy rate (U.S. Census 

Bureau, 2000b). The existing residences in the area consist of single-family rural residential 

homes. However, high density and multi-familylow density residential zoning designations are 

identified for areas northeast of the project site. As such, it is anticipated that residential 
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development will increase near the project site. 

TABLE 3-1011

SONOMA COUNTY POPULATION 2000-2008 

3.6.2 THE LYTTON RANCHERIA

Statistical information for the Lytton Rancheria was obtained from the Bureau of Indian Affairs’ 

Population and Labor Force Report, 2005 (U.S. Department of the Interior, 2005). As shown in 

Table 3-1112, the total Tribal enrollment for the Lytton Rancheria in 2005 was approximately 

273 members. Of this total, approximately 150 Tribal members were over the age of 16. 

TABLE 3-11 12 

LYTTON RANCHERIA POPULATION AND LABOR FORCE ESTIMATES 

Tribe Population Factor Members 

Enrollment 273 

Total Eligible for Services 273 

Under age 16 123 

Age 16 through 64 145 

At age 65 and over 5 

Not available for work 16 

Available for work (total workforce) 134 

Employed 59 

Not employed 75 

Source: U.S. Department of the Interior, 2005 

3.6.3 ECONOMY

Sonoma County had an estimated median household income of $53,645 in 2004, which was 

seven percent higher than the state average. The 2000 median household income in Windsor was 

$62,781, which was approximately 13 percent higher than Sonoma County. The Bay Area real 

median household income was the highest in the state (California Center for Leadership, 2007). 

Sonoma 

County

2000 2001 2002 2003 2004 2005 2006 2007 2008 

458,614 464,543 468,501 470,829 473,521 475,461 476,956 479,668 484,470 

Cloverdale 6,831 7,082 7,333 7,481 7,959 8,197 8,412 8,479 8,577 

Cotati 6,471 6,612 6,816 6,850 7,042 7,300 7,348 7,503 7,532 

Healdsburg 10,915 11,378 11,640 11,616 11,631 11,651 11,648 11,654 11,706 

Petaluma 54,550 55,435 55,730 55,804 56,057 56,337 56,455 56,743 57,418 

Rohnert Park 42,236 42,272 42,198 42,412 42,256 42,229 42,824 42,772 43,062 

Santa Rosa 147,595 149,520 151,933 153,879 154,855 155,471 156,407 157,319 159,981 

Sebastopol 7,774 7,799 7,809 7,783 7,765 7,756 7,718 7,727 7,714 

Sonoma 9,275 9,498 9,474 9,569 9,714 9,783 9,844 9,898 9,943 

Windsor 22,744 23,533 24,112 24,403 24,855 25,342 25,887 26,315 26,564 

Unincorporated County 150,223 151,414 151,456 151,032 151,387 151,395 150,413 151,258 151,973 

Source: State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties and the State, 2001-2008, with 

2000 Benchmark, Sacramento, CA, May 2008
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3.6.4 ENVIRONMENTAL JUSTICE FOR MINORITY AND LOW INCOME 

POPULATIONS

The project site is located adjacent to the Town of Windsor within incorporated Sonoma County. 

Land uses surrounding the project site consist of undeveloped land, agricultural fields, and sparse 

residential development. Residential development is primarily located within clusters of housing 

communities developed northeast of the project site adjacent to Windsor River Road. 

All projects involving a federal action (funding, permit, or land) must comply with Executive 

Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations, as amended, which directs federal agencies to take the appropriate 

and necessary steps to identify and address disproportionately high and adverse effects of federal 

projects on the health or environment of minority, low-income, and Native American populations 

to the greatest extent practicable and permitted by law. Low income is defined based on U.S. 

Census Bureau established poverty thresholds and is discussed further below. 

The following six principles are provided as guidance for the analysis of impacts under NEPA 

(CEQ, 1997:9c): 

 Agencies should consider the composition of the affected area, to determine whether 

minority populations, low-income populations, or Indian tribes are present in the area 

affected by the proposed action. 

 Agencies should consider relevant public health data and industry data concerning the 

potential for multiple or cumulative exposure to human health or environmental hazards 

in the affected population and historical patterns of exposure to environmental hazards. 

 Agencies should recognize the interrelated cultural, social, occupational, historical, or 

economic factors that may amplify the natural and physical environmental effects of the 

proposed agency action. 

 Agencies should, as appropriate, acknowledge and seek to overcome linguistic, cultural, 

institutional, geographic, and other barriers to meaningful participation, and should 

incorporate active outreach to affected groups. 

 Agencies should assure meaningful community representation in the process. 

 Agencies should seek tribal representation in the process. 

The USEPA.S. Environmental Protection Agency’s Final Guidance for Incorporating 
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Environmental Justice Concerns in the EPA’s NEPA Compliance Analysis, (April 1998) provides 

the following guidance for defining and assessing impacts to minority and/or low-income 

populations: 

 A minority population may be present if the minority population percentage of the 

affected area is ‘meaningfully greater’ than the minority population percentage in the 

general population or other ‘appropriate unit of geographic analysis’. 

 The NEPA analysis should also make every effort to identify the presence of distinct 

minority communities residing both within, and in close proximity to, the Proposed 

Project, and to identify those minority groups which utilize or are dependent upon natural 

resources that could be potentially affected by the Proposed Project. 

 Pursuant to the CEQ guidance, low-income populations in an affected area (that area in 

which the Proposed Project will or may have an effect) should be identified with the 

statistical poverty thresholds from the U.S. Census Bureau on Income and Poverty. 

 In identifying low-income populations, agencies may consider as a community a group of 

individuals living in geographic proximity to one another or set of individuals (such as 

migrant workers or Native Americans) where either type of group experiences common 

conditions of environmental exposure. 

In 2000 the estimated population of Windsor area was approximately 23,688 persons, with the 

following ethnic breakdown of minority populations as defined in the Executive Order Section 

101 (1-101) (U.S. Census Bureau, 2000a): 

 White 79.2 percent (18,763 people);

 Hispanic 23.5 percent (5,555 people);

 Native American or Alaska Native 1.5 percent (348 people);

 Asian 2.2 percent (530 people);

 African American 0.8 percent (186 people); and

 Native Hawaiian and Other Pacific Islander 0.1 percent (32 people).

 

In 2000, the Sonoma County total population was 458,614 people, with the following ethnic 

breakdown (U.S. Census Bureau, 2000b): 

 White 81.6 percent (374,209 people);

 Hispanic 17.3 percent (79,511 people);

 Native American or Alaska Native 1.2 percent (5,389 people);

 Asian 3.1 percent (14,098 people) ;
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 African American 1.4 percent (6,522 people); and

 Native Hawaiian and Other Pacific Islander 0.2 percent (934 people).

U.S. Census data for the year 2000 reported the average household size in Windsor as 2.99 

persons, which results in a federal poverty threshold of $13,874 (U.S. Census Bureau, 2000c). As 

identified above, the 2000 median household income in Windsor was $62,781. Since the median 

household income level is $48,907 above the poverty threshold, Windsor is not defined as a lowincome community. Pursuant to the CEQ and USEPA guidance on environmental justice 

analysis, there are no low-income populations identified in the project area. 

3.7 TRANSPORTATION AND CIRCULATION 

3.7.1 TRANSPORTATION NETWORKS

This section describes the existing intersections in the vicinity of the project site. A more detailed 

description and analysis is included in the Traffic Impact Study, which was updated in early 2010

(Abrams Associates, 20092010) (Appendix G). 

INTERSECTIONS

The Traffic Impact Study (Abrams Associates, 20092010) (Appendix G) evaluated the following 

ten intersections: 

 Eastside Road and Windsor River Road;

 Windsor River Road and Proposed Project Entrance (#1);

 Windsor River Road and River Oak Lane -Proposed Project Entrance (#3);

 Windsor River Road and Starr Road;

 Windsor River Road and Windsor Road;

 Windsor River Road and Bell Road;

 Windsor River Road and Old Redwood Highway/Conde Lane;

 Windsor River RoadOld Redwood Highway and South Bound Highway 101 Ramps;

 Windsor River RoadOld Redwood Highway and North Bound Highway 101 Ramp – 

Lakeside Road; and

 Windsor River RoadOld Redwood Highway and Project Entrance (#32).

Intersections were selected for analysis by Abrams Associates, Inc, based on their proximity to 

the site, Town of Windsor, Sonoma County, and Caltrans guidelines, and their potential to be 

impacted by the Proposed Project. All intersections were analyzed for the AM peak hour (7:30 – 

8:30 AM), and the PM commute peak hour (5:00-6:00 PM). 
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METHODOLOGY

Level of Service 

Level of Service (LOS) is a qualitative measure reflecting the traffic operation of the intersection, 

with LOS A representing best performance, and LOS F the worst. LOS describes the traffic 

conditions in terms of such factors as speed, travel time, delays, freedom to maneuver, traffic 

interruptions, comfort, convenience, and safety. Table 3-12 13 shows the corresponding average 

total delay per vehicle and a description of vehicular conditions at signalized intersections for 

each LOS category from A to F. These intersections are evaluated based upon the 2000 Highway 

Capacity Manual (HCM) methodologies. Table 3-13 14 provides similar information for 

unsignalized intersections. 

TABLE 3-1213

LEVEL OF SERVICE FOR SIGNALIZED INTERSECTION 

Level-of-Service Description 

LOS “A” 

 V/C Range1

 0.0 – 0.60 

 Average Stop Delay (seconds) 0.0 – 10.0 

Free flow. If signalized, conditions are such that no 

vehicle phase is fully utilized and no vehicle waits 

through more than one red indication. Very slight or 

no delay. 

LOS “B” 

 V/C Range 0.61 – 0.70 

 Average Stop Delay (seconds) 10.1 – 20.0 

Stable flow. If signalized, an occasional approach 

phase is fully utilized; vehicle platoons are formed. 

Slight delay. 

LOS “C” 

 V/C Range 0.71 – 0.80 

 Average Stop Delay (seconds) 20.1 – 35.0 

Stable flow or operation. Drivers occasionally may 

have to wait through more than one red phase. 

Acceptable delay. 

LOS “D” 

 V/C Range 0.81 – 0.90 

 Average Stop Delay (seconds) 35.1 – 55.0 

Approaching unstable flow or operation; queues 

develop but quickly clear. Tolerable delay. 

LOS “E” 

 V/C Range 0.91 – 1.00 

 Average Stop Delay (seconds) 55.1 – 80.0 

Unstable flow or operation; the intersection has 

reached capacity. Congestion and intolerable delay. 

LOS “F” 

 V/C Range2 1.00 or less 

 - Measured 1.01 or more 

 Average Stop Delay (seconds) >80 

Forced flow or operation. Intersection operates 

below capacity. Jammed. 

NOTES: 1 The “V/C” ratio is the ratio of the traffic volume to the roadway capacity (both in vehicles per hour) 

 2

 While forecast demands can exceed maximum capacity, actual measured volumes theoretically cannot. Since 

traffic intersections arise at capacity demand conditions, the calculated V/C ratios for LOS “F” conditions can 

be substantially below a V/C of 1.00. 

Source: Abrams Associates, 20092010

TABLE 3-1314

LEVEL OF SERVICE FOR UNSIGNALIZED INTERSECTIONS 

Level of Service Average Total Delay 

(seconds/vehicle) Traffic Condition 

A <10 No Delay 

B >10 – 15 Short Delay 

C >15 – 25 Moderate Delay 

D >25 – 35 Long Delay 

E >35 – 50 Very Long Delay 

F >50 Volume > Capacity 

Source: Abrams Associates, 20092010
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Existing Intersection Traffic Volumes and Levels of Service 

Table 3-14 15 summarizes the existing a.m. and p.m. peak-hour LOS at each study intersection, 

with the exception of intersection #2 (future stop sign). Eight out of nine study intersections 

currently operate at LOS D or better during both the a.m. and p.m. peak hours. Intersection #9 

(Windsor River Road and NB Highway 101 Off-Ramp-Lakeside Road) currently operates at LOS 

E+. 

Existing Bicycle and Pedestrian System 

Existing sidewalks and developed bike lanes along Windsor River Road terminate east of the 

project site near the Town of Windsor. The designated Class II lanes within the Town of 

Windsor are on-road lanes with designated striping and signage, whereas the Class III lanes 

closer to the project site are on-road with no designated lanes. The Sonoma County 

Transportation Authority Countywide Bicycle and Pedestrian Master Plan indicates that bike 

lanes along unincorporated Windsor River Road are expected to be designated as Class II 

(Sonoma County Transportation Authority, 2008). Observations of the road indicate that 

pedestrian and bicycle activities are low. 

TABLE 3-1415 (REVISED)

EXISTING LEVEL OF SERVICE AND AVERAGE DELAY OF STUDY INTERSECTIONS 

Intersection Traffic 

Control 

AM Peak PM Peak 

LOS Average 

Delay (sec) LOS Average Delay (sec) 

#1. Eastside Road and 

Windsor River Road 

Stop Sign 

(Future) B 10.1 B 10.0

#3. Windsor River Road and 

Project Entrance (#3) 

Stop Sign 

(Future) A 9.7 A 9.5 

#4. Windsor River Road and 

Starr Road All-Way Stop B 11.2 A 9.6 

#5. Windsor River Road and 

Windsor Road Traffic Signal D 37.4 C+ 30.4 

#6. Windsor River Road and 

Bell Road Stop Sign C 19.9 C 21.6 

#7. Windsor River Road and 

Old Redwood Hwy/Conde 

Lane 

Traffic Signal D 39.2 D 36.9 

#8. Old Redwood Highway 

and SB Hwy 101 Ramps Traffic Signal B 12.5 B 14.4 

#9. Old Redwood Highway and 

NB Hwy 101 Off-Ramp – 

Lakeside Road 

Traffic Signal C- 33.4 E+ 60.9 

#10. Old Redwood Highway 

and Project Entrance #2 Stop Sign A 9.7 A 9.5 

Source: Abrams Associates, 2010 

Transit Service 

Sonoma County Transit provides bus services to Sonoma County, and surrounding communities, 

including the Town of Windsor. Route 60 provides regional service between Cloverdale and 
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Santa Rosa and operates on Windsor River Road and Starr Road on one-hour headways. Route 

66 (Windsor Shuttle) provides local service through the Town of Windsor with headways of just 

over an hour. 

3.8 LAND USE 

NEPA requires an assessment of a project’s effect on adopted land use plans as well as plans that 

have been formally proposed and are being actively pursued by officials of the jurisdiction. 

Accordingly, adopted and proposed land use regulations are discussed below. 

Land uses on the 92124.12-acre project site include six twelve single-family residences and their 

ancillary structures as well as undeveloped oak woodland habitat. The site is located in 

unincorporated Sonoma County near the urban/rural community of Windsor, California, which is 

located approximately 150 feet north of the project site. As shown in Figure 3-56, APNs 066-

191-017, 066-191-018, 066-050-040, 066-050-047 and 066-191-022 are located within the Town 

of Windsor Sphere of Influence and Urban Growth Boundary (UGB). Only APN 066-050-047 is 

located within Town of Windsor limits; the remaining 13 parcels are outside town limits. Land 

between the project site and the Town of Windsor is comprised of rural residences, agriculture, 

and open space. Although the Town of Windsor includes land use designations for parcels within 

its Sphere of Influence, Sonoma County retains jurisdiction over land outside of the city limits. 

3.8.1 SONOMA COUNTY GENERAL PLAN (2020) 

According to the Sonoma County General Plan, APNs 066-300-028 and 066-300-033 have a land 

use designation of “Resources and Rural Development” (RRD), which protects lands used for 

timber, geothermal, and mineral resources production and for natural resource conservation 

(Figure 3-56). Under this designation, single-family homes/dwellings are permitted at low 

densities, between 20 and 320 acres per dwelling. These parcels are also zoned as “RRD” with 

the “Scenic Resources” combining district (Figure 3-56). RRD-zoned parcels may contain 

houses at the same densities allowed in RRD land use areas (Sonoma County Zoning Code 

[SCZC], 1993b). 

The remaining six twelve parcels within the project site have a land use designation of “Rural 

Residential” (RR) (Figure 3-56). The primary permitted use of RR is detached single-family 

homes, with other permitted uses including attached dwellings, farming, small scale animal 

husbandry, small scale home care and group care facilities, and other uses incidental to and 

compatible with the primary use. Condominiums are a secondary and allowable building type 

within Rural Residential areas. Densities for development in RR areas range from 1 to 20 acres 

per dwelling (SCZC, 1993a). According to the Sonoma County General Plan map, allowable 

densities for RR areas within the project site are generally one dwelling unit per five acres

(Sonoma County, 2008).
Eastside Rd

Richardson Rd

Springfield Ct Springfield Ct

Ventnor Ave

Indiana Ave

Stellar Ct

Sirius Dr Sirius Dr

Windsor River Rd

Starr Rd Starr Rd

Starr Rd

Figure 3-6

Sonoma County Land Use and Zoning Map

SOURCE: Healdsburg, CA” USGS 7.5 Topographic Quadrangle, Section 15, T8N, R8W & R9W, Mt. Diablo Baseline & Merdian; Sonoma County 

Permit Resource Planning Dept, 2004; AES 2011

Approximate Property Boundary

Town of Windsor Sphere of Influence/Urban Growth Boundary

ZONING DESIGNATIONS

Land Intensive Agriculture

AR Agriculture and Residential District

RRD Resources and Rural Development

LAND USE DESIGNATIONS

Land Intensive Agriculture

RR Rural Residential

RRD Resources and Rural Development

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Land uses surrounding the project site include RRD land use designations to the northwest, west, 

and south. Further wWest, along of the Russian River, land is designated as “Land Intensive 

Agriculture.” Lands to the northeast, east, and southeast have “Agricultural and Residential 

District” (AR) zoning designations (Figure 3-56). The twelve eastern parcels are also zoned as 

AR. AR-zoned parcels may contain houses at the same densities allowed in RR land use areas 

(SCZC, 1993a). 

3.8.2 TOWN OF WINDSOR GENERAL PLAN (2015) 

APNs 066-191-017, 066-191-018, 066-050-040, 066-050-047 and 066-191-022 are located 

within the Town of Windsor Sphere of Influence, UGB and Special Planning Area E (Figure 3-

67). APN 066-050-047 is the only parcel within Town of Windsor limits. According to the 

Town of Windsor General Plan Map, these parcels have a land use designation of “Estate 

Residential/Low Density Residential” (ER). Under this designation single-family homes are 

permitted at densities from 0.2-3 dwelling units/acre or 0.6-8.6 persons/acre. 

As shown in Figure 3-67, an agricultural buffer area is located on portions of APNs 066-191-

017, 066-191-018, and 066-191-022. Agricultural buffers are meant to protect the continued 

viability of neighboring agricultural operations. The Town of Windsor General Plan (2015; 

Town of Windsor, 2005) indicates that if the existing agricultural property lies outside the UGB, 

then the agricultural buffer should be permanent. Currently, the area contains several structures 

and a road; no permanent buffer is located in the agricultural buffer area. 

APNs 066-191-017, 066-191-018, 066-050-040 and 066-191-022 are located within Special 

Planning Area E. Items to be studied within Area E include an interconnected street system to 

provide a connection between Windsor River Road and Gumview Road and/or Windsor River 

Road and Starr View Road; area drainage and the use of detention points; biotic resources, the 

rural atmosphere, an appropriate density within the Estate Residential range, the community edge, 

and the Town’s western gateway. Policies specific to this planning area include: 

 New residences in this area should be compatible with the existing low density, dispersed 

development pattern. 

 Special attention should be accorded to natural resources preservation because the area 

contains both oaks and riparian habitat. 

 Because of the site’s natural amenities and location at the periphery of the Urban Growth 

Boundary, the Town should encourage the use of landscaped setbacks and trails to help 

define the edge for the neighborhood and the boundary for the Town’s urban limits. 
Eastside Rd

Starr Rd

Windsor River Rd

Richardson Rd

Springfield Ct Springfield Ct

Ventnor Ave

Dorthea Ct Dorthea Ct

Indiana Ave

Stellar Ct

Figure 3-7

Town of Windsor Land Use Designations

SOURCE: Town of Windsor, 2005; Brelje & Race Civil Engineers, 2005; AES, 2011

Approximate Property Boundary

Town of Windsor Sphere of Influence/Urban Growth Boundary

Town of Windsor City Limit

CITY OF WINDSOR LAND USE DESIGNATIONS

Special Planning Area E

Agricultural Buffer

Low Density Residential

Low-Medium Density Residential

Open Space

Parks

Public/Quasi-Public

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 In conjunction with discretionary review for development proposals in this area, the use 

of onsite detention ponds to reduce stormwater peak flows off-site shall be included in 

the environmental analysis and required if determined to reduce stormwater peak flow 

downstream. 

3.8.3 AGRICULTURE 

REGULATORY SETTING

Williamson Act 

The California Land Conservation Act of 1965, better known as the Williamson Act, enables 

local governments to enter contracts with private land owners to maintain agricultural or open 

space use on their properties in exchange for lower property tax assessments. These contracts 

have a term of no less than 10 years and are automatically renewed unless a notice of cancelation 

or nonrenewal is given (California Department of Conservation ([CDC], 2008). The project site 

is not under an active Williamson Act Contract, although several parcels in the vicinity, including 

a parcel immediately south of the site, are under a Williamson Act Contract (Figure 3-78). 

Farmland Protection Policy Act 

The Agriculture and Food Act of 1981 (Public Law 97-98) contained the Farmland Protection 

Policy Act (FPPA) (Subtitle I of Title XV, Section 1539-1549). The purpose of the FPPA is to 

minimize the impact of Federal programs on the unnecessary and irreversible conversion of 

farmland to nonagricultural uses. The Farmland Mapping and Monitoring Program (FMMP), 

within the California Department of Conservation (CDC), maps activity from the U.S. 

Department of Agriculture (USDA) on a continuing basis. The FMMP produces maps and 

statistical data used for analyzing impacts on California’s agricultural resources (CDC, 2004). 

The FPPA created the farmland classification system which consists of five specific farmland 

categories, all of which are found in the County. These categories include: 

Prime Agriculture Land: Soils which have the best combinations of physical and chemical 

characteristics for the production of crops. The land must have been used for the production of 

irrigated crops at sometime during the two updated cycles prior to the mapping date (7 U.S.C. 

4201(c)(1)(A)). 

 

Unique Farmland: Soils other than prime farmland that are used for the production of specific 

high value food and fiber crops. These soils have a special combination of physical and chemical 

characteristics for the production of high quality or high yields of specific crops when treated and 

managed according to acceptable farming methods (7 U.S.C. 4201(c)(1)(B)). 
Eastside Rd

Starr Rd

Windsor River Rd

Springfield Ct Springfield Ct

Ventnor Ave

Dorthea Ct Dorthea Ct

Indiana Ave

Stellar Ct

Starr Rd

Figure 3-8

Williamson Act Map

SOURCE: Sonoma County Permit Resource Planning Dept, 2004; AES, 2011

Appromximate Property Boundary

Sonoma County Parcels

Williiamson Act Prime Agricultural Land

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Important Farmland: Soils other than prime or unique farmland that is of statewide or local 

importance for the production of crops. The appropriate State or local government determines the 

important farmland with concurrence from the State Conservationist. In some localities, 

farmlands of statewide and local importance may include tracts of land that have been designated 

for agriculture by state law or local ordinance (7 U.S.C. 4201(c)(1)(C)). 

Grazing Land: Defined in Government Code § 65570(b)(3) as: “...land on which the existing 

vegetation, whether grown naturally or through management, is suitable for grazing or browsing 

of livestock. 

The project site consists of three four FMMP land classifications, farmland of local importance, 

grazing land, and other land, and urban and built-up land. The classification of other land is 

given to lands which are not included in any other mapping category. Examples of lands 

classified as other land include low density rural developments, brush, timber, wetland, and 

riparian areas not suitable for livestock (CDC, 2006). A map of the project site’s classifications is 

represented in Figure 3-89. The land to the west, across Eastside Road, is classified as prime 

agricultural land. The land to the north, south, and east is a mixture of farmland of local and 

statewide importance, prime farmland, and grazing land. A single winery is located immediately 

south of APN 066-300-031, within extensive associated vineyards.

The National Resource Conservation Service (NRCS), an agency of the Department of 

Agriculture (DOAUSDA), fulfills the directives of the Soil and Water Conservation Act (16 USC 

§ 2001-2009) by identifying significant areas of concern for the protection of our resources. 

NRCS uses a land evaluation and site assessment (LESA) system to establish a Farmland 

Conversion Impact Rating (FCIR) score. The FCIR is completed on form AD-1006 (NRCS, 

2008b). The FCIR form has two components: land evaluation, which rates soil quality up to 100 

points, and the site assessment, which measures other factors that affect the farm’s viability up to 

160 points. 

The total FCIR score is used as an indicator for the project’s sponsor to consider alternative sites 

if the potential adverse impacts on the farmland exceed the allowable level. Sites receiving a 

combined score of less than 160 (out of 260 possible points) do not require further evaluation; 

alternative project locations should be considered for sites with a combined score greater than 160 

points. An FCIR form was completed for the project site (Appendix H). The 124.12-acre 

project site received a total of 923 points; as this score is less than 160 points, no further 

evaluation is needed. 

Sonoma County Right to Farm Ordinance 

The Sonoma County Right to Farm Ordinance was adopted in 1999 by the Board of Supervisors 

to support County policies regarding the conservation and enhancement of agricultural operations 
R U S S I A N R I V E R

W i n d s o r C r e e k

Windsor Creek

W i n d s o r C r e e k

P o o l C r e e k

Starr Rd

Eastside Rd

Westside Rd

Windsor Rd

Redwood Hwy

Old Redwood Hwy

Arata Ln

Windsor River Rd

Los Amigos Rd

Hillview Rd

Conde Ln

A St

Shiloh Rd

Wilson Ln

Silk Rd

Herb Rd

Mark West Station Rd

Bell Rd

Sanders Rd

Mcclish Rd

Eagle Dr

Hozz Rd

B St

Jane Dr

Gumview Rd

L St

U St

Fontana Rd

Reiman Ln

P St

C St

Kidd Rd

Wilco

Pollard Way x Rd

Golf Course Dr

Starr View Dr

Richardson Rd

Nat alie Dr Day Rd

H St

Kabutts Rd

Cooper Way

Brooks Rd

Foothill Dr

Boehm Rd

S St

Buckingham Dr

Kloe r Rd

Rizzo Rd

Ballard Rd

3Rd St

Frost Rd

Lakew ood Dr

Jones Rd

O ak Way

Willow

St

Rio Ruso Dr

Colleen Dr

Wellington Cir

Bond Pl

Gemini Dr

Wild Oak Dr

Fulton Pl

Old Vine Ln

Plant Rd

Bark St

Russian River Gravel Company Rd

Honsa Rd

Armando Rd

Bell St

Mari e lene Ln

Airport Blvd

Ramp 

Prune Acres Rd

Pine St

Woody Creek Ln

Wilderhold Rd

Pulteney Pl

Amber Ridge Way

Alexis St

Petersen Rd

Knecht Rd

Lord Dr

Ward Rd

Starburst Ct

Old Oak Rd

Foxwood Dr

Bluebird Dr

Gertrude Dr

Mcclish Rd

Rizzo Rd

Brooks Rd

A St

Figure 3-9

Farmland Mapping & Monitoring Program (FMMP) Designations

SOURCE: State of California FMMP, 2006; Sonoma County GIS Data, 

2/9/2007; AES, 2011

LEGEND

Property Boundary

Water Bodies

Prime Farmland

Farmland of Statewide Importance

Unique Farmland

Irrigated Farmland

Nonirrigated Farmland

Farmland of Local Importance

Farmland of Local Potential

Grazing Land

Other Land

Urban and Built-Up Land

Water Area

0 1,500 3,000 Out of Survey Area

Feet

!¢NO

ÐR TH

Lytton Residential Development Final EA / 207513
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in unincorporated County lands. The stated purpose and intent of the Right to Farm Ordinance is 

to reduce impacts to County agricultural resources “by limiting the circumstances under which 

properly conducted agricultural operations on agricultural land may be considered a nuisance.” 

The ordinance promotes a good-neighbor policy by requiring that users of property adjacent to or 

near agricultural operations be notified of the inherent potential problems associated with being 

located near such operations, including noise, odors, dust, operation of machinery, application of 

fertilizers, soil amendments, seeds and pesticides and other potential effects. Through annual 

notification through a notice included with their annual tax bill, it is intended that property 

owners will better understand the potential consequences of being located near agricultural 

operations. The ordinance states that attendant conditions from properly conducted agricultural 

operations shall not be considered a nuisance to adjacent property owners and shall be accepted 

as being a normal and necessary aspect of being located in a rural area (Sonoma County, 1999). 

According to the 2007 Sonoma County Crop Report the value of agricultural production for the 

County was approximately $635,055,700. The majority of that value, $416, 549, 600, was from 

the cultivation of wine grapes. Wine grape cultivation covers approximately 60,000 acres of 

Sonoma County. Other crops include livestock and poultry, nursery plants, vegetables, apples, 

and oat hay. 

3.9 PUBLIC SERVICES 

3.9.1 WATER SUPPLY

APN 066-300-028 has an existing connection to the local municipal water provider for the area, 

the Windsor Water District (WWD). The WWD primarily collects and distributes water from a 

collection of groundwater wells located near the Russian River; one of these wells is located to 

the northwest of the project site across Eastside Road. Water is supplied to the Town of Windsor 

through two large transmission mains, one of which parallels the northern boundary of the project 

site, along Windsor River Road. The other four ten residences located on the project site, as well 

as neighboring residences and vineyards, currently utilize potable water from groundwater wells 

in the area. The two existing residences on APN 066-050-040 utilize a well with a septic and 

spray field system; approximately six other wells on different parcels provide water to existing 

residences within the 124.12-acre site. The principal aquifer in the region and vicinity of the 

project site is the Glen Ellen Formation. As discussed in Section 3.2.2 the groundwater yields in 

the Glen Ellen Formation are highly variable, as the hydraulic properties vary over small 

distances and the permeability is generally low. 

Due to an approved voter initiative in 1998, which was later incorporated into the Town of 

Windsor General Plan, areas outside of the Town Boundary are not to be served with water 

supply or sewer services by the municipality. 
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3.9.2 WASTEWATER SERVICE

The Windsor Wastewater Treatment, Reclamation, and Disposal Facility (WWTRDF), located at 

8400 Windsor Road, includes biological secondary treatment and advanced wastewater treatment 

(AWT). The WWTRDF is capable of treating 2.25 million gallons per day (mgd), average dry 

weather flow and 7.2 mgd, peak weekly wet weather flow. Treated and UV (ultra violet) 

disinfected effluent is reclaimed on Town-owned and private landscapes. Advanced treated 

effluent that is not reclaimed is discharged to Mark West Creek during the allowed discharge 

period (NCWQCB, 2007c). The point of discharge is shown on Figure 5 4 of Appendix LE. 

