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Environmental Impact Statement - Sonoma Land Trust

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California Department of Fish and Game<br />

U.S. Fish and Wildlife Service<br />

Section 3.11. Air Quality<br />

Under NEPA, there are no federal requirements mandating that climate change<br />

impacts be analyzed in NEPA documents at the time the NOP was issued.<br />

However, in 1997, the CEQ issued a draft guidance memorandum titled,<br />

Guidance Regarding Consideration of Global Climatic Change in <strong>Environmental</strong><br />

Documents Prepared Pursuant to the National <strong>Environmental</strong> Policy Act.<br />

Although the guidance was never approved in a final version and thus was never<br />

formally published, the findings and conclusions in the document are nonetheless<br />

useful for NEPA practitioners.<br />

The draft document states that “the NEPA process provides an excellent<br />

mechanism for consideration of ideas related to global climate change” and that<br />

“…federal agencies must determine whether and to what extent their actions<br />

affect GHGs. Further, federal agencies must consider whether the actions they<br />

take, e.g., the planning and design of federal projects, may be affected by any<br />

changes in the environment which might be caused by global climatic change.”<br />

The draft document also points out that the scope of NEPA and the CEQ<br />

regulations is broad enough to include global climate change and its predicted<br />

effects. For example, section 1508.8 defines “effects” to include ecological,<br />

aesthetic, historic, cultural, economic, social, or health effects.<br />

Further, several federal court rulings (including Centers for Biological Diversity<br />

vs. NHTSA) have found that GHG emissions should be analyzed within NEPA<br />

documents.<br />

<strong>Impact</strong>s and Mitigation Measures<br />

No Action Alternative<br />

Under the No Action Alternative, construction of the Project would not occur.<br />

Construction activities would be limited to construction of a new access road to<br />

the USFWS headquarters and California red-legged frog habitat enhancement.<br />

The Black Point Sports Club use of the Dickson Ranch would be discontinued<br />

prior to the property transfer to CDFG. Hunting would likely shift to primarily<br />

waterfowl hunting, although some upland hunting could also be permitted.<br />

Limited other recreational use (hiking, bird watching) may occur, although no<br />

formal hiking trails would be constructed. Agricultural use may continue, but<br />

would be reduced to portions of the site under the management of the USFWS.<br />

Because only minor changes in activities are expected under the No -Action<br />

Alternative, no substantial change in PM10, CO, ozone precursors, or other<br />

pollutants would be likely to occur.<br />

Sears Point Wetland and Watershed Restoration<br />

Project Final <strong>Environmental</strong> <strong>Impact</strong><br />

Report/<strong>Environmental</strong> <strong>Impact</strong> <strong>Statement</strong><br />

3.11-17<br />

April 2012

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