Carpinteria City Council
March 28, 2022

CITY COUNCIL HEARING
APPEAL OF PLANNING COMMISSION’S APPROVAL OF

RINCON TRAIL PROJECT
PROJECT 19-2015-CUP/CDP
MARCH 28, 2022
EXHIBIT 3: CONDITIONS OF APPROVAL
The Conditions set forth in this permit affect the title and possession of the real property that is the subject of this permit and shall run with the real property or any portion thereof. All the terms, covenants, conditions and restrictions herein imposed shall be binding upon and inure to the benefit of the owner (applicant, developer), his or her heirs, administrators, executors, successors and assigns.

Upon any sale, division or lease of real property, all the conditions of this permit shall apply separately to each portion of the real property and the owner (applicant, developer) and/or possessor of any such portion shall succeed to and be bound by the obligations imposed on the owner (applicant, developer) by this permit.

PROJECT DESCRIPTION

1. This Conditional Use Permit and Coastal Development Permit is based upon and limited to compliance with the project description, the hearing exhibits (Attachment A, Exhibit 2 to the staff report dated March 28, 2022) and conditions of approval set forth below. Any deviations from the project description, exhibits or conditions must be reviewed and approved by the City for conformity with this approval. Deviations may require approved changes to the permit and/or further environmental review. Deviations without the above described approval will constitute a violation of permit approval.

The project description is as follows:

The City of Carpinteria Parks and Recreation Department is seeking approval of a Conditional Use Permit and Coastal Development Permit to construct a 850-foot segment of Class I multi-use path in the City and Caltrans rights-of-way at the eastern end of the City of Carpinteria to allow for a dedicated bike and pedestrian path connection between the City of Carpinteria and Rincon Beach County Park in unincorporated Santa Barbara County. The remainder of the approximately 2,800-foot long trail is located in the jurisdiction of the County of Santa Barbara. The trail is intended to support alternative transportation in the area and fill in a missing link in the 1,200 mile California Coastal Trail.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

The overall project limits would extend from near the Carpinteria Avenue/State Highway 150 intersection to the western terminus of the Rincon Beach County Park parking lot in unincorporated Santa Barbara County. Beginning in the unimproved shoulder just east of the Carpinteria Avenue/State Highway 150 intersection, the trail would trend east/northeast, roughly paralleling the southbound US Highway 101 onramp. The trail would be situated on a new bench cut into the existing manufactured slope above the on-ramp and would gently descend in elevation toward the Union Pacific Railroad (UPRR) corridor where the trail would cross the UPRR corridor using a new pre-fabricated 160-foot long, 14-foot wide clear span bridge. South of the UPRR corridor, the trail would turn due east and gradually descend the face of the ocean-side bluff, terminating at the western terminus of the Rincon Beach County Park parking lot.

The portion of the trail under consideration by the City of Carpinteria City Council extends from Carpinteria Avenue to the eastern City boundary, roughly coincident with the middle of the trail segment north of the UPRR corridor, and measures approximately 850 linear feet. The County of Santa Barbara has permit jurisdiction over the remainder of the trail (approximately 1,950 linear feet), continuing east from the city boundary (and including the new bridge crossing over the UPRR corridor) to the pathway’s terminus at the Rincon Beach County Park parking lot.

The proposed concrete multi-use path would feature a five-foot travel lane in each direction, and a paved shoulder width of three feet on each side, for a total path width of 16 feet. A six-foot wide shallow concrete v-ditch would run along the inside of the trail length for the purposes of capturing and conveying stormwater to onsite drainage facilities. Protective fencing would be provided along the trail alignment to keep trail users on the improved path.

Total grading and earthwork quantities for the entirety of the project necessary to cut an Americans with Disability Act (ADA)-compliant trail bench, stabilize slopes, and control stormwater runoff through the project area are estimated at 96,040 cubic yards of cut. Approximately 10,519 cubic yards of the cut material would be used for fill onsite; the remaining 85,521 cubic yards of cut material would be exported offsite. Approximately 45% of the estimated earthwork (equivalent to ~43,200 cubic yards of cut) is expected to occur on the inland side of the UPRR alignment; and the remaining 55% (~52,800 cubic yards) on the ocean side of the UPRR alignment. A storm drain collection system is proposed for the trail alignment, which would utilize a combination of repaired existing and new piped storm drains on the bluff face and drain outlets to the ocean. The portion of the trail located in the jurisdiction of the City of Carpinteria would Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

tie into and be served by existing Caltrans storm drain infrastructure for US Highway 101. A habitat restoration plan is included to restore areas disturbed during construction and to mitigate for permanent removal of vegetation to accommodate the new trail.

As part of the project, the City will obtain an easement from UPRR for the bridge crossing over, and trail improvements within, the UPRR alignment.

The City is also anticipating the acquisition of right-of-way from the California Department of Transportation (Caltrans) to accommodate the trail alignment.

The grading, development, use, and maintenance of the property, the size, shape, arrangement, and location of structures, parking areas and landscape areas, and the protection and preservation of resources shall conform to the project description above and the hearing exhibits and conditions of approval below. The property and any portions thereof shall be sold, leased or financed in compliance with this project description and the approved hearing exhibits and conditions of approval hereto. All plans (such as Landscape Plans) must be submitted for review and approval and shall be implemented as approved by the City.

MITIGATION MEASURES FROM THE CERTIFIED PROJECT

ENVIRONMENTAL IMPACT REPORT (EIR)

2. MM-AES-1 Board of Architectural Review.

The Owner/Applicant shall obtain City Architectural Review Board (“ARB”) and County South Board of Architectural Review (“SBAR”) approval for project design. All project elements (e.g., design, scale, character, colors, materials, and landscaping) shall be compatible with vicinity development and shall conform in all respects to ARB/SBAR approval.

Plan Requirements and Timing: The Owner/Applicant shall submit architectural drawings of the project including photo renditions from the beach of the storm drains proposed along the bluff face for review and shall obtain final City ARB and County SBAR approval prior to issuance of the zoning clearance. Grading plans, if required, shall be submitted to the City’s Planning Department concurrent with or prior to ARB/SBAR plan filing with the Carpinteria Community Development Department or County Planning and Development. Monitoring: The Owner/Applicant shall demonstrate to Community Development Department staff and Planning & Development Department compliance monitoring staff that the project has been built consistent with approved ARB/SBAR design and landscape plans prior to Final Building Inspection Clearance.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

3. MM-BIO-1 Workers Environmental Awareness Program (WEAP).

The Owner/Applicant shall fund an approved biologist to prepare and implement a worker education and awareness program (WEAP) specific to the project. The program shall be presented to all individuals involved in the construction of the project. The program shall include information focused on sensitive vegetation communities, sensitive wildlife and plant species, and common wildlife species and their habitats and shall include, but not be limited to, the following:
 Description of sensitive vegetation communities.
 Workers shall be provided with photographs of sensitive biological resources including sensitive wildlife and plant species.  Workers shall be informed verbally and in writing of the various project tasks that require biological surveys and monitoring for resource protection.
 Workers shall be provided with a photograph or description of the markers for active bird nests, trees, or other mitigation areas, so that they shall know these are not to be disturbed without a biological monitor present.
 Workers shall be informed not to litter. All trash and litter shall be picked up and removed from the construction sites at the end of each day.
 Workers shall be informed to obey a speed limit of 15 miles per hour while traveling on the project site to avoid collisions with wildlife.  Workers shall avoid driving over or otherwise disturbing areas outside the designated construction areas.

Plan Requirements and Timing: The Owner/Applicant shall submit the WEAP to the City of Carpinteria (“City”) and County of Santa Barbara (“County”) for review and approval prior to zoning clearance approval. All workers, contractors, and visitors shall attend the WEAP prior to entering the project site and performing any work. The Owner/Applicant shall provide copies of the training attendance sheets to City and County staff as a record of compliance with this measure on a monthly basis. The WEAP shall be reviewed and approved by the City and County prior to Zoning Clearance approval. Implementation of the WEAP training shall occur prior to the start of construction and as new crew members are added to the project.

Monitoring: The City and County permit compliance staff will ensure compliance with the WEAP throughout construction by review of attendance sheets and hardhats, inspection of the site, and interviewing workers, as appropriate.

4. MM-BIO-2 Fencing.

To prevent inadvertent impacts on adjacent sensitive vegetation communities including County ESH and City ESHA, native vegetation, special-status species, and common wildlife species and their habitats, construction limits will be fenced with highly visible fencing and staked.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Wildlife safe highly visible construction fencing shall be installed to identify the limits of grading/disturbance, which would reduce potential human trampling outside of the construction limits and minimize the potential spread of non-native weeds or invasive plant species. Wildlife-safe construction fencing and flagging shall remain in place during construction and replaced as needed.

Plan Requirements and Timing: The detailed fencing plan, showing the location of required fencing shall be reviewed and approved by City and County staff prior to Zoning Clearance approval. This condition shall be printed on all project plans. The detailed fencing plan, showing the location of fencing shall be submitted to City and County staff for review and approval prior to Zoning Clearance approval. The fence shall be installed prior to the start of ground disturbing activities. Monitoring: The City of Carpinteria and County staff will inspect the project plans and site, to ensure compliance with this measure as appropriate.

5. MM-BIO-3 Pre-construction California Legless Lizard Survey and Relocation.

Prior to initiation of construction, capture and relocation efforts for California legless lizards shall be conducted. Trapping shall be conducted by a qualified biologist and shall include the following steps:
i. Prior to initiation of capture and relocation, a suitable receptor site shall be located. This site shall include areas with loose, moist soils occurring in scrub habitat with high coverage of deerweed (Lotus scoparius) or California goldenbush, in arroyo willow (Salix lasiolepis) thickets or in other suitable scrub or woodland habitat. ii. Capture and relocation shall take place no more than five days prior to the initiation of construction.
iii. These surveys shall be performed by lightly raking loose soil, sand and leaf litter with a wooden rake for a sufficient period to determine that no legless lizards are present, or all legless lizards have been captured.
iv. Any lizards found shall be placed in a receptacle with sand and a wet towel and relocated to the previously designated receptor site.

Plan Requirements and Timing: Prior to initiation of construction, capture and relocation efforts for California legless lizards shall be conducted where appropriate. Trapping shall be conducted by a qualified biologist.

Monitoring: The City of Carpinteria and County staff shall ensure the preconstruction survey and relocation efforts, if required, are completed prior to commencement of any earth-moving activities.

6. MM-BIO-4 Pre-construction Woodrat Survey and Relocation.

Prior to initiation of construction, capture and relocation efforts for woodrat shall be conducted. Trapping shall be conducted by a qualified biologist and shall include the following steps:

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

i. Prior to initiation of capture and relocation, a suitable receptor site shall be located. This site shall be within similar habitat and an adequate distance away from any locations that might be subject to increased human disturbance, such as adjacent to a walking path. ii. These pre-construction surveys shall be performed searching all coastal sage scrub or coastal bluff scrub within the disturbance area for middens or other sign of the species.
iii. Any middens and woodrats found shall be live-trapped and relocated to the pre-determined receptor site. The midden shall be dismantled and the materials placed at the relocation site.

Plan Requirements and Timing: Prior to initiation of construction, capture and relocation efforts for woodrat shall be conducted where appropriate.

Trapping shall be conducted by a qualified biologist. Monitoring: The City of Carpinteria and County staff shall ensure the pre-construction survey and relocation efforts, if required, are completed prior to commencement of any earth-moving activities.

7. MM-BIO-5 Habitat Mitigation and Monitoring Plan.

Prior to issuance of zoning clearance approval, the Owner/Applicant shall contract with a qualified biologist to develop a Habitat Mitigation and Monitoring Plan (Plan) to mitigate for impacts to County ESH/City ESHA vegetation communities. The Plan shall outline efforts to restore or enhance coastal sage scrub and coastal bluff scrub communities, and, therefore, preserve or provide wildlife habitat, in areas impacted by construction of the trail but outside the trail-related impervious surfaces and within similar habitats adjacent to the impacted biological resources. The Plan may focus on the following:
 In-kind, on-site restoration of areas where coastal sage scrub or coastal bluff scrub has been removed;
 Enhancement of impacted areas on site currently occupied by ornamental, disturbed or developed areas;
 Restoration of areas occupied by non-native habitats or native habitats with large components of non-native vegetation, within similar habitats adjacent to the impacted biological resources.