The project site is not currently developed for a direct connection to the municipal wastewater 

service system in the area. The existing, onsite residences are currently served by septic systems, 

as are other nearby residences. The WWTRDF is responsible for the proper treatment, storage, 

and disposal of wastewater in the Town of Windsor. As with the municipal water supply system, 

wastewater services for residences outside Town of Windsor City Limits are not provided by the 

municipality. 

3.9.3 SOLID WASTE

Management of non-hazardous solid waste in Sonoma County is mandated by Assembly Bill 

(AB) 939, the California Integrated Waste Management Act. The purpose of AB 939 is to 

reduce, recycle, and reuse solid waste generated in the State to the maximum extent feasible; 

improve regulation of existing solid waste landfills; ensure that new solid waste landfills are 

environmentally sound; streamline permitting procedures for solid waste management facilities; 

and specify the responsibilities of local governments to develop and implement integrated waste 

management programs. 

AB 939 set forth policies and mandated requirements for the State and local governments. 

Among them is a hierarchy of preferred waste management practices. The highest priority is to 

reduce the amount of waste generated at its source (source reduction). Second in the hierarchy is 

to reuse, by extending the life of existing products and recycling those wastes that can be reused 

as components or feed stock for the manufacture of new products, and by composting organic 

materials. Source reduction, reuse, recycling and composting are jointly referred to as waste 

diversion methods because they divert waste from disposal. Third and lowest in the hierarchy is 

disposal by environmentally safe transformation in a landfill. AB 939 and California Public 

Resources Code 41780 enforce this prioritization by requiring that all local jurisdictions, cities, 

and counties divert 50 percent of the total waste stream from landfill disposal by the year 2000 

and each year thereafter (using 1990 as the base year). Each local jurisdiction must demonstrate 

compliance by instituting source reduction programs. The County’s waste diversion rate for 2006 

was 64 percent. Waste that is not diverted for recycling is currently hauled out of the county to 

one of four private landfills (Sonoma County, 2008). 
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The project site is located in an area served by Windsor Refuse and Recycling, subsidiary to 

North Bay Corporation, which is a private contractor serving Sonoma County with solid waste 

services. Residents are provided with three roll out bins for garbage, organic wastes, and 

recyclables. Recyclables include glass, paper, plastic, and cardboards with a CRV 1-7 rating. 

3.9.4 ELECTRICITY, NATURAL GAS, AND TELECOMMUNICATIONS

Pacific Gas & Electric (PG&E) provides electrical and natural gas services to the Town of 

Windsor. Some rural areas do not have access to natural gas service due to lack of infrastructure. 

The majority of existing homes on the project site use individual propane tanks for a gas source. 

Propane providers in the area include Ferrell Gas and Americas Propane Inc. Natural gas for the 

private residence on APN 066-191-020 is provided by PG&E. AT&T provides the 

telecommunication services to the project area through transmission lines running parallel to 

Windsor River Road, north of the project site. AT&T also has internet, wireless phone, and long 

distance phone services. A variety of providers offer cellular and cable service in the County. 

3.9.5 LAW ENFORCEMENT

California is a Public Law 280 state that allows for state criminal law enforcement jurisdiction on 

Tribal trust lands; however, this jurisdiction does not include regulatory civil law authority. 

Depending on the crime (pursuant to Public Law 280 and the Major Crimes Act), the U.S. 

Marshals may provide support in specified situations. Law enforcement services for the 

unincorporated portions of the County are provided by the Sonoma County Sheriff’s Department 

Office (Office) headquartered in Santa Rosa. The Department Office is also under contract to 

provide law enforcement services to the Town of Windsor and the City of Sonoma. The Windsor 

Police Department (WPD) and Sonoma Police Department (SPD) are staffed by Sheriff’s 

Department Office employees and receive the same services as the unincorporated portions of the 

County. These services include but are not limited to: a helicopter unit, canine (K9) unit, crime 

scene investigation team, narcotics unit, special operations unit, bomb unit, and coroner unit 

(Sonoma County Sheriff’s Office [SCSDSCSO], 2009). 

In the 2007-2008 fiscal year, the Department Office had 1.17 sworn officers per 1,000 civilians 

and received approximately 18,114 incident calls for the Town of Windsor (SCSDSCSO, 2009). 

The Windsor Police Department is the closest Sheriff’s Office’s station and is located 

approximately 0.96 miles northeast of the project site. 

3.9.6 FIRE PROTECTION AND EMERGENCY MEDICAL

The Windsor Fire Protection District (WFPD) provides fire suppression and emergency medical 

services to the Town of Windsor and some surrounding unincorporated areas, which include the 

project site. As a fire protection district, WFPD is governed by an elected five-person Board of 
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Directors and is funded through taxes and donations. The WFPD has 10 paid employees and 31 

volunteers to serve 30,000 people in 30 square miles (5 square miles of Town of Windsor; 25 

square miles surrounding unincorporated area). WFPD staffs two fire stations: Station 1, located 

at 8200 Old Redwood Highway, and a new Station 2, which recently completed construction to 

replace the older station located at 444 Windsor River Road. Station 1 is open 24 hours a day 7 

days a week and is staffed with two fire captains, two fire engineers, and at least one fire fighter. 

Station 2 is staffed with volunteers from 10 a.m. – 6 p.m. dailya captain and engineer (WFPD, 

2011). Due to the population increase over the last decade, the WFPD is currently constructing 

aThe new Station 2 at 8600 Windsor Road completed construction in September 2009 (WFPD, 

20082011). The new existing Station 2 is the closest station, located approximately 1 1.3 miles

from the project site. However, when Station 2 is closed, Station 1, located approximately 2.5 

miles southeast, would serve the site. Response time to the project site ranges between 5-12 

minutes (WFPD, 2004).

The California Department of Forestry and Fire Protection (CAL FIRE) aids local fire 

departments in wildfire situations. It maintains the most resources in the fire season from late 

May to early October. CAL FIRE has a responsibility to provide wildland fire services to the 

project site, as is located in a State Responsibility Area that has a moderate wildfire threat (Fire 

and Resource Assessment Program [FRAP], 2007). The nearest CAL FIRE station is located at 

1745 Redwood Drive in Healdsburg, approximately 5.5 miles north of the project site. This 

station is open seasonally during fire season. The closest year round station is located at 1001

South Cloverdale Boulevard, approximately 22 miles north in Cloverdale. The Sonoma Air 

Attack Base (SAAB), located at the Sonoma County Airport, is one of 13 CAL FIRE Air Attack 

Bases statewide. The SAAB responds to an average of 300 calls per year both in and out of its 

immediate response area, which covers 4,000 square miles (CAL FIRE, 2005). 

According to the Coastal Valley Emergency Medical Services (EMS) Agency (2008), Redwood 

Empire Dispatch Communications Authority (REDCOM) is a joint powers authority (JPA), 

which operates the Sonoma County EMS Dispatch Center. REDCOM provides Emergency 

Medical Dispatch and pre-arrival instructions to the County’s Public Safety Answering Points. 

Ambulance services or emergency medical services are dispatched through 911 and are provided 

by several companies, including nine ground ambulance providers and two helicopter providers. 

The response time for the project site depends on which provider is available and where they are 

located. The nearest hospital emergency room is Healdsburg District Hospital, located at 1375 

University St in Healdsburg, California. 

3.9.7 PUBLIC SCHOOLS

The project site is located within the Windsor Unified School District (WUSD). Sonoma County 

is divided into 40 school districts for kindergarten through twelfth-grade (K-12) educational 

services, including: 31 elementary, three high school, and six unified districts (Office of 
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Education, 2010). Sonoma State University, part of the California State University system, and 

Santa Rosa Junior College are located in Sonoma County and offer higher education 

opportunities. Unified school districts operate both elementary and secondary schools for the 

students residing within their boundaries. The Lytton property lies within the boundary of the 

Windsor Unified School District (WUSD). Schools within approximately one mile of the site 

that are part of the WUSD are Cali Calmecac Charter School, Windsor High School, Windsor 

Oaks Academy, and Windsor Creek Elementary. Table 3-15 16 shows the location, grade range, 

and 2007-2008 enrollment for each of the schools. 

TABLE 3-1516

PUBLIC SCHOOLS 

School Location Grade Range 2007-2008 Enrollment 

Cali Calmecac 9491 Starr Rd. K-8 980 

Windsor High School 8695 Windsor Rd. 9-12 1,608 

Windsor Oaks Academy 8681 Windsor Rd. 10-12 82 

Windsor Creek 

Elementary 8955 Conde Lane 2-3 521 

Source: WUSD, 2007 

WUSD covers an area of approximately 31 square miles and serves students from the Town of 

Windsor, a portion of Healdsburg, and unincorporated areas of Sonoma County along the 

Highway 101 corridor north of Santa Rosa (Piper Jaffray, 2010). WUSD operates five 

elementary schools, one middle school, two high schools, and one continuation school (Ed-Data, 

2010). For the 2008/2009 school year, WUSD had a K-12 enrollment of approximately 5,301 

students and employed approximately 256.2 full-time equivalent teachers (Ed-Data, 2010). 

Enrollment in the WUSD has increased by 30 percent over the past decade from 4,250 students in 

2000/2001 to 5,515 students in 2008/2009. The average class size in the WUSD has decreased 

over the past decade from 25.1 in 2000/2001 to 21.5 in 2008/2009, a 3.6 percent decrease. The 

student to teacher ratio for the 2008/2009 school year, 21.5:1, was slightly greater than that of 

California (20.9:1) (Ed-Data, 2010). Approximately 31.0 percent of the enrolled students receive 

free or reduced meals. Developer fees within Windsor contribute to funding for permanent 

classroom facilities. Other financial burdens of WUSD due to growth are met primarily through 

property taxes and tax increment funds from the Redevelopment Agency (Town of Windsor, 

2010). 

Other schools in the vicinity, not associated with the WUSD, include the Windsor Cooperative 

Nursery, Grace Academy, and Santa Rosa Junior College Public Safety Training Center. 

According to the Windsor General Plan (Town of Windsor, 2005), a future 40-acre high school 

will be designed within Windsor by 2015. 
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3.9.8 PARKS AND RECREATION

The Austin Creek State Recreation Area (SRA) and the Armstrong Red Woods State Natural 

Reserve (SNR) are located approximately 10 miles west of the project site. The SRA offers 

campsites specific to bikers and hikers, campers, and families. The 5,583-acre SRA also boasts 

numerous trails for hiking and horseback riding that scale the park’s rugged topography, with 

elevations ranging from 150-1500 feet (California State Parks [CSP], 2008a). The SNR borders 

the SRA to the south and is accessible thought the same entrance. The 805-acre park does not 

have campsites, but it does have trails for hikers, horseback riders, and nature lovers throughout 

the redwood grove. There is a visiting center with information on the exhibits and programs 

available in the SNR (CSP, 2008b). The Windsor Golf Club is located approximately 1.5 miles 

southeast of the project site. 

3.10 NOISE 

3.10.1 NOISE EXPOSURE AND COMMUNITY NOISE

Noise is generally defined as unwanted sound. Sound, traveling in the form of waves from a 

source, exerts a sound pressure level (referred to as sound level) which is measured in decibels 

(dB), with zero dB corresponding roughly to the threshold of human hearing and 120 to 140 dB 

corresponding to the threshold of pain. 

Environmental noise is typically measured in A-weighted decibels (dBA). A dBA is a dB 

corrected for the variation in frequency response of the typical human ear at commonly 

encountered noise levels. In general, A-weighting of environmental sound consists of evaluating 

all of the frequencies of a sound, taking into account the fact that human hearing is less sensitive 

at low frequencies and extremely high frequencies than in the frequency mid-range. 

An individual’s noise exposure is a measure of noise over a period of time. A noise level is a 

measure of noise at a given instant in time. However, community noise varies continuously over 

a period of time with respect to the contributing sound sources in the community noise 

environment. What makes community noise constantly variable throughout a day is the addition 

of short duration single event noise sources such as aircraft flyovers, vehicle pass-bys, sirens, etc., 

which are readily identifiable to the individual. These successive additions of sound to the 

community noise environment varies the community noise level from instant to instant, requiring 

the measurement of noise exposure over a period of time to legitimately characterize a 

community noise environment and evaluate cumulative noise impacts. This time-varying 

characteristic of environmental noise is described using statistical noise descriptors such as Leq, 

Ldn, and Community Noise Equivalent Level (CNEL), which averages noise over a specified 

number of hours. 
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Part of community noise level is construction noise. Construction noise is dominated by heavy 

equipment and is discussed further in Section 4.11. In general, noise emitted from construction 

projects is intermittent and short-term in nature and will generally occur during the daytime 

hours. 

Generally, the noise environment in a community is dominated by traffic noise. Typically it takes 

an additional 200 vehicles per hour to increase the ambient noise levels in an area (Traffic Noise 

Calculator, 2007). 

3.10.2 REGULATORY SETTING

The Department of Housing and Urban Development and the Federal Highway Administration 

(FHWA), Federal agencies, consider outdoor day-night noise exposure up to 65 dBA, Ldn as 

acceptable under most circumstances. The FHWA considers 75 dBA as acceptable during 

construction, if construction is conducted between the hours of 7 am and 6 pm (FHWA, 2006). 

Sonoma County General Plan 

The Sonoma County general General plan Plan policies are listed for the purpose of analyzing 

off-reservation impact from traffic noise. Policies contained within the Sonoma County General 

Plan, 1989 (General PlanSonoma County, 2008) provide standards for ambient noise levels. The 

following Goal and Objectives are applicable: 

Noise level performance standards in Table NE-2 (shown as Table 3-1617) below are to be 

applied as performance standards for noise producing land uses which may affect noise sensitive 

land uses and vice versa. Infrequent single events such as passage of a train, truck, or airplane 

may interfere with adjacent uses even though the cumulative noise exposure is within acceptable 

limits. These events call for a single event noise standard. The potential for sleep disturbance is 

often the main concern in these cases. 

Goal 

NE-1.1: Protect people from the harmful effects of exposure to excessive noise and to achieve an 

environment in which people and land uses may function without impairment from noise.

Objective 

NE-2.1: Protect the present noise environment and prevent intrusion of new noise sources which 

would substantially alter the noise environment. 
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TABLE 3-16 17 

NOISE LEVEL PERFORMANCE STANDARDS 

Maximum Exterior Noise Level Standards, dBA

Category Cumulative Duration of Noise 

Event in any one-hour period 

Daytime 7 a.m.

to 10 p.m. 

Nighttime10 p.m.

to 7 a.m. 

1 30-60 Minutes 50 45 

2 15-30 " 55 50 

3 5-15 " 60 55 

4 1-5 " 65 60 

5 0-1 " 70 65 

Source: Sonoma County, 2008 

The following policies shall be used to achieve the above objective: 

NE-2a: Designate areas within Sonoma County as noise impacted if they are exposed to existing 

or projected exterior noise levels exceeding 60 dB Ldn, 60 dB CNEL, or the performance 

standards of Table NE-2 (Shown as Table 3-16). 

NE-2b: Avoid noise sensitive land use development in noise impacted areas unless effective 

measures are included to reduce noise levels. For noise due to traffic on public roadways, 

railroads and airports, reduce exterior noise to 60 dB Ldn or less in outdoor activity areas and 

interior noise levels to 45 dB Ldn or less with windows and doors closed. Where it is not 

possible to meet this 60 dB Ldn standard using a practical application of the best available noise 

reduction technology, a maximum level of up to 65 dB Ldn may be allowed but interior noise 

level shall be maintained so as not to exceed 45 dB Ldn. 

3.10.3 SENSITIVE RECEPTORS

Some land uses are considered more sensitive to noise than others due to the amount of noise 

exposure (in terms of both exposure duration and insulation from noise) and the types of activities 

typically involved. Residences, motels and hotels, schools, libraries, churches, hospitals, nursing 

homes, auditoriums, and parks and other outdoor recreation areas generally are more sensitive to 

noise than are commercial and industrial land uses. A sensitive receptor is defined as any living 

entity or aggregate of entities whose comfort, health, or well-being could be impaired or 

endangered by the existence of the criteria pollutant, whether it is emissions or noise, in the 

atmosphere. 

Sensitive receptors in the vicinity of the project site primarily include primarily nearby 

residences. The closest of these are located approximately 100 50 feet north of APN 066-191-

016east of APN 066-191-022 and approximately 100 feet east of APN 066-191-020. Another 

nearby residence is located approximately 150 feet north of APN 066-300-031, on the north side 

of Windsor River Road. Approximately eight 15 residences are located on large individual 

parcels within 0.25 miles of the proposed project. The closest of these are located approximately 
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50 feet north of APN 066-191-016 and approximately 100 feet west of APN 066-191-019. Other 

nearby residences are located approximately 50 feet north of APN 066-300-017 south of Windsor 

River Road and 150 feet north of APN 066-300-031, on the north side of Windsor River Road. A 

high-density residential development is located directly north of APN 066-191-022 and east of 

APN 066-050-047; approximately 10 35 houses in this development are located along Windsor 

River Road in the vicinity of the Proposed Project’s northeast corner. The nearest schools are the 

Windsor Cooperative Nursery and the Cali Calmecac Charter School, both of which are located 

approximately 0.50 miles from the project site. 

3.10.4 EXISTING NOISE SOURCES

The noise environment surrounding the project site is influenced primarily by vehicle noise 

traveling on Windsor River Road. The surrounding area is mainly populated with single-family 

residences. Therefore, the area is characterized as rural suburban and is assumed to have a typical 

ambient noise level of 55 dBA during the day and 45 dBA or less at night. 

3.11 HAZARDOUS MATERIALS 

Two A total of seven Phase I Environmental Site Assessments (ESA) and three supplemental 

Phase I ESAs were conducted for the 92124.12-acre project site (fourteen parcels) to determine if 

any Recognized Environmental Conditions (RECs) exist (Appendix J). RECs refer to the 

presence or likely presence of conditions on a property that indicate an existing release, a past 

release, or a material threat of release of any hazardous substances or petroleum products on the 

property or into the ground, groundwater, or surface water of the property. This includes 

hazardous substances and petroleum products. All Phase I ESAs were prepared in accordance 

with the BIA Guidelines (602 DM Chapter 2) and the American Society for Testing and Materials 

(ASTM) Standard Practice E 1527-05. The ESAs included site reconnaissance, review of federal 

and state regulatory agency records and databases, interviews with local officials and property 

owners and review of historical aerial photographs of the 92124.12-acre project site. Following is 

a summary of the site reconnaissance for each parcel. 

APN 066-191-017 includes one single-story house, one mobile home and a detached barn. The 

remaining land consists of pasture and open space. The house is supplied with water by an onsite domestic well and is equipped with a septic system. A 500-gallon propane tank, two tires, 

water trough, and a pile of non-hazardous debris were observed on the parcel (AES, 2009d2009b;

Appendix J). 

APN 066-191-018 includes one pole mounted transformer (AES, 2009d2009b; Appendix J). 

APN 066-191-020 includes one single-story 1,800 square foot house. The remaining land 

consists of pasture and open space. The house is supplied with water by an on-site domestic well. 
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The house is equipped with a septic system located in the driveway with visible inspection 

covers. Two 55-gallon drums of bio diesel (non-petroleum) and other non-hazardous debris were 

observed. Although the two 55-gallon drums were not in secondary containment, no leaks or 

visible stains were observed (AES, 2009e2009c; Appendix J). 

APN 066-191-022 includes four chicken coops which are used for storage, while an additional 

coop is overgrown with berry bushes. The remaining land consists of pasture and open space 

(AES, 2009d2009b; Appendix J). 

APN 066-300-028 includes two two-story houses and one storage shed. The remaining land 

consists of undeveloped oak woodland. The houses are supplied with water by the Town of 

Windsor. Each house has a 325-gallon propane tank and septic system (AES, 2008a; Appendix 

J). 

APN 066-300-031 includes a two-story house and a shop/carport. The remaining land consists of 

undeveloped oak woodland. The house is supplied with water by an on-site domestic well. The 

house is equipped with a septic system. Containers of anti-freeze, motor oil, brake fluid, and 

gasoline were observed in the shop/carport area. None of the chemicals were in bulk quantity and 

all were stored within approved commercial containers. No unusual chemical odors or surface 

staining were observed on any portion of the parcel (AES, 2007a; Appendix J). 

APN 066-300-033 consists primarily of undeveloped oak woodland. Non-hazardous debris was 

observed, including appliances, an automobile, two camper shells, an empty 55-gallon drum and 

several piles of wood debris (AES, 2007b; Appendix J). 

APN 066-191-019 consists of partially developed land and pasture. A residential structure with 

associated storage facilities, workshop, chicken coop, bee keeping facilities, landscaping, and 

garden are located in the northern half of the parcel. The southern half of the property consists of 

a horse barn, with a second story apartment, as well as horse pasture. Several transformers 

attached to power poles are located adjacent to the parcel. Storage facilities contained various 

chemicals and pesticides stored in approved commercial containers with no sign of surface 

staining or odor inside or outside the facilities (AES 2009e; Appendix J). 

APN 066-191-021 consists of mostly developed land. The northern third of the parcel is planted 

in walnut orchard, while the remainder of the parcel consists of a residential unit, two-story aged 

storage structure, two-car garage and single-story storage units. A water well is located behind 

the residential storage shed, which houses a pressurized water tank and water softener. Several 

bags of unopened salt pellets were observed within the shed. No sign of surface staining or odor 

was observed within outside the shed. Four piles of non-hazardous debris were observed on the 

parcel, and a few spent fire extinguishers and four open cans of latex paint were observed in one 
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of the piles. These cans of paint are considered de minimus conditions, and therefore do not 

constitute a REC (AES, 2009d; Appendix J).

APN 066-300-023 consists primarily of pasture and small vineyard, a private residence and a 

storage shed. The storage shed contained various chemicals including pesticides, paint, gasoline, 

and landscape/gardening materials which were all stored in approved commercial containers. No 

surface staining or leaks were observed outside the shed (AES, 2010g; Appendix J).

APN 066-300-017 consists primarily of a private residence, a domestic well and associated water 

treatment structures, a single story barn and a two-car garage. The barn contained a tractor, 

various tools for winemaking, and a wine cellar with barrels of wine. One electric transformer 

was observed, and several others were observed attached to power poles outside this parcel (AES, 

2010g; Appendix J).

APN 066-191-016 consists primarily of undeveloped pasture, as well as a two-story private 

residence, three-car carport, barn, and associated storage structures. A water well was observed 

in the service area behind the southern portion of the residence. Individual containers of various 

pesticide, plant nutrients and paint were observed in the storage structures. All chemicals were 

stored within approved commercial containers and no surface staining or odor was observed 

inside or outside the structures. Various lawn and gardening equipment was stored in the barn. 

An electric service line from a transformer across the Windsor River Road connected to a power 

pole near the storage shed and a pole near the residence (AES, 2010h; Appendix J).

APN 066-050-040 consists of mostly undeveloped land, with two single-story residences, a threecar carport, old barn, and associated storage structures. A water well was observed between the 

residence and Windsor River Road. Both residences are linked to a septic tank and leachfield 

system, located north of the two residences. Several paint cans and containers of chemicals were 

observed within the storage structures, with the majority stored with approved commercial lids. 

No sign of surface staining or odors near this structure was observed. Multiple empty 55-gallon 

drums were found along the parcel, with no sign of surface staining in the vicinity of these barrels

(AES, 2010i; Appendix J). 

APN 066-050-047 consists of undeveloped pasture with some oak trees. An electric power line 

extends from a transformer along Windsor River Road to the residences on the adjacent parcel

(AES, 2010i; Appendix J). 

Database searches were conducted for records of known storage tank sites and known sites of 

hazardous materials generation, storage, or contamination. Databases were searched for sites and 

listings up to 1.5 miles from a point roughly equivalent to the center of the 92124.12-acre 

property. Environmental Data Resources, Inc (EDR) indicated a total of two sites within a 0.5-
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mile radius of all parcels. The first site is the Windsor Prisoner of War Camp (POW) located 

approximately 0.40 miles north of the project site. No address is given for the former POW site. 

Historically, the site was used by the U.S. Department of AgricultureUSDA as a camp for 

migrant farm workers and later as a POW labor camp during World War II. There are no records 

of hazardous material being released on the site. No potential hazards related to Department of 

Defense activity have been located at this site. Based on the current regulatory status and lack of 

violations reported, this site is not considered to represent a likely past, present, or material threat 

of release on the property (AES, 2009d2009b). The second site is the Eff Waugh site which is 

located approximately 0.44 miles southwest of the project site at 9228 Eastside Road, 

Healdsburg, California. The site is listed on the Leaking Underground Storage Tank (LUST) and 

the California State Hazardous Wastes and Substances Sites (Cortese) databases for the release of 

gasoline into the groundwater. Preliminary site assessments are underway and affected soils were 

being excavated and removed to an approved site during the time the Phase I site assessments 

were being conducted (AES, 2007a). 

Based on the site reconnaissance of the parcels, review of federal and state regulatory agency 

records and databases, interviews with local officials and property owners and review of 

historical aerial photographs, the Phase I ESAs did not identify any Recognized Environmental 

ConditionsRECs on the parcels. 

3.12 VISUAL RESOURCES 

The visual characteristics of the project site and surrounding areas are similar to the rest of the 

Town of Windsor and typical of rural Sonoma County. The Sonoma County General Plan 

designates the project site as Resources and Rural Development, which allows low-density 

development as well as resource management and enhancement activities, including but not 

limited to the management of timber, geothermal and aggregate resources, fish and wildlife 

habitat, and watershed. APNs 066-300-028 and 066-300-033 are located within the Eastside 

Road Scenic Landscape Unit, which require the uses and intensities of any land development to 

be consistent with preservation of important scenic features (Sonoma County, 2008). Specific 

objectives related to scenic resources in the Open Space and Resource Conservation Element of 

the Sonoma County General Plan (Sonoma County, 2008) call for the retention of the rural, 

scenic character of Scenic Landscape Units by permitting very low density uses, minimizing cuts 

and fills of ridges and hills, and protecting ridges and crests of prominent hills from the 

silhouetting of structures against the sky. 

The project site is sparsely developed with six twelve single-family houses, three barns, and four 

chicken coops located throughout the property. The site is primarily comprised of gently sloping 

to hilly mixed oak woodland habitat, with mature trees found throughout the 92 124.12 acres. 

Highway 101 is located approximately two miles to the east and is not visible from the project 
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site. Main access is provided by Windsor River Road, which is a two-lane rural collector road 

with a speed limit of 45 mph and paved shoulders. Regular street lamps are not provided along 

Windsor River Road or Eastside Road, and most local residences use limited outdoor lighting. 

Photographs of the surrounding visual setting and some of the nearest sensitive visual receptors 

are provided in Figure 3-910. 

Visual resources surrounding the project site include views of Windsor River Road (Photo 1, 

Figure 3-910), Eastside Road, commercial vineyards, and mostly low-density rural residential 

development. Surrounding areas have limited views of the project site due to screening from 

hilly terrain and extensive vegetation around and within the project site. 

Sensitive visual receptors are limited to nearby residences. The closest of these are located 

approximately 50 feet north of APN 066-191-016, 100 feet west of APN 066-191-019, and 100 

feet east of APN 066-191-022 (Photo 2, Figure 3-910) and, approximately 100 feet east of APN 

066-191-020 (Photo 3, Figure 3-910). Another nearby residence is located approximately 50 feet 

north of APN 066-300-017 south of Windsor River Road and 150 feet north of APN 066-300-

031, on the north side of Windsor River Road (Photo 4, Figure 3-910). Approximately eight 

fifteen residences are located on large (>1greater than one acre) individual parcels within 0.25 

miles of the proposed project. A high-density residential development is located directly north of 

APN 066-191-022; approximately 10 35 houses in this development are located along Windsor 

River Road in the vicinity of the Proposed Project’s northeast corner (bordering APNs 066-050-

047, 0666-191-021 and 066-191-022). However, this neighborhood has an eight-foot high fence 

bordering Windsor River Road that effectively screens views to and from the project site (Photo 

5, Figure 3-910). A single winery is located immediately south of APN 066-300-031, within 

extensive associated vineyards (Photo 6, Figure 3-910). 
Lytton Residential Development Final EA / 207513

Figure 3-10

Site Photographs

SOURCE: AES, 2011

PHOTO 5

View of a residential development located north of APN 066-191-022.

PHOTO 6

View of vineyards and winery located south of APN 066-300-031.

PHOTO 4

View of residence located north of APN 066-300-031.

PHOTO 3

View of residence located east of APN 066-191-020.

PHOTO 1

View of Windsor River Road facing west.

PHOTO 2

View of residence located east of APN 066-191-022.
SECTION 4.0 

ENVIRONMENTAL CONSEQUENCES
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SECTION 4.0 

ENVIRONMENTAL CONSEQUENCES 

In this section, environmental consequences are described for Alternative A (Proposed Project), 

Alternative B (Onsite Water and Wastewater with two options: summer treated wastewater 

reclamation and winter surface water discharge, or all-year on-site reclamation of wastewater), 

Alternative C (Reduced Intensity with Onsite Water and Wastewater), and Alternative D (NoAction). Areas that are analyzed include direct and indirect impacts to land resources, water 

resources, air quality, biological resources, cultural resources, socioeconomic conditions and 

environmental justice, transportation and circulation, land use, public services, noise, hazardous 

materials, and visual resources. The Council on Environmental Quality (CEQ) regulations state 

that direct impacts are those that are caused by the action and occur at the same time and place, 

while indirect impacts are caused by the action and occur later in time or further in distance, but 

are still reasonably foreseeable (CEQ 1508.8). Cumulative and growth-inducing effects of the 

Proposed Action are also assessed for each of these issue areas. Note that, consistent with the 

CEQ’s NEPA Regulations Section 1508.8, the term “effects” is used synonymously with the term 

“impacts.” 

4.1 ALTERNATIVE A - PROPOSED PROJECT 

4.1.1 LAND RESOURCES

Topography 

The housing community was designed to avoid constructing on slopes greater than 20 percent. 

This design will reduce the amount of grading and other earthwork necessary for the construction 

of the project features (i.e., housing, community center, etc.). Architectural designs 

accommodate the topography in order to preserve the natural aesthetics of the project site. This 

alternative would require approximately 7,050 cubic yards (cy) of cut material, and 7,200 cy of 

fill material for result in approximately 1,800150 cy of excess soil that would either be used on 

site along roadways by strategic dispersion or disposed of in an approved off-site location (Adobe 

Associates, 2010; Appendix A). Alternative A would not result in significant impacts related to 

topography. 