A total of 4.32 acres of impacts are proposed to County ESH/City ESHA native vegetation communities. Under the Plan, impacts to S3/County ESH/City ESHA native vegetation communities (California brittle bush – ashy buckwheat scrub alliance, Encelia californica association and lemonade berry scrub alliance, Rhus integrifolia association) that total 0.59 acres shall be restored in-kind at 4:1. Impacts to S4 and S5/County ESH/City ESHA native vegetation communities (quailbush scrub alliance, Atriplex lentiformis association, California sagebrush – (purple sage) scrub alliance, Artemisia californica association, and coyote brush scrub alliance, Baccharis pilularis association) that total 3.73 acres shall be restored in-kind at 2:1. To the extent feasible, restoration should occur on site and, any additional Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

mitigation required shall be carried out on areas within adjacent land controlled by the County or City, such as the Rincon Bluffs Preserve or Rincon Beach County Park.

A qualified biologist/botanist shall develop the Plan, which shall provide specific measures to restore or enhance habitat to replace the loss of coastal sage scrub and coastal bluff scrub communities. This Plan shall be focused on adaptive management principles, and shall identify detailed enhancement areas and strategies based on the parameters outlined below, with long term timing and monitoring requirements. The Plan shall:
i. Provide an up-to-date inventory of on-site native vegetation resources.
ii. Define attainable and measurable goals and objectives to achieve through implementation of the Plan. Goals and objectives shall focus on replacement of coastal sage scrub, coastal bluff scrub and rare plants removed during construction.
iii. Provide site selection and justification. Prior to identifying habitat restoration mitigation areas, both within the project area and adjacent lands, the habitat shall be surveyed for sensitive vegetation communities and special-status species, to ensure avoidance of impacts during habitat restoration implementation. Additionally, potential adjacent mitigation lands shall be assessed to ensure sites are suitable and appropriate for implementation of habitat restoration for the impacted native vegetation communities.
iv. Detail a restoration work plan including methodologies, restoration schedule, plant materials (seed and container plant) sourcing – locally genetic stock, and implementation strategies.
v. Provide a detailed maintenance plan to include removal of invasive non-native species.
vi. Define annual and final performance standards. Prior to grading, the project-related native coastal bluff scrub and coastal scrub vegetation communities shall be assessed by vegetation community type for percent cover (both basal and vegetative), species diversity, density, and abundance. This project site native vegetation community data shall be used to define performance standards for native habitat restoration by vegetation layers (tree, shrub, grass, and forb) for each vegetation community type and for non-native plant species. vii. Identify that the restoration areas shall be irrigation-free for at least 3 years and the performance standards have remained stable (no negative trend for richness/ diversity/ abundance/ cover of native species and no positive trend for invasive/non-native cover for each vegetation layer) for at least 3 years.
viii. Provide a monitoring plan to include methods and analysis of results.

Also, include goals, success or failure criteria, and an adaptive management plan, contingency actions, and suggestions for failed restoration efforts.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Plan Requirements and Timing: Prior to issuance of zoning clearance approval, the Owner/Applicant shall contract with a qualified biologist to develop the Plan. The Plan shall outline efforts to restore or enhance coastal sage scrub and coastal bluff scrub communities in areas impacted by construction of the project. Monitoring: The City of Carpinteria and County staff shall ensure development of the Plan and adherence to Plan measures are completed prior to commencement of any earth-moving activities.

Additionally, California Department of Fish and Wildlife shall approve the Plan prior to issuance of zoning clearance approval. City and County staff shall periodically conduct site inspections to ensure compliance on site.

Restored areas shall be monitored for five years following planting. Annual reports and the final report shall be submitted to the City and County.

8. MM-BIO-6 Weed Management Plan.

Prior to issuance of zoning clearance approval, the Owner/Applicant shall contract with a qualified biologist to develop a Weed Management Plan to be implemented during construction and implementation of the Habitat Mitigation and Monitoring Plan. The Weed Management Plan shall include, but is not limited to, the following:
 Prior to ground disturbance, a City approved qualified biologist shall map invasive weeds within the limits of impacts plus a 100-foot buffer. Invasive weeds shall be defined as California Invasive Plant Inventory Database (Cal-IPC) moderate and high ratings. Invasive species subject to control measures shall be identified. Note that non-native grasses such as bromes and wild oats shall be mapped but are not subject to control measures. Prior to ground disturbance, areas with invasive weeds shall be treated according to control methods below and BMPs for invasive weeds.
 To prevent the spread of invasive weeds and inhibit germination, the following shall be implemented:
o Maintain vehicle wash and conduct inspections to monitor the types of materials brought on site to minimize the potential for invasive weed introduction
o Limit disturbance areas to the permitted disturbance area o Limit ingress and egress to defined routes
o Use certified weed-free products
 Invasive weed control methods shall include legally permitted herbicide, manual, and mechanical methods approved for
application. The application of herbicides shall be in compliance with state and federal laws and regulations under the prescription of a pest control advisor, with the City’s concurrence, and shall be implemented by a licensed qualified applicator. All product labels shall be followed. Spot treatments shall be the method of application and broadcast applications shall be avoided. Herbicides shall not be applied during or within 72 hours of a forecasted measurable rain Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

event or during high wind conditions. Invasive weed debris accumulated during manual and mechanical removal methods shall be disposed of at an appropriate location off-site. Maintenance shall be timed to remove invasive weeds prior to seed production. The maintenance crew shall coordinate with the City approved biologist to avoid and minimize impacts to plant species and wildlife species.  A City approved qualified biologist shall perform annual monitoring within the limits of disturbance and a 100-foot buffer to map and document invasive weed species. At any time during implementation of the Weed Management Plan, monitoring frequency may increase as needed to provide guidance to maintenance crews.

Plan Requirements and Timing: Prior to issuance of zoning clearance approval, the Owner/Applicant contract with a qualified biologist to develop the Plan. The Plan shall outline efforts to implement a weed management plan to control invasive weeds. Pre-construction survey results shall be reported and ongoing invasive weed control efforts and annual survey results shall be submitted annually and for the five year duration of the Habitat Mitigation and Monitoring Plan. Monitoring: The City of Carpinteria and County staff shall ensure development of the Plan and adherence to Plan measures are completed prior to commencement of any earth-moving activities. City and County staff shall periodically conduct site inspections to ensure compliance on site and to ensure the Plan is fully implemented.

9. MM-BIO-7 Pre-construction Nesting Bird Surveys.

Within 30 days prior to any vegetation clearing or ground disturbance, or use of noise-generating equipment associated with construction or grading that would occur during the nesting/breeding season of native bird species potentially nesting on the site (typically mid-February through August in the project region, or as determined by a qualified biologist), the Owner/Applicant shall have weekly surveys conducted by a qualified biologist to determine if active nests of special-status bird species, or of any bird species protected by the Migratory Bird Treaty Act or the California Fish and Game Code, are present in the disturbance zone or within 300 feet (500 feet for raptors) of the area to be disturbed. The surveys shall occur on a weekly basis, with the last survey being conducted no more than seven days prior to initiation of disturbance work. If ground disturbance is delayed, then additional pre-disturbance surveys shall be conducted such that no more than seven days will have elapsed between the survey and ground disturbance activities. The Owner/Applicant or contractor shall provide the biologist with plans detailing the extent of proposed ground disturbance prior to the survey effort.

If active nests are found, including any nests for Cooper’s hawk, clearing and use of noise-generating construction within 300 feet of the nest (500 feet for raptors) shall be postponed or halted, at the discretion of the biologist, until the nest is vacated and juveniles have fledged, as determined by the Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

biologist, and there is no evidence of a second attempt at nesting. Limits of construction to avoid an active nest shall be established in the field with highly visible construction fencing, and construction personnel shall be instructed on the sensitivity of nest areas. The results of the surveys, including graphics showing the locations of any nests detected, and any avoidance measures recommended, shall be submitted to the City and County within 14 days of completion of the pre-construction surveys to document compliance with applicable state and federal laws pertaining to the protection of native birds.

Plan Requirements and Timing: Pre-construction nesting bird surveys shall be completed within 30 days prior to any vegetation clearing or ground disturbance associated with construction or grading during the bird nesting season (typically mid-February to August). The surveys shall occur on a weekly basis, with the last survey being conducted no more than seven days prior to initiation of disturbance work. Monitoring: The City of Carpinteria and County staff shall ensure the pre-construction nesting bird surveys and any avoidance requirements are completed prior to commencement of any earthmoving activities.

10. MM-CR-1 Cultural Resource Treatment and Inadvertent Discovery Plan.

Potential impacts to cultural resources shall be minimized through development of protocols for practical adherence of mitigation measures CR2 and CR-3 prior to and after ground disturbing construction activities associated with the proposed project. These protocols shall be outlined in a Cultural Resource Treatment Plan (CRTP). The CRTP shall be developed by a City-qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards, prior to the implementation of ground disturbing activities and include wording of each mitigation measure CR-2-4, specific and detailed explanation for implementation of each mitigation measure and contact protocol. The CRTP shall be provided to all agency personnel, consulting tribes, contractors and archaeological personnel. The existence and necessity for adherence to the CRTP shall be noted on plans, handbooks, or the like associated with tasks that may incur ground disturbance either intentionally or inadvertently.

Plan Requirements and Timing: Prior to issuance of a grading permit, the Owner/Applicant shall contract with a County-qualified/City-approved archaeologist to develop the required CRTP in accordance with the above criteria. Monitoring: City of Carpinteria/County of Santa Barbara staff shall review and authorize the CRTP prior to the commencement of ground disturbance activities to ensure that the CRTP adheres to the criteria established in CR-1.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

11. MM-CR-2 Workers Environmental Awareness Program (WEAP) Training.

All personnel participating in tasks that may incur ground disturbance either intentionally or inadvertently shall be briefed regarding unanticipated discoveries prior to the start of said activities. A basic presentation shall be prepared by a City-qualified archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards to inform all personnel working on the project about the archaeological sensitivity of proposed project areas.

The purpose of the WEAP training is to provide specific details on the kinds of archaeological materials that may be identified during project activities and explain the importance of and legal basis for the protection of cultural resources. Each personnel shall also be instructed in the proper procedures to follow in the event that cultural resources or human remains are encountered. These procedures include work curtailment or redirection, and the immediate contact of the site supervisor, qualified archaeologist and if human remains are encountered, the County coroner.

Plan Requirements and Timing: Prior to issuance of a grading permit, the Owner/Applicant shall contract with a County-qualified/City-approved archaeologist to develop and conduct the required WEAP Training in accordance with the above criteria. Monitoring: City of Carpinteria/County of Santa Barbara staff shall ensure the required WEAP training has been conducted by attending the WEAP Training and documenting attendance of required personnel by means of a sign in sheet completed by all attendees of the WEAP Training.

12. MM-CR-3 Archaeological Monitor.

Initial ground disturbing activities shall be monitored by a Countyqualified/City-approved archaeologist in accordance with the following specifications:

Temporary Impact Areas (equipment staging and materials storage outside trail alignment) – a County-qualified/City-approved archaeologist shall monitor transport and placement activities until such time that it is reasonable to ascertain that no additional prehistoric archaeological/cultural resources are located within areas of temporary disturbance of the proposed project site.

Permanent Impact Areas not including bridge piling installation (all areas of the trail alignment excepting the bridge approaches area on both sides of the UPRR alignment) – a County-qualified/City-approved archaeologist shall monitor project implementation during the initial grading and excavation activities until such time as sufficient subsurface soil has been uncovered/excavated to ascertain that no additional prehistoric archaeological/cultural resources are located on the proposed project improvement area.

Bridge piling installation – a County-qualified/City-approved archaeologist shall monitor the installation of bridge pilings within intact soils and/or any Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

soils deeper than 10 feet below current ground surface to ascertain that no additional prehistoric archaeological/cultural resources are located on the proposed project improvement area.

The monitor shall immediately inform equipment operators in the event archaeological resources are encountered, and shall be empowered to immediately halt construction activity in the area of the discovery until assessment can be completed, and materials recovered as appropriate (refer to CR-2 for additional detail). Monitoring reports shall be provided to the City of Carpinteria/County of Santa Barbara on a monthly basis during construction, with a final monitoring report produced at the conclusion of construction activities and provided to both the City and County.