Geologic Setting and Seismicity 

The projected earthquake magnitudes for the region indicate that the project site could potentially 

be exposed to future seismic shaking (RGH Consultants, 2008). Construction of Alternative A 
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would adhere to design standards equivalent to requirements in to the California Building Code 

(CBC), as described in Section 2.0. Use of the CBC design and construction standards for 

Seismic Zone 4 would allow ground shaking-related hazards to be managed from a geologic, 

geotechnical, and structural standpoint such that risks to the health or safety of workers or 

members of the public would be reduced to a less than significant level. 

 

Soils 

The soil types located on the site are characterized by steep slopes and moderately high 

permeability rates. All but one of the soil types has an erosion hazard rating of slight or 

moderate. Due to the woody vegetation, substantial groundcover and minimized grading in these 

areas, erosion hazards would be less than significant. Felta very gravelly loam (FaF) has an 

erosion hazard rating of severe (NRCS, 2008a). During construction the exposure of soil 

increases the risk of erosion. The ceremonial dance circle and existing building pad are the 

proposed developments in the location of this soil type. Nonetheless, pProtective measures are 

listed under Section 5.0. 

The soils found on the site appear hard and strong when dry but will lose strength rapidly and 

settle under the stresses of construction (RGH Consultants, 2008). The moisture content of the 

soils can increase as the result of rainfall, irrigation, or condensation of water vapor under fills, 

foundations, pavement, and slabs. Mitigation measures for reducing impacts related to these soil 

properties are listed under Section 5.0.

The soils on the project site are characterized as moderately to highly corrosive to steel (NRCS, 

2008a, 2010). The protective measure listed under Section 2.0 1.9 would be implemented if any 

steel is used in the construction of Alternative A. 

With the implementation of the protective measures listed in Section 2.0 1.9 and the mitigation 

measures listed in Section 5.01, impacts to land resources would be less than significant. No 

additional mitigation measures would be warranted. 

Mineral Resources 

As stated in Section 3.1.5, there are no known mineral resources within the project area. 

Although areas along the Russian River are known to contain extensive mineral resources, the 

project site is located outside the valley in a region where significant mineral resources are not 

likely to occur. Construction of the Proposed Project would not result in the loss of mineral 

resources. No mitigation is warranted. 
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4.1.2 WATER RESOURCES

Surface Water, Drainage, and Flooding 

Alternative A (Figure 2-1) has been designed to avoid the majority of wetlands, drainages and 

water resources located on the site. A Two small, man-made isolated pits, an isolated seasonal 

wetland and an isolated seasonal wetland swale cwould be filled or otherwise impacted; however, 

this pitthese features is are not considered a jurisdictional features to the U.S. Army Corps of 

Engineers (USACE) pursuant to the Clean Water Act (CWA) and filling it in them would not 

result in a significant impact (Section 3.4.4; AES, 2010d). As mentioned in Section 2.03.4.4, the 

isolated pits within the project site are man-made holes that may have functioned as watering 

holes for cattle, test percolation pits, or potential sites for trash disposal. Further discussion of the 

surface waters found on the site is included in the Biological Assessment (BA) included

inprovided as Appendix E. 

Alternative A would increase impervious surfaces on the site through the construction of roads, 

houses, community buildings, and sidewalks. It is estimated that the construction of the project 

would increase impervious areas by approximately 18.636.26 acres. Increased impervious 

surfaces would result in increased peak flows and increased total discharge from the project site 

during wet weather events, which if not properly dealt with, could add increased stormwater flow 

to the area’s drainage systems and result in localized flooding. To reduce this impact, preparation 

of a drainage plan, including vegetated swales and the use of permeable surfaces, has been 

incorporated into the project design, as discussed in Section 2.01.9. The use of permeable 

surfaces in the project design would further minimize runoff and ensure that no significant 

impacts occur. 

All buildings, roadways, and other proposed amenities would be constructed outside the Federal 

Emergency Management Agency (FEMA)-designated 100-year flood zone. No significant 

impacts related to flooding would occur. 

Water Supply and Groundwater 

Under Alternative A, water would be supplied through a pipeline extension to the municipal 

water system of the Town of Windsor, under an agreement to be negotiated between the parties. 

An 18-inch diameter water main runs along Windsor River Road, bordering the project site to the 

north. As described in Section 2.1.5, two connections equipped with meters and backflow 

prevention facilities, if required, would be constructed into the project from the existing 18-inch 

main. It is anticipated that the existing municipal system would be able to accommodate the 

water demands of the project. Water demands are summarized in Table 4-1 and discussed in 

further detail in the water and wastewater feasibility study provided in Appendix B. The 

projected average daily demand (ADD) of the Proposed Project is 82,300 gallons per day (gpd) or 

57 gallons per minute (gpm) (ECO:Logic, 2009a2010a) (Appendix B). 
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TABLE 4-1 

WATER DEMAND FOR THE PROPOSED PROJECT 

Description Average Day Demand (gpd) 

Single-family houses 59,850 

Cottages 9,600 

High-density units 11,200 

Community Center 1,200 

Retreat 400 

Roundhouse 0 

Total Water Demand 82,300

Source: ECO:Logic, 2009a2010a

The Department of Water Resources (DWR) monitors the levels of groundwater in the Santa 

Rosa Basin. Readings from a monitoring well located in the Town of Windsor, approximately 

one mile east of the project site, show a seasonal rising and falling of the groundwater table. 

However, the general trend from 1976 to 2002 (the most recent date of measurement) indicates a 

rising of the groundwater table (DWR, 2008). This can be inferred as an increase in the amount 

of water held in the groundwater basin. Another well, located approximately 0.66 miles east of 

the Russian River and one mile southwest of the project site, has been monitored by the DWR 

from 1989 to 2008. Readings from this well show an annual rise and fall of the groundwater 

level. However, the general trend for this well shows a constant groundwater level since 1992. 

These data indicate that, the closer a well is to the Russian River, the more likely it will be able to 

maintain a constant water supply. Due to the proximity to the Russian River and the positive 

trends in groundwater levels, it is anticipated that the additional water demand from the Proposed 

Project from the Windsor water system would cause a less than significant impact to the Santa 

Rosa Basin. 

Wastewater Treatment and Disposal 

Estimated wastewater flows and loads from the Proposed Project and alternatives are summarized 

in Table 4-2. The Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), and 

Total Kjeldahl Nitrogen (TKN) loads are estimated using typical literature values. The loads are 

also based on wastewater flow estimates with 100-year inflow and infiltration rates and the 

assumption that a Septic Tank Effluent Pumping (STEP) pressure sewer system would be 

utilized. The STEP system is comprised of a pretreatment tank and a small submersible pump 

with a control panel located on each house (ECO:Logic, 2009a2010a). 

TABLE 4-2 (REVISED)

SUMMARY OF INFLUENT FLOW AND LOAD PROJECTIONS 

Parameter Alternative A Alternative B Alternative C 

Flows (gallons per day) 80,000 80,000 31,300 

BOD (pounds per day) 127 127 50 

TSS (pounds per day) 140 140 55 

TKN (pounds per day) 27 27 10 

Source: ECO:Logic, 2010a
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The existing Windsor Wastewater Treatment, Reclamation, and Disposal Facility (WWTRDF) is 

located approximately three miles southeast of the project site. The processes used by the 

WWTRDF are described in Section 3.09.2. A sewage lift station and approximately 3,200 feet of 

force main would be constructed to pump the wastewater from the housing community to a 

manhole located near the intersection of Windsor River Road and Starr Road. Treated effluent 

from the WWTRDF is either reclaimed and used for irrigation on public and private landscapes 

or discharged into Mark West Creek, which eventually flows into the Russian River (Figure 4 of 

Appendix L). The potential impacts to the surface water and groundwater quality are discussed 

below. 

Surface Water Quality 

The effluent from the WWTRDF that is not used for irrigation is discharged into Mark West 

Creek. The WWTRDF must comply with the provisions described in Section 3.2.4. According 

the WWTRDF’s National Pollutant Discharge Elimination System (NPDES) Permit Renewal, the 

WWTRDF has an excellent compliance history, with only five minor effluent limitation 

violations over the five-year lifespan of its permit. The additional discharge that would result 

from Alternative A would be approximately three percent of the existing WWTRDF daily 

capacity. This would not result in significant impacts to Mark West Creek or the Russian River. 

Runoff from residential and community facility areas could transport debris, oil, sediments, and 

grease into adjoining surface waters, potentially affecting surface water quality. Increased runoff 

could create scouring and could impact riparian and aquatic habitats. The Tribe is required to 

adhere to the provisions of the Clean Water Act (CWA). To reduce the effects of increased 

surface runoff volume and associated pollutants, the Tribe will comply with the terms of the 

General Construction NPDES permit and ensure that Best Management Practices (BMPs), such 

as those listed in Section 2.0 1.9 and Section 5.02, are used to reduce the risk of soil erosion and 

polluted discharge. Construction activities could increase the potential for erosion to occur, 

which would increase silt loads of the Russian River. The recommended BMPs would 

significantly reduce erosion and minimize off-site sediment transport. The Tribe will prepare and 

implement a Stormwater Pollution Prevention Plan (SWPPP) that will include practices that 

reduce potential surface water contamination during storm events. As discussed in Section 5.02, 

BMPs would be implemented through the SWPPP to reduce potential construction-related 

adverse impacts to surface waters to a minimal level. 

Groundwater Quality 

The treated effluent from the WWTRDF that is used for irrigation receives biological secondary 

treatment and ultraviolet (UV) disinfection. This has been deemed acceptable in the WWTRDF’s 

NPDES permit. The additional discharge resulting from Alternative A would be approximately 

three percent of the existing WWTRDF daily capacity. This would not result in significant 
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impacts to groundwater quality, because it is believed that the WWTRDF has sufficient treatment 

and disposal capacity to serve the Proposed Project (ECO:Logic, 20092010a). 

4.1.3 AIR QUALITY

Significance Criteria 

A significant impact would occur if the project construction or operational emissions of the ozone 

precursors nitrogen oxide (NOx) or reactive organic gases (ROG) were to exceed de minimis

levels as provided in Federal Conformity Regulations found at 40 CFR 93. Conformity de 

minimis levels for NOx and ROG are 100 tons per year (tpy). All other federal criteria air 

pollutants (CAPs) have attainment status in the San Francisco Bay Area Air Basin (SFBAAB). 

Under the Federal Conformity Regulations, project emissions of these CAPs would have a lessthan-significant impact on regional air quality, as demonstrated below. 

Methodology 

Construction and operational emissions for Alternative A were estimated using URBEMIS 9.2.4, 

which is the latest air quality model approved by the California Air Resource Board (CARB) and 

the United States Environmental Protection Agency (USEPA). Construction and operational 

emissions were then compared to de minimis levels. A construction period of three four years 

was assumed, with construction expected to begin in 2010 2012. URBEMIS operational defaults 

were used. Trip generation rates used by the URBEMIS modeling program to determine air 

quality impacts were derived from the Institute of Transportation Engineers’ (ITE) Trip 

Generation Manual (ITE, 20072008). The Trip generation rates used in the air quality analysis 

are consistent with the Traffic Impact Analysis (Abrams Associates, 20092010) (Appendix G). 

Anticipated Air Quality Impacts 

Construction Impacts 

Construction of the Proposed Project would generate emissions of the six federal CAPs described 

in Section 3.3.4. Alternative A construction emissions were modeled using URBEMIS with the 

results presented in Table 4-3; URBEMIS output files are provided in Appendix D. The 

URBEMIS default construction equipment inventory was used, which is based on typical 

residential development construction. Construction assumptions include a maximum disturbance 

of 2.4 acres per day for site grading. Other construction assumptions include the implementation 

of construction BMPs to reduce emissions, as described in Section 5.03. 
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TABLE 4-3 (REVISED)

MITIGATED (UNMITIGATED) CONSTRUCTION EMISSIONS – ALTERNATIVES A AND B 

Construction Year 

ROG NOx PM2.5

tons per year

2012 1.20 (1.30) 6.40 (7.47) 0.16 (2.05) 

2013 1.74 (2.63) 5.88 (6.82) 0.07 (0.48) 

2014 1.63 (2.52) 5.51 (6.40) 0.06 (0.44) 

2015 1.29 (2.16) 4.29 (4.98) 0.05 (0.35) 

Maximum Annual Emissions 1.74 (2.63) 6.40 (7.47) 0.16 (2.05) 

De Minimis Level 100 100 100 

Significant No No No 

Source: URBEMIS, 2007; AES, 2011 

The generation of construction-related emissions is considered a short-term impact with a high 

nuisance potential, especially in regard to fugitive dust generation. The Proposed Project has 

been designed with BMPs that will reduce the potential for short-term dust impacts, as per the 

mitigation measures listed in Section 5.03. Short-term construction impacts would be less than 

significant even without the implementation of these measures; however, they are included to 

reduce impacts by the maximum amount feasible. 

Operational Emissions 

Operational emissions would primarily be associated with residential motor vehicle use. Area 

source emissions associated with landscaping maintenance equipment, space heaters, and water 

heaters would contribute to operational emissions and are included in Table 4-4 under Area 

Sources. Based on residential trip generation rates and defaults for trip length, average trip 

speeds, and vehicle fleet composition as contained in the URBEMIS 9.2.4 modeling program, 

operational emissions were estimated for a build-out year of 20132015. Table 4-4 summarizes 

the total operation emissions, which would not exceed the federal de minimis levels. Therefore, 

this impact would be less than significant, and no mitigation is warranted. URBEMIS output files 

are provided in Appendix D. 

TABLE 4-4 (REVISED)

UNMITIGATED OPERATIONAL EMISSIONS – ALTERNATIVES A AND B 

Sources ROG NOx PM2.5

tons per year 

Area 1.83 0.35 0.00 

Mobile 1.67 2.20 0.89 

Total Emissions 3.50 2.55 0.89 

De Minimis Levels 100 100 100 

Significant No No No 

Source: URBEMIS, 2007; AES, 2011. 

Climate Change 

Climate change would not only have global impacts, such as more erratic weather patterns, more 

frequent droughts, and rising sea level, but climate change would cause regional and local 
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impacts as well. Climate change has the potential to reduce the snow pack in the mountain 

regions, increase drought periods, reduce water tables, potentially directly affecting the project 

site (Climate ChangeIntergovernmental Panel on Climate Change, 2007). 

 

Development of Alternatives A, B, and C would result in an increase in GHG related to mobile 

sources (trips generated), area sources (components of the Proposed Project that directly emit 

GHG), and indirect sources related to electrical power generation, water conveyance, and 

wastewater treatment. 

Methodology 

Project-related GHG emissions were quantified using the guidance from the BAAQMD 

guidelines (BAAQMD, 2009 2010). Specifically, direct construction, mobile, and area GHG 

emissions were quantified using the USEPA and CARB approved air quality modeling program 

URBEMIS 2007 and Local Government Operations Protocol, 2008 (LGOP) emission factors. 

Indirect GHG emissions from electricity usage, water conveyance, and wastewater treatment 

were quantified using emission factors from the LGOP. Indirect and direct emissions were 

totaled and compared to the BAAQMD recommended significance threshold (BAAQMD, 2010). 

Carbon Dioxide Equivalent

Carbon dioxide equivalent (CO2e) is a method by which GHGs other than CO2 are converted to a 

CO2-like emission value based on a heat-capturing ratio. As shown in Table 4-5, CO2 is used as 

the base and is given a value of one. Methane (CH4) has the ability to capture 21 times more heat 

than CO2; therefore, CH4 is given a CO2e value of 21. Emissions are multiplied by the CO2e 

value to achieve one GHG emission value. By providing and common measurement, CO2e 

provides a means for presenting the relative overall effectiveness of emission reduction measures 

for various GHGs in reducing project contributions to global climate change.

TABLE 4-5 (NEW TABLE)

GREENHOUSE GAS CO2 EQUIVALENT 

Gas CO2e Value

CO2 1 

CH4 21 

N2O 310 

HFCs/PFCs1 6,500 

SF6

1

 23,900 

Notes: 

CO2ee= carbon dioxide equivalent 

CH4 = methane; N2O = nitrous oxide 

HFCs/PFCs = Hydroflourocarbons/ perflourocarbons

SF6 = sulfur hexafluoride 1 High-global warming potential pollutants 

Source: BAAQMD, 2006 

Emission Estimates

Alternative A construction year 2014 would emit 1,169.56 MT per year of CO2, which is the year 

with the greatest GHG emissions. Using the BAAQMD threshold of 1,100 MT per year, GHG 
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emissions from construction activities would be considered potentially significant. Total 

construction emissions for Alternative A are estimated at 4,236.45 MT of CO2e. 

Table 4-6 shows the estimated operational emissions and project-related reductions. Once 

construction is completed, the project would emit approximately 2,708 MT of CO2e from mobile 

and area sources. CH4 and N2O emissions from mobile sources were estimated using emission 

factors from the Local Government Operations Protocol, 2008 (LGOP) and converted to CO2e. 

Indirect emissions, electricity use, water conveyance, and wastewater treatment as required under 

the BAAQMD CEQA guidelines, 2009 were estimated using LGOP emission factors and are 

estimated at 236 MT of CO2e. Total annual emissions are estimated at 2,944 MT of CO2e. 

Alternative A’s contribution to cumulative global climate change is greater than the BAAQMD 

threshold of 1,100 MT per year of GHG emissions; therefore, this is considered a potentially 

significant impact. Mitigation measures to reduce GHG emissions are provided Section 5.3, 

which would reduce project-related GHG emissions below 1,100 MT per year, resulting in a lessthan-significant impact to climate change. 

TABLE 4-6 (NEW TABLE)

ALTERNATIVES A AND B GHG EMISSIONS 

Alternative A and B GHGs 

CO2e 

Emissions 

(ST) 

Conversion 

Factor 

(ST/MT) 

GHG 

Emissions in 

CO2e (MT) 

Direct2

Mobile CO2 2,533.96 0.91 2,305.90 

Mobile CH4/N2O 11.49 0.91 10.46 

Area CO2 430.08 0.91 391.37 

Indirect3

Electricity Usage CO2 212.75 

Electricity Usage CH4/N2O 1.88 

Water Conveyance CO2e 9.01 

Water Conveyance CH4/N2O 0.08 

Wastewater Treatment CO2e 12.00 

Wastewater Treatment CH4/N2O 0.11 

Total Baseline Project-Related GHG Emissions 2,943.56 

Notes: 

ST = short tons; MT = metric tons; CO2e = carbon dioxide equivalent 1 Project-related GHG emissions were estimated using protocols from the BAAQMD CEQA Guidelines 2

 GHG emissions estimated using URBEMIS air modeling program. 

3

 GHG emissions estimated using Local Government Operations Protocol, September, 2008 emission factors. 

Source: BAAQMD, 2010; AES, 2011

The Proposed Project would emit greenhouse gases during construction and operation. Carbon 

dioxide (CO2) is the most prevalent greenhouse gas and is used as a measurement standard (CO2

equivalent) for other greenhouses gases such as methane. For this project significance will be 

determined by compliance with applicable mitigation measures set forth by the California 

Attorney General. Mobile source CO2 equivalent emissions were estimated at 4,657 tpy for 
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construction and 2,967 tpy during operation of Alternative A. Mobile construction and 

operational CO2 emissions were estimated using URBEMIS; output files are provided in

Appendix D. N2O and CH4 emissions from mobile sources were estimated using emission 

factors from the Climate Action Registry (CAR). Area source emissions for operation were 

estimated using CAR emission factors; operational emissions were estimated at 68 tpy of CO2

equivalent. Total estimated project GHG CO2 equivalent emission in the first year of

construction and operation would be 7,624 tpy. Thereafter, project-related GHG emissions would 

be 2,967 tpy. Project-related emissions would be reduced by implementing the protective 

measures provided in Section 2.0. These measures include applicable mitigation measures 

provided by the California Attorney General. With implementation of the measures provided in 

Section 2.0 and Section 5.0, there would be a less-than-significant impact to climate change. 

4.1.4 BIOLOGICAL RESOURCES

Significance Criteria 

Significant impacts to biological resources would occur if implementation of the Proposed Project 

would result in direct or indirect take of any federally protected species, including the destruction 

or degradation of any identified sensitive habitat. 

Methodology 

The analysis of potential impacts is based on the existing biological setting, which is discussed in 

Section 3.4. The evaluation of biological resources impacts is based on a comprehensive 

examination of the existing project site and the anticipated extent of habitats, potentially 

jurisdictional waters of the U.S., native trees, and the presence/absence or potential occurrence of 

special-status species that would be impacted by each of the proposed alternatives. 

Anticipated Impacts to Biological Resources 

Habitats 

The Proposed Project is likely to result in direct and/or indirect impacts (i.e., development) to the 

annual grassland, mixed oak woodland, oak savannah, ruderal/ developed, pasture and mixed 

riparian habitats onsite. Of these habitat types, oak woodland, oak savannah, and mixed riparian 

are generally considered sensitive. To the maximum extent possible, the Proposed Project has 

incorporated the mixed oak woodland, oak savannah, and riparian woodland habitats into the site 

design to minimize impacts to these habitats by adjusting the locations of lots and structures, 

utilize existing roadways and cleared areas to avoid more pristine stands of woodlands and 

exceptionally large individual trees (heritage trees), maintain woodland corridors, and establish 

aesthetic woodland buffer regions around development areas. Potential impacts to these habitats 

(i.e., woodlands) are more specifically addressed below in the native tree section. Recommended 

protective measures described within Section 2.0 1.9 as well as mitigation measures presented in 
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Section 5.4 would reduce potential impacts to the mixed oak woodland and oak savannah habitats 

onsite to less than significant levels. 

The Proposed Project is likely tocould result in direct and/or indirect impacts to the aquatic 

habitats (e.g., perennial drainage, ephemeral drainages, seasonal wetlands, and seasonal wetland 

swale) within the project site. Although the mixed riparian habitat is considered a terrestrial 

habitat, it is associated with the aquatic habitats because it surrounds two of the ephemeral 

drainages and the perennial drainage onsite (see Figure 8 of Appendix E; AES, 2010d). Project 

design incorporates avoidance and setbacks from mixed riparian habitat as well as identified 

wetlands and drainages, as discussed in Section 2.1.9. The recommended mitigation measures 

for waters of the U.S. under jurisdiction of USACE within Section 5.0 4 would minimize the 

potential for direct and indirect impacts to the aquatic habitats, including the mixed riparian 

habitat, to less than significant levels. 

The Proposed Project would also impact areas of ruderal/developed and pasturine pasture habitat 

onsite. However, these habitat types are of little biological value because they are disturbed areas 

that provide minimal resources for native plant and wildlife species, given that they are already 

notably altered and/or developed. Thus impacts to the ruderal/developed and pasturine habitats 

within the project site are considered insignificant. Table 4-5 7 provides a summary of the 

acreages of the habitat types impacted by the maximum build-out AlternativeProposed Project

(Alternative BA). No impacts to mixed riparian habitat would occur as a result of the Proposed 

Project. Anticipated impacts for Alternative A are less than the table summarized below due to 

the smaller footprint of development in Alternative A (see Section 2.0). 

TABLE 4-75 (REVISED)

ANTICIPATED IMPACTS TO HABITAT TYPES - ALTERNATIVE A 

Habitat Type Total Acres Within 

Project Site

Acreage 

Affected

Percentage of 

Habitat Affected 

Terrestrial Habitats 

Annual Grassland 5.48 1.88 34.31 

Mixed Oak Woodland 53.59 17.04 31.80 

Oak Savannah 8.21 3.94 48.00 

Mixed Riparian 1.56 0 0 

Pasture 36.78 13.75 37.38 

Ruderal/Developed 16.99 4.81 28.31 

Aquatic Habitats

Ephemeral Drainage 0.379 0.0155 4.09 

Isolated Pit 0.022 0.00831 37.77 

Seasonal Wetland 0.624 0.0159 2.55 

Seasonal Wetland Swale 0.273 0 0 

Stock Pond 0.266 0 0 

Perennial Drainage 0.034 0 0 

TOTAL 124.12 41.49 33.43% 

Source: AES, 2010a (Appendix E). 
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Upon implementation of the protective measures and recommended mitigation measures provided 

in Sections 2.0 and 5.04, anticipated impacts to sensitive habitat types within the project site 

would be less than significant. 

Waters of the U.S. 

The Proposed Project has the potential to result in direct and/or indirect impacts to the potentially 

jurisdictional waters of the U.S. within the project site. Direct impacts would include fill and/or 

discharge and indirect impacts would include sedimentation and/or modification of existing water 

quality. As discussed in Section 3.4.4, a formal wetland delineation has been conducted within 

the project site (AES, 2010d). The wetland delineation identified 0.8561.6 acres of potential 

waters and of these, 1.297 acres of potentially jurisdictional wetland features within the project 

site; this delineation is subject to USACE verification (AES, 2009f2010d). To the maximum 

extent feasible, the Proposed Project has been designed to eliminate direct impacts to waters of 

the U.S. by situating lots and structures away from wetland features (Table 4-7). Two small, 

man-made isolated pits, an isolated seasonal wetland and an isolated seasonal wetland swale 

could be filled or otherwise impacted; however, these features are not considered jurisdictional 

features to the USACE pursuant to the CWA and filling them would not result in a significant 

impact (Section 3.4.4; AES, 2010d). Upon implementation of the recommended mitigation 

measures described in Section 5.04, potential impacts to waters of the U.S., including the 

sensitive mixed riparian habitat, would be reduced to less-than-significant levels. 

Native Trees 

The Proposed Project has the potential to result in direct impacts (i.e., removal or damage) to oak 

and other native trees within the sensitive mixed oak woodland and oak savannah habitats onsite. 

Table 4-6 8 estimates the total number of trees greater than nine inches DBH that would be 

directly impacted by each of the project alternatives, as well as the number and percentage of 

trees that would be preserved (AES, 2010e). The majority of the identified valley oaks within the 

Valley Oak Habitat (VOH) Combining District shall be preserved owing to project design and 

avoidance of these trees. The development of the proposed project would preserve large, existing 

blocks of mixed oak woodland, particularly along sensitive areas of drainages and wetlands. 

TABLE 4-68 (REVISED)

TREE IMPACT SUMMARY FOR EACH PROJECT ALTERNATIVE 

Alternative 

Approximate 

Number of Trees 

Impacted 

Approximate 

Number of Trees 

Preserved 

Percentage of 

Trees Preserved 

A 1,669 2,858 63.12% 

B (Option 1) 1,717 2,811 62.08% 

B (Option 2) 1,701 2,827 62.43% 

C 1,364 3,164 69.88% 

D 0 4,528 100% 

Source: AES, 2010e. 
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Native trees within the mixed oak woodland and oak savannah se two habitat types could also be 

indirectly impacted by construction activities because development practices often result in stress 

factors that leave native trees susceptible to further damage, limb and/or trunk failure, disease, 

decay, and increased susceptibility to insect infestations. Examples of indirect impacts to native 

trees caused by development practices include root death caused by oxygen deficiency in 

compacted or waterlogged soils, root death caused by soil changes associated with 

implementation of new structures or pavement, weakened resistance to disease, insect infestation 

from associated stress factors, and introduction of pathogens and insects to the habitat. 

Overcrowding of trees in the mixed oak woodland habitat on site has resulted in stressed growing 

conditions, which increases the potential for these indirect impacts, as well as creating a fire 

hazard. Upon implementation of the protective measures in Section 2.0 1.9 and additional 

mitigation measures in Section 5.04, potential impacts to native trees would be reduced to lessthan-significant levels. 

Special-Status SpeciesAnimals

As described in Section 3.4.4, six plant species were the only federal species determined to have 

the potential to occur within the project site (described in following paragraph). Another 14 state 

and CNPS- listed plant species could occur within the project site, and were considered during 

focused botanical surveys conducted within the project site (Attachment E to the BA: Appendix 

E). Two CNPS List 4 species were identified during focused botanical surveys within the project 

site: Lobb’s aquatic buttercup and harlequin lotus. As described in Attachment E of Appendix E, 

these two species would be avoided in their wetland habitats owing to project design, therefore no 

impacts would occur. Five non-federal animal species have the potential to occur within the 

project site: northwestern pond turtle, great blue heron, white-tailed kite, pallid bat and American 

badger (Table 3-10). Suitable habitat for the northwestern pond turtle would be avoided by 

project design, owing to avoidance of wetland habitats. The project site provides only foraging 

habitat for pallid bat, primarily over waters and wetlands (which would be avoided by project 

design). While there is only marginally suitable habitat for American badger, no badgers were 

observed during years of field surveys.

Special-Status Plants 

As previously discussed in Section 3.4.4, several federally listed plant species have potential to 

occur within the project site; however, none have actually been identified on the property despite 

years of repeated surveys. Listed species include Sonoma alopecurus, Sonoma sunshine, Burke’s 

goldfields, Sebastopol meadowfoam, Pitkin Marsh lily, and many-flowered navarretia. All of 

these plant species, except Sonoma alopecurus and Pitkin Marsh lily, are addressed in the Santa 

Rosa Plain Conservation Strategy (Conservation Strategy: USFWS, 2005a). The Proposed 

Project has the potential to result in direct impacts to special-status plant species should they 

occur within the project site. The Proposed Project could also result in indirect impacts to 

special-status plant species through loss of suitable habitat. Habitat loss is considered a 
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significant impact to special-status plant species within the Santa Rosa Plain because a persistent 

seed bank may be present even if the special-status plant species has not been detected. 

Determinant-level floristic surveys for potentially occurring special-status plant species (i.e., 

federal, state, and CNPS) have been conducted within the majority entirety of the project site for 

at least one year (majority for two years) and no special-status plant species were observed (AES, 

2009g2010e; Attachment E to Appendix E). In addition, the floristic survey efforts were 

conducted in accordance with the Conservation Strategy protocol and occurred within the 

appropriate bloom periods for all potentially occurring special-status plant species. As previously 

mentioned, the Conservation Strategy protocol requires that three separate floristic surveys be 

conducted within the project site, when at least one local reference population of the target 

special-status plant species is blooming, for two consecutive years (USFWS, 2005a). This 

requirement has been met for half of the parcels for the project site (APNs 066-300-031 and , 

066-300-033, 066-300-028, 066-191-018, 066-191-017, 066-191-020 and 066-191-022) since 

two consecutive years of floristic surveys, substantiating negative results, have been completed. 

One year of floristic surveys, substantiating negative results, has been completed on APNs 066-

300-028023, 066-191300-017, 066-191-0168, 066-191-020021, and 066-191-022019, 066-050-

040 and 066-050-047. Floristic surveys for these five seven project parcels will be totally

completed by the end of the blooming period in 20102011 or by early 2012. Completely 

substantiated negative results are anticipated. 