Plan Requirements and Timing: Prior to issuance of a grading permit, the Owner/Applicant shall contract with a County-qualified/City-approved archaeologist to monitor initial ground disturbance activities in accordance with the above criteria. Monitoring: City of Carpinteria/County of Santa Barbara staff shall ensure the contracted archaeologist provide monitoring of initial ground disturbance activities in accordance with the above criteria through receipt of field documentation describing each day of monitoring, construction activity occurring during the monitoring, and observed soil profile conditions related to the potential for presence of archaeological resources.

13. MM-CR-4 Discovery of Cultural Resources.

In the event cultural resources are encountered, construction shall be redirected to another area of the project while data/resource assessment and recovery is accomplished.

Grading/construction shall be immediately suspended in the immediate area (no less than 50 feet from the area of the discovery) where cultural resources are encountered and temporarily redirected to another portion of the project area to allow the archaeologist to assess the nature, extent and significance of any discoveries and develop appropriate management recommendations for archaeological resource treatment consistent with Santa Barbara County Guidelines for the Implementation of California Environmental Quality Act of 1970 (as amended May 25, 2010). It is anticipated that recovery of artifacts would occur where project elements (such as pilings) would conflict with in situ artifact locations, and such artifacts would be properly archived in accordance with the project CEQA, City of Carpinteria and Santa Barbara County guidelines and the CRTP protocol.

Identified remedial action for the discovery shall be completed prior to allowing construction to recommence in the area, no less than 50 feet from the area of the discovery. The project sponsors shall be responsible for funding the assessment of archaeological resources encountered during construction, and for the proper archiving or preservation of such resources.

A Phase 3 Archaeological Resources Assessment and Data Recovery Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Report shall be prepared to document any archaeological resources encountered during construction.

Plan Requirements and Timing: Prior to issuance of a grading permit, the Owner/Applicant shall contract with a County-qualified/City-approved archaeologist to provide archaeological assessment and recovery of any archaeological resources encountered during project construction, in accordance with the above criteria. Monitoring: City of Carpinteria/County of Santa Barbara staff shall ensure the contracted archaeologist assess the nature, extent and significance of any archaeological discoveries occurring during project construction and develop appropriate management recommendations for archaeological resource treatment in accordance with the project CEQA, City of Carpinteria and Santa Barbara County guidelines and the CRTP protocol.

The contracted archaeologist shall assess the nature, extent and significance of any archaeological discoveries occurring during project construction and develop appropriate management recommendations for archaeological resource treatment.

14. MM-GEO-1 Seismicity.

The pedestrian bridge shall adhere to the recommendation identified in Appendix E to the Environmental Impact Report to withstand a peak ground acceleration (PGA) at the site of 0.8g generated by an earthquake of moment magnitude Mw=7.4.

Plan Requirements and Timing: Prior to issuance of a grading permit, the City of Carpinteria/County of Santa Barbara shall verify the engineering plans include this bridge design specification. Monitoring: City of Carpinteria/County of Santa Barbara public works staff or construction inspector retained for the project shall inspect bridge construction to verify conformance with this specification.

15. MM-GEO-2 Differential Settlement of Pedestrian Bridge Foundations.

Bridge foundation construction shall adhere to the recommendation identified in Appendix E to the Environmental Impact Report, which specifies a deep foundation employing cast-in-drilled hole (CIDH) piles. Based on the anticipated loadings, Caltrans Standard Plan 24” CIDH Concrete Piles with 200 kips design capacity are recommended in the geotechnical report.

Should hard cemented bedrock be encountered during the installation of the CIDH piles, coring may be necessary.

Plan Requirements and Timing: Prior to issuance of a grading permit, the City of Carpinteria/County of Santa Barbara shall verify the engineering plans include this bridge foundation specification. Monitoring: City of Carpinteria/County of Santa Barbara public works staff or construction inspector retained for the project shall inspect foundation construction to verify conformance with this specification.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

16. MM-GEO-3 Soil Erosion/Slope Stability.

Slope construction shall adhere to the recommendations in the geotechnical report, summarized below:
i. All new fills placed along the trail alignment shall be placed as engineered geotextile-reinforced soils with subsurface/back drains. ii. Manufactured slope profiles shall be no steeper than as specified in the Bengal 2019 geotechnical report (Appendix E), or any updated version thereof which has been prepared to address final trail design. iii. Install adequate surface drainage facilities to collect and dispose of surface runoff properly, consistent with the drainage system designs included in 30% Project Plans for Rincon Multi- Use Trail (Appendix E), or as updated to address final trail design.
iv. Hydro-seed the exposed newly cut and fill surfaces. Periodic watering and re-application of hydroseed shall occur as necessary until vegetation on slope surfaces has been successfully established.

These measures, in conjunction with the slope flattening and load reduction resulting from the proposed slope cutbacks, should substantially reduce the hazards associated with both slope erosion and local/surficial slope instability under both static and seismic loading conditions.

Plan Requirements and Timing: Prior to issuance of a grading permit, the City of Carpinteria/County of Santa Barbara shall verify the engineering plans include the above specifications. Monitoring: City of Carpinteria/County of Santa Barbara public works staff or construction inspector retained for the project shall inspect slope and drainage system construction to verify conformance with these specifications.

17. MM-HAZ-1 Aerially Deposited Lead (ADL).

Surface soils within the trail alignment segment north of the UPRR corridor shall be tested for potential ADL presence to determine if such soils may be used as fill, or must be disposed in a properly licensed landfill. Using the risk based screening levels developed by California Office of Environmental Health Hazard Assessment (OEHHA), excavated soils with a lead concentration less than or equal to 80 mg/kg total lead (analyzed by USEPA Method 6010 or 6020) would be acceptable for reuse without restrictions, including as fill material within the Rincon Trail project. Excavated soils that are considered a California hazardous waste (total lead concentration greater than or equal to 1,000 mg/kg or a soluble lead concentration greater than or equal to 5 milligrams per liter [mg/L] as determined by the California Waste Extraction Test [CAWet]) or are a RCRA hazardous waste and must be disposed of in a Class I hazardous waste landfill. Excavated soils with lead concentrations below 1,000 mg/kg but above 80 mg/kg total lead may be eligible for reuse with specific restrictions to reduce or eliminate exposure, with prior written approval from DTSC, or may be disposed of at an appropriately permitted landfill.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Plan Requirements: ADL testing requirements and soil re-use restrictions according to identified ADL concentration shall be shown on grading and building plans. Since excess soil material would be generated through proposed grading activities, soils containing greater than 80 mg/kg total lead shall not be used as fill material for the project but shall be exported off site.

Soil containing total lead greater than 1,000 mg/kg shall be disposed in a Class I hazardous waste landfill. Timing: Condition shall be adhered to throughout all grading and construction activities. Monitoring: City of Carpinteria and County of Santa Barbara staff shall ensure measures are on plans. City and County Grading Inspectors shall spot check and ensure compliance on site.

18. MM-WAT-1 Obtain Coverage Under Construction General Permit.

The project shall obtain coverage under a Construction General Permit via the State Water Resources Control Board (SWRCB) (Water Quality Order 99-08-DWQ).

Plan Requirements: The requirement to obtain coverage from the SWRCB under a Construction General Permit shall be indicated on grading plans.

Timing: Evidence of coverage under a Construction General Permit shall be provided to the City of Carpinteria Public Works Department and County of Santa Barbara Public Works Division prior to the initiation of grading.

Monitoring: City and County Public Works staff shall confirm evidence of the Construction General Permit issuance prior to issuance of grading permits.

19. MM-WAT-2 Stormwater Pollution Prevention Plan.

The construction contractor shall prepare a Stormwater Pollution Prevention Plan that includes Best Management Practices (BMPs) to be implemented and monitored prior to and during construction. The following BMPs shall be incorporated into the SWPPP to minimize potential construction-related water quality impacts:
i. Disturbed areas shall be stabilized or re-vegetated prior to the start of the rainy season. The work area shall be flagged to identify its limits.

Vegetation shall not be removed or intentionally damaged beyond these limits.
ii. Construction materials shall be placed in designated areas where they could not enter water bodies or storm drains due to spillage or erosion.
iii. Waste and debris generated during construction shall be stored in designated waste collection areas and containers away from watercourses and shall be disposed of regularly.
iv. During construction, washing of concrete trucks, paint, equipment, or similar activities shall occur only in areas where polluted water and materials can be contained for subsequent removal from the site.

Wash water shall not be discharged to the storm drains, street, drainage ditches, creeks, or wetlands. The concrete washout area Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

shall be isolated from water bodies, and wash water and waste shall be removed from the project site. The location of the washout area shall be clearly noted at the construction site with signs. v. All fueling of heavy equipment shall occur in a designated area removed from water bodies and other drainages, such that any spillage would not enter surface waters. The designated refueling area shall include a drain pan or drop cloth and absorbent materials to clean up spills. The location of the fueling area shall be clearly noted at the construction site with signs.
vi. Vehicles and equipment shall be maintained properly to prevent leakage of hydrocarbons and coolant and shall be examined for leaks on a daily basis. All maintenance shall occur in a designated off-site area. The designated area shall include a drain pan or drop cloth and absorbent materials to clean up spills.
vii. Any accidental spill of hydrocarbons or coolant that may occur on the construction site shall be cleaned up immediately. Absorbent materials shall be maintained on the construction site for this purpose.
viii. Special considerations for work during the rainy season: stockpiled soils should be covered at the end of the work day, and concrete pouring shall be avoided within 15 days of a forecasted rain event to allow full curing, due to its toxic nature until it has fully cured.

Plan Requirements: A Stormwater Pollution Prevention Plan (SWPPP) shall be prepared and implemented prior to construction and shall include the above elements. The SWPPP shall be submitted to City and County Public Works for review and approval prior to the issuance of grading permits for the project. Timing: The stormwater features and BMPs shall be installed and operational prior to initiation of grading. Monitoring: City and County Public Works staff shall site inspect for installation and maintenance in accordance with the approved plan and periodically thereafter to ensure proper maintenance over the duration of construction activities.

20. MM-WAT-3 Erosion and Sediment Control Plan.

Best available erosion and sediment control measures shall be implemented and maintained during grading and construction. Best available erosion and sediment control measures may include, but are not limited to, use of sediment basins, gravel bags, silt fences, geo-bags or gravel and geotextile fabric berms, erosion control blankets, coir rolls, jute net and straw bales.

Construction access points shall be stabilized using gravel beds, rumble plates or other measures to prevent sediment from being tracked onto adjacent roadways. Any sediment or other materials tracked off site shall be removed the same day as they are tracked using dry cleaning methods.

Plan Requirements and Timing: An erosion and sediment control plan shall be submitted to and approved by City and County Public Works prior to issuance of grading permits. The plan shall be designed and implemented to Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

address erosion and sediment control during all phases of development of the site. Monitoring: City and County Public Works shall perform site inspections throughout construction.

21. MM-WAT-4 Planting of Vegetation.

As soon as practicable following the completion of trail construction, the contractor shall install native plantings for biological restoration and hydroseed slope areas with an appropriate native plant seed mix, in order to provide long-term stabilization of soils disturbed during construction. Periodic watering and re-application of hydro-seed shall occur as necessary until vegetation on slope surfaces has been successfully established.

Plan Requirements and Timing: Landscaping plans including biological restoration areas and hydro-seeding of manufactured slope areas submitted to City Community Development Department and County Planning & Development (CDD/P&D) for review prior to issuance of zoning clearance.

Monitoring: CDD/P&D shall site inspect vegetation plantings and hydroseed application before issuing final clearance and acceptance of the trail project.

22. MM-WAT-5 Periodic Inspection and Maintenance of Storm Drain Components.

Staff from City and County Parks/Public Works departments shall perform an annual inspection of stormwater components annually, prior to the on-set of the rainy season (November 1) to ensure all components are in good repair and are not blocked by debris or sediment. Any materials found to be obstructing flow in the drainage system shall be removed prior to November 1 each year. The exposed vertical portion of each of the corrugated metal pipe drains shall be examined annually for signs of corrosion, damage or openings in the drain pipe wall. Corrosion visible on the exterior pipe wall shall be treated and sealed promptly, any holes through the pipe wall shall be patched, or the damaged/affected segment shall be replaced or modified.

Plan Requirements and Timing: The Applicant/Owner shall include these inspection and maintenance requirements in the final drainage system design plans. The plans shall be submitted to Community Development Department/Planning & Development (CDD/P&D) and City and County Public Works for review prior to approval of a grading permit and issuance of zoning clearance. Monitoring: A memo with the annual inspection notes and corrective maintenance performed shall be prepared and submitted to the City and County Public Works Departments.

23. MM-WAT-6 Storm Drain Filters.

To minimize pollutants impacting the ocean, storm drain filters/inserts shall be installed in the project area storm drain inlets. The filters/inserts shall be maintained in working order.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Plan Requirements: Prior to approval of Grading Permits and issuance of zoning clearance, the Owner/Applicant shall submit plans identifying the type and location of filters/inserts to Community Development Department/Planning & Development (CDD/P&D) and City and County Public Works for review and approval. The location of such filters/inserts shall be noted on grading and building plans. Timing: Filters/inserts shall be installed prior to final clearance and shall be cleaned using approved methods at least twice a year, once immediately prior to November 1 (before the start of the rainy season) and once in January. Monitoring: CDD/P&D and City and County Public Works shall site inspect periodically throughout the construction phase to ensure proper installation. Records of maintenance shall be maintained by City/County and shall be submitted to CDD/P&D and City and County Public Works on an annual basis prior to the start of the rainy season and for five years thereafter. After the fifth year, the records shall be maintained by the City/County. CDD/P&D and Public Works shall review the maintenance records and site inspect as needed following completion of construction to ensure periodic cleanout.

24. MM-NOI-1 Construction Hours.

Construction activity for site preparation and for future development shall be limited to the hours between 8:00 a.m. and 5:00 p.m., Monday through Friday. No construction shall occur on state holidays (e.g., Thanksgiving, Labor Day) or weekends. Construction equipment maintenance shall be limited to the same hours. Non-noise generating construction activities are not subject to these restrictions.

Plan Requirements: Two signs stating these restrictions shall be posted on site at each end of the proposed trail. Timing: Signs shall be in place prior to the beginning of and throughout all grading and construction activities.

Monitoring: City and County Grading Inspectors shall spot check and respond to complaints.

25. MM-NOI-2 Construction Equipment.

All construction equipment with engines must have original manufacturer’s approved muffling devices. All stationary equipment shall be physically buffered from nearby sensitive receptors.

Plan Requirements: Plans shall indicate the requirement of original equipment manufacturer (“OEM”) muffled equipment. Timing: This condition applies when any engine driven equipment is in use at the project site during construction. Monitoring: City of Carpinteria and County of Santa Barbara Grading Inspectors shall spot check and respond to complaints.

26. MM-TCR-1 Native American Monitor/Observer.

Initial ground disturbing activities shall be monitored by a Native American observer in accordance with the following specifications:

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

Temporary Impact Areas (equipment staging and materials storage outside trail alignment) – a Native American observer, ancestrally affiliated with the area, shall monitor transport and placement activities until such time that it is reasonable to ascertain that no additional prehistoric archaeological/cultural resources are located within areas of temporary disturbance of the proposed project site.

Permanent Impact Areas not including bridge piling installation (all areas of the trail alignment excepting the bridge approach areas on both sides of the UPRR alignment) – a Native American observer, ancestrally affiliated with the area, shall monitor project implementation during the initial grading and excavation activities until such time as sufficient subsurface soil has been uncovered/excavated to ascertain that no additional prehistoric archaeological/cultural resources are located on the proposed project improvement area.

Bridge piling installation – a Native American observer, ancestrally affiliated with the area, shall monitor the installation of bridge pilings within intact soils and/or any soils deeper than 10 feet below current ground surface to ascertain that no additional prehistoric archaeological/cultural resources are located on the proposed project improvement area.

The monitor/observer shall immediately inform equipment operators in the event archaeological resources are encountered, and shall be empowered to immediately halt construction activity in the area of the discovery until assessment can be completed, and materials recovered as appropriate (refer to CR-2 for additional detail). Monitor reports shall be provided to the City of Carpinteria/County of Santa Barbara on a monthly basis during construction, with a final monitoring report produced at the conclusion of construction activities and provided to the City and County.

Plan Requirements and Timing: Prior to issuance of a grading permit, the Owner/Applicant shall contract with a Native American observer, ancestrally affiliated with the area, to monitor initial ground disturbance activities in accordance with the above criteria. Monitoring: City of Carpinteria/County of Santa Barbara staff shall ensure the Native American observer, ancestrally affiliated with the area, provide monitoring of initial ground disturbance activities in accordance with the above criteria through receipt of field documentation describing each day of monitoring, construction activity occurring during the monitoring, and observed soil profile conditions related to the potential for presence of archaeological resources.

PROJECT SPECIFIC CONDITIONS

27. Mitigation Compliance, Monitoring and Reporting Requirement.

Owner/Applicant shall submit to the Community Development Department and County Planning & Development (CDD/P&D) a draft monitoring program for the mitigation measures identified in the Certified EIR, approved Project Description and Conditions of Approval for review and Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

comment. A City-approved biologist and mitigation monitors responsible for permit compliance monitoring shall be retained and paid for by the applicant. The mitigation monitoring program shall include, but not be limited to the following elements for the entirety of the project:
 Mitigation Measures. A list of the project's mitigation measures.  Implementation of Mitigation. Timing and party responsible for implementation of each mitigation measure.
 Mitigation Monitoring. Timing and party responsible for monitoring of each mitigation measure and a list of mitigation monitors to be retained.
 Mitigation Reporting. Procedures, timing and responsible party for reporting to the City on project mitigation compliance and monitoring.

28. Biologist. A City-approved qualified biologist shall be designated by the Owner/Applicant. The biologist shall be responsible for ensuring compliance with the provisions of the Mitigation Monitoring and Reporting Program. The biologist shall have authority over all other environmental monitors provided by the Owner/Applicant. The Owner/Applicant shall submit the name, contact information and qualifications of the biologist and obtain approval from the Community Development Director prior to commencement of construction.

29. Final Architectural Review. The project shall return to the City of Carpinteria Architectural Review Board (“ARB”) for final review and approval of construction plans. Plan Requirements: Plans submitted for final review by the ARB shall include construction plans and specifications all project elements, including but not limited to, fencing and railing, bridge design, signage, landscaping, and any proposed lighting. Timing: Final review by the ARB shall occur prior to zoning clearance and issuance of grading permits. Monitoring: CDD staff shall be responsible for ensuring the project receives final approval from the ARB prior to zoning clearance or issuance of grading permits. CDD staff shall ensure that the final plans approved for construction reflect any required revisions by the ARB.

30. Traffic Management Plan. Provide a detailed Traffic Management Plan for review by Public Works, Community Development, Carpinteria-Summerland Fire Protection District and the Santa Barbara County Sheriff's Office, and obtain approval from the Public Works Director in consultation with the Community Development Director. The plan shall identify:
 Construction Phases. Project construction stage exhibits including work descriptions.
 Staging and Parking Areas. Equipment staging, materials storage and construction worker parking areas.
 Truck Routes. Construction truck routes to minimize noise and traffic effects to residential neighborhoods.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

 Ramp Closures and Detours. Any proposed closures of US 101 ramps and/or detours, by construction stage, if applicable.  City Street Closures and Detours. Any proposed closures of City streets and/or detours, by construction stage.
 Signs and Traffic Control Measures. Signage and other planned temporary traffic control measures, by construction stage.  Public Awareness. A program for public awareness and outreach to commuters, property owners, businesses, residents and agencies affected by project construction.
 Public Relations Committee. Applicant is required to form and support a Public Relations Committee consisting of Caltrans, SBCAG, a public relations consultant, business representatives, residents, transit and public safety agencies and City representatives.

The Committee shall meet regularly prior to and during construction.

Applicant shall review construction, construction phasing, mitigation measures, public relations efforts and permit conditions of approval with the committee. Applicant shall consider feedback and comments from the committee and the general public throughout project construction and make necessary adjustments in response to problems and/or concerns when possible.
 Maintenance of Access. Plans for providing access to businesses, coastal dependent uses and recreational uses during construction.  Motorist Information Measures. Elements such as radio announcements and appropriate signage.
 Incident Response Measures. Strategies such as construction zone enhanced enforcement program (“COZEEP”) and freeway service patrol.
 Coordination and Reporting. A program for ongoing reporting and coordination with the City and other affected agencies throughout construction.

31. Trail Improvement Maintenance Agreement. The City and County shall enter into a Trail Improvement Maintenance Agreement to define the maintenance responsibilities of the trail improvements. The Trail Improvement Maintenance Agreement must be signed and entered into prior to issuance of any Engineering Permits.

32. Pre-Construction Conference. Prior to commencement of construction, a preconstruction conference shall be held by the Resident Engineer to include construction processes and environmental mitigation and monitoring. The conference shall include representatives from Public Works, Community Development, County of Santa Barbara staff, Project Engineer, Landscape Architect, Contractor and Subcontractor(s), Biologist, and Mitigation Monitors.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

33. Temporary Construction Staging Areas. The applicant shall submit to the Public Works Director for approval any areas intended for temporary staging of construction equipment and materials in the City of Carpinteria.

34. Interpretive Signage. Consistent with development standard Carpinteria Municipal Code (“CMC”) § 14.45.030(8)(b), an educational or interpretive display shall be installed which describes the nearby harbor seal rookery.

Plans and details depicting the proposed location, design, construction and content of the display shall be prepared and submitted to the Community Development Department for review and approval prior to issuance of any Engineering Permits for the project.

35. Timing of Project Completion. Pursuant to the requirements of the Transportation Corridor Wetland Overlay District (CMC §14.45), the Santa Claus Lane Multi-Use Path project shall be completed and open to the public no later than the completion of the Linden Avenue and Casitas Pass Road Interchanges and Via Real Extension construction.

CONDITIONAL USE PERMIT CONDITIONS

36. This Conditional Use Permit is not valid until an Engineering Permit for the development and/or use has been obtained. Failure to obtain said Engineering Permit shall render this Conditional Use Permit and Coastal Development Permit null and void. Prior to the approval of the Engineering Permit, all of the conditions listed in this Conditional Use Permit and Coastal Development Permit that are required to be satisfied prior to approval of an Engineering Permit must be satisfied. Upon issuance of the Engineering Permit, the Conditional Use Permit and Coastal Development Permit shall be valid. The effective date of this Permit shall be the date of action by the City Council, or if appealed, the date of action by the Coastal Commission.

37. If the City Council determines at a noticed public hearing that the permittee is not in compliance with any permit condition(s), the City Council is empowered, in addition to revoking the permit pursuant to said section, to amend, alter, delete or add conditions to this permit.

38. Any use authorized by this Conditional Use Permit and Coastal Development Permit shall immediately cease upon expiration or revocation of this Conditional Use Permit and Coastal Development Permit. Any Engineering Permit issued pursuant to this Conditional Use Permit and Coastal Development Permit shall expire upon expiration or revocation of the Conditional Use Permit and Coastal Development Permit. Conditional Use Permit and Coastal Development Permit renewals must be applied for Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

prior to expiration of the Conditional Use Permit and Coastal Development Permit.

39. The owner/applicant's acceptance of this permit and/or commencement of construction and/or operations under this permit shall be deemed acceptance of all conditions of this permit by the permittee.

40. Within two years after the effective date of this permit, construction shall commence. Construction cannot commence until an Engineering Permit has been issued. Failure to commence the construction pursuant to a valid Engineering Permit shall render the Conditional Use Permit and Coastal Development Permit null and void.

41. All time limits may be extended by the City Council for good cause shown, provided a written request, including a statement of reasons for the time limit extension request is filed with Community Development prior to the expiration date.

42. If the owner/applicant requests a time extension for this permit, the permit may be revised to include updated language to standard conditions and/or mitigation measures and additional conditions and/or mitigation measures which reflect changed circumstances or additional identified project impacts. Mitigation fees shall be those in effect at the time of issuance of an Engineering Permit.

43. Before commencing any work pertaining to the erection, alteration, enlarging or rebuilding of any structure or improvement, the owner/applicant shall obtain an Engineering Permit. The permit is necessary to ensure implementation of the conditions required by the City Council. Before any Permit will be issued by Community Development, the owner/applicant must obtain written clearance from all agencies having conditions; such clearance shall indicate that the applicant has satisfied all pre-construction conditions. A form for such clearance is available from Community Development.