UAs mentioned above, under the Conservation Strategy, loss of any potential habitat for Sonoma 

sunshine, Burke’s goldfields, Sebastopol meadowfoam, and many-flowered navarretia would be 

considered a significant impact. Implementation of the recommended mitigation measures 

outlined in Section 5.0 4.3 would reduce potential impacts (i.e., loss of potential habitat) to 

special-status plant species within the Santa Rosa Plain to a less-than-significant level. If specialstatus plant species are observed within the project site during the floristic surveys yet to be 

conducted, implementation of the additional recommended mitigation measures would reduce 

any potential impacts to special-status plant species to a less-than-significant level. 

Nesting Migratory Birds 

The Proposed Project has potential to impact migratory nesting birds if construction activities 

occur during the nesting season (MarchFebruary 15 through September 15). Activities associated 

with the Proposed Project, such as ground disturbance and vegetation removal, could impact 

nesting birds if their nests are located within development areas. Likewise, increased human 

activity and traffic, elevated noise levels, and operation of machinery could also impact nesting 

birds if their nests are located within the vicinity of development areas. Disturbance of this 

nature that occurs within 500 feet of an active nest could cause nest abandonment or premature 

fledging of the young. This would be a potentially significant impact. Upon implementation of 

the recommended mitigation measures in Section 5.04.4, potential impacts to migratory nesting 

birds would be reduced to a less than significant level. 
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4.1.5 CULTURAL RESOURCES

This section identifies direct and indirect impacts to cultural and paleontological resources that 

would result from implementation of the Proposed Project. 

Archaeological Resources 

For historic properties, a significant adverse impact would result if implementation of the 

undertaking resulted in one of the following effects to cultural resources that are listed, or eligible 

for listing, on the National Register of Historic Places (NRHP): 

 Physical destruction of or damage to all or part of the resource. 

 Alteration of a resource. 

 Removal of the resource from its historic location. 

 Change of the character of the resource’s use or of physical features within the 

resource’s setting that contribute to its historic significance. 

 Introduction of visual, atmospheric, or audible elements that diminish the integrity of 

the resource’s significant historic features; 

 Neglect of a resource that causes its deterioration. 

 Transfer, lease, or sale of the property. 

As part of the cultural resources study, a literature review, records search, Native American 

consultation, and pedestrian surveys for the presence of cultural resources were conducted within 

the project site. No potentially significant cultural resources were identified as a result of that 

effort. While five three residences meeting the minimum age requirement for the NRHP are 

located within the project site, they do not rise to the level of significance necessary for 

consideration as historic properties. Therefore, no impacts to known historic properties would 

occur as a result of the undertaking. 

There is always a possibility, however remote, that significant subsurface cultural resources may 

exist in the project site, as archaeological sites may be buried with no surface manifestation. In 

addition, there is a remote possibility that an unanticipated discovery of human remains could 

occur. Development proposed as a part of this undertaking may adversely affect previously 

unknown subsurface prehistoric or historic archaeological resources, including human remains. 

This would be a potentially significant impact. 

Mitigation measures are presented in Section 5.0 5 for the protection and treatment of 

unanticipated discoveries of archaeological resources and/or human remains. Implementation of 

these mitigation measures would reduce impacts to cultural resources to a less-than-significant 

level. 
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Paleontological Resources 

With respect to paleontological resources, an impact would be considered significant if it would 

directly or indirectly destroy such resources. As described in Section 3.5.4, indicators of 

paleontological resources within the project site are absent in the sources consulted, and no such 

resources were observed in the course of site reconnaissance visits between 2007 and 2010 in 

2007, 2008, and 2009 by AES staffarchaeologists. Geologic formations that underlie the project 

site have a low probability of containing paleontological resources. Therefore, no impacts are 

expected. 

There is always the possibility, however slight, that previously unknown paleontological 

resources could be encountered during construction activities. Mitigation measures are presented 

in Section 5.0 5 for the protection and preservation of unanticipated discoveries of 

paleontological resources. Implementation of these mitigation measures would reduce impacts to 

paleontological resources to a less-than-significant level. 

4.1.6 SOCIOECONOMIC CONDITIONS / ENVIRONMENTAL JUSTICE

Alternative A would remove the seven project parcels totaling 92 124.12 acres from the County’s 

property tax rolls, which would result in a loss of tax revenues. For the 2008-2009 tax year, the 

property taxes for the seven fourteen proposed trust parcels total $59,956.80167,777.22. Property 

taxes for individual parcels for the 20082009-2009 2010 tax year are listed below (Sonoma 

County, 2010): 

 APN 066-191-017: $2,095.2826,152.24 

 APN 066-191-018: $0.0023.32 

 APN 066-191-020: $5,040.148,006.70 

 APN 066-191-022: $1,294.5231,207.70 

 APN 066-300-028: $7,474.6618,678.94 

 APN 066-300-031: $27,834.5629,094.74 

 APN 066-300-033: $16,217.6416,941.14 

 APN 066-300-023: $1,421.30

 APN 066-300-017: $7,839.02

 APN 066-191-016: $2,545.06

 APN 066-191-019: $11,785.00

 APN 066-191-021: $10,579.72

 APN 066-050-040: $3,303.46

 APN 066-050-47: $1,198.88

The Sonoma County Tax Collector collected approximately $690.6681.6 million in property 

taxes for the 2008-20092009-2010 year. The tax on the project parcels was approximately 0.009 
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0.02 percent of the county’s total tax revenue. In determining impacts to the County’s tax base, 

the 0.009 02 percent loss in property taxes is de minimisdiminutive, would not lead to any 

adverse physical effects, and therefore would not be significant under NEPA. 

Because the Proposed Project would include the development of only 147 housing units, and 

because most of the children expected to live in these homes already live within Sonoma County, 

there would be no significant net increase in enrollment in local schools. Therefore, no adverse 

impacts to local school districts would occur, and no mitigation measures are warranted.

Environmental Justice 

This environmental justice analysis was prepared using guidance from the CEQ for compliance 

with Executive Order 12898. The intent of this evaluation is to determine whether the Proposed 

Project or alternatives would impose disproportionately high and adverse human health or 

environmental effects of (BIA’s) programs, policies, and activities on minority populations and 

low-income populations. 

The project site is located in a rural area with increased development occurring near the project 

site and no low-income or minority populations are located adjacent to or near the project site. 

The identified Native American population would not be subjected to disproportionately high or 

adverse human health or environmental impacts. The Proposed Project is not anticipated to 

create any adverse impacts with regard to environmental justice, and no mitigation measures are 

warranted. 

4.1.7 TRANSPORTATION AND CIRCULATION

Transportation Networks 

The Traffic Impact Study (Abrams Associates, 20092010; Appendix G) was conducted for both 

existing and cumulative conditions. For both conditions the peak-hour trip generation of the 

Proposed Project was estimated based on information published in Trip Generation (Institute of 

Transportation Engineers, 2003). Table 4-7 9 summarizes the estimated a.m. and p.m. peak-hour 

trip generation of the Proposed Project. 

TABLE 4-79

PROPOSED PROJECT TRIP GENERATION ESTIMATES 

AM Peak-Hour Trips PM Peak-Hour Trips 

Land Use Size In Out Total In Out Total

Single Family 

Residential 

147 

Units 28 82 110 94 54 148 

NET TOTAL 28 82 110 94 54 148 

Source: Institute of Transportation Engineers, 20032008; Abrams Associates, 201009

The Proposed Project is estimated to generate a gross total of approximately 110 a.m. peak-hour 

trips (28 inbound and 82 outbound) and 148 p.m. peak-hour trips (94 inbound and 54 outbound). 
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Based on the standards in the Caltrans’ Guide to the Preparation of Traffic Impact Studies (State

Department of Transportation, 2002), additional analysis of roadway segments and freeway 

facilities is not required. Caltrans requirements state that an environmental review should include 

any State Highway facility where more than 100 trips would be added or any State Highway 

facility operating at LOS C or LOS D where more than 50 trips would be added. Based on the 

trip generation for the Proposed Project, the project would add fewer than 50 trips to any one 

freeway segment. In addition, the intersection level of service (LOS) analysis indicates that the 

project would not cause any roadway segments to exceed capacity (Appendix G). 

Trip Distribution 

The distribution of project traffic for the Proposed Project was determined based on existing 

travel patterns and the nature of the roadway system serving the project site (Appendix G). 

Significance Criteria 

The Town of Windsor General Plan 2015 established the LOS standards for intersections within 

the Town limits. A LOS of D is the standard that applies to all intersections with the exception of 

the Project Intersection #9, which is identified as an intersection with an acceptable LOS of E 

(Town of Windsor, 19962005). Sonoma County designates LOS D as a standard for intersection 

within their jurisdiction. Thus, each intersection operates acceptably according to the Town’s and 

County’s LOS standards. None of the project intersections warrant installation of a traffic signal 

under existing conditions according to Caltrans standards. 

Background Plus Project Intersection Levels of Service 

Traffic generated by the Proposed Project was added to the background a.m. and p.m. peak-hour 

volumes based on the distribution percentages described above. Table 4-8 10 summarizes the 

a.m. and p.m. peak-hour level of service (LOS) at each study intersection under background plus 

Proposed Project conditions. All project intersections are projected to continue to operate at LOS 

D or better, with the exception of the Windsor River RoadOld Redwood Highway/NB US 101 

Off-ramp-Lakeview Road intersection (Project Intersection #9), which is identified as an 

intersection with an acceptable LOS of E (Town of Windsor, 19962005). Since the traffic 

generated by the Proposed Project would not deteriorate the LOS at current intersections in the 

vicinity of the project site to unacceptable Sonoma County or Town of Windsor standards, a lessthan-significant impact to local intersections would result. No mitigation measures would be 

warranted. 
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TABLE 4-810 (REVISED)

LEVEL OF SERVICE SUMMARY FOR BACKGROUND PLUS PROJECT CONDITIONS 

Background Background plus Project

Intersection Traffic 

Control 

AM Peak PM Peak AM Peak PM Peak

LOS Average 

Delay LOS Average Delay LOS Average Delay LOS Average Delay 

#1. Eastside Road 

and Windsor River 

Road 

Stop 

Sign 

(Future) 

B 10.1 B 10.1 B 10.2 B 10.2 

#2. Windsor River 

Road and Project 

Entrance #1 

Stop 

Sign 

(Future) 

N/A N/A N/A N/A B 10.1 A 10.0 

#3. Windsor River 

Road and Project 

Entrance #3 

Stop 

Sign A 9.7 A 9.5 B 10.8 B 10.9 

#4. Windsor River 

Road and Starr 

Road 

All-Way 

Stop B 11.4 A 9.6 B 12.1 B 10.3 

#5. Windsor River 

Road and Windsor 

Road 

Traffic 

Signal D 38.1 C 31.5 D 39.4 C 31.5 

#6. Windsor River 

Road and Bell Road 

Stop 

Sign C 21.7 C 22.9 C 23.8 D 26.2 

#7. Windsor River 

Road and Old 

Redwood 

Hwy/Conde Lane 

Traffic 

Signal D 39.1 D 36.7 D 39.6 D 38.0 

#8. Old Redwood 

Hwy and SB Hwy 

101 Ramps 

Traffic 

Signal B 16.9 B 15.7 B 17.7 B 16.8 

#9. Old Redwood 

Hwy and NB Hwy 

101 Off-Ramp – 

Lakeside Road 

Traffic 

Signal C 33.7 D- 61.6 D 36.1 E 62.2 

#10. Old Redwood 

Hwy and Project 

Entrance #2 

Stop 

Sign N/A N/A N/A N/A A 9.4 A 9.4 

Note: LOS- Level-of-Service; all average delay times in seconds 

Source: Abrams Associates, 2010

Bicycle, Pedestrian, and Transit Networks 

The project would not generate a large number of new pedestrian trips, bicycling activity, or 

transit riders along Windsor River Road or the other public roads in the area. Existing nonvehicular networks would not be affected by the predicted LOS levels. Thus, no significant 

impacts are projected to these networks as a result of the Proposed Project. 

Construction Traffic

Traffic impacts resulting during the construction of the Proposed Project would be temporary in 

nature. These construction trips are not anticipated to occur during peak hour and they are would

be less in number than those trips anticipated after construction has completed (Table 4-9). 

Construction worker arrival would peak between 6:30 AM and 7:30 AM, and departure would 
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peak between 4:00 PM and 5:00 PM. The AM peak is prior to the area wide commute peak of 

7:30 AM to 8:30 AM. In the evening, there would be a period of overlap in the employee 

commute peak and the area wide commute peak of 4:30 PM to 5:30 PM. 

The delivery and removal of heavy equipment to the site would happen only a few times during 

the construction duration, as large construction vehicles would stay on-site during the grading 

phase of construction. When transport of these vehicles occurs, all trucks would comply with 

applicable Department of Transportation load limits to reduce potential road degradation. 

Therefore, due to the temporary nature of construction traffic, the limited number of trips 

expected, and the timing of these trips, construction trips on study intersections or roadways 

would result in a less than significant traffic impact.

4.1.8 LAND USE

The Proposed Project would result in the construction of 147 housesresidence units, a community 

center, a roundhouse, and a retreat. The development would be compatible with surrounding 

residential land uses, including a housing community located northeast of the site. 

Once the 92124.12-acre site is brought into federal trust, the Sonoma County General Plan (2020) 

and Town of Windsor General Plan (2015) land use policies and standards would no longer apply 

to the project site. Overall consistency with of the proposed project with the County and Town of 

Windsor land use and zoning designations would require productive agriculture and/ or lower 

density of dwelling units. According to Sonoma County and Windsor zoning regulations (using 

Windsor zoning for parcels within the Town’s Sphere of Influence), 143 housing units would be 

allowable on the project site. This is substantially similar to Alternative A’s proposed 147 

housing units. The nature of the proposed housing development with associated community 

facilities is similar to the rural housing use that the Town Windsor would most likely develop for 

the parcels within the urban growth boundary (should the land not be taken into trust). Therefore, 

Alternative A is generally compatible with the existing land use designations and zoning. As 

similar uses currently occur in the surrounding area (such as the residential subdivision northeast 

of the project site), and no significant land use conflicts would occur (such as a restriction in 

access) effects to land use would be less than significant. 

Coastal Zone 

The project site is located outside of the Coastal Zone. There are no activities that would affect 

coastal resources. Measures proposed in Section 2.0 1.9 and Section 5.0 2 for management of 

stormwater runoff would reduce potential off-site impacts to a less than significant level. 
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Agriculture 

The area proposed for the development of the housing community is located adjacent to 

agricultural operations. Proximity to agricultural operations could result in potential impacts 

associated with noise from farm equipment, dust, irrigation overspray, and other effects. 

However, the Sonoma County Right-to-Farm Ordinance would continue to protect neighboring 

farmers from potential nuisance suits. 

Development of the project site would result in a loss of agricultural grazing land and farmland of 

local importance, as defined by the U.S. Department of Agriculture’s Natural Resources 

Conservation Service (NRCS). However, this land is currently wooded, nonirrigated and not in 

agricultural production. As discussed in Section 3.8.3, the project site did not receive a Farmland 

Conversion Impact Rating (FCIR) of 160 or above (Appendix H). Therefore, the impact to 

agriculture would be less than significant. 

4.1.9 PUBLIC SERVICES

Water Supply 

The estimated ADD for Alternative A is 57 gpm for an annual average supply of 92 acre-feet per 

year (ECO:Logic, 2009a2010a; Appendix B). Alternative A would obtain water through a 

connection with the Town of Windsor’s public water supply system. As discussed in Section 

2.01.5, the Town of Windsor maintains a water transmission main that parallels Windsor River 

Road (ECO:Logic, 2009a2010a). 

In order to connect to the existing municipal system, minimal facilities would be required. Two 

connections would be constructed into the project site from the existing 18-inch diameter water 

main in Windsor River Road. The meter at each connection would allow the Town of Windsor to 

account for usage by the private water system. It is likely that there is sufficient flow and 

pressure in the existing water transmission main to supply water for both potable water service 

and fire protection (ECO:Logic, 2009a2010a). No Less than significant impacts would occur to 

the Windsor public water supply system, therefore no mitigation measures are warranted. 

Wastewater Service 

Wastewater from the Proposed Project would be conveyed to the Town of Windsor Wastewater 

Treatment, Reclamation, and Disposal Facility (WWTRDF) through the existing municipal sewer 

collection system. A sewage lift station and approximately 3,200 feet of force main would be 

constructed to pump the wastewater from the community to a manhole located near the 

intersection of Windsor River Road and Starr Road. The connection to the municipal wastewater 

system from the Proposed Project would result in the increase of wastewater treated by the 

WWTRDF by 63,600 gpd. The WWTRDF has sufficient treatment and disposal capacity to serve 

the Proposed Project. The Tribe would adhere to the local regulations, including the Town’s 
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Sanitary Sewer Management Plan, when planning and constructing sewer collection systems for 

the project site (ECO:Logic, 2009a2010a). The WWTRDF would not experience any adverse 

impacts from the connection of the Proposed Project. No mitigation measures are warranted. 

Solid Waste 

Potential solid waste streams from construction would include paper, wood, glass, aluminum and 

plastics from packing materials; waste lumber; insulation; empty non-hazardous chemical 

containers; concrete; metal, including steel from welding/cutting operations; and electrical wiring. 

This impact is considered temporary and less than significant. Solid waste and recycling from the 

residences on the project site would be collected by Windsor Refuse and Recycling, or another 

similar company. 

Assuming a disposal rate of 2.53 lbs/person/day (USEPA, 2007c), and 147 residences with an 

average household size of 2.61 persons (U.S. Census Bureau, 2006), approximately 971 lbs of 

solid waste per day would be generated. As described in Section 2.1, the community center will 

house administrative offices with space for approximately 12 full-time equivalent employees. 

Public administration facilities typically dispose of 0.4 tons of solid waste per employee per year 

(California Integrated Waste Management Board [CIWMB], 2007c); therefore, the community 

center would generate approximately 49.2 tons of waste per year. The retreat and roundhouse 

will only be used by the community’s residents on occasion; their contribution to solid waste is 

therefore minimal. Because most Tribal members that would be project residents and employees 

already live within the County, their net impact to the four private landfills used by Windsor 

Refuse and Recycling would not change and impacts would be less than significant. 

Electricity, Natural Gas, and Telecommunications 

Electrical and telephone infrastructure facilities are currently located on and near the project site. 

The Tribe will coordinate with Pacific Gas & Electric (PG&E) and AT&T regarding the 

extension of services to the project site. The project would use propane rather than natural gas, 

which it would contract directly from local supply companies in the area. No adverse utility 

service impacts would occur. 

Law Enforcement 

Under Public Law 280, 18 U.S.C. §1162, the State of California and other local law enforcement 

agencies have criminal enforcement authority on Tribal lands. The Sonoma County Sheriff’s 

Department Office would provide law enforcement services to the project site. The planned 

facilities would result in a negligible increase in demands on the Department. Calls for service 

would not be disproportionate to other residential or commercial development in the County; 

therefore, no significant impacts would occur. 
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Fire Protection and Emergency Medical Services 

Construction-related impacts include the potential fire threat associated with equipment and 

vehicles coming into contact with wildland areas. Construction vehicles and equipment such as 

welders, torches, and grinders may accidentally spark and ignite vegetation or building materials. 

The increased risk of fire during the construction of the proposed facilities would be similar to 

that found at other construction sites. Since the project site is in an area classified as a High 

Wildland Fire Zone, construction related impacts are considered potentially significant. With the 

implementation of the protective measures and mitigation measures described in Section 2.0 1.9 

and Section 5.09, respectively, impacts would be less than significant. 

Design standards equivalent to cCurrent building and fire codes would be adhered to in relation to 

fire safety. Use of the site for residential purposes would create additional demand for fire 

protection, and require more frequent responses from local fire-fighting agencies. The project 

site is located in a State Responsibility Area, and the California Department of Forestry and Fire 

Protection (CAL FIRE) would be reimbursed for wildland protection services as specified in the 

Statewide Annual Operating Plan between the BIA and CAL FIRE, as provided for in the 

Cooperative Wildland Fire Management and Stafford Act Response Agreement (Appendix I). 

The Cooperative Agreement commenced in December 2007 and is active through December 

2012. During periods of higher fire danger, normally occurring in the region during the summer 

months, the Healdsburg CAL FIRE station, located approximately 5.5 miles north of the project 

site would be staffed. Impacts related to fire protection services would be less than significant. 

Increased emergency calls to 911 as a result of the Proposed Project may result in slight delays in 

response times or result in the need for ambulances to be dispatched from more distant locations. 

Because several ambulance companies provide services in the area, and because new demands 

would be minimal owing to the fact that most potential residents of the Proposed Project already 

live within the County, the increased demand for emergency medical services would not create a 

significant impact.

Public Schools 

Residents that relocate to Windsor under the Proposed Project would increase the number of 

kindergarten through 12th grade students enrolled in the Windsor Unified School District 

(WUSD). As discussed in Section 3.9.7, enrollment in the WUSD has increased by 30 percent 

over the past decade from 4,250 students in 2000/2001 to 5,515 students in 2008/2009 (Ed-Data, 

2010). The average class size in the WUSD has decreased over the past decade from 25.1 in 

2000/2001 to 21.5 in 2008/2009, a 3.6 percent decrease (Ed-Data, 2010). As stated in Section 

2.0, construction of the Proposed Project is anticipated to be completed in 2015. Based on 

historical trends in WUSD enrollment and teacher employment, WUSD would have a 2012/2013 

enrollment of 6,077 and a 2013/2014 enrollment of 6,215. If teacher employment rates remain 

consistent with past trends, the average class size in the WUSD would be 21.2 in the 2012/2013 
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school year, and 21.1 in the 2013/2014 school year. The proportion of occupied Windsor housing 

units to students enrolled in WUSD is determined by taking the 2008/2009 WUSD enrollment 

(5,515 students) and dividing by the total number of households in Windsor as of January 1, 2009 

(9,147 units; CA Department of Finance, 2009), which is equivalent to 60.2 percent of 

households with one child enrolled in a local school. 

An impact to local schools could occur as a result of the development of 147 housing units under 

the Proposed Project if the schools lack capacity and staff to serve the additional students. 

Assuming that residents of the Proposed Project would retain the same proportion of students as 

observed within the Town of Windsor, Alternative A is projected to result in approximately 89 

new students requiring enrollment in WUSD upon completion of the project in 2015; however 

because some of the residents may be relocating from within the Town of Windsor, this is 

considered a worst-case estimate of potential impacts to enrollment. Given that any anticipated 

new students would be distributed across all grade levels between kindergarten through the 

continuation school; 89 new students would be considered a nominal impact to WUSD. The 

Windsor Unified School District (WUSD) is located within the Healdsburg Planning Area (HPA) 

of the Sonoma County General Plan (2020). The General Plan projects that the baseline number 

of students (K-12) within the HPA will increase by 2.5 percent to 2,845 by the 2020 Plan year. 

New students entering the WUSD as a result of the Proposed Project would be negligible because

most potential residents of the project site currently live within the County. In addition, Title VIII 

of the U.S. Elementary and Secondary Education Act of 1965 avoids significant impacts to school 

districts impacted by federal acquisition of land by providing special funding from the U.S.

Department of Education to school districts impacted by federal acquisition of land where certain 

thresholds are met. The potential increase in enrollment would not be anticipated to significantly 

affect the ability of WUSD to provide education services at existing levels; therefore, no 

significant impact would occur. 

Parks and Recreation 

The Proposed Project would include recreation areas, parks, and multi-use trails for use by Tribal 

members. No adverse impacts would occur to local parks or recreational facilities. 

4.1.10 NOISE

Construction Noise 

Grading and construction activities associated with the Proposed Project would be intermittent 

and temporary in nature. The closest sensitive receptors that would be exposed to noise during 

project construction are is the private residences located approximately 2500 feet or more east 

north of APN 066-191-016 and others located greater than 100 feet northeast of where the 

proposed construction activities would occur. 
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Construction noise levels at and near the Project Site would fluctuate depending on the particular 

type, number, and duration of uses of various pieces of construction equipment. Constructionrelated material haul trips would raise ambient noise levels along haul routes, depending on the 

number of haul trips made and types of vehicles used. Table 4-9 11 shows typical noise levels 50 

feet from the sources during different construction stages. 

TABLE 4-911

TYPICAL CONSTRUCTION NOISE LEVELS 

Construction Phase Noise Level (dBA, Leq)

*

Ground Clearing 84 

Excavation 89 

Foundations 78 

Erection 85 

Finishing 89 

Notes: 

* Average noise levels correspond to a distance of 50 feet from the noisiest piece of equipment 

associated with a given phase of construction and 200 feet from the rest of the equipment 

associated with that phase. 

Leq: the equivalent sound level is used to describe noise over a specified period of time, typically 

one hour, in terms of a single numerical value. The Leq is the constant sound level which would 

contain the same acoustic energy as the varying sound level, during the same time period (i.e., 

the average noise exposure level for the given time period). 

Source: Bolt, Baranek, and Newman, 1971

Stationary point sources of noise attenuate (lessen) at a rate of 6 to 7.5 dBA per doubling of 

distance from the source, depending on environmental conditions (i.e., atmospheric conditions, 

topography and type of ground surfaces, noise barriers, etc.). The nearest sensitive receptors to 

construction noise are residences located approximately 20050 feet from where construction 

activities would occur. The maximum construction noise would be 89 dBA at 50 feet, 82.5 dBA 

at 100 feet and 75 dBA at 200 feet. Construction noise impacts would be temporary, intermittent, 

and would occur between the hours of 7 a.m. and 6 p.m. It is important to note that the project 

site encompasses a large area and construction activities would be phased, and would not occur 

throughout the entire project site or all at once. According to the Federal Highway 

Administration (FHWA) guidelines, a 75 dBA noise level is acceptable during construction 

(FHWA, 2006). A few houses would be located closer than 200 feet to the construction area and 

would therefore be exposed to noise levels greater than 75 dBA for short periods of time during 

the day; therefore, noise from construction activities would be less than significantpotentially 

significant at these houses. It is important to note that the Project Site encompasses a large area 

and construction activities would not occur throughout the entire project site or all at once. 

Further reduction of construction noise impacts would occur with tThe implementation of 

measures outlined in Section 5.0 10 would ensure noise impacts during construction are less than 

significant. 

 

Operation Noise 

The primary source of noise in the area is generated by traffic. As discussed in Section 3.10, an 

increase of 200 peak hour vehicle trips on a roadway would be necessary to cause a noticeable 
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increase in the ambient noise level (FHWA, 2006). According to the traffic impact analysis 

(Abrams Associates, 20092010) (Appendix G) and the discussion in Section 4.1.7, the Proposed 

Project would result in an increase of a maximum of 148 cars per peak hour on local roadways. 

Therefore, no audible increase in the ambient noise level would occur. The Proposed Project 

would not increase the existing ambient noise level (55 dBA) beyond the FHWA guideline of 65 

dBA (Section 3.10). In addition, as discussed in Section 2.01.9, outdoor spaces of houses 

associated with the Proposed Project will be oriented to minimize noise levels for offsite residents 

in the vicinity of the project site. Consequently, there would be a less-than-significant impact 

resulting from noise during operation of the Proposed Project. 

4.1.11 HAZARDOUS MATERIALS

No hazardous materials have been identified on site or within a distance that would affect the 

Proposed Project (AES, 2007a, 2007b; 2008a; 2009d2009b-ee; 2010g-i; Appendix J). As 

discussed in Section 5.011, the removal of all non-hazardous debris on the seven fourteen parcels 

will be completed before development begins on the project sitethe parcels are placed into trust. 

During grading and construction, it is possible that hazardous substances such as gasoline, diesel 

fuel, and hydraulic fluid, would be transported to the site. Temporary bulk aboveground storage 

tanks as well as storage sheds/trailers would likely be used by various contractors for fueling and 

maintenance purposes. As with any liquid and solid, there is potential for an accidental release 

exists during handling and transfer from one container to another. Depending on the relative 

hazard of the material, the accidental release could pose both a hazard to construction employees 

as well as the environment. Although typical construction management practices limit and often 

eliminate the impact of such accidental releases, the potential exists with the temporary onsite 

storage of hazardous materials that a significant release could occur. This impact would be 

potentially significant. Mitigation measures are listed in Section 5.11 that would reduce the 

impact to a less-than-significant level. 

4.1.12 VISUAL RESOURCES

Impacts related to visual resources would be considered significant if the Proposed Project were 

to substantially alter or interrupt locally important scenic vistas, introduce visual elements that 

would conflict with the County’s Rural Character Design Guidelines (Sonoma County, 2008), or 

create sources of inappropriate or excessive glare or nighttime illumination. 

The Proposed Project would result in the construction of a mixed-density residential 

development, community center, retreat, and roundhouse, as well as community infrastructure 

and amenities such as roads and bicycle/pedestrian pathways, and open space/parkland areas. 

Development of the project site would be completed in general conformance with Sonoma 
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County’s Rural Design Guidelines, and would complement existing rural residential development 

in the project vicinity. The project would leave natural open space areas along Windsor River 

Road and Eastside Road in order to provide a transition between the development and other 

nearby rural and agricultural uses. Existing oak woodland vegetation and the topography of the 

site would minimize the visual prominence of the proposed housing and other buildings. The 

project would not be visible to travelers on Highway 101. 

Single-family homes would be one to two stories, and would be located to take advantage of the 

natural site topography, exposure, and vegetation. Cottage homes would be smaller, attached 

(duplex) one-story buildings, also sited to preserve vegetation and minimize cuts/fill along slopes. 

Multi-family housing units would be two stories, with central shared “motor court” areas to 

maximize use of space while requiring minimum grading and paving. The higher-density areas 

of housing would be located toward the southern side of the property, away from public roadways 

and public view, as would the community center and roundhouse facilities. Single-family houses 

would primarily be oriented toward the interior of the property, so that limited development 

would be visible to local residents or travelers on Eastside Road and Windsor River Road. 

The Proposed Project would incorporate understated signage and safety lighting within public 

areas. All lighting at roadway intersections and in parking lots for the community 

center/roundhouse would be downcast and shielded, in accordance with “dark sky” principles. 

As stated indescribed by the protective measures in Section 2.01.9, light poles would be no more 

than 18 feet high and will be required to have cut-off lenses. 

The Proposed Project would not interrupt or substantially alter local views, or create any sources 

of glare or excessive nighttime illumination. Development would generally conform to the 

appropriate Rural Design Guidelines, although once the property is taken into federal trust, the 

Sonoma County General Plan goals, objectives, and policies of the Open Space Element would 

no longer apply. Visual impacts would be less than significant and no mitigation measures would 

be warranted. 