44. If, at any time, the City Council determines that there has been, or may be, a violation of the findings or conditions of this Conditional Use Permit and Coastal Development Permit, or of the Municipal Code regulations, a public hearing may be held before the City Council to review this permit. At said hearing, the City Council may add additional conditions, or recommend enforcement actions, or revoke the permit entirely, as necessary to ensure compliance with the Municipal Code, and to provide for the health, safety, and general welfare of the City.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

45. City Manager and/or Community Development Director shall be informed of any minor changes to the project scope. Any minor changes may be approved by the City Manager and/or Community Development Director.

Any major changes will require the filing of a revision application to be considered by the City Council.

46. The owner/applicant shall comply with all requirements of the City of Carpinteria (including but not limited to public improvements as defined in CMC Section 15.16.110) and any other applicable requirements of any federal, state or local law or regulation by an agency of the State and/or any government entity with jurisdiction over the permit or activities thereunder.

47. The standards defined within the City's adopted model Building Codes (UBC; NEC; UMC; UFC; UPC; UHC) relative to the building and occupancy shall apply to this project.

48. Any and all damage or injury to public property resulting from this development, including without limitation, City streets and storm drain infrastructure, shall be corrected or result in being repaired and restored to its original or better condition.

49. No Engineering Permit shall be issued for this project prior to meeting all required terms and conditions listed herein. When not specified herein, all conditions shall be satisfied prior to issuance of an Engineering Permit or prior to commencement of construction when allowed by the Community Development Director.

50. To allow time for the utility companies to locate and mark their facilities for the contractor, the applicant shall telephone Underground Service Alert (USA) toll free at 1-800-227-2600 a minimum of 48 hours prior to the start of construction. For best response, provide as much notice as possible, up to 10 working days.

51. Compliance with the attached Departmental and District letters is required as follows. Where not specified otherwise, Conditions shall be met prior to the start of construction:
a. Carpinteria Sanitary District letter dated October 31, 2019 b. Santa Barbara County Air Pollution Control District letter dated November 12, 2019

52. All applicable final conditions of approval shall be printed in their entirety on applicable pages of grading/construction plans submitted to Community Development. These shall be graphically illustrated where feasible. The approved set of plans shall be retained at the construction site for review by the Public Works Director during the course of construction.

Conditions of Approval, Resolution No. 6111
Rincon Trail Project Appeal
March 28, 2022

53. Owner/Applicant shall ensure that the project complies with all approved plans and all project conditions including those which must be monitored after the project is built and occupied. To accomplish this, owner/applicant agrees to contact Community Development at least two weeks prior to commencement of construction activities to schedule an onsite preconstruction meeting with agency personnel and key construction personnel.

54. Prior to issuance of an Engineering Permit, the owner/applicant shall provide a signed copy of the Conditions of Approval on a form acceptable to Community Development. Such form may be obtained from the Community Development Department. Written authorization to proceed and consent to conditions of approval by the applicant shall be provided to the City prior to commencement of any demolition or construction activity.

55. Written authorization to proceed and consent to conditions of approval by the applicant shall be provided to the City prior to grading permit issuance.

Approved by the City Council on March 28, 2022

I HAVE READ AND UNDERSTOOD, AND I WILL COMPLY

WITH ALL ABOVE STATED CONDITIONS OF THIS PERMIT
_______________________________________________
Owner/Applicant Date

Attachment B
Planning Commission staff
report packet for January 18,
2022 meeting
Rincon Trail Project Appeal
19-2015-CUP/CDP
City Council Hearing, March 28, 2022

Exhibit 1
Resolution PC-22-001
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022

Exhibit 1
Attachment A: Findings for
Approval
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022

Exhibit 1
Attachment B: Proposed Plans
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022
For the Project Plans, please refer to
Attachment A, Exhibit 2
of the City Council Staff Report dated March 28, 2022
Exhibit 1
Attachment C: Recommended
Conditions of Approval
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022

Exhibit 2
Draft Environmental Impact Report
(EIR)
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022
For the Draft Environmental Impact Report (EIR),
please refer to
Attachment C, Exhibits 2 and 3
of the City Council Staff Report dated March 28, 2022
Exhibit 3
Proposed Final Environmental
Impact Report (FEIR)
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022
For the Proposed Final Environmental Impact Report
(FEIR), please refer to
Attachment C, Exhibit 1
of the City Council Staff Report dated March 28, 2022
Exhibit 4
Supporting Project Exhibits &
Graphics
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022

Exhibit 5
October 28, 2021 ARB Meeting
Minutes & Public Comment Letters
Submitted to the ARB
Rincon Trail Project
19-2015-CUP/CDP
PC Hearing, January 18, 2022

Attachment C
Exhibit 1: Proposed Final
Environmental Impact Report
(EIR) Errata
Rincon Trail Project Appeal
19-2015-CUP/CDP
City Council Hearing, March 28, 2022
FINAL

ENVIRONMENTAL IMPACT REPORT

CARPINTERIA RINCON TRAIL PROJECT
STATE CLEARINGHOUSE NUMBER 2020100582

Prepared for:

City of Carpinteria Community Development Department
5775 Carpinteria Avenue
Carpinteria, California 93013
Contact: Nick Bobroff, Principal Planner
Prepared by:
621 Chapala Street
Santa Barbara, California 93101
Contact: Jonathan Leech
DECEMBER 2021
Printed on 30% post-consumer recycled material.

Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 TOC-i
Table of Contents
Section Page No.
1 PREFACE .................................................................................................................................................... 1-1

1.1 Purpose............................................................................................................................................... 1-1

1.2 Format of the Final EIR ...................................................................................................................... 1-1

1.3 Environmental Review Process ......................................................................................................... 1-2

1.3.1 Notice of Preparation............................................................................................................ 1-2

1.3.2 Noticing and Availability of the Draft ................................................................................... 1-3

1.3.3 Final EIR ................................................................................................................................ 1-3

1.4 Revisions to the Draft EIR.................................................................................................................. 1-4 2 RESPONSES TO COMMENTS ..................................................................................................................... 2-1

2.1 Introduction......................................................................................................................................... 2-1

2.2 Global Responses............................................................................................................................... 2-3 Global Response No. 1 – Air Flow Analysis & Impacts to Soaring................................................... 2-3 Global Response No. 2 – Earthwork / Landform Modification ....................................................... 2-6 Global Response No. 3 – Biological Resources ............................................................................... 2-8 Global Response No. 4 – Alternatives Discussion ........................................................................... 2-9

2.3 Individual Comment Letters and Responses..................................................................................2-11 3 CHANGES TO THE DRAFT EIR ..................................................................................................................... 3-1

3.1 Introduction......................................................................................................................................... 3-1

3.2 Errata................................................................................................................................................... 3-1

2.7 Project Description ..................................................................................................................... 3-1

3.1 Aesthetics .................................................................................................................................... 3-4

3.2 Air Quality .................................................................................................................................... 3-5

3.3 Biological Resources (Replacement Section) ........................................................................... 3-6

3.5 Geology & Soils .........................................................................................................................3-54

3.8 Hydrology & Water Quality ........................................................................................................3-55

3.9 Land Use and Planning..............................................................................................................3-58

3.11 Recreation ...............................................................................................................................3-61

6.6.2 Alternative 2............................................................................................................................3-62

6.6.3 Alternative 3............................................................................................................................3-63

6.6.4 Alternative 4............................................................................................................................3-69 8 References ....................................................................................................................................3-70 Appendix C-1.....................................................................................................................................3-77 Appendix C-2.....................................................................................................................................3-77 Figures

3.3-1 Biological Resources......................................................................................................................................3-73

6.2 Alternative 3 Conceptual Design...................................................................................................................3-75 Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 TOC-ii
Acronyms and Abbreviations
Acronym or Abbreviation Definition
µg/m3 micrograms per cubic meter
AB Assembly Bill
ADA Americans with Disabilities Act
ADL aerially deposited lead
ADT average daily trip
AFY acre-feet per year
amsl above mean sea level
APE area of potential effect
APN Assessor’s Parcel Number
ARB Architectural Review Board
AST aboveground storage tank
ATCM Airborne Toxic Control Measure
BAR Board of Architectural Review
Basin Plan Water Quality Control Plan for the Central Coast Basin BMPs Best Management Practices
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CalARP California Accidental Release Prevention Program CalEEMOD California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CAL FIRE California Department of Forestry and Fire Protection CALGreen California Green Building Standards Code
CalOES Governor’s Office of Emergency Services
Cal/OSHA California Occupational Safety and Health Administration CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CARB California Air Resources Board
CAWet California Waste Extraction Test
CBC California Building Code
CCIC Central Coast Information Center
CCR California Code of Regulations
CDB coastal development permit
CDD/P&D Community Development Department/Planning & Development CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFC California Fire Code
CGS California Geological Survey
CH4 methane
CHRIS California Historical Resources Information System CIDH cast-in-drilled hole
City City of Carpenteria
Acronyms and Abbreviations
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 TOC-iii
Acronym or Abbreviation Definition
CGP Construction General Permit
CLUP Coastal Land Use Plan
CNCL California Natural Community List
CNDDB California Natural Diversity Database
CNEL community noise equivalent level
CNPS California Native Plant Society
CNRA California Natural Resources Agency
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
County County of Santa Barbara
CPUC California Public Utilities Commission
CRHR California Register of Historical Resources
CRPR California Rare Plant Rank
CRTP Cultural Resource Treatment Plan
CSFPD Carpinteria-Summerland Fire Protection District
CUP conditional use permit
CUPAs Certified Unified Program Agencies
CVWD Carpenteria Valley Water District
CY cubic yards
dB decibel
dBA A-weighted decibel
DOC California Department of Conservation
DOT U.S. Department of Transportation
DPM diesel particulate matter
DTSC Department of Toxic Substances Control
DVP development plan permit
ECAP Energy and Climate Action Plan
EERP Enforcement and Emergency Response Program
EIA U.S. Energy Information Administration
EIR Environmental Impact Report
EISA Energy Independence and Security Act of 2007
EO Executive Order
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
ESH environmentally sensitive habitat
ESHA environmentally sensitive habitat area
EV electric vehicle
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
FE federally endangered
FEMA Federal Emergency Management Agency
FHSZ Fire Hazard Severity Zone
FHWA Federal Highway Administration
FIRM Flood Insurance Rate Map
FMMP Farmland Mapping and Monitoring Program
FP fully protected
Acronyms and Abbreviations
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 TOC-iv
Acronym or Abbreviation Definition
FPPA Farmland Protection Policy Act
FRA Federal Railroad Administration
FT federally threatened
FTA Federal Transit Administration
GHG greenhouse gas
GWP global warming potential
HCFCs hydrochlorofluorocarbons
HERO Human and Ecological Risk Office
HFC hydrofluorocarbons
HHRA Human Health Risk Assessment
Hz Hertz
IEPR Integrated Energy Policy Report
IPCC Intergovernmental Panel on Climate Change
kBTU thousand British thermal units
LCP local coastal plan
Ldn average A-weighted noise level
Leq equivalent noise level
Lmax maximum A-weighted sound level
Lmin minimum A-weighted sound level
LOS Level of Service
LUDC Land Use Development Code
LUST leaking underground storage tank
MCV2 Manual of California Vegetation, 2nd edition
mg/kg milligrams per kilogram
MLD most likely descendant
MM Mitigation Measure
MMRP Mitigation Monitoring and Reporting Program
MMT million metric ton
MND Mitigated Negative Declaration
MS4 Municipal Separate Storm Sewer System
MT metric ton
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NHTSA National Highway Traffic Safety Administration
NO2 nitrogen dioxide
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
OEHHA Office of Environmental Health Hazard Assessment
OES Office of Emergency Services
O3 ozone
OPR Governor’s Office of Planning and Research
PCRs Post Construction Requirements
PFCs perfluorocarbons
PGA peak ground acceleration
PM2.5 particulate matter with an aerodynamic diameter less than or equal to 2.5 microns Acronyms and Abbreviations
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 TOC-v
Acronym or Abbreviation Definition
PM10 particulate matter with an aerodynamic diameter less than or equal to 10 microns ppm parts per million
PPV peak particle velocity
PRC California Public Resources Code
Preserve Carpinteria Bluffs Nature Preserve
PSR Project Study Report
RCRA Resource Conservation and Recovery Act
RFS Renewable Fuel Standard
RHNA Regional Housing Needs Allocation
RMS root mean square
ROC reactive organic compound
RPS Renewables Portfolio Standard
RSLs Residential Screening Levels
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SAB State Allocation Board
SARA Superfund Amendments and Reauthorization Act
SB Senate Bill
SBCAG Santa Barbara County Association of Governments
SBCAPCD Santa Barbara County Air Pollution Control District SBCCO Santa Barbara County Code of Ordinance
SCCAB South Central Coast Air Basin
SBCOEM Santa Barbara County Office of Emergency Management SCE Southern California Edison
SCS Sustainable Communities Strategy
SDL state delisted
SE state endangered
SF6 sulfur hexafluoride
SLF Sacred Lands File
SLPC short-lived climate pollutants
SLRVA Sea Level Rise Vulnerability Assessment
SLs screening levels
SNA state not applicable
SNR state no rank
SO2 sulfur dioxide
SOx sulfur oxides
SPCC Spill Prevention, Control and Countermeasure
SR State Route
SRA State Responsibility Area
SSC Species of Special Concern
ST state threatened
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminants
TCM Transportation Control Measures
TCR Tribal Cultural Resource
TDM transportation demand management
Acronyms and Abbreviations
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Acronym or Abbreviation Definition
UPRR Union Pacific Railroad
USACE U.S. Army Corps of Engineers
USDA U.S. Department of Agriculture
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UST underground storage tank
UWMP Urban Water Management Plan
UWMP Act Urban Water Management Planning Act
VdB vibration decibel
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic compound
WEAP Workers Environmental Awareness Program
WL Watch List
WQO water quality objectives
ZEV zero emissions vehicle
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 1-1
1 Preface

1.1 Purpose
This Final Environmental Impact Report (EIR) has been prepared by the City of Carpinteria (City) for the Carpinteria Rincon Trail Project (project or proposed project). This Final EIR has been prepared in conformance with the California Environmental Quality Act of 1970 (CEQA) statutes (Cal. Pub. Res. Code, Section 21000 et. seq., as amended) and implementing guidelines (Cal. Code Regs., Title 14, Section 15000 et. seq.).

Before approving a project, CEQA requires the lead agency to prepare and certify a Final EIR. The City has the principal responsibility for approval of the proposed project and is therefore considered the lead agency under CEQA Section 21067. According to the CEQA Guidelines, Section 15132, the Final EIR shall consist of:
• The Draft EIR or a revision of the Draft EIR
• Comments and recommendations received on the Draft EIR either verbatim or in summary • A list of persons, organizations, and public agencies commenting on the Draft EIR • The responses of the lead agency to significant environmental points raised in the review and consultation process; and
• Any other information added by the lead agency

1.2 Format of the Final EIR
This Final EIR consists of the March 2021 Draft EIR and the following three chapters:

1.0 Preface. This chapter summarizes the contents of the Final EIR, the environmental review process, and several minor updates that occurred in the Draft EIR subsequent to the release of the Final EIR for public review.

2.0 Response to Comments. During the 45-day public review period for the Draft EIR, 52 comment letters were received.

This chapter contains these comment letters and the City’s responses to the comments.

3.0 Errata. Comments that are addressed in Chapter 2.0 may have resulted in minor revisions to the information contained in the March 2021 Draft EIR. Where necessary, deletions to the text are shown in strikeout and additions to the text are shown in underline in all chapters of the Draft EIR where revisions were deemed necessary as a result of received comments. Additionally, through the certification of this Final EIR, where the term “Draft EIR” is used in the text, this is now deemed to be “Final EIR.”

1.3 Environmental Review Process

1.3.1 Notice of Preparation
CEQA requires preparation of an EIR when there is substantial evidence supporting a fair argument that a proposed project may have a significant effect on the environment. The purpose of an EIR is to provide decision makers, public agencies, and the general public with an objective and informational document that fully discloses the environmental effects of the proposed project. The EIR process is intended to facilitate the objective evaluation of 1 – Preface
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 1-2
potentially significant direct, indirect, and cumulative impacts of the proposed project, and to identify feasible mitigation measures and alternatives that would reduce or avoid the proposed project’s significant effects. In addition, CEQA requires that an EIR identify adverse impacts determined to be significant after mitigation.

In accordance with the CEQA Guidelines, a Notice of Preparation (NOP) was distributed on October 30, 2020, to public agencies, organizations, and interested individuals. The purpose of the NOP was to provide notification that the City plans to prepare an EIR and to solicit input on the scope and content of the EIR. A public scoping meeting was also held via Zoom video conference on November 17, 2021. The purpose of this meeting was to seek input from public agencies and the general public regarding the potential environmental impacts of the proposed project.

Various agencies, organizations, and individuals submitted 78 written comment letters in response to the NOP.

These letters and the NOP were included in Appendix A of the Draft EIR.

1.3.2 Noticing and Availability of the Draft EIR
The Draft EIR was made available for public review and comment pursuant to CEQA Guidelines Section 15087.

The 45-day public review period for the Draft EIR started on March 12, 2020 and concluded on April 26, 2021.

At the beginning of the public review period, an electronic copy of the Draft EIR and an electronic copy of the Notice of Completion (NOC) were submitted to the State Clearinghouse. Relevant State agencies received electronic copies of the documents. A Notice of Availability (NOA) was distributed to interested parties and filed with the State Clearinghouse. The NOA described where the document was available and how to submit comments on the Draft EIR. The NOA and Draft EIR were also made available to be viewed on the City website at:
https://carpinteriaca.gov/public-works/engineering-division/rincon-multi-use-trail/ During the 45-day public review period, a public hearing was held virtually over Zoom by the City of Carpinteria Environmental Review Committee (ERC) on April 13, 2021. A total of 52 agency, organization, and individual comment letters were received and are included in Chapter 2, Responses to Comments, of this Final EIR.

1.3.3 Final EIR
The Final EIR addresses the comments received during the public review period and includes minor changes to the text of the Draft EIR in accordance with comments that necessitated revisions. This Final EIR will be presented to City decision-makers for potential certification as the environmental document for the proposed project. All agencies who commented on the Draft EIR will be provided with a copy of the Final EIR, pursuant to CEQA Guidelines Section 15088(b). The Final EIR will also be posted on the City’s website at:
https://carpinteriaca.gov/public-works/engineering-division/rincon-multi-use-trail/ Pursuant to CEQA Guidelines Section 15091, the City shall make findings for each of the significant effects identified in this EIR and shall support the findings with substantial evidence in the record. After considering the Final EIR in conjunction with making findings under Section 15091, the lead agency may decide whether or how to approve or carry out the project. When a lead agency approves a project that will result in the occurrence of significant effects that are identified in the Final EIR, the agency is required by CEQA to state in writing the specific reasons to support its action based on the Final EIR and/or other information in the record (a statement of findings). A “statement of findings” will be prepared pursuant to CEQA Guidelines Section 15093 and supported by substantial evidence in the record.
1 – Preface
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 1-3

1.4 Revisions to the Draft EIR
The comments received during the public review period for the Draft EIR resulted in several minor clarifications and modifications in the text of the March 2021 Draft EIR. In addition, minor editorial corrections have been made in sections of the Draft EIR. These changes are included as part of the Final EIR, to be presented to City decision makers for certification and project approval.

CEQA Guidelines Section 15088.5 identifies when a lead agency must recirculate an EIR. A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the Draft EIR but before certification of the Final EIR. Information includes changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not considered significant unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. As defined in CEQA Guidelines Section 15088.5(a), significant new information requiring recirculation includes the following:

1. A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.

2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.

3. A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.

4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

The minor clarifications, modifications, and editorial corrections that were made to the Draft EIR are shown in Chapter 3.0, Changes to the Draft EIR, of this Final EIR. None of the revisions that have been made to the EIR resulted in new significant impacts; none of the revisions resulted in a substantial increase in the severity of an environmental impact identified in the Draft EIR; and, none of the revisions brought forth a feasible project alternative or mitigation measure that is considerably different from those set forth in the Draft EIR. Furthermore, the revisions do not cause the Draft EIR to be so fundamentally flawed that it precludes meaningful public review.

As none of the CEQA criteria for recirculation have been met, recirculation of the EIR is not warranted. As stated in CEQA Guidelines Section 15088.5(b), “recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” 1 – Preface
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INTENTIONALLY LEFT BLANK

2 Responses to Comments
The Draft EIR was circulated for public review on March 12, 2021 through April 26, 2021, in accordance with the 45-day comment period required under Section 15105(a) of the CEQA Guidelines. A total of 52 comment letters were received on the Draft EIR from agencies, organizations, and individuals as shown in the list below. In response to the comments received during public review and to City of Carpinteria (City) staff input subsequent to distribution of the Draft EIR, minor revisions, clarifications, and/or additions have been made to the document which do not change the conclusions of the Final EIR regarding the project’s potential environmental impacts and required mitigation. These minor revisions do not represent significant new information. No new significant environmental impacts would occur from these modifications, and similarly, no substantial increase in the severity of environmental impacts would occur. When a comment is not directed to significant environmental issues, the responses indicate that the comment has been acknowledged and no further response is necessary.

The list of commenters and the unique letter-number designators for each letter are shown in Table RTC-1, List of Commenters. Individual comments within each letter are bracketed and subsequently numbered in the right-hand margin of the comment letter. Bracketed/numbered comment letters are placed before the responses to the letter provided below.

Four topics or issue areas were identified in a large percentage of the comment letters, including concerns about the air flow analysis and related impacts to recreation (soaring opportunities), the magnitude of earthwork or landform modification, impacts to biological resources, and the range of alternatives considered. Since these issue areas were present in multiple comment letters, Dudek created a global response addressing each of these areas. The global responses are presented first, preceding the individual comment letters and responses.

Table RTC-1. List of Commenters
Commenter Letter No.

State Agency
Southern California Gas S-1
California Public Utilities Commission S-2
California Coastal Commission S-3
California Department of Fish and Wildlife S-4
Local Agency
Santa Barbara County Association of Governments L-1
Carpinteria Sanitary District L-2
Carpinteria Sanitary District L-2a
County of Santa Barbara Planning Department L-3
County of Ventura Resource Management Agency L-4
Tribes
Northern Chumash Tribal Council T-1
Organizations
Friends of Bates Beach O-1
Individuals
Aaron LaPlante I-1
E. Arciniega I-2
E. Arciniega I-3
Aaron LaPlante I-4
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-2
Table RTC-1. List of Commenters
Commenter Letter No.

E. Arciniega I-5
Scott Wuebber I-6
Myles Connolly I-7
Ottis Gillespie I-8
Laura Davalos, PT, DPT I-9
E. Arciniega I-10
Ottis Gillespie I-11
Desmond I-12
Caleb Pillips I-13
Michael Hilbreath I-14
Brandon Stingham I-15
Jamie Bishop I-16
Wayne Michelsen I-17
Randall McCormick I-18
Mike Harrington I-19
Adam Zerkel I-20
Ottis Gillespie I-21
Robin Cushman I-22
Ryan Soares I-23
Jon Lewis I-24
Betty Winholtz I-25
Riebeeck van Niekerk I-26
Jeffrey Longcor I-27
Jason Lombard I-28
John Greynald I-29
Ajay Rajamani I-30
Rob Sporrer I-31
Ottis Gillespie I-32
Tim Barker I-33
Karl Cameron I-34
William C. Prechter I-35
Jorge Granier I-36
George Jimenez I-37
Mark Rayburn Patterson, PhD I-38
Derek Musashe I-39
Morgan Waterman de Granier I-40
Derek Arculli I-41
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-3
Global Responses for Topics Common to Multiple Comment Letters GR1: Impacts Upon Soaring Opportunities / Airflow Study A number of commenters suggested that the Recreation Section should not have included a discussion on the fundamentals of soaring or Federal Aviation Administration (FAA) regulations pertaining to soaring activities, and also expressed skepticism regarding the conclusions of the airflow analysis study and the determination of a less than significant project impact on existing soaring opportunities. The response below is intended to address these issues, which are common to multiple comments received.