4.2 ALTERNATIVE B - ONSITE WATER AND WASTEWATER 

4.2.1 LAND RESOURCES

Impacts related to soils under Alternative B would be similar to those described for Alternative A 

(Section 4.1.1). However, nominal additional grading and leveling would be needed to 

accommodate construction of the wastewater treatment and reclamation facility (WTRF) that 

would be located in the northwest or southeast corner of the site (location 1 or 2) with the first 

option under Alternative B. With the gentle slopes in this area, grading will result in less than 

significant impacts to topography. Approximately 3,000150 cy of surplus fill would be generated 
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by the project and would need to be disposed of along roadways or by strategic dispersion either 

on site or off site (Adobe Associates, 2010). With the implementation of the protective measures 

listed in Section 2.0 1.9 and the mitigation measures listed in Section 5.0, impacts to land 

resources would be less than significant. 

4.2.2 WATER RESOURCES

Surface Water, Drainage, and Flooding 

Alternative B (Figure 2-2) has been designed to avoid the majority of wetlands, drainages and 

water resources located on the site. As in with the Proposed Project (Alternative A), a two small 

man-made isolated pits, an isolated seasonal wetland and isolated seasonal wetlands swale would 

could be filled or otherwise impacted. However, this pitthese features is are not considered a 

jurisdictional features pursuant to the CWA and filling them it in would not result in a significant 

impact. Discussion of the surface waters found on the site is included in the Biological 

Assessment (Appendix E) and a stream characterization discussing potential effects of surface 

water disposal (locations 1 and 2) is provided as Appendix L. 

Alternative B would create approximately 21.426.80 acres of impervious servicessurfaces. As in 

the Proposed Project, increased impervious surfaces would result in increased peak flows and 

increased total discharge from the project site during wet weather events, which if not properly 

dealt with, has the potential to add increased stormwater flow to the area’s drainage systems and 

result in localized flooding. To reduce this impact, preparation of a drainage plan, including 

vegetated swales and the use of permeable surfaces combined with planned areas for reclamation 

of tertiary treated water, has been incorporated into the project design, as discussed in Section 

2.1.9. The use of permeable surfaces in the project design would further minimize runoff and 

ensure that no significant impacts occur. 

All of the proposed structures and facilities would be located outside of the Federal Emergency 

Management Agency (FEMA) 100-year floodplain; therefore, there would be no significant 

impacts due to flooding as a result of the Proposed Project. 

Water Supply and Groundwater 

Because the number and size of residences and community buildings are equal to Alternative A, 

the projected water demands are equal to those summarized in Table 4-1. The projected ADD of 

this alternative Alternative B is 82,300 gpd or 57 gpm. Under this alternative, water would be 

supplied through the development of on-site groundwater wells. Analysis of the test well results 

shows that a production well could sustain a continuous pumping rate of 75 gpm and could meet 

peak pumping rates of 150 gpm (ECO:Logic, 2010b; Appendix C). 
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The water supply system would consist of at least two groundwater production wells, a water 

treatment facility sized to treat the maximum day demand design flow (WTRF), a 400,000-gallon 

ground level storage tank with a booster pump station, and a backup power generator. This tank 

size would provide 300,000 gallons for fire flow storage and an additional 100,000 gallons for 

operational storage. Detailed descriptions of these facilities are provided in Section 2.4.2 of 

Appendix B. Both wells and associated facilities would be located in the northwestern portion of 

the project site as shown in Figure 2-2 (ECO:Logic, 2009a2010a). 

As discussed in Section 4.1.2, the results from the DWR groundwater monitoring show that the 

basin has the overall capacity to accommodate the water demand generated by the proposed 

development. However, groundwater exploitation has the possible impact of lowering the water 

table. During the December 2008 well testing, two additional wells were used to monitor the 

impact of the test on wells in the vicinity. Analysis of the results from these monitoring wells 

shows that after continuously pumping a hypothetical production well for one year at a rate of 57 

gpm, interference drawdown at the nearest existing well (located approximately 700 feet to the 

east) would be approximately 8.5 feet. This was calculated assuming that the existing well 

derives groundwater from the same strata as the test well, that there are no hydrologic boundaries 

present that would isolate the existing well from the test well site, and that there is no recharge to 

the aquifer. At a distance of approximately 2,000 feet, drawdown was calculated to be 

approximately three feet. Assuming an aquifer thickness of 300 feet, the calculated drawdown 

represents only one to three percent of available drawdown. Estimated overall impacts to the 

aquifer as a result of Alternative B would not be significant (ECO:Logic, 2009a2010a; 

2009b2010b), and impacts to neighboring wells would not occur. 

Wastewater Treatment and Disposal 

As summarized in Table 4-2, estimated wastewater flows and loads from Alternative B are equal 

to the Proposed Project. The wastewater will be conveyed to an onsite wastewater treatment and 

reclamation facility (WTRF) in either the northwest or southeast corner of the project site, where 

under the first option for Alternative B it will go through treatment before being discharged into 

either (location 1) an onsite drainage ditch along Windsor River Road that terminates at an 

abandoned quarry in the northwest corner of the project site or (location 2) an onsite unnamed 

stream tributary of to Windsor Creek (thence Russian River) which runs along the southeastern 

border of the project site (Figure 2-2). During the periods when surface water discharge is 

prohibited, the treated wastewater would be used for irrigation throughout the site. 

Under both discharge locations/discharge options, the approximately one to 2.5-acre WTRF 

would include: flow measurement, influent pumping, fine screening, equalization and emergency 

storage, secondary and tertiary treatment with membrane bioreactors (MBRs), UV disinfection, 

effluent pumping, onsite stormwater detention, solids handling facilities, and effluent disposal 

facilities. Detailed descriptions of these facilities are included in Appendix B. The onsite 
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storage facility would be designed to hold a minimal amount of reclaimed water during irrigation 

season to achieve sufficient supply of reclaimed water. 

As discussed in Section 3.2.4, no waters are allowed to be discharged into the Russian River or 

its tributaries between May 15 and September 30 or periods when the waste discharge flow is 

greater than one percent of the receiving stream’s flow. Based on the monthly means shown in 

Table 3-4, the WTRF under the first option for Alternative B would be permitted to discharge 

between November and May 14. The flows in October have, on average, been too low to allow 

for discharge by the WTRF. The discharge of treated effluent from the WTRF would be treated 

to tertiary standards under Chapter 3, Division 4, Title 22, California Code of Regulations (CCR), 

Section 60304, et seq. (Title 22) and would not significantly impact the flows of the Russian 

River or its tributaries. 

Under Alternative B, effluent would be stored seasonally (under the first option) or year-round

(under the second option). The 100-year rainfall design conditions for effluent storage are shown 

in Table 4-12 below. The first option will utilize winter surface water disposal of treated 

wastewater, with summer storage in a closed tank or in a detention basin in the north end of the 

project site, north of Windsor River Road (Figure 2-2). The second option would utilize this 

open-topped, earthen basin designed to hold effluent and 100-year event precipitation, estimated 

to be 23.49 million gallons (Mgal) (Table 4-12). Synthesized 100-year rainfall data was used to 

estimate the maximum effluent and rainfall collected in storage basins, based on basin area. As 

discussed in Section 2.2.3, this accounts for the worst-case scenario. The irrigation land 

requirement is estimated to be 11.75 and 42.1 acres for the first and second options under 

Alternative B, respectively. Areas proposed for irrigation include landscaped areas such as parks, 

yards, and residential and communal structure landscaping. Additional irrigation areas include 

approximately 14 acres within the two parcels north of Windsor River Road (Figure 2-2). APN 

066-050-040 has an existing spray field system in place, which will be expanded on under the 

second option under Alternative B (Section 3.9.1). During years of average rainfall, the amount 

of land required for irrigation would be much lower (Table 4-12). 

Surface Water Quality 

Under this alternative, the WTRF would be located in either the northwestern (location 1) or 

southeastern (location 2) portion of the site (Figure 2-2). The WTRF would produce disinfected 

tertiary recycled water, which is allowed under Title 22 regulations to irrigate residential 

landscapes and parks. The proposed state-of-the-art WTRF would use a three-step process that 

includes physical screening, MBR processing, and ultraviolet disinfection (Section 2.2.3). MBR 

combines the biological and membrane filtration steps, in which organic and inorganic 

contaminants and nutrients present in the sewer water will be removed using microorganisms. 

The effluent is then filtered through the membrane filtration units. Effluent from the MBR would 

be exposed to UV light to inactivate pathogenic microbes including viruses. The exact 
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mineralogical and chemical composition of the effluent is not yet known and would depend 

primarily on the mineral and chemical makeup of the potable water supply and the mineral and 

chemical use practices of future residents (ECO:Logic, 2009a2010a). 

TABLE 4-12 (NEW TABLE)

EFFLUENT STORAGE AND IRRIGATION ESTIMATES 

Parameter 

Alternative 

B (Option 1) B (Option 2) C

Annual Effluent Flowrate (with infiltration and inflow), gpd 80,000 80,000 31,300 

Annual Effluent Flowrate (without infiltration and inflow), gpd 64,000 64,000 25,000 

Yearly effluent generation (Mgal) 29.21 29.21 11.4 

100-Year Precipitation 2 

Storage Need (Mgal) 1.011 23.491 10.271

Irrigation Need (acres) 11.75 42.1 17.6 

Normal Year Precipitation 

Storage Need (Mgal) 0.76 13.61 6.23 

Irrigation Need (acres) 11 25.9 10.4 

Proposed Storage type Closed tank Open-topped 

basin 

Open-topped 

basin 

Notes: 

1

 80% of basin surface area was utilized to estimate water loss due to evaporation. 

2 Synthesized 100-year rainfall data was used to estimate the maximum effluent and rainfall collected in storage basins, based on basin area. Source: ECO:Logic, 2010a (Appendix B) 

Effluent from the WTRF would be totally completely safe for landscape irrigation, other nonpotable uses, and accidental exposures, in compliance with Title 22 regulations. Under 

Alternative B, WTRF effluent would be utilized for irrigating common areas, front yards, parks, 

and playgrounds. Effluent not used for irrigation in winter would be discharged to either of the 

onsite drainages mentioned above, depending on the final location of the WTRF. A stream 

characterization report that analyzes the two surface water disposal locations is attached as 

Appendix L.

A NPDES permit would be obtained prior to any discharge of tertiary treated effluent into a 

tributary of the Russian River, as described in Section 5.02. As conditions of this permit, effluent 

would be monitored for various chemical and physical constituents prior to discharge, including 

ammonia, biological oxygen demand, nitrate, total dissolved and suspended solids, pH, dissolved 

oxygen, total coliform bacteria, oil and grease, and whole effluent toxicity (ECO:Logic, 

2009a2010a). The Tribe would fully comply with the terms and conditions of the NPDES permit; 

therefore, the water quality impacts to the Russian River and its tributaries would be less than 

significant. 

Groundwater Quality 

During the summer, treated effluent would be used for landscape irrigation, which could increase 

the concentrations of nitrogen and salinity in the localized groundwater, if the irrigation water is 

not properly treated and applied. 
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The proposed WTRF includes a nitrogen-reduction process that would reduce the average 

nitrogen concentration in its effluent to less than than 10 milligrams per liter (mg/l). Under this 

alternativethe first option for Alternative B, up to 23 11.6 million gallons (Mgal) of effluent 

would be applied annually to 30 11 acres of land on the project site under normal rainfall 

conditions. Under the second option for Alternative B, up to 27.3 Mgal would be applied 

annually to 25.9 acres of land on the project site under normal rainfall conditions. This would 

result in a nitrogen application rate not exceeding 8865 pounds per acre per year (lbs/ac/year), 

which is 200 to 300 lbs/acre/year less than the typical nitrogen fertilization rate for turf grass. 

Degradation of groundwater from nitrogen would not result from the use of effluent to irrigate the 

project site (ECO:Logic, 2009a2010a). 

The preliminary estimate of salinity of the reclaimed water from the WTRF (as applied to the 

land) is approximately 550 468 mg/L total dissolved solids (TDS). This estimation takes into 

account the salinity of the source water, the estimated added salinity from the consumptive use of 

the water, and the estimated added salinity from the treatment and storage of the water. The 

expected overall average percolate salinity under the first option for Alternative B is 308 mg/L 

and 475 under the second option for Alternative B (Appendix B). Although no total maximum 

daily loads (TMDLs) have been set by the North Coast Regional Water Quality Control Board 

(NCRWQCB) or the USEPA with regard to TDS for the Santa Rosa Plain groundwater sub-basin 

(NCRWQCB, 2007), degradation of groundwater from increased salinity could result from the 

use of effluent to irrigate the project site. The project design protective measures in Section 2.1.9

and recommended mitigation measures in Section 5.0 2 would reduce this potential impact to a 

less-than-significant level. 

Concentrations of arsenic (0.058 mg/L) and manganese (0.015 mg/L) in water from the on-site 

test well do not meet California or Federal drinking water standards. The water treatment 

plantWTRF ,(also described in Section 2.4.2 of Appendix B), would treat these two constituents 

such that there would be no public health impact associated with consumption of this 

groundwater. 

4.2.3 AIR QUALITY

Under Alternative B, the significance criteria and methodology used to analyze impacts to air 

quality are the same as those used for Alternative A. Project components of Alternative B that 

would result in emissions of CAPs and greenhouse gases would be same as Alternative A (Table 

4-6). Both construction and operational emissions under Alternative A are considerably less than 

de minimis levels; these emissions would be similar under the construction and operation of 

Alternative B. Therefore, impacts to air quality under Alternative B would be less than 

significant. 
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Alternative B includes a wastewater treatment and reclamation facility, which has the potential to 

emit odors. The wastewater treatment facility would incorporate an active odor control system, 

consisting of a packaged biofilter with an active carbon absorption unit, as described in Section 

2.02.6. In general, the odor control system will vacuum air off the headworks and blow it 

through the biofilter and carbon absorption unit before exhausting the treated air (refer to 

Wastewater Feasibility Study provided asECO:Logic, 2010a: Appendix B). The result of the 

active odor control system would be the minimal release of odors; therefore, a less than 

significant impact would occur due to odor. 

Alternative B has the potential to emit GHGs during construction and operation. Construction 

and operational emissions are similar to Alternative A GHG emissions, as shown in Table 4-5. 

Thus, as with Alternative A, a potentially significant impact would result for Alternative B. 

Mitigation measures to reduce GHG emissions are provided Section 5.3, which would reduce 

project-related GHG emissions below 1,100 MT per year, resulting in a less-than-significant 

impact to climate change. 

4.2.4 BIOLOGICAL RESOURCES 

Under Alternative B, the significance criteria and methodology used to analyze impacts to 

biological resources are the same as those utilized for Alternative A. 

Anticipated Impacts to Biological Resources 

Impacts to biological resources under Alternative B would be similar to those described for the 

Proposed Project, Alternative A. However, under Alternative B, treated effluent from the onsite 

wastewater treatment facilityWTRF (in locations 1 or 2) would be used for irrigation during the 

summer and discharged during the winter pursuant to a NPDES permit that would be issued by 

the USEPA. The Tribe would fully comply with the terms and conditions of the permit. 

Treated effluent would either be discharged into an onsite drainage that flows into the roadside 

drainage ditch along Windsor River Road (location 1) or into an unnamed tributary located along 

the eastern boundary of the project site (location 2), which flows into Windsor Creek south of the 

project site. 

Waters of the U.S.

Alternative B has the potential to result in direct and/or indirect impacts to the potentially 

jurisdictional waters of the U.S. within the project site. Potential impacts are the same as those 

described for Alternative A in Section 4.1.4. To the maximum extent feasible, Alternative B has 

been designed to eliminate direct impacts to waters of the U.S. by situating lots and structures 

away from wetland features and providing wetland setbacks (Table 4-7). As with the Proposed 
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Project (Alternative A), two small man-made isolated pits, an isolated seasonal wetland and 

isolated seasonal wetlands swale could be filled or otherwise impacted. However, these features 

are not considered jurisdictional features pursuant to the CWA and filling them would not result 

in a significant impact. Discussion of the surface waters found on the site is included in the 

Biological Assessment (Appendix E) and a stream characterization discussing potential effects of 

surface water disposal (locations 1 and 2) is provided as Appendix L. Upon implementation of 

the recommended mitigation measures described in Section 5.4, potential impacts to waters of the 

U.S., including the sensitive mixed riparian habitat, would be reduced to less-than-significant 

levels. 

Surface Water Disposal

The habitat quality observed in the unnamed tributary to Windsor Creek (proposed WTRF and 

disposal location 2; Figure 2-2) is minimally suitable for a suite of regionally occurring common 

and sensitive freshwater species typically found within the Russian River hydrologic unit (AES, 

2009b2010b;) (Appendix EL). Many of the streams tributary to and associated with the lower 

Russian River have the potential to support special status species such as steelhead trout, Chinook 

salmon, and Coho salmon. As shown in Figure 5 4 of Appendix EL, the documented natural 

limit to anadromy is just above the Trenton Healdsburg Bridge crossing on Mark West Creek, far 

downstream of the potential discharge point and near the Town of Windsor’s existing wastewater 

effluent discharge point. Migratory fish species have no potential to occur on or within the 

vicinity of project site and any fish in the lower reaches of Mark West Creek would not be 

significantly impacted by treated effluent from the project site. The unnamed stream was 

dominated by fine sediments and contained no large substrates. It supported no diversity in flow 

regime habitat as the gradient was below 1one % percent and the reach was saturated by both fine 

and course particulate organic decomposing matter. This has created a very anoxic and narrow 

niche for macroinvertebrates, leading to low species richness. Very few invertebrates other than 

mosquito larvae were observed during the survey. Species richness is an indicator of relative 

stream health and niche availability, and can be the basis for a multitude of biological 

assumptions and hypotheses. Overall, the biological suitability for this stream unnamed tributary 

to Windsor Creek is lacking. Additionally, there are potential water quality impacts to the 

unnamed tributary from the residential development to the north. Stormwater from the residential 

development is assumed to flow into the unnamed tributary through the culverts. A tertiary 

treated effluent wastewater discharge could potentially benefit the water quality in this stream 

(AES, 2009bAppendix L). 

The unnamed drainage channel that extends from the northwest corner of the property proposed 

WTRF and disposal location 1; Figure 2-2) to the abandoned quarry is best characterized as a 

roadside ditch. Although this channel initiates flow from two ephemeral drainages and supports a 

dominant gravel substrate base, it does not contain the habitat suitability, surficial connection, 

vegetative cover, or flow duration that would support a significant number of commonly 
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occurring local aquatic species. It receives flashy roadside runoff during rain events that may 

contribute petroleum based pollutants due to this influence. No aquatic species were observed 

during the survey. Potential impacts from a tertiary treated effluent wastewater discharge would 

be negligible in this drainage channel (AES, 2009bAppendix L). 

Native Trees

As indicated in Table 4-68, the first option under Alternative B would result in impacts to 2,009 

approximately 1,717 native trees exceeding nine inches DBH. The second option under 

Alternative B would result in impacts to approximately 1,701 native trees. As with Alternative A,

the majority of valley oaks identified within the VOH Combining District would be preserved 

with project design (Section 4.1.4). Mitigation measures described in Section 5.4.2 would ensure 

potential impacts are less than significant.

Habitats

It As with Alternative A, construction of Alternative B would could also result in potentially 

significant impacts to special-status plants or their annual grassland, mixed oak woodland, oak 

savannah and pasture habitats on-site during to ground disturbance during construction., and 

nesting migratory birds. Potential direct impacts from ground disturbance to habitats within the 

project site from construction of Alternative B are shown in Table 4-13. As described in Section 

2.2.3, approximately 11.75 and 42.1 acres of land would be required for irrigation of treated 

wastewater under the 100-year precipitation event (worst case scenario) under the first and 

second options for Alternative B, respectively. During years of average rainfall, the amount of 

land required for irrigation would be much lower (Table 4-12). Areas proposed for irrigation 

include landscaped areas such as parks, yards, and residential and communal structure 

landscaping. Additional irrigation areas include approximately 14 acres within the two parcels 

north of Windsor River Road (Figure 2-2). The irrigation of landscaped areas would have no 

impact on habitats. However, irrigation of the currently unirrigated pasture north of Windsor

River Road could cause a shift in the species composition of this area. Irrigation could lead to 

higher concentrations of non-native species within irrigated areas, which could be a benefit to 

some species and a detriment to others. Since no special status species are known to occur on the 

project site, and the habitats within the project site are common throughout the region, irrigation 

of this area would not constitute a significant impact. 

Special-Status Species and Migratory Birds

Potential impacts to special-status plants, non-federal special-status species and nesting migratory 

birds are similar as those described for Alternative A in Section 4.1.4. Implementation of all the 

protective measures listed in Section 2.0 2.6 and the recommended mitigation measures in 

Section 5.0 4 would reduce significant these impacts to all of the potentially affected biological 

resources within the project site to less-than-significant levels. 
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TABLE 4-13 (NEW TABLE)

ANTICIPATED IMPACTS TO HABITAT TYPES - ALTERNATIVE B 

4.2.5 CULTURAL RESOURCES

Alternative B would be similar to the Proposed Project. However, associated water and 

wastewater facilities (WTRF) would be constructed. Because there are no known cultural 

resources on site, the only potential impacts would be to unknown archaeological and 

paleontological resources which may be unearthed during the construction process. Mitigation 

recommended in Section 5.0 5 would apply to Alternative B, to reduce these potential impacts to 

a less-than-significant level. 

4.2.6 SOCIOECONOMIC CONDITIONS/ ENVIRONMENTAL JUSTICE

Alternative B is similar to the Proposed Project with the exception of the on-site WTRF. Under 

this alternative the socio-economic benefits to the Tribe would be equal, when compared with the

to those of the Proposed Project. Overall theThe Tribe would benefit from taking the 124.12 

acres of land into trust and the construction of 147 residences and associated facilities. Sonoma 

County would lose minor approximately $168,777.22 of its tax roll revenue from property taxes 

for the 2009-2010 fiscal year after the site project site is taken into federal trust (as described for 

the Proposed Project in Section 4.1.6). This loss of revenue would beis a small fraction 

percentage (0.02 percent) of total County tax revenues, would not lead to any adverse physical 

effects, and therefore would not be significant under NEPA. 

Habitat Type Total Acres Within 

Project Site

Alt B1 -

Acreage 

Affected 

Percent 

affected 

Alt B2 -

Acreage 

Affected 

Percent 

affected 

Terrestrial Habitats 

Annual Grassland 5.48 1.88 34.31 1.88 34.31 

Mixed Oak Woodland 53.59 17.51 32.67 17.04 31.79 

Oak Savannah 8.21 3.94 48.00 5.11 62.24 

Mixed Riparian 1.56 0.01 0.64 0 0 

Pasture 36.78 13.75 37.38 13.75 37.38 

Ruderal/Developed 16.99 5.47 32.19 4.81 28.31 

Aquatic Habitats 

Ephemeral Drainage 0.379 0.0155 4.09 0.0155 4.09 

Isolated Pit 0.022 0.00831 37.77 0.00831 37.77 

Seasonal Wetland 0.624 0.0159 2.55 0.0159 2.55 

Seasonal Wetland Swale 0.273 0.05 18.32 0 0 

Stock Pond 0.266 0 0 0 0 

Perennial Drainage 0.034 0 0 0 0 

TOTAL 124.12 42.68 34.39% 42.66 34.37%

Alt B1 – First option under Alternative B 

Alt B2 – Second option under Alternative B 

Source: AES, 2010a (Appendix E). 
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Environmental Justice 

The impacts to low-income and minority populations for Alternative B are the same as for the 

Proposed Project. No adverse health or environmental impacts to low-income and minority 

populations would occur as a result of Alternative B. Low income and minority populations 

would not be disproportionately adversely affected and there would be no effect with regards to 

environmental justice for adjacent and close-proximity residents. Alternative B would not create 

any adverse impacts with regard to environmental justice. 

4.2.7 TRANSPORTATION AND CIRCULATION

Trip Generation and Distribution 

The a.m. and p.m. peak-hour trip generation for Alternative B was estimated using factors from 

the ITE Trip Generation manual (ITE, 2008). The trip generation figures are summarized in 

Table 4-1014. As shown, this alternative will generate an estimated total of 110 trips in the a.m. 

peak hour (28 inbound and 82 outbound) and 148 trips in the p.m. peak hour (94 inbound and 54 

outbound). Project-related trips were assigned to the local roadway network as described in 

Appendix G. 

TABLE 4-1014

ALTERNATIVE B TRIP GENERATION ESTIMATE 

AM Peak-Hour Trips PM Peak-Hour Trips

Land Use Size In Out Total In Out Total

Single Family 

Residential 

147 Units 28 82 110 94 54 148 

NET TOTAL 28 82 110 94 54 148 

Source: Abrams Associates, 201009

Significance Criteria 

The significance criteria would be the same as described under the Proposed Project, described 

Section 4.1.7. 

Background Plus Project Intersection Levels of Service 

The a.m. and p.m. peak-hour traffic volumes generated by Alternative B are the same as those 

expected under the Proposed Project. It is assumed that, as under the Proposed Project scenario, 

all intersections would continue to operate at acceptable LOS D (Table 4-810) with the exception 

of the Windsor River RoadOld Redwood Highway/NB US 101 Off-ramp-Lakeview Road 

intersection, which is defined as an exception under Town of Windsor General Plan 2015. 

Therefore, this impact would be less than significant. 
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Bicycle, Pedestrian, and Transit Networks 

Alternative B would not generate substantial increases in bicycling activity, pedestrian activity, or 

transit riders. Impacts in these areas would be less than significant. Alternative B would not 

affect any planned pedestrian or bicycling networks. 

Construction Traffic

Traffic impacts resulting during the construction of the Alternative B would be temporary in 

nature. These construction trips are not anticipated to occur during peak hour and they are 

anticipated to be less in number than those trips anticipated after construction has completed 

(Table 4-9). Construction worker arrival would peak between 6:30 AM and 7:30 AM, and 

departure would peak between 4:00 PM and 5:00 PM. The AM peak is prior to the area wide 

commute peak of 7:30 AM to 8:30 AM. In the evening, there would be a period of overlap in the 

employee commute peak and the area wide commute peak of 4:30 PM to 5:30 PM. 

The delivery and removal of heavy equipment to the site would happen only a few times during 

the construction duration, as large construction vehicles would stay on-site during the grading 

phase of construction. When transport of these vehicles occurs, all trucks would comply with 

applicable Department of Transportation load limits to reduce potential road degradation. 

Therefore, due to the temporary nature of construction traffic, the limited number of trips 

expected, and the timing of these trips, Alternative B construction trips on study intersections or 

roadways would result in a less than significant traffic impact.

4.2.8 LAND USE

Development of Alternative B would include 147 residences, community buildings, and 

associated water and wastewater facilities. Remaining land would be preserved as open space. 

The development would be compatible with surrounding land uses in that there are residential, 

agricultural, and commercial uses near the project site. As similar, existing uses occur in the 

vicinity, effects to land use from this alternative would be less than significant. 

Coastal Zone 

The project site is located outside of the Coastal Zone. Similar to the Proposed Project, there are 

no activities that would affect coastal resources. 

Agriculture 

Implementation of Alternative B would not result in any significant agricultural resource impacts, 

similar toas described for the Proposed Project (Alternative A). 
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4.2.9 PUBLIC SERVICES

Water Supply 

Under Alternative B the project site would obtain water through the development of onsite 

groundwater sources. This option would have no impact on municipal water supplies. The water 

demands and potential effects to other groundwater wells are discussed in Section 4.2.2. 

Wastewater Service 

Under this the first option for Alternative B, wastewater would be treated onsite at the proposed 

treatment plant and discharged to (location 1) a drainage ditch along Windsor River Road that 

terminates at an abandoned quarry or (location 2) an unnamed tributary of Windsor Creek which 

runs along the eastern border of the project site (see Figure 2-2). During the periods when 

surface water discharge is prohibited, the water would be used for irrigation throughout the site 

(Section 4.2.2). Because an NPDES permit would be obtained prior to any discharge of tertiary 

treated effluent into a tributary of the Russian River, and because the Tribe would fully comply 

with the terms and conditions of the permit, the impacts to the Russian River and its tributaries 

would be less than significant. The construction and operation of the onsite WRFWTRF would 

not impact existing municipal treatment facilities. 

Solid Waste 

Construction waste would be generated and would consist of the same materials described 

previously under the Proposed Project. This impact would be temporary and less than significant. 

Solid waste and recycling from the residences on the project site would be collected by Windsor 

Refuse and Recycling, or another similar company. Generation rates are essentially equal to 

those of the Proposed Project; impacts to solid waste would be less than significant. 

Electricity, Natural Gas, and Telecommunications 

Electrical, natural gas, and telephone services are the same as those described for the Proposed 

Project. The Tribe will coordinate with PG&E and AT&T regarding the extension of services to 

the project site. The project would use propane rather than natural gas, which would be 

contracted directly from local supply companies in the area. No adverse utility service impacts 

would occur under Alternative B. 

Law Enforcement 

Under Public Law 280, the State of California and other local law enforcement agencies have 

criminal enforcement authority on Tribal lands. The Sonoma County Sheriff’s Department 

Office would provide law enforcement services to the project site. Calls for service would not be 

disproportionate to other residential or commercial development in the County. No significant 

impacts to law enforcement services would occur from implementation of Alternative B. 
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Fire Protection and Emergency Medical Services 

The increased risk of fire during the construction of the proposed facilities would be similar to 

that found at other construction sites. Because the project site is in an area classified as a High 

Wildland Fire Zone, construction-related impacts would be potentially significant. With the 

implementation of the protective measures listed in Section 2.0 1.9 and the mitigation measures 

listed in Section 5.09, impacts to fire protection and emergency medical services would be less 

than significant. 

CDesign standards equivalent to current building and fire codes will be adhered to in relation to 

fire safety. The additional demand for fire protection and emergency medical services under 

Alternative B would be similar to that of the Proposed Project. Due to the existing agreements 

and availability of emergency medical services, the impact to emergency services would be less 

than significant. 

Public Schools 

As described in Section 4.1.9, Sonoma County has set forth policies that would accommodate for 

the minor increase in students within the HPA. No significant impacts to public schools would 

occur. 

Parks and Recreation 

Alternative B would include recreation areas, parks and multi-use trails for use by Tribal 

members. No adverse impacts would occur to local parks or recreational facilities. 

4.2.10 NOISE

With the implementation of Alternative B, construction activity noise (which is considered 

intermittent and temporary in nature) would be similar to Alternative A. Although construction 

noise impacts from Alternative A would be less than significant, implementation of the protective 

measures presented in Section 2.1.90 would reduce noise impacts by the maximum extent 

feasible. These same mitigation measures would be applied to Alternative B, ensuring a lessthan-significant impact due to construction noise. 