Discussion of Soaring Fundamentals
Responses to the Notice of Preparation (NOP) by members of the soaring community identified the need to assess impacts of the Project on existing opportunities for soaring in the air space above the Project alignment. While members of the soaring community are required to possess an understanding of the principles affecting paragliding or hang-gliding flight, including factors that influence launch and flight duration, members of the general public and decision-makers are unlikely to have familiarity with such principles. Consequently, it is appropriate to provide a summary of fundamentals pertaining to hang-gliding and paragliding, in order for the public to have a basic understanding of the physical conditions needed to support soaring.

The fundamentals description was derived from the Elementary Pilot Training Guide (British Hang-gliding and Paragliding Association, 2021). As a reference for beginning soaring pilots, the guide provides straight-forward discussion of flight principles and wind effects for soaring, using explanations that should be understandable for new pilots as well as interested individuals that do not engage in soaring.

Federal Aviation Administration (FAA) Regulations on Soaring For each environmental issue area (organized by individual sections or chapters), the EIR provides a summary of the federal, state and local regulations that pertain to the given issue area. Adopted General Plan Policies, ordinances, and regulations, often govern the activities or development allowed on a given property or may be a component of the significance thresholds established for that issue area.

In that NOP responses identified the need to address Project impacts on existing opportunities for soaring in the air space above the Project alignment, it is appropriate to present FAA regulations on soaring as part of the regulatory discussion in the Recreation Section of the EIR.

Airflow Analysis Study
Multiple commenters expressed the perception that the Airflow Analysis Report “specifically states it is based on theory and not intended for this purpose.” This perception is evidently based upon the disclaimer provided at the end of the report, which is standard for an aerodynamics analysis of this type. The report disclaimer neither represents the study is based on theory alone, nor that the conclusions are inapplicable to the analysis of airflow alterations resulting from the proposed topographic modifications. The analysis methodology and the intent of the disclaimer are discussed in detail below.

Modeling is commonly employed in the evaluation of environmental effects that could result from a proposed action.

Agricultural land conversion, air quality emissions, noise levels, and traffic generation typically are analyzed with the aid of models. The models use equations, which are based upon the measurement of various characteristics Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-4
associated with existing activities, to predict these same characteristics for a proposed new project or action. As the number of measurements of characteristics from existing activities increases, the statistical integrity of the data and equations improves, and the model results become more accurate; but the model results remain a prediction, and are not guaranteed to 100 percent reflect actual future conditions. With respect to environmental aerodynamics, a comprehensive model for the prediction of airflow alterations from topographic modification has not been developed at this time (Luzzatto-Feliz, Email Communication, June 2021). The airflow analysis report (Airflow Analysis for the Proposed Regrading of the Rincon Bluffs, Paolo Luzzatto-Feliz, PhD, January 22, 2021) therefore incorporates existing data from field measurements of air flow over large-scale topographic features, from aerodynamic experiments conducted with scaled models in wind tunnels, from engineering standards for wind stress on buildings, and from published literature addressing wind flow over topography as related to soaring activities, to evaluate potential changes in airflow dynamics associated with the project.

Wind amplification is an important concept in the discussion of air flow over topography. When a mass of air which is moving horizontally over a level surface (e.g., wind blowing over the ocean surface) encounters a hill or cliff, the air volume in front of the hill is compressed into a smaller volume which flows at a faster rate over the hill/cliff, compared to the remainder of the air mass much higher above the hill. In other words, the wind speed approaching the hill at elevations below the top of the hill will be lower than the wind speed as it passes over the top of the hill.

As discussed in the air flow analysis study, extensive experiments in 1977 with scaled models in a wind tunnel investigated the effects of changing the angle of the slope, relative to the amount of wind amplification produced by the slope. These original wind tunnel experiments concluded that increasing the angle of the slope for gentle slopes (i.e., slopes from 4:1 or 14 degrees to 2:1 or 27 degrees) did result in wind speed increases. However, for slopes steeper than 2:1, the maximum flow velocity no longer increased with an increase in the slope angle; and likewise decreases in slope angle that do not reduce the slope to less than 2:1 did not decrease the maximum wind velocity. Equations from the wind tunnel experiments were developed to address the wind amplification related to steepness of the slope; subsequent researchers have conducted environmental measurements of wind flow over slopes with varying slope angle, and showed that, for the front and top regions of the topography, field measurements at full scale agreed closely with the wind tunnel experiments. It should be noted that the existing bluff face along the project site has a slope angle greater than 2:1, and the resulting slope angle following the regrading under the proposed project or under Alternative 3 would also maintain a slope angle greater than 2:1.

Because of this, horizontal wind speeds at low altitudes over the bluff top are not expected to be altered by the project.

Vertical wind speed, or uplift, is of interest to the soaring community and is also produced when horizontal wind encounters a slope. Soaring literature contains simple equations for converting horizontal wind speed to a vertical wind speed component, which involves the sine of the slope angle. These equations are again based upon those developed from wind tunnel experiments. For more complex topography, for instance, a slope that has sections of varying steepness or which includes benches, researchers have identified an appropriate semi-empirical approach to estimate uplift. The semi-empirical approach generally involves applying the equations developed from wind tunnel experiments using simple slope models, compare the prediction results of these equations against data from vertical air flow measurements on existing large-scale complex topography in the environment, and make adjustments to the applied equation until the predicted vertical wind speeds are close to those measured.

Researchers have identified two approaches that have been successful for the prediction of vertical wind velocities produced from flow over complex topography. The first approach is to use the mean or average slope degree across the entire face of the slope. The second approach uses the average slope degree over the upper portion of the slope (approximately the top third of the slope face), which is immediately below the wind flow amplification zone.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-5
The air flow analysis report employs both of these approaches to predict changes to vertical wind velocities from slope angle modification (i.e., regrading), and reports the results of each approach.

The vertical wind speed prediction approach using the average slope degree of the upper third portion of the slope is based upon research and environmental wind measurements by Crawley & Schmanske (1994). The equation resulting from this approach was specifically focused on vertical wind speeds closer to the surface of the topography, which are important for low elevation soaring operations including take-off and landing maneuvers.

Using this approach, vertical wind speeds within the zone that extends upward approximately 20 feet from the bluff top are predicted to be reduced by no more than 10 percent. This predicted reduction in vertical wind speed at low altitudes addresses the re-grading of the bluff face for the proposed project and for Alternative 3. This equation and method is considered to be most accurate within approximately 20 vertical feet of the evaluated topographic feature; the other equation (described below) is appropriate for predicting wind speed alterations at higher elevations above the ground.

The vertical wind speed prediction approach using the average slope degree of the entire slope was developed by researchers to provide a conservative assessment of potential wind speed alterations from slope modification, at altitudes up to a height (elevation) equal to the height of the topographic feature. This approach predicts a potentially conservative vertical wind speed reduction from proposed project regrading of between 25 and 30 percent for elevations within 30 feet above the bluff-top, and approximately 30 percent at elevations above 30 feet over the bluff. For Alternative 3, this approach predicts a vertical wind speed reduction of approximately 20 percent for elevations up to approximately 120 feet above the bluff top.

The disclaimer at the end of the airflow analysis report (Page 11, Luzzatto-Feliz, January 2021) is standard for the type of predictive modeling contained in the report. Sufficient research was performed in the study to identify and compare technical experts’ analytical approaches which included wind tunnel experiment results, environmental measurements of horizontal and vertical wind velocity effects associated with topography, and calculations employed for estimating wind velocities for soaring. As indicated in the airflow analysis report, results from the application of appropriate formulas to predict wind velocity changes from the project were checked against published results from various research and were found to compare favorably (Page 9, Luzzatto-Feliz, January 2021). The disclaimer is intended simply to indicate the analysis is predictive in nature, and as with all modeling efforts, future conditions could vary slightly from the predicted conditions.

Conclusion of Less Than Significant Impact Regarding Soaring Opportunities Published data for the Torrey Pines Gliderport indicate tandem hang-gliders (which can carry pilot and passenger or instructor and student) require a horizontal wind speed between 7 and 15 mph, while tandem para-gliders require wind speed between 10 and 18 mph. According to the U.S. Hang Gliding and Paragliding Association, the ideal wind speed for launching solo gliders is from 5 to 20 mph (https://www.ushpa.org/page/hang-gliding-frequently-askedquestions). This horizontal wind speed range ensures the air movement across the “wing” of the glider is sufficient to produce lift, thereby making launch (take-off) feasible. These data reflect a range of at least 50 percent wind speed across which launch of tandem gliders is feasible, with a range of 75 percent for solo glider launch. Research findings from the air flow analysis indicate, that for slopes steeper than 2:1 (27 degrees), a change to the average slope face does not result in changes to air flow amplification or horizontal wind speeds along the top of the slope. (Page 11, Luzzatto-Feliz, January 2021). Existing slopes, and those resulting from the project or Alternative 3, would each remain greater than 2:1. Hence no decrease in the horizontal wind speeds immediately above the bluff are anticipated from the project, and the ability to launch gliders from areas adjacent to the project alignment would not be affected.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-6
Vertical wind velocities, which affect the ability for a hang-glider or para-glider to increase their altitude and thus extend flight duration, could be reduced in the air space above the trail alignment under the Project and Alternative 3, compared to existing conditions. Using an approach following the methodology of an analysis of topographic effects upon air flow that was conducted specifically for soaring that, as discussed above, employed a specific altitude for determining vertical wind speeds from different slope angles and using the average slope degree for the upper slope, the air flow analysis predicts only a maximum of 10 percent reduction in the vertical wind speeds within approximately 20 vertical feet of the bluff top (refer to additional explanation above). Thus, very low altitude soaring flights over the project alignment are not expected to be substantially affected under most conditions.

Vertical wind velocities at altitudes greater than 30 feet above the bluff face could be reduced by up to 30 percent, meaning there could be fewer opportunities for gliders to gain altitude and extend the duration of their flights in the area above the project alignment, as compared to existing conditions. Based again upon the reported 50 percent range in horizontal wind speeds for successful launch and flight at Torrey Pine Gliderport, and a 75 percent wind speed range for solo glider launch (USHPA), a reduction by 30 percent of the vertical wind speeds at higher elevations over the project alignment is not expected to result in a substantial decrease in soaring opportunities. In addition, the existing bluff face to the west of the trail crossing over the UPRR alignment would not be modified by the project, and therefore ambient air flow conditions along this bluff face would remain unchanged.

Further, as discussed in Section 3.11.4 of the Draft EIR, CEQA requires an analysis of physical impacts to the environment; it does not require analysis of social and economic impacts resulting from a project. (Preserve Poway v. City of Poway (2016) 245 Cal.App.4th 560, 566, 579-580; CEQA Guidelines, § 15064(e).) The airflow analysis report demonstrates that any potential adverse impacts on the usability of air space above the proposed trail alignment are unlikely to cause significant physical impacts on the environment. (See, e.g., Chico Advocates for a Responsible Economy v. City of Chico (2019) 40 Cal.App.5th 839 (reasoning that loss of convenience is merely an example of a social problem, and without an accompanying physical change to the environment, CEQA does not require its analysis); CEQA Guidelines, § 15131(a).) Section 3.3.4 of the Final EIR further evaluates the extent to which the project’s topographic changes associated with regrading result in a less than significant environmental impact to migratory avian species. As such, the airflow analysis report provides an expert opinion, based on substantial evidence, that the project will not result in a significant environmental impact.

GR2: Earthwork/Landform Modification
Several commenters highlighted concerns with the volume of earthwork necessary to implement the proposed project and indicated that additional effort should be completed to identify alternatives for trail development that could further reduce earthwork volumes and landform modification. One commenter correctly provided a comparison of the amount of earthwork between the original trail proposal (2015) and the current proposal, indicating the original design involved substantially less earthwork. However, that original design was later found via geotechnical investigation to be infeasible due to the presence of active landslide areas along the originally proposed (2015) trail alignment (Carpinteria Rincon Trail Project Draft EIR, Page 6-9).

With respect to the modification of landforms, the proposed project would re-contour manufactured slopes originally created for the past and current UPRR alignments, the former State Highway 2, and U.S. Highway 101. The remanufacture of such slopes would result in minimal change to the existing appearance of the slopes, in that they already exhibit more regular planar characteristics than the undulating surfaces that pre-dated the transportation corridor mass grading activities affecting all of the slopes along the trail alignment. Existing sparse vegetation on sloped areas would be replaced with an appropriate assemblage of native, drought-tolerant species using hydro- Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-7
seeding and individual container plants, such that short-term visual impacts from earthwork and vegetation removal would be adequately mitigated.