The primary source of operational noise generated by Alternative B would be traffic on Windsor 

River Road and project roadways, as well as occasional and intermittent noise from the proposed 

WRFWTRF. Vehicle trips generated during the peak AM and PM hours would be the same as 

those described under Alternative A (maximum of 148 vehicle trips per peak hour). The existing 

noise environment is approximately 55 decibels (dB). The WRFWTRF operational noise would 

not be noticeable at any on-site or off-site residences unless operational pumps and generators 

were not enclosed or shielded. Similar to Alternative A, Alternative B would generate less than a 

3 dBA increase in noise, thus impacts to the ambient noise environment would be less than 
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significant with the possible exception of intermittent impacts to sensitive receptors located near 

the WTRF should it have unshielded pumps or generators. Thus, a potentially significant impact 

could result. Implementation of the protective measures presented in Section 2.0 .1.9 and 

mitigation measures in Section 5.10 would further reduce noise impacts to offsite residents in the 

vicinity of the project siteensure impacts are less than significant. 

4.2.11 HAZARDOUS MATERIALS

As discussed in Section 4.1.11, there are no identified hazardous materials on site or within a 

distance that would affect Alternative B. During construction of any development it is possible 

that hazardous materials, such as gasoline, diesel fuel, and hydraulic fluid, would be brought on 

site in temporary aboveground storage tanks. Additionally, the proposed WRFWTRF may use 

hazardous materials such as sodium hypochlorite and citric acid. The use and storage of 

hazardous materials is considered potentially significant. Mitigation measures are listed in 

Section 5.011; implementation of these measures would ensure a less-than-significant impact 

under Alternative B. 

4.2.12 VISUAL RESOURCES

Alternative B would result in the construction of a residential development and community 

facilities and amenities similar to Alternative A, with the addition of on-site water and wastewater 

treatment facilities. Development of all facilities on the project site would generally be 

completed in conformance with Sonoma County’s Rural Design Guidelines, and would 

complement existing rural residential development in the project area. As described in the 

analysis of Alternative A (Section 4.1.12), the project would leave natural areas along Windsor 

River Road in order to provide a transition to the nearby rural and agricultural uses. Topography 

of the site and oak woodland vegetation would also limit views of the property from the 

surrounding sensitive visual receptors and travelers on local roadways. The proposed locations 

for the WTRF are shielded from public view by existing trees and topography, and would be

located away from existing residences. Nonetheless, Alternative B would include additional 

trees, shrubs, and vegetation to further screen views of the proposed wastewater facilities. 

Lighting from public areas would be the minimum required for safety and security, and would 

consist of shielded, downcast lights on poles not more than 18 feet high. As with Alternative A, 

visual impacts would be less than significant. 
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4.3 ALTERNATIVE C - REDUCED INTENSITY WITH ONSITE 

WATER AND WASTEWATER 

4.3.1 LAND RESOURCES

Environmental consequences under the Reduced-Intensity Alternative would be less than those 

described for Alternatives A and B. This includes impacts with regard to soils. As discussed in 

Section 2.3, this Alternative would require approximately 6,000 cy of cut material and will utilize 

this amount for no net cy of surplus soil (Adobe Associates, 2010: Appendix A)result in 1,700 cy

of surplus soil which would be either used onsite or deposited offsite at an approved location. As 

with Alternatives A and B, Alternative C would not result in significant impacts related to 

topography. With the implementation of the protective measures listed in Section 2.0 1.9 and the 

mitigation measures listed in Section 5.01, impacts to land resources would be less than 

significant. 

4.3.2 WATER RESOURCES

Surface Water, Drainage, and Flooding 

Alternative C (Figure 2-3) has been designed to avoid the majority of wetlands, drainages and 

water resources located on the site. One small, man-made isolated pit may be filled or otherwise 

impacted; however, this feature is not considered jurisdictional features pursuant to the CWA and 

filling it would not result in a significant impact (Section 3.4.4, AES, 2010d). No other existing 

surface waters would be disrupted due to Alternative C. 

The Reduced-Intensity Alternative would result in fewer impervious surfaces than the Proposed 

Project or Alternative B, which would lessen the resulting runoff flow. Housing, community 

buildings, and roads would create approximately 18.117.74 acres of impervious surfaces. No 

significant impacts to surface water or drainage would occur. The protective measures and BMPs 

described in Section 2.0 3.6 would also be implemented for Alternative C. 

As with the Proposed Project, the all project components would be located completely outside of 

the 100-year floodplain. Impacts related to flooding would be less than significant. 

Water Supply and Groundwater 

The ADD for this alternative would be 31,700 gpd or 22 gpm. Under the Reduced-Intensity 

Alternative water would be supplied though the development of wells similar to those described 

in Section 4.2.2. Due to the reduced ADD, the impacts to the water basin and neighboring wells 

would be less than those described for Alternative B. 
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Wastewater Treatment and Disposal 

Estimated wastewater flows and loads for Alternative C are summarized in Table 4-2 and Table 

4-12. The WRFWTRF for this alternative would be located in the southern portion of the project 

site (location 2) and have the same treatment components as described for Alternative B (see 

Figure 2-3). The WRFWTRF would implement the BMPs listed in Sections 2.0 2.6 and 2.3.6 to 

improve the quality of effluent being discharged. Depending on the time of year the effluent 

would either be used for irrigation throughout the site or pumped into a storage basin. Alternative 

C requires a 4.810.27 Mgal 100-year effluent storage basin and 11.717.6 acres of irrigation land 

to accommodate 100-year flood flows. The storage facility would be located adjacent to the 

WRFWTRF in the southeastern half of the project site and possible irrigation areas include 

landscaping areas for parks and facilities. This effluent disposal method would not be limited by 

soil types, depths, and slopes on the property. 

Surface Water Quality 

No treated effluent would be discharged into surface waters under this alternative. This 

alternative would include preparation and implementation of a SWPPP and BMPs, including 

those listed in Section 2.0, to ensure that impacts to surface waters are minimized. Because no 

treated effluent would be discharged into surface waters, no NPDES permit would be required, 

and the impact to surface waters would be less than significant. 

Groundwater Quality 

The WTRF would discharge reclaim effluent by using it for onsite irrigation during the summer 

months. As described in Section 4.2.2, the possible impacts to groundwater quality would be 

caused by increased nitrogen and salinity due to irrigating the property with treated effluent 

generated by Alternative C. Under Alternative C, approximately 10.9 Mgal of effluent would be 

applied annually to 10.4 acres of vegetated land on the project site during average years of 

rainfall. The expected overall average percolate salinity for Alternative C is 300 mg/L 

(Appendix B). Both tThe nitrogen and salinity reduction processes for the WTRF for the 

Reduced-Intensity Alternative would be the same as for Alternative B, therefore and degradation 

to groundwater from nitrogen and salinity would not occur. Implementation of the recommended 

mitigation measures in Section 5.0 2 would reduce significant impacts associated with increased 

salinity to less-than-significant levels. 

4.3.3 AIR QUALITY

Under the Reduced-Intensity Alternative, the significance criteria and methodology used to 

analyze impacts to air quality would be the same as those used for Alternative A. 
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Anticipated Air Quality Impacts 

Construction Impacts 

Construction of the Reduced-Intensity Alternative would generate the CAPs described in Section 

3.3.4. Construction emissions for Alternative C were modeled using URBEMIS 9.2.4, with the 

results presented in Table 4-11 15 and URBEMIS output files provided in Appendix D. The 

URBEMIS default construction equipment list was used, which is based on typical residential 

construction. Assumptions include a maximum disturbance of 2.4 acres per day for site grading, 

and other construction assumptions similar to those listed for Alternative A. 

TABLE 4-1115 (REVISED)

MITIGATED (UNMITIGATED) CONSTRUCTION EMISSIONS – ALTERNATIVE C 

REDUCED-INTENSITY ALTERNATIVE

Construction Year ROG NOx PM2.5

tons per year 

2012 1.15 (1.18) 6.22 (7.29) 0.15 (2.04) 

2013 1.42 (1.75) 5.56 (6.50) 0.05 (0.47) 

2014 1.32 (1.65) 5.22 (6.11) 0.04 (0.42) 

2015 1.03 (1.35) 4.09 (4.79) 0.03 (0.33) 

Maximum Emission 1.42 (1.75) 6.22 (7.29) 0.15 (2.04) 

De Minimis Level 100 100 100 

Significant No No No 

Source: URBEMIS, 2007; AES, 2011 

The generation of construction-related emissions is considered a short-term impact with a high 

nuisance potential, especially in regards to fugitive dust generation. The Reduced-Intensity 

Alternative has been designed with BMPs that will reduce the potential for short-term dust 

impacts, as per the description in Section 2.05.3. Short-term construction impacts would be less 

than significant even without the implementation of these measures; however, they are included 

to reduce impacts by the maximum amount feasible. 

Operational Emissions 

Operational emissions would primarily be associated with residential motor vehicle use. Area 

source emissions associated with landscaping maintenance equipment, space heaters, and water 

heaters would contribute to operational emissions; these are included in Table 4-12 16 under 

Area Sources. Based on residential trip generation rates and defaults for trip length, average trip 

speeds, and vehicle fleet as presented in the URBEMIS 9.2.4 modeling program, operational 

emissions were estimated for a build-out year of 20132015. Table 4-12 16 summarizes the 

operational emissions, which would not exceed the federal de minimis levels. This impact would 

be less than significant, therefore no mitigation is warranted. URBEMIS output files are provided 

in Appendix D. 
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TABLE 4-1216 (REVISED)

UNMITIGATED OPERATIONAL EMISSIONS – ALTERNATIVE C: 

REDUCED-INTENSITY ALTERNATIVE 

Sources ROG NOx PM2.5

tons per year 

Area 0.68 0.13 0.00 

Mobile 0.63 0.82 0.33 

Total Emissions 1.31 0.95 0.33

De Minimis Levels 100 100 100 

Significant No No No

Source: URBEMIS, 2007; AES, 2011 

Climate Change 

Methodology 

The methodology for Alternative C is the same as Alternative A. 

 

Emission Estimates

Alternative C construction year 2014 would emit 829.40 MT per year of CO2e, which is the year 

with the greatest GHG emissions. Using the BAAQMD Guidelines threshold of 1,100 MT per 

year, GHG emissions from construction activities would be less-than-significant. Total 

construction emissions for Alternative C are estimated at 3,130.64 MT of CO2e. 

Table 4-17 shows the estimated operational emissions and project-related reductions. Once 

construction is completed, the project would emit approximately 1,019.64 MT of CO2e from 

mobile and area sources. CH4 and N2O emissions from mobile sources were estimated using 

emission factors from the Local Government Operations Protocol, 2008 (LGOP) and converted to 

CO2e. Indirect emissions, electricity use, water conveyance, and wastewater treatment were 

estimated at 88.48 MT of CO2e. Total annual emissions are estimated at 1,108.12 MT of CO2e. 

Alternative C’s contribution to cumulative global climate change is greater than the BAAQMD 

CEQA threshold of 1,100 MT per year of GHG emissions; therefore, this is considered a 

potentially significant impact. Mitigation measures to reduce GHG emissions are provided 

Section 5.3, which would reduce project-related GHG emissions below 1,100 MT per year, 

resulting in a less-than-significant impact to climate change. 

Mobile source CO2 equivalent emissions were estimated at 3,442 tpy for construction and 1,110

tpy for operations (see Appendix D). Area source emissions for operation were estimated using 

Climate Action Registry emission factors; these emissions were estimated at 36 tpy of CO2

equivalent. The implementation of protective measures presented in Section 2.0 would reduce 

project emissions and result in a less-than-significant impact to climate change. 
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TABLE 4-17 (NEW TABLE)

ALTERNATIVE C GHG EMISSIONS 

Alternative C GHGs 

CO2e 

Emissions 

(ST) 

Conversion 

Factor 

(ST/MT) 

GHG 

Emissions in 

CO2e (MT) 

Direct1

Mobile CO2 948.08 0.91 862.75 

Mobile CH4/N2O 11.49 0.91 10.46 

Area CO2 160.91 0.91 146.43 

Indirect2

Electricity Usage CO2 79.60 

Electricity Usage CH4/N2O 0.70 

Water Conveyance3 CO2e 3.47 

Water Conveyance3 CH4/N2O 0.03 

Wastewater Treatment3 CO2e 4.64 

Wastewater Treatment3 CH4/N2O 0.04 

Total Baseline Project-Related GHG Emissions 1,108.12 

Notes: 

ST = short tons; MT = metric tons; CO2e = carbon dioxide equivalent 1 Project-related GHG emissions were estimated using protocols from the BAAQMD 

 CEQA Guidelines. 

2

 GHG emissions estimated using URBEMIS air modeling program. 3

 GHG emissions estimated using Local Government Operations Protocol, September, 2008 emission 

factors. 

Source: BAAQMD, 2010; AES, 2011

Odor 

Alternative C would incorporate a WRFWTRF similar to Alternative B. The odor control system 

outlined under Alternative B and included as a protective measure in Section 2.0 2.6 would be 

incorporated in the WRFWTRF under Alternative C; therefore, a less-than-significant impact 

would occur due to odor. 

4.3.4 BIOLOGICAL RESOURCES

Under the Reduced-Intensity Alternative, the significance criteria and methodology used to 

analyze impacts to biological resources are the same as those utilized for Alternatives A and B. 

The project components of Alternative C are similar to Alternative B, although this Alternative 

contains fewer residential units and has a slightly different overall configuration. 

Anticipated Impacts to Biological Resources 

Environmental consequences under Alternative C would be similar to those described for 

Alternative B, although Alternative C contains fewer residential units. As such, Alternative C 

would result in proportionally lessened, but still potentially significant impacts to the mixed oak 

woodland, oak savannah, mixed riparian, and aquatic habitats (Table 4-18). It would also result 

innot result in any potentially significant impacts to potential waters of the U.S., One small, 
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man-made isolated pit may be filled or otherwise impacted; however, this feature is not 

considered jurisdictional features pursuant to the CWA and filling it would not result in a 

significant impact (Section 3.4.4, AES, 2010d). Approximately 1,564 364 native trees (as per 

Table 4-68) could be directly impacted by development of Alternative C,. Potential impacts from 

construction of Alternative C could occur to special-status plants and other species or their 

habitats, and nesting migratory birds. Implementation of all the protective measures listed in 

Section 2.0,1.9 as well as the recommended mitigation measures in Section 5.04, would reduce 

significant impacts to all of the potentially affected biological resources within the project site to 

less-than-significant levels. 

 

TABLE 4-18 (NEW TABLE)

ANTICIPATED IMPACTS TO HABITAT TYPES - ALTERNATIVE C 

4.3.5 CULTURAL RESOURCES

Impacts to cultural resources would be the same as in Alternatives A and B. Since there are no 

known cultural resources on site, the only potential impacts are to unknown sites which may be 

unearthed during the construction process. Mitigation is recommended in Section 5.0 5 to reduce 

potential impacts to a less-than-significant level. 

4.3.6 SOCIOECONOMIC CONDITIONS / ENVIRONMENTAL JUSTICE

The Reduced-Intensity Alternative is similar to Alternative B; however, it includes 92 fewer 

housing units. The Tribe would benefit from taking the 124.12 acres of land into trust and the 

construction of residences and associated facilities. Under this alternative the socio-economic 

benefits to the tribe would be reduced when compared with the Proposed Project and Alternative 

B, because there would be less housing available for Tribal members who wish to live in a 

cohesive community and promote Tribal unity. Overall, however, the Tribe would still benefit 

Habitat Type Total Acres Within 

Project Site

Acreage 

Affected

Percentage of 

Habitat Affected 

Terrestrial Habitats 

Annual Grassland 5.48 0.89 16.24 

Mixed Oak Woodland 53.59 12.10 22.57 

Oak Savannah 8.21 4.94 60.17 

Mixed Riparian 1.56 0 0 

Pasture 36.78 6.33 17.21 

Ruderal/Developed 16.99 2.37 13.95 

Aquatic Habitats

Ephemeral Drainage 0.379 0.0158 4.17 

Isolated Pit 0.022 0.00690 31.36 

Seasonal Wetland 0.624 0.00630 1.01 

Seasonal Wetland Swale 0.273 0.00260 0.95 

Stock Pond 0.266 0 0 

Perennial Drainage 0.034 0 0 

TOTAL 124.12 26.66 21.48% 

Source: AES, 2010a (Appendix E). 
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from the construction of 55 residences. The County would lose minor revenue from property 

taxes after the site is taken into trust (Section 4.1.6). This loss of revenue would not lead to any 

adverse physical effects, and therefore would not be significant under NEPA as per the discussion 

under Section 4.1.6. 

Environmental Justice 

The impacts to low-income and minority populations from the Reduced-Intensity Alternative 

would be the same as for Alternative B. No adverse health or environmental impacts to lowincome and minority populations would occur as a result of the Reduced-Intensity Alternative. 

Low income and minority populations will not be disproportionately adversely affected and there 

would be no effect with regards to environmental justice for adjacent and close-proximity 

residents. This alternative is not anticipated to create any adverse impacts with regard to 

environmental justice. 

4.3.7 TRANSPORTATION AND CIRCULATION

Trip Generation and Distribution 

The a.m. and p.m. peak-hour trip generation for Reduced-Intensity Alternative was estimated 

using factors from the Institute of Transportation Engineers (ITE) Trip Generation manual. The 

trip generation figures are summarized in Table 4-1319. As shown, this alternative would 

generate an estimated total of 41 trips in the a.m. peak hour (10 inbound and 31 outbound) and 56 

trips in the p.m. peak hour (36 inbound and 20 outbound). Reduced-Intensity Alternative traffic 

would create a minimal addition to local traffic numbers and patterns. 

TABLE 4-1319

REDUCED-INTENSITY ALTERNATIVE TRIP GENERATION ESTIMATE 

AM Peak-Hour Trips PM Peak-Hour Trips 

Land Use Size In Out Total In Out Total 

Single Family 

Residential 

55 

Units 10 31 41 36 20 56 

NET TOTAL 10 31 41 36 20 56 

Source: Abrams Associates, 201009

The distribution of the trips associated with Reduced-Intensity Alternative is expected to be 

approximately the same as the distribution calculated for the Proposed Project (Appendix G). 

Significance Criteria 

The significance criteria are the same as described under the Proposed Project (Section 4.1.7). 

Background Plus Project Intersection Levels of Service 

The a.m. and p.m. peak-hour traffic volumes generated by this alternative would be less than 

those under the Proposed Project. It can be assumed that, as under the Proposed Project, all 
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intersections would continue to operate at acceptable LOS D (Table 4-810) with the exception of 

the Windsor River RoadOld Redwood Highway/NB US 101 Off-ramp-Lakeview Road 

intersection, which is defined as an exception under Town of Windsor General Plan. This impact 

would therefore be less than significant, and no mitigation is warranted. 

Bicycle, Pedestrian, and Transit Networks 

The Reduced-Intensity Alternative would not generate substantial increases in bicycling activity, 

pedestrian activity, or transit riders. Impacts in these areas would be less than significant. The 

Reduced-Intensity Alternative would not affect any planned pedestrian or bicycling networks. 

Construction Traffic

Traffic impacts resulting during the construction of the Alternative C would be temporary in 

nature. These construction trips are not anticipated to occur during peak hour and they are 

anticipated to be less in number than those trips anticipated after construction has completed 

(Table 4-9). Construction worker arrival would peak between 6:30 AM and 7:30 AM, and 

departure would peak between 4:00 PM and 5:00 PM. The AM peak is prior to the area wide 

commute peak of 7:30 AM to 8:30 AM. In the evening, there would be a period of overlap in the 

employee commute peak and the area wide commute peak of 4:30 PM to 5:30 PM. 

The delivery and removal of heavy equipment to the site would happen only a few times during 

the construction duration, as large construction vehicles would stay on-site during the grading 

phase of construction. When transport of these vehicles occurs, all trucks would comply with 

applicable Department of Transportation load limits to reduce potential road degradation. 

Therefore, due to the temporary nature of construction traffic, the limited number of trips 

expected, and the timing of these trips, Alternative C construction trips on study intersections or 

roadways would result in a less than significant traffic impact.

4.3.8 LAND USE

Development of the Reduced-Intensity Alternative would include 55 residences, community 

facilities, and associated water and wastewater facilities. Remaining land would be open space. 

The development would be compatible with surrounding land uses in that there are residential, 

agricultural, and commercial uses near the project site. As similar uses occur in the area, effects 

to land use would be less than significant. 

Coastal Zone 

The project site is located outside of the Coastal Zone. Similar to the Proposed Project, there are 

no planned activities that would affect coastal resources. 
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Agriculture 

Implementation of the Reduced-Intensity Alternative would not result in any significant 

agricultural resource impacts, similar to the Proposed Project. 

4.3.9 PUBLIC SERVICES

Water Supply 

The Reduced-Intensity Alternative would obtain water through the development of onsite 

groundwater wells. This option would have no impact on municipal water supplies. The 

proposed alternatives, demands, and potential effects to other groundwater wells are discussed in 

Section 4.2.2. 

Wastewater Service 

Under this alternative, wastewater would be treated onsite at the proposed treatment plant and 

utilized for landscape irrigation during the dry season. The potential impacts to water quality are 

discussed in Section 4.2.2. The construction and operation of the onsite WRFWTRF would not 

impact the existing municipal treatment facilities. 

Solid Waste 

Construction waste would consist of the same materials described previously under the Proposed 

Project; however, due to the reduced number of residences, less construction waste would be 

generated under Alternative C. This impact is considered temporary and less than significant. 

Solid waste and recycling from the residences on the project site would be collected by Windsor 

Refuse and Recycling, or another similar company. 

Assuming a disposal rate of 2.53 lbs/person/day (USEPA, 2007c), and 55 residences with an 

average household size of 2.61 persons (U.S. Census Bureau, 2006), 363 lbs of solid waste per 

day would be generated. The amount of solid waste generated by the community buildings would 

be equal to the Proposed Project. Because most Tribal residents and potential employees already 

live within the County, and because the solid wastes generated by this development could be 

taken to any of four landfills used by Windsor Refuse and Recycling, the impact would be less 

than significant. 

Electricity, Natural Gas, and Telecommunications 

Electrical, natural gas, and telephone services would be the same as those described for the 

Proposed Project. The Tribe would coordinate with PG&E and AT&T regarding the extension of 

services to the project site. The project would use propane, rather than natural gas, which it 
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would contract directly from local supply companies in the area. No adverse utility service 

impacts would occur. 

Law Enforcement 

Under Public Law 280, the State of California and other local law enforcement agencies have 

criminal enforcement authority on Tribal lands. The Sonoma County Sheriff’s Department 

Office would provide law enforcement services to the project site. Calls for service would not be 

disproportionate to other residential or commercial development in the County. No significant 

impacts to law enforcement services would occur. 

Fire Protection and Emergency Medical Services 

The increased risk of fire during the construction of the proposed facilities would be similar to 

that found at other construction sites. Because the project site is in an area classified as a High 

Wildland Fire Zone, construction-related impacts would be potentially significant. With the 

implementation of the protective measures listed in Section 2.0 1.9 and the mitigation measures 

listed in Section 5.09, impacts to fire protection and emergency medical services would be 

reduced to less-than-significant levels. 

Current Design standards equivalent to current building and fire codes will be adhered to in 

relation to fire safety. The additional demand for fire protection and emergency medical services 

would be similar to that of the Proposed Project. Due to the existing agreements and availability 

of emergency medical services, the impacts to these services would be less than significant. 

Public Schools 

As described in Section 4.1.9, Sonoma County has set forth policies that would accommodate the 

minor increase in students within the HPA. No significant impacts to public schools would 

occur. 

Parks and Recreation 

The Reduced-Intensity Alternative would include multi-use trails and a greater amount of 

recreational area than Alternatives A or B. No adverse impacts would occur to local parks or 

recreational facilities. 

4.3.10 NOISE

Construction activity noise for the Reduced-Intensity Alternative would be reduced in duration 

and/or intensity compared with Alternative A. Construction noise is considered intermittent and 

temporary in nature; the inclusion of the mitigation presented in Section 5.10 would ensure that 

construction noise impacts from Alternative C would be less than significant. 
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The primary source of area noise that would be generated by the Reduced-Intensity Alternative 

would be traffic on Windsor River Road, as well as occasional and intermittent noise from the 

proposed WRFWTRF. Vehicle trips generated during the peak AM and PM hours would be less 

than those described under Alternative A. The existing noise environment is approximately 55 

dB. The WRFWTRF operational noise would not be noticeable at any on-site or off-site 

residences unless operational pumps and generators were not enclosed or shielded. Similar to 

Alternatives A and B, Alternative C would generate less than a three dBA increase in noise, thus 

impacts to the ambient noise environment would be less than significant with the possible 

exception of intermittent impacts to sensitive receptors located near the WTRF should it have 

unshielded pumps or generators. Thus, a potentially significant impact could result. 

Implementation of the protective measures presented in Section 2.1.9 and mitigation measures in 

Section 5.10 would ensure impacts are less than significant.. The Reduced-Intensity Alternative

would generate less than a 3 dB change in noise. In addition, implementation of the protective

measures presented in Section 2.0 would reduce noise impacts to offsite residents in the vicinity 

of the project site. Impacts to the noise environment would be less than significant. 

4.3.11 HAZARDOUS MATERIALS

As discussed under the Proposed Project and Alternative B, there are no identified hazardous 

materials on or near the project site. During construction, it is possible that hazardous materials, 

such as gasoline, diesel fuel, and hydraulic fluid, would be brought on site in temporary 

aboveground storage tanks. Additionally, the proposed WRFWTRF may use hazardous materials 

such as sodium hypochlorite and citric acid. The use and storage of hazardous materials is 

considered potentially significant. Protective measures are listed in Section 2.0 2.6 to reduce 

potential impacts to a less-than-significant level. 

4.3.12 VISUAL RESOURCES

Alternative C would result in the construction of a lower-density residential development 

compared with Alternatives A and B, and would include the same community center, retreat, 

roundhouse, water treatment and wastewater facilities. Development of the Reduced-Intensity 

Alternative would generally be completed in conformance with the County’s Rural Design 

Guidelines, and would complement existing rural residential development in the project area. 

Alternative C would include additional trees and shrubs to screen views of the wastewater 

facilities. Topography of the site and extensive existing vegetation also limits complete views of 

the property from the surrounding sensitive visual receptors and travelers on Eastside and 

Windsor River Roads. The development of Alternative C would not result in any significant 

impacts to visual resources. 
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4.4 ALTERNATIVE D - NO-ACTION 

4.4.1 LAND RESOURCES

Under the No-Action Alternative, the land would not be taken into trust and the proposed 

development would not occur. The site would remain as largely undeveloped woodland with a 

few scattered rural residences. Land resources would not be adversely impacted. 

4.4.2 WATER RESOURCES

Under the No-Action Alternative, the proposed residential, commercial, and recreational uses 

would not be developed. No additional impervious surfaces would be created on the project site. 

No adverse impacts to water resources would occur under the No-Action Alternative. 

4.4.3 AIR QUALITY

Under the No-Action Alternative the site would continue to be undeveloped land and none of the 

construction or operational air quality impacts identified for Alternatives A, B, or C would occur. 

The property could ultimately be developed, which would introduce a source of both direct 

(stationary source) and indirect (mobile source) emissions of pollutants of concern; however, 

because any development would be required to comply with the Sonoma County General Plan 

and would incorporate protective measures and BMPs for air quality, these impacts would likely 

be less than significant. 

4.4.4 BIOLOGICAL RESOURCES

Under the No-Action Alternative D, no development would occur within the project site. As 

such, there would be no significant direct or indirect impacts to the biological resources within or 

in the vicinity of the project site. 

4.4.5 CULTURAL RESOURCES

Under the No-Action Alternative the 92 124.12 acres would remain undeveloped. Therefore, 

there would be no adverse impacts to any unknown archaeological or paleontological resources 

on the site. 

4.4.6 SOCIOECONOMIC CONDITIONS/ ENVIRONMENTAL JUSTICE

Under the No-Action Alternative, the 92124.12-acre site would not be placed in trust for the 

benefit of the Tribe and the associated housing, community center, roundhouse, retreat facility, 

and water and wastewater facilities would not be constructed. The Tribe would not receive any 

of the socioeconomic benefits associated with the Proposed Project. The seven fourteen parcels 

comprising the project site would remain on Sonoma County’s property tax rolls. 
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4.4.7 TRANSPORTATION AND CIRCULATION

Under the No-Action Alternative, there would be no increase in vehicular traffic on project area 

roadways. None of the traffic impacts identified for the Proposed Project would occur under NoAction Alternative. 

4.4.8 LAND USE

Under the No-Action Alternative, the project site would remain under the jurisdiction of Sonoma 

County. No land use consistency or compatibility impacts would occur under this alternative. 

The project site would remain as woodland habitat under this alternative and no loss of 

agricultural resources or land use conflicts would occur. 

4.4.9 PUBLIC SERVICES

The No-Action Alternative would not increase demands on public services. The occupied 

residence on the project site would continue to utilize the existing groundwater well and septic 

system. No new utility extensions would be required. 

4.4.10 NOISE

Under the No-Action Alternative, the project site would remain undeveloped and largely open 

space with the exception of the existing houses. Any future development of the project site 

would be required to meet County design standards. With regard to noise, the project site would 

not be a source of transportation and/or non-transportation noise. No noise impacts would occur 

under the No-Action Alternative. 

4.4.11 HAZARDOUS MATERIALS

No hazardous material impacts would occur under the No-Action Alternative. 

4.4.12 VISUAL RESOURCES

Under the No-Action Alternative, the project site would remain undeveloped open space with the 

exception of the existing six twelve residences. Any future development of the project site would 

be required to meet County design standards. 
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4.5 CUMULATIVE EFFECTS 

Potential cumulative impacts for each environmental issue area are discussed below. Cumulative 

impacts are defined in 40 CFR §1508.7 as the impacts: 

... on the environment which result from the incremental impact of the action when added 

to other past, present, and reasonably foreseeable future actions regardless what agency 

(federal or non-federal) or person undertakes such other actions. Cumulative impacts 

can result from individually minor but collectively significant actions taking place over a 

period of time. 

Section 3.0 describes the existing conditions for the project site, documenting the current 

environmental conditions that are the result of past cumulative development. Any previous 

development within the project site would have occurred consistent with Sonoma County or 

Town of Windsor land use designations and general plans. As such, historical aerial photos 

dating back to 1952 indicate that the majority of the project site has undergone little changes in 

land use and development. Within the project site, individual residences and associated structures 

have been built on certain parcels. Minor oak woodland conversions primarily occurred on APN 

066-191-017, when mixed oak woodland was converted to pasture sometime between 1998 and 

2005. Consistent with County land use designations, agricultural operations have occurred on 

APNs 066-191-016, 066-191-019, 066-191-020, 066-191-021, 066-191-022 and 066-300-023, as 

evident from aerial photography between 1952 and now. Detailed descriptions of the existing 

conditions on each parcel are provided in Section 3.11. 

Cumulative impacts are considered based on a defined geographical boundary and time frame. 

For the purposes of this analysis, most potential cumulative effects are considered for the Town 

of Windsor, located adjacent to the east of the project site, and for Sonoma County on a larger 

scale. Estimated time frame for cumulative analysis is through 2030, for which information was 

available based on local general and specific plans. In accordance with CEQ guidelines

“Considering Cumulative Effects” and guidance for cumulative analysis under the BIA’s NEPA 

Handbook (59 IAM 3-H), not all potential cumulative effects are analyzed in this EA; only those 

considered to be relevant or consequential are discussed in depth below. 

The current and reasonably foreseeable future projects in the vicinity of the Proposed Project 

which have been considered for the cumulative impact analysis include: the Town of Windsor’s 

Eastside Road Storage Project, development of a retail tractor store (Tractor Supply Company), 

and the development of a senior citizen community complex (Town of Windsor, 2005). 
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Eastside Road Storage Project (Town of Windsor)

The proposed Eastside Road Storage Project would include an 18-acre storage pond located near 

the intersection of Eastside Road and Mark West Station Road approximately 3.5 miles south of 

the Proposed Project. The storage pond would be used in conjunction with an onsite pump 

station and pipeline to connect to the existing Town of Windsor recycled water distribution 

system. A Draft Supplemental Environmental Impact Report (SEIR) was prepared for the Town 

of Windsor to assess the impacts of the storage facility. The Draft SEIR was released for public 

and agency review for a 45-day comment period from May 22 to July 7, 2008 (CH2M Hill, 

2008a). A Final SEIR including responses to comments was published in October 2008 (CH2M 

Hill, 2008b). The project was approved by the Town of Windsor in October of 2008. 

Construction of the storage project may begin in approximately five years, with a completion date 

unknown at this time. 

Tractor Supply Store and Community Complex

The development sites for the retail tractor store and senior citizen complex are located 

approximately three miles southeast of the Proposed Project. The tractor supply store will be 

located at 1000 American Way. According the Town of Windsor Planning Department, the 

development of the retail tractor store and senior citizen complex have been preliminarily 

approved by the Town of Windsor; . The Town of Windsor passed Resolution 564-09 granting a 

Use Permit request for the tractor supply store in March, 2009; however, no record could be 

found regarding building permits have been issued for these two developmentsfor the senior 

citizen complex (Thompson, 2009). The tractor supply store development was determined to be

Categorically Exempt from CEQA. The proposed 3.03 acre development consisted of an 

approximately 23,000 square foot building with another 19,800 +/- square feet of storage (Town 

of Windsor, 2009). Currently, no other details or documentation on these projects are available. 

No known additional projects are currently planned in the vicinity of the Proposed Project. 

4.5.1 LAND RESOURCES

Potential project impacts to land resources (topography, soils, seismicity, and mineral resources) 

are related to measures required to ensure proper design for site conditions. Minimal changes in 

topography would occur, as cut and fill volumes would largely be utilized on-site. Reasonably 

foreseeable development projects could result in alterations to land resources to accommodate 

development in urban areas or areas designated under the Town of Windsor or Sonoma County 

General Plans. Future developments would be required to be in compliance with local and state 

building codes and ordinances to ensure buildings are constructed to appropriate seismic 

standards. Potential cumulative impacts to mineral resources would be less than significant. No 

potential cumulative impacts would be relevant to this issue area.
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4.5.2 WATER RESOURCES

The cumulative water resources analysis includes the Russian River watershed, including its 

receiving waters, San Pablo Bay thence San Francisco Bay, owing for the potential for water 

quality to be affected within this geographic region. Potential effects to water resources include 

sedimentation, pollution, stormwater flows and groundwater hydrology. As the Russian River 

originates from the Inner North Coast Ranges flowing throughout much of Sonoma County, 

reaches of the Russian River are already considered impaired as a result of urban runoff, water 

temperature and pollution. 

Developments within the Russian River watershed have the potential to impact existing runoff 

patterns owing to a decrease in impervious surface area. Future development projects along the 

Russian River watershed and Bay Area as a whole are expected to gradually increase, increasing 

the potential for increased runoff and pollution. However, tThe Proposed Project and other 

cumulative projects that may be constructed in the vicinity would be required to comply with the 

CWA as it relates to stormwater and point-source discharges. Compliance with USEPA for an 

NPDES permit and/or State stormwater pollution prevention requirements will prevent off-site 

development, in combination with the Proposed Project, from causing cumulatively significant 

stormwater related impacts. 

Impacts to the groundwater basin would not be cumulatively significant, as the Proposed Project, 

in combination with other known projects in the area, would use a relatively small increment of 

the available groundwater, because none of the cumulative projects would be a major water 

consumer. Additionally, the Eastside Road Storage Project is located in a separate geologic and 

hydrogeologic formation, the Wilson Grove Formation, than the Proposed Project (CH2MHill, 

2008a). Therefore, no cumulatively significant impact to groundwater would occur. 

Wastewater effluent would be required to meet Federal standards. Water for both the Proposed 

Project and the Eastside Road Storage Project would be treated to tertiary standards, in 

compliance with California Title 22 standards. As a part of the project Proposed Project design, 

any onsite wells would include 50-foot sanitary seals for protection of water quality. Impacts to 

water quality from the Proposed Project and Alternatives are further discussed under Sections 

4.1.2, 4.2.2, and 4.3.2. With the implementation of the protective measures listed in Section 2.0 

2.6 and the mitigation measures listed in Section 5.02, impacts to groundwater and surface water 

would be less than significant. Future projects would be required to comply with Town of 

Windsor and Sonoma County grading and erosion control ordinances. None of the cumulative 

projects would have an individually significant impact on groundwater quality, and cumulative 

impacts would also be less than significant. 
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4.5.3 AIR QUALITY

Cumulative impacts to the air basin are addressed within the requirements of the CAA and the 

General Conformity Rule. Significance levels under the General Conformity Rule are de minimis

levels shown in Table 4-1320. The Proposed Project does not reach the de minimis levels or 

exceed 10 percent of Sonoma County emissions required for Federal conformity (see Table 4-

1420). Therefore the Proposed Project would not result in a change in the basin’s air quality 

designation. The emission inventory for Sonoma County shows ROG at 9,015.5 tpy and 9,307.5 

tpy of NOx (CARB, 2008b). The Proposed Project, Alternative B, and Reduced-Intensity 

Alternative, when considered in combination with other planned and reasonable foreseeable 

future actions, would not lead to a cumulatively significant impact to air quality. 

TABLE 4-1420

ALTERNATIVES A, B, AND C CUMULATIVE EMISSIONS 

CAPs Alt A and B Alt C 

tons per year 

ROG 2.74 1.02 

NOx 1.22 0.46 

De Minimis Levels 100 100 

10% of County Emission Inventory? No No 

Significant? No No 

Source: URBEMIS, 9.2.4, 2007 

Please see Sections 4.1.3, 4.2.3, and 4.3.3 for an analysis potential cumulative climate change 

impacts. 

4.5.4 BIOLOGICAL RESOURCES

Potential impacts to biological resources on the project site, including sensitive habitats, 

potentially jurisdictional waters of the U.S., native trees, riparian habitat, special-status species, 

and migratory birds, will be reduced to a less-than-significant level through measures 

incorporated into project construction and design (Section 2.01.9) and mitigation (Section 5.04). 

Other developments in the vicinity, such as the Eastside Road Storage Project, would have the 

potential to impact similar habitats, including mixed oak woodland, oak savannah, annual 

grassland, mixed riparian and related aquatic habitats, and ruderal/developed or pasturine 

habitats. Any sensitive habitats with the potential to support populations of local endangered 

species would be protected from developmentthrough mitigation requirements outlined in by the 

Santa Rosa Plain Conservation Strategy (USFWS, 2005a). Cumulative iImpacts to native trees 

would be mitigated by compliance with the Sonoma County Tree Ordinance and/or the VOH 

Combining Design zoning designation, depending on the location of specific cumulative projects. 

Any cumulative developments affecting jurisdictional waters of the U.S. or special-status species 

would be required to mitigate according to the applicable provisions of the CWA and the FESA, 

and migratory birds would be protected from take subject to the MBTA. Owing to the 
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requirement to comply with pertinent local, state and federal regulations, cCumulative impacts to 

biological resources would be less than significant. 

4.5.5 CULTURAL RESOURCES

Cumulative effects to cultural resources typically occur when sites that contain cultural features 

or artifacts are disturbed by development. As these resources are destroyed or displaced, 

important information is lost and connections to past events, people and culture is diminished. As 

the Town of Windsor and Sonoma County continue to grow, resources, including historic 

buildings and archaeological sites, may be lost. Sonoma County contains extensive cultural 

resources, including Pomo and Coast Miwok Indian sites and historical sites associated with early 

ranching, homesteads, and agriculture. Known sites in Sonoma County include Native American 

archaeological sites with bedrock mortars, village sites, and dance houses or roundhouses; and 

historic sites, including historic buildings, homes, and churches. Impacts to these cultural 

resources are likely to occur as residential and commercial growth occurs in Sonoma County, 

including near the communities of Windsor, Healdsburg and their surrounding cities. 

No significant cultural resources were identified within or adjacent to the project site. However, 

the records search and archival research indicate that the study area is in a region sensitive for 

both prehistoric/pre-contact resources and historic-period resources. Prehistoric archaeological 

sites recorded in the general vicinity of the project area include rock alignments, human 

cremations, habitation areas, trails, and lithic scatters. Historic-period archaeological sites in the 

general area include wagon roads, trails, homesteads and ranches. Based on this sensitivity, the 

Proposed Project may impact previously unknown archaeological resources, as these sites may be 

buried with no surface manifestation. Significant cumulative impacts to unknown cultural 

resources could occur if sites continued to be lost, damaged, or destroyed without appropriate 

recordation or data recovery. Mitigation for potential cumulative impacts to unknown cultural 

resources has been specified in Section 5.0 5 and similar measures are required for all 

development in Sonoma County to comply with Sonoma County policies, Federal regulations as 

described in Section 3.5.1, and the California Environmental Quality Act (CEQA). 

Implementation of these measures would reduce cumulative impacts to a less-than-significant 

level. 

4.5.6 SOCIOECONOMIC CONDITIONS / ENVIRONMENTAL JUSTICE

Potential effects to socioeconomic/ environmental justice conditions include significant increases 

in crime, dramatic shifts in employment and adverse changes in a town or community’s ability to 

fund public services. The current trend within Sonoma County and much of the Bay Area is a 

rising availability of vacant homes, with slight drops in employment in certain areas. The 

Proposed Project and alternatives, Alternative B, and Reduced-Intensity Alternative when 
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considered in combination with other planned and reasonable foreseeable future actions such as 

the Eastside Road Storage Project, have the potential to reduce housing vacancy and provide job 

opportunities for local residents. This could be a potential benefit to Sonoma County and the 

Town of Windsor, and would not lead to a significant cumulative impact to socioeconomic 

conditions or environmental justice. 

4.5.7 TRANSPORTATION AND CIRCULATION

Trip Generation and Distribution 

The estimated a.m. and p.m. peak-hour trips under the Proposed Project were added to the 

cumulative condition volumes, which were developed using information from the Town of 

Windsor 2015 General Plan (Town of Windsor, 2005). This resulted in the estimated traffic 

volumes on the study area roadway system under Cumulative plus Proposed Project conditions 

(Appendix G). 

Cumulative Plus Project Intersection Levels of Service 

The LOS at the study intersections were evaluated using the estimated a.m. and p.m. peak-hour 

traffic volumes for Cumulative plus Proposed Project conditions. Table 4-15 21 summarizes the 

results of this analysis. Intersection #6 (Windsor River Road and Bell Road) is expected to 

operate at LOS F in the Cumulative scenario; addition of project traffic to this intersection would 

exacerbate the already unacceptable operating conditions. This would be considered a significant 

impact. 

Improvements are planned for Intersections # 6 and #9 (Windsor River Road and NB 101 Offramp). Specifically, the Town of Windsor Traffic Impact Fee Program includes the installation of 

a traffic signal at Intersection # 6 (Windsor River Road and Bell Road) and improvements at 

Intersection # 9 (Old Redwood Highway and northbound Hwy 101 Off-Ramp). The programmed 

improvements at Intersection # 9 include construction of an additional southbound left turn lane, 

an additional southbound right turn lane, and restriping the northbound approach to include a 

shared through left lane. It should be noted that Caltrans has also specified the future 

improvements at this intersection could include a separate right turn pocket for the westbound 

approach and widening of the northbound 101 off-ramp to allow for an exclusive left turn lane, a 

shared left through lane, a through lane, and a right turn lane (for a total of four approach lanes). 

However, full funding for these improvements has not currently been secured, thus they were not 

assumed to be in place for the cumulative analysis. Therefore, tTraffic generated from the 

Proposed Project at Intersection # 9 would decrease the operations at this intersection to an 

unacceptable LOS, creating a potentially significant impact. Implementation of proposed 

mitigation measures described in Section 5.0 7 would reduce these impacts to less-thansignificant levels. 
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TABLE 4-1521

LEVEL OF SERVICE SUMMARY FOR CUMULATIVE PLUS PROJECT CONDITIONS (REVISED)

Cumulative Cumulative plus Project

Intersection Traffic 

Control 

AM Peak PM Peak AM Peak PM Peak

LOS Average 

Delay LOS Average Delay LOS Average Delay LOS Average Delay 

#1. Eastside 

Road and Windsor 

River Road 

Stop 

Sign 

(Future) 

B 10.4 B 10.4 B 10.5 B 10.5 

#2. Windsor River 

Road and Project 

Entrance (#1) 

Stop 

Sign 

(Future) 

A 9.9 A 9.7 B 10.4 B 10.1 

#3. Windsor River 

Road and Project 

Entrance (#3) 

Stop 

Sign A 10.0 A 9.7 B 11.0 B 11.2 

#4. Windsor River 

Road and Starr 

Road 

All-Way 

Stop B 13.3 B 11.1 B 14.8 B 12.4 

#5. Windsor River 

Road and Windsor 

Road 

Traffic 

Signal D 42.1 C 31.4 D 44.1 C 31.6 

#6. Windsor River 

Road and Bell 

Road 

Stop 

Sign E 46.4 F 62.2 F 54.7 F 82.5 

#7. Windsor River 

Road and Old 

Redwood 

Hwy/Conde Lane 

Traffic 

Signal C 37.1 D 44.8 D 37.8 D 48.8 

#8. Old Redwood 

Hwy and SB Hwy 

101 Ramps 

Traffic 

Signal C 20.1 C 24.8 C 22.4 C 25.7 

#9. Old Redwood 

Hwy and NB Hwy 

101 Off-Ramp – 

Lakeside Road 

Traffic 

Signal C 32.5 D 40.5 C 34.4 D 41.8 

#10. Old 

Redwood Hwy and 

Project Entrance 

#2 

Stop 

Sign A 9.5 A 9.5 A 9.5 A 9.5 

Note: LOS- Level-of-Service 

Source: Abrams Associates, 2010; Appendix G

Bicycle, Pedestrian, and Transit Networks 

The Proposed Project would not result in an increase in bicycling or transit rider activity. 

Additionally, the project would not adversely affect a pedestrian or bicycle networks under the 

Cumulative plus Proposed Project conditions. None of the known cumulative scenario projects 

are expected to affect these networks. No significant cumulative impacts would occur. 

4.5.8 LAND USE

Cumulative land use impacts are generally defined for Sonoma County, owing to the project site 

location and consideration of proposed cumulative impacts within the County, which would be 

considered negligible outside the County. If taken into Federal trust, the project site would not be 
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subject to City or County jurisdiction regarding land uses. Any surrounding cumulative projects, 

however, would be subject to local land use regulations. Cumulative impacts would occur if 

expected growth would conflict with established General Plans or Specific Plans, conflicts with 

existing land uses, or create impediments to such plans. Since the project alternatives and the 

Eastside Road Storage Project are generally consistent with the existing and proposed land uses in 

the vicinity, no cumulative land use impacts would occur. 

Agriculture 

The retention or development of agricultural land is largely a policy consideration for 

governmental entities. Prime and unique agricultural lands are considered a limited and valuable 

resource. Impacts to these lands must therefore be analyzed according to NEPA and the 

Farmland Protection Policy Act (FPPA). All land uses in the region are subject to approval by 

local government entities. The project site does not contain prime or unique farmland (Appendix 

H), however the parcel immediately south of the site is designated as prime agricultural land and 

is currently in vineyard operation. The developers of any nearby projects would be required to 

comply with local jurisdictional approval. Considering that the proposed project site is not used 

for agriculture, and no known agricultural conversions are proposed for the area, cumulatively 

significant impacts to agricultural land would not occur. 

4.5.9 PUBLIC SERVICES

Public services for the Proposed Project would be accommodated by existing and planned public 

services, or would be provided by the Tribe’s own facilities. As development of other areas 

continues, the combined need for public services may create a cumulative impact. As 

development occurs within Sonoma County and surrounding the Town of Windsor, demands on 

community and public services may increase. The County and Town may respond by increasing 

local taxes and fees to fund law enforcement, fire fighting, water and wastewater facilities to 

serve the increase demand. Development of the Proposed Project would not be subject to County 

or Town fees or taxes. However, aAll future land uses in the region would be subject to approval 

by local governments, and would include provisions for public services. Additionally, the Tribe 

would enter into service agreements with public service providers in manner that may be 

mutually compatible. As a result, the Proposed Project combined with future potential 

developments would not result in significant cumulative impacts to public services. 

4.5.10 NOISE

Traffic noise would dominate the noise environment in the area surrounding the project site 

during cumulative conditions. The impact of the proposed project on the cumulative noise 

environment would not change during future cumulative conditions and only minimal cumulative 

development would occur within the vicinity of the project site. Thus, Tthe Proposed Project, in 
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combination with the proposed cumulative projects in the area, would cause a less-thansignificant impact with regard to noise. 

4.5.11 HAZARDOUS MATERIALS

There is the potential for impacts related to hazardous materials to be discovered during 

construction of the Proposed Project , which could result in an environmental impact. as well as 

the oOther cumulative projects and a. Any new developments would be required to adhere to 

State and municipal regulations regarding the delivery, handling, and storage of hazardous 

materials, thereby reducing the risk to the public’s health and welfare due to accidental exposure. 

Therefore, with the implementation of mitigation measures for the Proposed Project described in

Section 5.11, there are no significant cumulative hazardous materials impacts associated with the 

Proposed Project. 

4.5.12 VISUAL RESOURCES

The geographic boundary of the cumulative analysis for visual resources is defined as the general 

viewshed surrounding the project site. Surrounding topography, geographical barrier and 

physical structures would obscure views of visual resources over a significant distance. 

Development of the project site under the Proposed Project, Alternative B and the ReducedIntensity Alternative would be generally consistent with the County’s Rural Design Guidelines, 

with no significant impacts to scenic views or features. Maintenance of existing native vegetation 

and planting of new vegetation would provide visual screens in character with the region. Any 

future development in the vicinity would be subject to County review and approval, and 

potentially significant impacts to visual resources would require mitigation. Therefore, the 

Proposed Project, Alternative B, or Reduced-Intensity Alternative, when considered in 

combination with other planned and reasonably foreseeable future actions, would not lead to a 

significant cumulative impact to visual resources. 

4.6 INDIRECT AND GROWTH-INDUCING EFFECTS 

Under NEPA, indirect and growth-inducing effects of a Proposed Project must be analyzed (40 

CFR §1508.8[b]). The CEQ Regulations define indirect effects as effects that are caused by the 

action and are later in time or further removed in distance, but are still reasonably foreseeable. 

Growth-inducing effects are defined as effects that foster economic or population growth, either 

directly or indirectly. Direct growth inducement could result, for example, if a project included 

the construction of a new residential development. Indirect growth inducement could result if a 

project established substantial new permanent employment opportunities (e.g., new commercial, 

industrial, or governmental enterprises) or if it removed obstacles to population growth (e.g., 

expansion of a wastewater treatment plant to increase the service availability). Section 4.6.1
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assesses the potential for growth inducing effects caused by the alternatives. Section 4.6.2 

assesses indirect effects caused by the offsite construction of water and wastewater infrastructure 

and associated pipeline proposed for Alternative A. Other indirect effects are analyzed in 

previous sections by issue area. 

4.6.1 GROWTH INDUCING EFFECTS

Growth inducement may constitute an adverse impact if the increased growth is not consistent 

with or accommodated by the land use and growth management plans and policies for the area 

affected. Local land use plans provide for development patterns and growth policies that allow 

for orderly development supported by adequate public services and utilities such as water supply, 

roadway infrastructure, sewer services, and solid waste disposal services. A project that would 

induce “disorderly” growth (i.e., would conflict with local land use plans) could indirectly cause 

adverse environmental or public service impacts. 

The Proposed Project would include new housing for Lytton Tribal members. Many Tribal 

members are currently residents of Sonoma County, notably the greater Windsor/Santa Rosa area, 

and these families and individuals would constitute the majority of the expected residents of the 

new housing. Few, if any, long-term or permanent employment opportunities would be created. 

Therefore, it is anticipated that the net direct local population growth resulting from the project 

would be minimal. 

Analyses of the adequacy of local infrastructure and services are included in the discussion of 

environmental consequences for each proposed Alternative. No significant, unmitigatible 

impacts have been identified that would result from the Proposed Project. Utility infrastructure 

would not be significantly improved or expanded to increase service availability to any areas 

surrounding the project site. Growth-inducing impacts would be less than significant for all of 

the proposed alternatives. 

4.6.2 INDIRECT EFFECTS FROM OFF-SITE WATER AND WASTEWATER 

 IMPROVEMENTS 

Offsite water and wastewater infrastructure and associated pipeline may be constructed under 

Alternative A as described in Section 2.1 and Appendix B. Water would be supplied to the 

project site through a connection to the municipal water system of the Town of Windsor under an 

agreement to be negotiated between the parties. It is anticipated that the existing municipal 

system would be able to accommodate the water demands of the project. An existing 18-inch 

diameter water main associated with the Town of Windsor’s public water supply system is 

located parallel to Windsor River Road, immediately north of the project site. Two connections 

would be made to this water main to serve the project site. If required, each of these connections 

would include a meter and backflow prevention facilities. Wastewater would be conveyed to the 
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Town of Windsor WWTRDF through the existing municipal sewer collection system. The Tribe 

would enter into an agreement with the Town of Windsor for sewer service. It is anticipated that 

the existing WWTRDF would have sufficient treatment and disposal capacity. In order to 

connect to the WWTRDF, a sewage lift station and approximately 3,200 feet of force main would 

be constructed that would connect to a manhole located near the intersection of Windsor River 

Road and Starr Road. The construction of these improvements would occur primarily along 

existing disturbed roadways. The following section identifies the potential indirect environmental 

effects of construction of these improvements. 

Land Resources 

The construction of offsite improvements may require trenching and backfilling/re-paving, which 

could result in erosion of soils. Applicable local agency requirements, including California 

Environmental Quality Act (CEQA) review if required, would be satisfied prior to 

commencement of construction of offsite improvements. If construction of offsite improvements 

would disturb over one acre in area, a NPDES construction permit would be obtained from the 

Regional Water Quality Control Board. A SWPPP would be developed that would include soil 

erosion and sediment control practices to reduce the amount of exposed soil, prevent runoff from 

flowing across disturbed areas, slow runoff from the site, and remove sediment from the runoff. 

With standard construction practices and specifications required by the NPDES permit program, 

the offsite improvements are expected to result in less than significant indirect effects to land 

resources. 

Water Resources 

The development of offsite improvements could affect water resources due to construction 

activities. Potential effects include increased erosion that could adversely affect surface water 

quality due to increases in sediment. As discussed above, a SWPPP would be developed, which 

includes soil erosion and sediment control practices. With implementation of the soil erosion and 

sediment control practices identified in the SWPPP, effects to water resources would be less than 

significant. 

Air Quality 

Construction of offsite water and wastewater infrastructure and associated pipeline would result 

in short-term construction-related air pollution emissions. The construction phase is anticipated 

to produce two types of air contaminants: exhaust emissions from construction equipment and 

fugitive dust generated as a result of demolition and soil movement. Exhaust emissions from 

construction activities include those associated with the transport of workers and machinery to the 

site, as well as those produced on site as the equipment is used. Construction of offsite 

improvements would be limited in scope and duration. Thus a less than significant indirect effect 

would result. In addition, mitigation measures are typically required by local jurisdictions to 
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reduce construction emissions, often in conjunction with required CEQA review. These include 

watering the exposed soil to reduce dust, maintaining equipment properly, etc. 

Biological Resources 

Construction of the offsite water and wastewater infrastructure and associated pipeline has the 

potential to impact vegetation communities and unidentified potential waters of the U.S. 

Removal of sensitive native vegetation and vegetation that provides habitat for special-status 

species or supports migratory birds could result in potentially significant effects. The 

modifications of potential waters of the U.S. and the direct loss or harm to sensitive animal 

species are also considered potentially significant effects. 

Most of the habitat that exists in the offsite improvement area is highly disturbed roadsides or 

totally disturbed roadways. Due to the degraded condition of the roadway/roadside areas, habitat 

quality is generally low and it is unlikely that construction would result in a significant effect to 

sensitive species. However, in order to address potential impacts to biological resources, 

biological resource surveys may be required to comply with CEQA. The lead agency under 

CEQA would be required to mitigate any potential impacts to a less than significant level or to 

issue a finding of fact and statement of overriding considerations if significant impacts could not 

be mitigated. Due to the limited nature of the offsite improvements along existing roadways, the 

degraded condition of existing habitat, and the requirements of CEQA to address impacts to 

biological resources, the effects of extending existing pipelines would be less than significant. 

Cultural Resources 

The construction of offsite improvements has the potential to disturb or destroy historical features 

and archaeological resources. Trenching to add pipeline may disturb previously unknown sites. 

Due to prior grading of the existing roadways and occasional traffic on roadsides, it is likely that 

resources remaining in these areas are highly disturbed and lack integrity, thus diminishing the 

significance of the remaining resources. 

To address potential impacts to cultural resources, cultural resource surveys may be required to 

comply with CEQA. The lead agency under CEQA would be required to mitigate potential 

impacts to a less than significant level or to issue a finding of fact and statement of overriding 

considerations if significant impacts could not be mitigated. Mitigation may include the 

avoidance of resources, the preservation of key historical features, or the removal, documentation, 

and curation of cultural resources. Therefore, a less than significant indirect effect to cultural 

resources would result. 

Socioeconomic Conditions/Environmental Justice 

Construction of offsite improvements could result in short-term inconveniences and minor delays 

due to constricted traffic movements and possible temporary detouring of traffic. The 
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improvements are not expected to result in long-term disruption of access to surrounding land 

uses or to minority or low-income populations and would not result in a significant indirect effect 

related to socioeconomic conditions. 

Transportation and Circulation 

As mentioned previously, construction of offsite improvements could result in minor delays due 

to constricted traffic movements and possible temporary detouring of traffic. Local agency 

requirements would be implemented during construction. The improvements are not expected to 

result in long-term road closures and would not result in a significant indirect effect to 

transportation and circulation. 

Land Use 

Construction of offsite water and wastewater infrastructure and associated pipeline may require 

utility easements which would limit future construction. An easement is a right, privilege or 

interest limited to a specific purpose which one party has in the land of another. Underground 

utility easements are typically laid out as corridors of sufficient width to give some latitude in 

locating the actual utility line, and to permit sufficient room for periodic inspection, repair and 

maintenance. Underground utility easements typically prohibit the construction of building 

improvements, but may permit the construction of non-structural improvements, such as paved 

surface parking or landscaping. The force main is anticipated to follow public roads and would 

not be in an area where a building would normally be built or where an agricultural field would 

be plowed. Therefore, less than significant indirect impacts to land uses would occur. 

Public Services 

The Tribe would adhere to local regulations for extending water and sewer service to the project 

site, including the Town’s Sanitary Sewer Management Plan. Construction of offsite 

improvements could result in a temporary break in water, wastewater, or other services to some 

homes in the area. However, because these effects are common when upgrading and maintaining 

utility services, and because potential service breaks would be temporary, these effects would be 

less than significant. No effects to fire or emergency medical services are expected as access to 

adjacent homes would be maintained during construction of the improvements. 

Noise 

Construction activities would result in short-term increases in the local ambient noise 

environments. However, because construction activities would be temporary in nature and are 

expected to occur during normal daytime hours, a less than significant effect is expected. 
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Hazardous Materials 

The accidental release of hazardous materials used during construction activities could pose a 

hazard to construction employees and the environment. Additionally, equipment used during 

construction activities could ignite dry grasses and weeds in construction areas. However, these 

hazards, which are common to construction activities, would be minimized with adherence to 

standard operating procedures, such as refueling in designated areas, storing hazardous materials 

in approved containers, and clearing dried vegetation. These potential hazards are therefore 

considered to be less than significant. 

Visual Resources 

Because the majority of the proposed offsite water and wastewater infrastructure and associated 

pipeline would be constructed below ground, visual indirect effects would be less than 

significant. 
SECTION 5.0 

MITIGATION MEASURES
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SECTION 5.0 

MITIGATION MEASURES 

The Tribe shall pass a resolution requiring full compliance with all of the following mitigation 

measures. All mitigation that is necessary to reduce significant impacts to a less than significant 

level will be binding on the Tribe because it is subject to a Tribal resolution, intrinsic to the 

project, required by federal law, and/or required by agreements between the Tribe and local 

agencies. The construction contract for the Proposed Project will include applicable mitigation 

measures, and inspectors shall be retained during construction. 

5.1 LAND RESOURCES 

Implementation of the protective measures and Best Management Practices (BMPs) described in 

Section 2.01.9, along with the mitigation measures below shall minimize potential impacts 

related to soils. These measures are recommended for Alternatives A, B, and C. 

 All site preparation and earthwork construction in the field shall be performed by 

licensed contractors. 

 Suitability of earth and construction materials shall be determined by a licensed 

professional employing geotechnical/soils laboratory testing standards according to 

standard engineering practice. 

 All grading plans, subsurface investigations, and slope stability and seismic design 

calculations as well as all foundation, paving, and building design parameters shall be 

produced under the supervision of appropriate licensed professionals. 

 Construction on expansive soil shall be mitigated by using specialized grading techniques 

or designing structural foundations to withstand expansion pressures. 

 The effects of soil movement shall be mitigated by strengthening the soils during grading 

and/or designing and constructing satisfactory foundation support. 

 Prior to finalization of the grading and development plans for the property, design-level 

geotechnical specifications addressing the specific grading and development plans shall 

be developed. The specifications should include, but not be limited to, the following: 

 Site, building and facility-specific grading recommendations regarding site 

preparation, clearing and grubbing. 

 Select grading procedures, remedial grading procedures, material suitability and 

compaction criteria. 
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 Cut and fill slope stability analyses, recommended slope configurations and 

inclinations. 

 Evaluation of soil expansion and corrosion potential. 

 Building-specific foundation design parameters. 

 Site-specific seismic design parameters. 

 Lateral earth pressure parameters for retaining wall design, if any. 

 Pavement design specifications. 

 

5.2 WATER RESOURCES 

Implementation of the protective measures and BMPs described in Section 2.0 1.9 along with the 

recommended mitigation measures below would minimize potential impacts related to the 

construction of Alternatives A, B, and C. 

 The Tribe shall obtain a National Pollutant Discharge Elimination System permit 

(NPDES General Permit) from the USEPA for construction site runoff during the 

construction phase in compliance with the Clean Water Act (CWA). A Storm Water 

Pollution and Prevention Plan (SWPPP) shall be prepared, implemented, and maintained 

throughout the construction phase of the development, consistent with General Permit 

requirements. The SWPPP would detail the BMPs to be implemented during 

construction and post-construction operation of the Proposed Project. The BMPs may 

include, but are not limited to, the following: 

 Straw wattle placement on cut and fill slopes. 

 Straw wattle check dam installation within drainage swales. 

 Covering disturbed areas with plastic, hydro-seed applications, or straw. 

 Construction entrance installation to reduce off-site sediment transport. 

 Revegetation following construction activities. 

 If Alternative B or C is chosen, the Tribe shall construct a the tertiary wastewater 

treatment and reclamation plant facility (WTRF) as described in Appendix B. Salt-based 

chemicals shall not be used whenever feasible in the wastewater treatment process. 

Water softeners that dispose of salt into the wastewater system shall be prohibited. 

 Should Alternative B be chosen, the Tribe shall obtain a NPDES permit for surface 

discharge of treated effluent. An energy dissipater that does not result in any fill of 

waters of the U.S. shall be installed at the effluent discharge outfall. 

Implementation of the recommended mitigation measure below would minimize potential 

impacts related to the wastewater effluent discharge from Alternatives B and C.
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 Wastewater effluent discharge shall be reduced or eliminated, if possible, during the 

issuance of an Urban and Small Streams Flood Advisory by the National Weather 

Service for the receiving waters into which project effluent is discharged. 

 Community education programming will be conducted to educate residents of the 

importance of reducing chemical product use and disposal in the home and minimizing 

release of medicines and other contaminants into wastewater. 

 All effluent discharge basins shall maintain a minimum vertical distance of two feet 

freeboard between the high water level and pond levee crowns. Storage basins will also 

be gated to restrict access. All basins shall be equipped with draining systems and level 

monitors.

 Spray drift from the spray disposal irrigation areas would be monitored daily during 

operation by qualified personnel. Spray drift shall not be allowed to migrate outside of 

the irrigation area. 

 Spray irrigation would cease when winds exceed 30 miles per hour.

 The Tribe would adopt standards equivalent to the landscape irrigation standards in the 

State Water Resources Control Board Recycled Water Policy (as referenced in 

Resolution No. 2009-0011).

 A wastewater contingency plan shall be developed that ensures untreated wastewater is 

not discharged to the environment in the event of WTRF failure or malfunction. 

Implementation of the recommended mitigation measure below for Alternatives A, B, and C 

would assist in regional groundwater monitoring efforts.

 The nested monitoring well constructed for the hydrogeologic investigation shall be 

maintained and used for groundwater-level monitoring. 

5.3 AIR QUALITY 

5.3.1 CONSTRUCTION

Implementation of the protective measures and BMPs described in Section 2.0 along with the 

recommended mitigation measures listed below would minimize potential impacts associated 

with air quality for Alternatives A, B, and C. 

 Construction vehicles, delivery, and commercial vehicles shall not idle for more than five 

minutes. 

 The Tribe shall designate an onsite Air Quality Construction BMP Manager (AQCBM),

who shall be responsible for directing compliance with BMPs for the project construction 

heavy-duty equipment.

 Heavy, diesel-powered equipment idling shall be limited to two minutes. 
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 The Tribe shall use heavy duty construction equipment equipped with a diesel particulate 

matter filter. 

 The Tribe shall fully fund a program to encourage and facilitate the use of ‘carpools’ by 

construction workers, including providing an off-site location for construction workers to 

park their vehicles and meet to carpool.

 If possible, the Tribe shall use heavy duty construction equipment, which meets CARB’s 

most recent certification standards.

 The Tribe shall provide a storage area for recyclables and green waste during 

construction. 

 The Tribe shall recycle 50 percent or more of construction waste.

 The Tribe shall use environmentally preferable materials to the extent practical for 

construction of facilities. Buildings will be designed to meet LEED or equivalent 

certification standards, except with respect to indoor smoking allowed in certain 

restricted areas. 

 The AQCBM shall be responsible for directing compliance with the following BMPs for 

fugitive dust control practices during project construction: 

 For any earth moving which is more than 100 feet from all property lines, conduct 

watering as necessary to prevent visible dust emissions from exceeding 100 feet in 

length in any direction. 

 For all disturbed surface areas apply dust suppression in a sufficient quantity and 

frequency to maintain a stabilized surface; any areas, which cannot be stabilized, as 

evidenced by wind driven dust, must have an application of water at least twice per 

day to at least 80 percent of the unstabilized area. 

 Establish a vegetative ground cover as soon as feasible after active operations have 

ceased. 

 For all unpaved roads either water all roads used for any vehicular traffic as often as 

necessary to minimize dust; or apply chemical stabilizer to all unpaved road surfaces 

in sufficient quantity and frequency to maintain a stabilized surface. 

 Provide track-out control to minimize tracking of soil onto neighboring roadways.

 For all off site haul vehicles, cover loads. 

 Grading activities shall not occur when winds exceed 25 miles per hour (mph).

 Speed on unpaved roads shall be limited to 15 mph.

5.3.2 CLIMATE CHANGE 

Table 5-1 shows the unmitigated, project-related GHG emissions. Implementation of the 

mitigation measures described in Table 5-1 would reduce all construction and operational-related 

criteria air pollutants to levels below the BAAQMD thresholds for significance. Thus, the project 

would result in a less-than-significant cumulative impact from GHG emissions for all 

alternatives. 
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TABLE 5-1 (NEW TABLE)

ESTIMATED GHG EMISSIONS AND QUANITIFICATION OF MITIGATION REDUCTIONS 

CONSTRUCTION Percent 

Reduction 

Alternatives 

A and B C 

Metric Tons of CO2e 

CONSTRUCTION 

Unmitigated Emissions1 1,169 829 

Mitigation Reductions2

Purchase Carbon Credits (refer to MM below) 69 0 

GHG Emissions After Mitigation 1,100 829 

Significant After Mitigation No No 

OPERATION 

Unmitigated Emissions1 2,946 1,109 

Mitigation Reductions2

Mobile (refer to Mobile MM below) 1% Mobile 29 11 

Electricity (refer to Electricity MM below) 100% 

Electricity 215 80 

Subtotal 2,702 1,018 

Purchase Carbon Credits (refer to MM below) 1,602 0 

Total GHG Reductions 1,846 91 

Estimated Project Related GHG Emissions After Mitigation 1,100 1,018 

Significant After Mitigation No No 

Notes: 

MM = Mitigation measure.

1

 Emissions estimates provided by URBEMIS air quality model (Appendix D of EA). 2 Emission reduction provided in the BAAQMD Guidelines. 

Source: AES, 2010 

Mobile

 For operation of the proposed project, the Tribe shall institute and fund an on-site waste 

composting program. Waste composting reduces GHG emissions from landfills. This 

mitigation measure would reduce GHG emissions from mobile sources by one percent. 

Electricity 

 For operation of the proposed project, the Tribe shall plant trees and other carbonsequestering vegetation (as part of the Mitigation Measure outlined for native oak trees in 

Section 5.4.2). The addition of photosynthesizing plants would reduce atmospheric 

carbon dioxide (CO2) because plants use CO2 for elemental carbon and energy 

production. Trees planted near buildings would result in additional benefits by providing 

shade to the buildings, reducing heat absorption and the need for air conditioning. 

According to the BAAQMD, implementation of this mitigation measure would reduce 

the project’s electricity consumption, thus lowering indirect GHG emissions in the 

residential air conditioning sector by up to 30 percent (Table 5-1). 

 The Tribe shall use solar hot water heaters where possible for all project components. 

The use of solar hot water heaters would reduce project’s energy usage, thus lowering 
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indirect related GHG emissions by reducing natural gas and electricity usage. According 

to the BAAQMD, implementation of this mitigation measure would reduce the project’s 

indirect GHG emissions in the residential natural gas water heating sector by up to 70 

percent (Table 5-1).

 The Tribe shall seal all residential and other buildings heating, ventilation, and air 

conditioning ducts. According to the BAAQMD, implementation of this mitigation 

measure would reduce the project’s electricity consumption, thus lowering indirect GHG 

emissions in the residential air conditioning sector by up to 30 percent (Table 5-1).

Implementation of the following mitigation measure (if necessary) for construction of the 

proposed project would reduce Alternatives A and B project-related GHG emissions to below the 

BAAQMD threshold.

 

 Purchase GHG emissions credits in the amount specified in Table 5-1. 

5.4 BIOLOGICAL RESOURCES 

Implementation of the protective measures and BMPs described in Section 2.0, along with the 

mitigation measures below, would ensure that impacts to biological resources are less than 

significant. 

5.4.1 WATERS OF THE U.S. 

The following mitigation measures are recommended for Alternatives A, B, and C to avoid and/or 

reduce impacts to waters of the U.S. (including wetlands) within the project site: 

 A 50-foot setback, where possible, shall be established around each of the potentially 

jurisdictional wetland features within the project development and no development 

shall occur within the setback areas. 

 Prior to the onset of construction activities, these wetland avoidance setbacks shall be 

established around jurisdictional wetland features using high-visibility fencing. A 

qualified biologist shall be present during construction activities that ensue within the 

vicinity of the wetland avoidance buffer zones. The qualified biologist shall monitor 

during construction to make sure that the fencing remains intact and that construction 

activities do not penetrate the wetland avoidance buffer zones. When project 

development is completed, the high-visibility fencing may be removed. 

 Temporary fencing shall be installed around riparian habitats. Fencing shall be in 

place prior to the initiation of any construction activities and no encroachment into the 

fenced areas shall be permitted. Fencing shall remain in place until all construction 

activities have ceased. 
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 Any proposed construction activities that would occur within the vicinity 50 feet of 

jurisdictional waters of the U.S. shall be conducted during the dry season (i.e., April 15 

through October 15) to further reduce sedimentation within the watershed. 

 If complete avoidance of waters of the U.S. is not possible and impacts to wetland 

features cannot be avoided, authorization from the USACE is required. A Section 404 

CWA permit shall be obtained from the USACE and mitigation ratios defined within 

the permit conditions shall be implemented. Typical Nationwide Permits (NWP) 

mitigation occurs at a ratio of 1:1 acres created versus impacted and 2:1 acres 

preserved versus impacted. Individual permit conditions may vary. A CWA Section 

401 Water Quality Certification permit from the U.S. EPA would also be required. 

5.4.2 NATIVE TREES 

 Trees of notable size (i.e., heritage trees exceeding 33 inches diameter at breast height) 

shall be preserved to the greatest extent feasible.

 Impacts to valley oak trees within the Valley Oak Habitat Combining District shall be 

avoided to the maximum extent feasible.

 Protection of tree crowns and root zones shall be required for all trees planned for 

retention in the vicinity of the construction footprint.

 The highest density areas of mixed oak woodland habitat shall undergo a vigorous 

thinning regime, such that up to 50 percent of the trees within these areas are removed 

in order to reduce the intense fire hazard posed by the existing conditions on site. 

Systematic thinning within the mixed oak woodland habitat on site would facilitate 

optimal growth and development of the remaining (i.e., preserved) trees on-site, and 

would reduce susceptibility to disease, insects infestation, and parasites. Upon 

completion of thinning and project construction, remaining trees within these areas 

should be trimmed by a certified arborist or forester to remove any dead or injured 

branches. This recommendation is proposed for all of the alternatives, including the 

No Action Alternative, and should be applied to trees remaining in the overcrowded 

areas following project construction. 

 Native oak trees permanently removed as a result of project construction will be 

mitigated through re-planting of removed trees at a 1:1 ratio, as detailed below, or 

alternatively, preserving an equivalent area of oak woodland. 

o Replacement oak trees will be planted on Tribally-owned land and/or other 

parcels in the vicinity of the project site. 

o Oak trees may be established by planting in replacement areas trees salvaged 

from construction impact zones, 15 gallon-sized trees, 24-inch boxes, 36-inch 

boxes, saplings, propagated seedlings, acorns or any combination of these sizes

or stages.

o To ensure the success of planted oak trees, the trees shall be monitored annually 

by a qualified biologist for a period of five years, with a survival target goal of 60 
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percent by the third year. If it is determined after the third year of monitoring 

that the 60 percent survival rate is not being met, additional trees shall be planted 

to meet a 80 percent survival goal near the end of five years. 

o Trees removed for construction shall be assessed by a qualified biologist to see if 

the removed trees would be suitable for relocation in replacement areas. 

5.4.3 SPECIAL-STATUS PLANTS

The following mitigation measures are recommended for Alternatives A, B, and C to avoid and/or 

reduce impacts to any potentially occurring special-status plant species or their habitats within the 

project site: 

 The remaining floristic surveys for Sonoma sunshine, Sebastopol meadowfoam, 

Burke’s goldfields, and many-flowered navarretia (Section 4.1.4; Attachment E to

Appendix E) shall be conducted within the required areas of the project site in 

accordance with the Santa Rosa Plain Conservation Strategy protocol prior to 

groundbreaking on those parcels. 

 If the protocol-level floristic survey results are positive, then formal consultation with 

USFWS must be initiated. Upon consultation, an appropriate course of action shall be 

established. 

 Prior to the onset of construction activities, an avoidance plan must be formulated, 

submitted, and approved by the USFWS. It is likely entail the following basic 

principles: 

 Prior to the onset of construction activities the areas where the plants occur shall 

be delineated with avoidance buffers via high visibility fencing. The avoidance 

buffers may be 50 feet in width, unless otherwise specified by USFWS. 

 A qualified botanist shall be present during construction activities that ensue 

within the vicinity of the special-status plant avoidance buffer zones and 

monitored to ensure that the fencing remains intact and that construction 

activities do not penetrate the special-status plant avoidance buffer zones. 

 When project development is completed, the high-visibility fencing may be 

removed. However, future development shall not occur within the setback buffer 

areas. 

 If complete avoidance of the Santa Rosa Plain special-status plants is not feasible, the 

Tribe shall mitigate for impacts to the plants according to the mitigation ratios in Table 

5-1, which are outlined in the Programmatic Consultation for USACE 404 Permitted 

Projects that May Affect Four Endangered Plant Species on the Santa Rosa Plain, 

California (File Number 223420N) (USFWS, 2007). 
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TABLE 5-21

SUMMARY OF MITIGATION RATIOS FOR THE FEDERALLY LISTED PLANTS 

OF THE SANTA ROSA PLAIN* 

Impact to: Occupied Habitat 

Compensation 

Suitable Habitat 

Compensation 

Burke’s goldfields 

OR 

Sonoma sunshine 

3:1 occupied or established 

habitat (any combination) with 

success criteria met prior to 

groundbreaking at project site 

1:1 occupied or established 

habitat (any combination) with 

success criteria met prior to 

groundbreaking at project site 

AND 

0.5:1 established habitat with 

success criteria met prior to 

groundbreaking at project site. 

Sebastopol meadowfoam 2:1 occupied or established 

habitat (any combination) with 

success criteria met prior to 

groundbreaking at project site 

1:1 occupied or established 

habitat (any combination) with 

success criteria met prior to 

groundbreaking at project site 

AND 

0.5:1 established habitat with 

success criteria met prior to 

groundbreaking at project site. 

Source: USFWS, 2007 

Note: *According to the USFWS Biological Opinion issued for the 2007 Consultation, “This Programmatic will not cover 

the many-flowered navarretia because of its limited distribution [on the Santa Rosa Plain].” (USFWS, 2007:4)

5.4.4 NESTING MIGRATORY BIRDS

The following mitigation measures are recommended for Alternatives A, B, and C to avoid and/or 

reduce impacts to any potentially occurring migratory bird species within the project site: 

 If any construction activities are scheduled to occur during the nesting season 

(February 15 – August 31), pre-construction bird surveys shall be conducted. Preconstruction surveys for any nesting bird species shall be conducted by a qualified 

wildlife biologist, throughout all areas of suitable trees and habitat that are within 500 

feet of any proposed construction activity, including oak trees slated for removal. The 

surveys shall occur no more than 14 days prior to the scheduled onset of construction 

activities. If construction is delayed or halted for more than 14 days, another preconstruction survey for nesting bird species shall be conducted. If no nesting birds are 

detected during the pre-construction surveys no additional surveys or mitigation 

measures are required. 

 If migratory nesting bird species are observed within 500 feet of the construction area 

during the surveys, appropriate avoidance setbacks shall be established by the qualified 

biologist. The size and scale of nesting bird avoidance setbacks is dependent upon the 

species of nesting bird observed and the habitat that the nest occurs. Avoidance 

setbacks shall be established around all active nest locations via stakes and high 

visibility fencing. The nesting bird setbacks shall be completely avoided during the 

duration of construction activities and the fencing must remain intact. The qualified 

biologist shall also determine an appropriate monitoring plan and shall decide if 
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construction monitoring is necessary during the duration of construction activities. 

Again, monitoring requirements are dependent upon the species of nesting birds 

observed, the habitat in which the nests are contained, and the number of nests 

observed. The setback fencing may be removed when the qualified biologist confirms 

that the nest(s) are no longer occupied and all young have fledged. 

 If impacts (i.e., take) to migratory nesting bird species are unavoidable, consultation 

with USFWS shall be initiated. Through consultation, an appropriate and acceptable 

course of action shall be established. 

5.5 CULTURAL RESOURCES 

The following mitigation measures are recommended for Alternatives A, B, and C to reduce the 

potential for significant construction-related impacts to previously unknown cultural resources, 

including archaeological sites, human remains, and/or paleontological resources: 

 Should any buried cultural materials (archaeological or paleontological) be uncovered 

during ground-disturbing project activities, such activities shall cease within 100 feet 

of the find. Prehistoric archaeological indicators include: obsidian or chert flakedstone tools and waste flakes (debitage) resulting from the toolmaking process; bedrock 

outcrops and boulders with mortar cups; ground stone implements (grinding slabs, 

mortars and pestles); and locally darkened midden soils containing any of the 

previously listed items plus fragments of faunal bone or shell, fire-affected rocks, 

and/or unusual amounts of charcoal. Historic period site indicators generally include: 

fragments of glass, ceramic and metal objects; milled and split lumber; and structural 

and feature remnants such as building foundations, privy pits, wells, irrigation ditches, 

and refuse dumps; and old trails. The Lytton Rancheria shall be notified of the 

discovery and a professional archeologist (or paleontologist, as appropriate) shall be 

retained to evaluate the find and recommend appropriate treatment measures in 

consultation with the Lytton Rancheria. Project-related activities shall not resume 

within 100 feet of the find until all mitigation measures have been approved and 

completed. 

 If suspected human remains are encountered, work should halt in the vicinity and the 

Sonoma County Coroner should be notified immediately. At the same time, the Lead 

Agency and a qualified archaeologist should be contacted to evaluate the find. If 

human remains are determined to be of Native American origin, the Coroner must 

notify the NAHC within 24 hours of this identification. Construction activities shall 

not resume within 100 feet of the find until the NAHC-designated Most Likely 

Descendant (MLD) and the Tribe approves and implements a strategy for the 

appropriate disposition of the remains. 
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 Should paleontological resources be unearthed, a paleontological resource impact 

mitigation plan (PRIMP) shall be created prior to further earthmoving in the vicinity of 

the find. The PRIMP shall detail the procedures for collecting and preserving the 

discovered fossils. Any fossils discovered during construction shall be accessioned in 

an accredited scientific institution for future study.

5.6 SOCIOECONOMIC CONDITIONS/ ENVIRONMENTAL 

JUSTICE 

No mitigation is necessary for Alternatives A, B, C, or D. 

5.7 TRANSPORTATION AND CIRCULATION 

The following mitigation measures shall be implemented for Alternatives A, B, or C due to 

potential impacts for the cumulative plus project traffic conditions in the Year 2030. 

 The Tribe shall pay a proportionate share for necessary intersection improvements at 

the intersection of Windsor River Road and Bell Road (Intersection #6). The 

improvements shall include, but not limited to, installation of a traffic signal if and 

when the Town of Windsor determines a signal is warranted. 

 The Tribe shall pay a proportionate share for intersection improvements at the 

intersection of Windsor River RoadOld Redwood Highway and the Northbound U.S. 

101 Off-Ramp at Lakewood Drive (Intersection #9). Improvements would include the 

construction of an additional southbound left turn lane, an additional southbound rightturn lane, and restriping the northbound approach to include a shared through-left lane. 

It is assumed that the project’s equitable share of any planned improvements at this 

intersection would be calculated based on the methodology set forth in Appendix “B” 

of the California Department of Transportation “Guide for the Preparation of Traffic 

Impact Studies.” It is also assumed this will be determined in consultation with 

Sonoma County, the Town of Windsor and the Tribe. construction of an additional 

southbound left and right turn lane and the restriping of the northbound U.S. 101 offramp to include a shared through-left lane. 

5.8 LAND USE 

No mitigation would be necessary for Alternatives A, B, C, or D. 
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5.9 PUBLIC SERVICES 

Implementation of the protective measures and BMPs described in Section 2.01.9, along with the 

mitigation measures below, would ensure that the construction and operation of Alternatives A, 

B, and C would have a less than significant impact on fire and emergency services. 

 To minimize the risk of fire and the need for fire protection services during construction, 

any construction equipment that normally includes a spark arrester shall be equipped with 

a spark arrester in good working order. This includes, but is not limited to, vehicles, 

heavy equipment, and chainsaws. 

 During construction, staging areas, welding areas, or areas slated for development using 

spark-producing equipment would be cleared of dried vegetation or other materials that 

could serve as fire fuel. To the extent feasible, the contractor would keep these areas 

clear of combustible materials in order to maintain a firebreak. 

 Fire extinguishers shall be maintained onsite and inspected on a regular basis. 

 An evacuation plan shall be developed for the proposed development in the event of a 

fire emergency. 

 Fire hydrants shall be spaced no less than 500-feet apart throughout the developed 

portions of the site.

 Fire alarm and suppression systems installed shall conform to design standards equivalent 

to the requirements of the California Building and Fire Codes as amended and adopted by 

Sonoma County.

 On-site development shall be generally consistent with Sonoma County Fire Safe 

Standards Sections 13-54 through 13-59.

 A vegetation management plan shall be prepared by a qualified professional prior to 

occupation of any residences. The plan shall include, at a minimum, defensible space 

zones, identification of vegetation types, replacement of non-native flammable vegetation 

with fire resistive vegetation, and a maintenance program for all vegetation. The Tribe 

shall approve the plan and pass a resolution that requires that it will be implemented and 

maintained. Prior to approving the plan, the Tribe shall submit it to the County Fire 

Chief for review. 

 The Tribe shall arrange and coordinate with local law enforcement and emergency 

services if needed to assist with large events held at the proposed community center. 

If Alternative A is selected, the Tribe and the Town of Windsor shall enter into a mutually 

agreeable binding service contract for the provision of water and sewer service to the project. 
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5.10 NOISE 

Implementation of the protective measures and BMPs described in Section 2.01.9, along with the 

mitigation measures below, would ensure that the construction and operation of Alternatives A, 

B, and C would have a less than significant impact on Noise. 

 The Tribe shall restrict construction activities to normal daytime hours (7 a.m. to 7 p.m.), 

Monday through Saturday, with no work performed on Sundays. 

 The Tribe shall ensure that construction equipment used at the project site shall be 

equipped with the best available noise reduction technology feasible, including the use of 

mufflers on motorized equipment according to the manufacturer’s specifications. 

 All existing residences within 200 feet of the project site shall be notified at least one day 

in advance of construction that is proposed to take place within 300 feet of the residence.

 Stationary noise-producing equipment such as compressors and generators shall be 

placed as far as practical from homes, and shielding shall be provided between any such 

equipment and homes when it is necessary to operate the equipment closer than 200 feet 

from a home.

 On-site water reclamation facility equipment shall be shielded or enclosed. 

5.11 HAZARDOUS MATERIALS 

The mitigation measures listed below are recommended to reduce potential impacts associated 

with construction and operation of Alternatives A, B, and C. 

 Potentially hazardous materials, including fuels, shall be stored away from drainages and 

secondary containment shall be provided for all hazardous materials during construction. 

 A spill prevention and countermeasure plan shall be developed which shall identify 

proper storage, collection, and disposal measures for potential pollutants (such as fuel 

storage tanks) used onsite, as well as the proper procedures for cleaning up and reporting 

of any spills. 

 Vehicles and equipment used during construction shall be provided proper and timely 

maintenance to reduce potential for mechanical breakdowns leading to a spill of materials 

into water bodies. Maintenance and fueling shall be conducted in an area that meets the 

criteria set forth in the spill prevention plan. 

 Before development begins on the propertythe parcels are taken into trust, all items of 

non-hazardous debris shall be removed for the site and properly disposed of or recycled 

an appropriate off-site facility. 

 A hazardous materials storage and disposal plan shall be prepared that contains an 

inventory of hazardous materials stored and used on site, maintains an emergency 
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response plan for a release and disposal of unused hazardous materials, and provides 

provisions specifying employee training in safety and emergency response procedures. 

5.12 VISUAL RESOURCES 

No mitigation is necessary for Alternatives A, B, or C. 
SECTION 6.0 

CONSULTATION, COORDINATION, AND LIST OF PREPARERS
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SECTION 6.0 

CONSULTATION, COORDINATION, AND LIST OF 

PREPARERS 

6.1 FEDERAL AGENCIES CONSULTED 

United States Department of Interior – Bureau of Indian Affairs 

John Rydzik, Chief, Division of Environmental, Cultural Resource Management 

and Safety, Pacific Regional Office 

Patrick O’Mallan, Environmental Protection Specialist, Pacific Regional Office 

United States Environmental Protection Agency, Region 9

David Smith, NPDES Permits Office

United States Fish and Wildlife Service 

Informal consultation, Sacramento Fish and Wildlife Office 

Natural Resource Conservation Service 

Jennifer Gabor 

6.2 STATE AGENCIES CONSULTED 

California Department of Parks and Recreation, Office of Historic Preservation 

Wayne Donaldson, State Historic Preservation Officer 

California Department of Transportation (CalTrans)

Jose Olveda, Local Development, Intergovernmental Review

Native American Heritage Commission 

Debbie Pilas-Treadway 

6.3 TRIBES CONSULTED 

Lytton Rancheria 

Margie Mejia, Chairperson 

Mishewal-Wappo Tribe of Alexander Valley 

Scott Gabaldon, Chairperson 
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Earl Couey, Cultural Resources Manager 

Cloverdale Rancheria of Pomo Indians 

Patricia Hermosillo, Chairperson 

Mario Hermosillo Jr., Tribal Environmental Planner 

Dry Creek Rancheria of Pomo Indians 

Harvey Hopkins, Chairperson 

The Federated Indians of Graton Rancheria 

Greg Sarris, Chairperson

Gene Buvelot 

Frank Ross 

Tribal/Individuals 

 Ya-Ka-Ama 

Kathleen Smith 

6.4 LOCAL AGENCIES CONSULTED 

County of Sonoma Planning Department 

County of Sonoma Public Works Department 

County of Sonoma Tax Collector’s Office 

Windsor Fire Protection District 

Town of Windsor Planning Department 

Pauletta Cangson, Associate Planner/Code Enforcement

Windsor Unified School District

Steven Herrington, Superintendent

 Sheryl Feldman

6.5 PREPARERS OF ENVIRONMENTAL ASSESSMENT 

Analytical Environmental Services (AES) 

Project Director, David Zweig, P.E. 

Project Manager, Shelley McGinnis, Chad Broussard

Deputy Project Manager, Melissa Oberti, Ona Alminas
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AES Technical Staff: 

Mike Taggart, RPA, Cultural Resources 

Melinda McCrary, MA, RPA, Cultural Resources

Laura Brown, MS, Cultural Resources (Architectural History)

Damon Haydu, Cultural Resources 

Jennifer Bowden, Cultural Resources 

Shawn Reim, Cultural Resources 

Peter Bontadelli, Biological Resources 

Kristie Haydu, Biological Resources 

Kenna Lehmann, Biological Resources 

Ben Barker, Biological Resources 

Ona Alminas, Biological Resources

Adrienne Edwards, PhD, Biological Resources

Jessica Griggs, Biological Resources

Bibiana Sparks, Land Resources, Water Resources, Land Use, and Public Services 

Melissa Oberti, Socioeconomics, Hazardous Materials, Visual 

Ashley Wells, Socioeconomics

David Sawyer, Traffic, Agriculture and Land Resources 

Erin Quinn, Air Quality and Noise 

Dana Hirschberg, GIS, Graphics 

Glenn Mayfield, GIS, Graphics 

Abrams Associates 

Stephen Abrams 

Adobe Associates, Inc. 

David R. Brown, RCE 

Tim Schram 

Eco:Logic (Stantec) 

Steven Beck, P.E. 

Mark Hanneman, RG 
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Dale C. Bugenig 

Vijay Sundaram, P.E.

RGH Consultants, Inc. 

Jared J. Pratt, CEG 

Eric G. Chase, RPE 
SECTION 7.0 

BIBLIOGRAPHY
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SECTION 7.0 

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Williams and Paddon. 2009. Lytton Band of Pomo Indians: Windsor Community Site Analysis. 

March 2009.

Windsor Fire Protection District (WFPD), ). California. 2004. 2004 Calls for Service. 

Available at: http://www.windsorfire.net/images/pdf/05_staffing_reports/ 

wfpd%202004%20fh%20response%20time%20data.pdf. Accessed: October 2008. 

WFPD, California. 2008. History of the Windsor Fire Protection District. Available at: 

http://www.windsorfire.net/history.htm. Accessed: October 2008.

WFPD. 2011. WFPD Station 2. Available at http://www.windsorfire.net/station_2.htm

Accessed: January 2011.
7.0 Bibliography 

Analytical Environmental Services 7-16 Lytton Property Residential Development 

May 2011 Final Environmental Assessment

Windsor Unified School District (WUSD). 2007. Available at: http://www.wusd.org/. Accessed: 

November 2008. 

WUSD. 2010. Facilities Utilization Master Plan: 2011-2015. October 1, 2010. Available online 

at: www.wusd.org/files/FUMP_PDF_Version.pdf. Accessed on November 15, 2010.