The City and County local coastal plans do reference Coastal Act Section 30251, which requires that the scenic and visual qualities of coastal areas shall be considered and protected, and that new development is sited and designed to minimize alteration of natural land forms and also be subordinate to the character of its setting. The project is consistent with Coastal Act Section 30251 based on the following considerations included in the trail design:
a) Earthwork would largely affect manufactured slope areas—containing debris and excavated material from previous railroad and state highway construction projects—not natural landforms. The top elevation of local ridges within the project area would be preserved, thus maintaining the most visible aspect of site topography which relates to the ridges and bluff-top east and west of the project site. b) The trail itself would remain a subordinate feature in the visual environment of the site, with a scale that would not draw attention away from the high slopes and ridges against which it is set. The resulting landforms from earthwork to construct the trail would have a similar appearance to both existing slopes along the alignment, as well as to the manufactured slopes extending eastward and westward from the project alignment along the UPRR and U.S. Highway 101 corridors. c) As part of the remanufacturing of the ocean-side slope east of the existing UPRR alignment, the abandoned former railroad bench cut would be largely filled in, such that the bluff face would continue to have a prominent bench cut into its face, but in a new location slightly higher on the bluff face in order to achieve the necessary trail slope profile. In this respect, the visual condition of a bench cut traversing the face of the manufactured slope would not differ significantly from the existing condition. d) Once re-manufactured slopes are revegetated (as proposed) such slopes would be more compatible with the natural surrounding than the historic cut slopes remaining from the railroad and state highway construction. Because the project proposes to reduce the slope angle of manufactured slopes (compared to existing), run-off velocity for storm run-off would be reduced, erosion of the bluff face would be reduced, and additional moisture would be retained to support re-planted native and drought-tolerant plants.

With regard to the smaller volume of earthwork identified for the original trail proposal, substantial height retaining walls were proposed as an alternative to earthwork. The original trail design would have necessitated approximately 1,000 feet of retaining wall, with a maximum height of 14 feet. That design was prepared without the benefit of specific geotechnical investigation methods, which have subsequently identified deep-seated landslides along the former extensive switchback section that would have extended eastward from the UPRR rail crossing. The original alignment, due to the presence of severely unstable slope sections, has since been deemed infeasible by the project engineers. Another aspect of the original retaining wall design is that they were intended to anchor the trail itself but would not have addressed soil creep or rock fall from steep manufactured slopes above the elevation of the trail. Thus, trail users would not have been as protected from risk of falling earth materials and the trail itself could have been subject to more intensive maintenance or repair activities. The current design anchors the trail itself on one bench (situated on a low angle slope), with a more stable low-angle slope above it.

Consequently, while earthwork volumes would increase under the current proposal, the resulting slopes and landforms would have greater long-term stability, retaining walls (which are generally more prominent visually) would be completely avoided, and slope angles more conducive to successful revegetation would result, as compared to the original design from 2015. With regard to a proposal which respects the scenic qualities of coastal Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-8
areas and remains visually subordinate to the character of the setting, the current proposal is more consistent with coastal policy mandates than the original 2015 alignment. In addition, as discussed above, the original alignment that theoretically could have involved lower earthwork volumes has been proven infeasible. Any trail project within this highly modified environment characterized by remnant manufactured slopes from current and relic transportation corridors by necessity must address correction of unstable steep slope faces, leading to what could appear to be “excessive” grading.

The engineering design for Alternative 3 was specifically driven by an intent to minimize overall project earthwork volumes. Alternative 3 would result in a reduction of 40 cubic yards of excavation compared to the proposed project (with exported material reduced by 121 cubic yards). In this regard, Alternative 3 represents the greatest opportunity to minimize excavation and exported soil earthwork volumes to implement the project. Once again, it is worth reiterating that the slopes along the trail alignment have been subject to previous modification to accommodate transportation projects, and therefore the proposed earthwork would affect manufactured slopes and not natural landforms. Additionally, the remnant slope faces in most cases are steeper than current engineering standards would recommend (and which would be corrected via the project), and the grading to create the benches for the trail are dictated, in part, by the maximum grade percent which is acceptable under ADA. In fact, an approximately 690 foot portion of the trail south of the UPRR crossing with Alternative 3 would marginally exceed the 5 percent maximum ADA trail slope face (this 690-foot segment of the trail would be constructed with trail surface of 6 percent slope) in order to capitalize on as much of the former railroad bench as possible and thereby minimize project earthwork.

The engineering design evaluation to create Alternative 3 informed the project development team, and the proposed project has been subsequently revised to remove the previously proposed mid-elevation bench above the trail segment south of the UPRR alignment. This design change reduces the earthwork volume by 11,346 CY (9.6 percent reduction) for the currently proposed version of the project, compared to the previous version of the proposed project evaluated in the Draft EIR. Alternative 3 further reduces the volume of excavated and exported materials (40 CY less excavation, 121 CY less exported earth material). Alternative 4 was determined to have a very similar total volume of earthwork as the proposed project but would increase export material volumes by approximately 10,000 CY (as compared to the project). Alternative 2 was initially thought to involve substantially less earthwork, but additional geotechnical investigations indicate the presence of extensive landslide features that would require massive retaining structures; as well, available engineering and geotechnical methods for stabilizing the landslide mass are not known to be feasible. The alternatives investigated represent three different potential alignments for the trail, with the degree of topographic modification being a chief factor in the identification of potential alignments. The earthwork for each alignment has been identified for comparison, with total variance between the most and least volume of earthwork at approximately 10 percent. Consequently, the EIR authors do not believe that additional alternatives for the purpose of minimizing earthwork volumes would be warranted in order to meet the criteria for sufficiency of alternatives analysis under CEQA Section 15126.6(d).

GR3: Biological Resources
Commenters have indicated that the field surveys have failed to detect some plant and wildlife species that are present within the project alignment, and that further alternatives should be developed and studied in order to avoid or minimize project impacts upon environmentally sensitive habitat areas (ESHA).

Dudek biologists have conducted general biological resources surveys of the project site in multiple instances, during the spring season of five separate years (2011, 2018, 2019, 2020 and 2021). Because of the history of the design development and subsequent re-design efforts for the proposed trail, the site has been evaluated for the Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-9
presence of biological resources much more extensively than typically occurs for a development proposal. Dudek biologists are therefore confident that all important biological resources present within and adjacent to the project alignment and all alternatives have been identified.

According to City of Carpinteria General Plan/Local Coastal Land Use Plan Figure OSC-1, the entire area east of Bailard Avenue and lying between U.S. Highway 101 and the beach is included in an ESHA overlay. While not all area included within the ESHA overlay may have sensitive resources present, it would not evidently be feasible to implement a trail connecting the eastern terminus of Carpinteria Avenue to the northern terminus of the Coast Bike trail (at the southern end of Rincon Beach Park) without impacting some area designated as ESHA. It should be noted that no ESHA designation has been applied by the County of Santa Barbara for the portion of the Rincon Trail alignment within their jurisdiction.

While the total native plant community impact area appears to substantially increase under the current proposal as compared to the original proposal (Alternative 2), this is because of greater area involved with slope remanufacturing. What must be kept in mind, however, is that the regrading of the slopes to have lower slope angles will enhance the success of the revegetation effort. The original proposal (Alternative 2) would not have included as extensive modification of slopes but would have incorporated substantial retaining walls (which would not provide area for replanting); in essence, the vertical retaining wall area under Alternative 2 represents a larger overall hardscape footprint for the project that would be unavailable to support vegetation, as compared to the current proposal. In this regard, the current proposal, while producing a larger area of impact due to more extensive earthwork area, would have lower residual (permanent) impacts upon native plant communities and ESHA than the original proposal. Mitigation has been required for the impacts to native plant communities (ESHA) including a mandatory restoration plan within both the City of Carpinteria and County of Santa Barbara portions of the project.

The final restoration plan will include performance standards and an appropriate combination of hydro seeding and container plants to support long-term revegetation of the re-manufactured slopes.

GR4: Alternatives
A substantial number of commenters expressed support for implementation of Alternative 4 instead of the Project.

Due to this expression of interest by members of the public, Santa Barbara County requested each of the alternatives identified in the EIR include sufficient depth of analysis to support a potential approval based on any of the alternatives.

The No Project Alternative (Alternative 1) would not entail any approvals and would simply perpetuate all existing conditions within the trail alignment. No further analysis was deemed necessary to address this alternative.

Alternative 2 was previously addressed in a certified mitigated negative declaration (MND); analysis from the MND was summarized in the Alternative 2 discussion in the EIR, as updated with findings from more recent geotechnical investigations. Hence the Alternative 2 analysis presented in the Draft EIR is considered to contain sufficient detail to satisfy CEQA; it must be recognized, however, that due to the need for extraordinary structural engineering and landslide stabilization components that could entail unique impacts to the environment, subsequent environmental review would likely be necessary to implement the trail based on the original alignment (Alternative 2).

The alignment for Alternative 3 is substantially the same as for the project, and the area of potential effect is also principally the same as for the project. Alternative 3 involves a slight shift in the trail alignment on the south side of the UPRR corridor, in order to intersect the historic rail bench at a more westward location to employ more of the existing bench for the trail, and the incorporation of a 6 percent trail surface slope for an approximately 690 foot section of the trail (compared to 5% for the proposed project). Identification of relative impacts of this design and Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-10
the applicability of prescribed mitigation measures are adequate under the Alternative 3 discussion of the EIR to support an approval based on this design, without the need for any bolstering of the existing discussion.

Alternative 4 includes a portion (east of the UPRR trail crossing) that is outside of the alignment that has been studied for the project. Notably the biological resources and potential cultural resources within this portion of Alternative 4 were not previously surveyed. Dudek conducted a biological survey of this portion of the trail unique to Alternative 4, and also re-evaluated the findings from the record search conducted for archaeological resources.

The discussion under Alternative 4 has been updated accordingly, and now adequately identifies relative impacts of this design and the applicability of prescribed mitigation measures to support an approval based on this design, without the probable need for subsequent environmental review under CEQA (refer to Chapter 3, Alternatives). 1 **EXTERNAL EMAIL**
CAUTION: This email originated from outside the City of Carpinteria. DO NOT OPEN attachments or CLICK on links unless you are sure they are safe. Remember, reputable vendors, banks, etc. will not ask you to disclose passwords or other sensitive information.

Hello Nick – Does the Rincon Trail/EIR have impacts to utilities such as SoCalGas or water, sewer, telecom, electric/Edison, etc? Thanks, Tim.

From: Nick Bobroff <[email protected]>
Sent: Thursday, March 11, 2021 4:43 PM
To: Nick Bobroff <[email protected]>
Subject: [EXTERNAL] Public Release of the Draft Environmental Impact Report for the Carpinteria Rincon Trail Project *** EXTERNAL EMAIL ‐ Be cautious of attachments, web links, and requests for information *** Good afternoon,
The City of Carpinteria will be releasing the Draft Environmental Impact Report (DEIR) prepared for the Carpinteria Rincon Trail project for a 45‐day public review and comment period beginning on Friday, March 12, 2021 and ending at 5:00 p.m. on Monday, April 26, 2021.

The DEIR will be considered by the City of Carpinteria Environmental Review Committee (ERC) at a public meeting to be held Tuesday, April 13, 2021, beginning at 4:00 p.m. Note, due to COVID 19 social distancing protocols, the scheduled ERC meeting will be held virtually on Zoom Webinar.

Information on how to access the DEIR, submit comments, and attend the virtual ERC meeting are provided in the attached Rincon Trail EIR Notice of Availability document (“NOA Rincon Trail EIR_final.pdf”). The documents can also be viewed and accessed at the Rincon Trail Project webpage HERE [carpinteriaca.gov].

Should you have any questions about the DEIR or the Rincon Trail Project, please contact me at the phone number or email provided below.

Thank you,
Nick Bobroff, Principal Planner
Community Development Department
(805) 755‐ 4407 / [email protected]
This email originated outside of Sempra Energy. Be cautious of attachments, web links, or requests for information.

Comment Letter S1
S1-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-12

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Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-13
Response to Comment Letter S1
Southern California Gas
Timothy Mahoney
March 18, 2021
S1-1 The commenters questions whether the EIR outlines impacts to utilities such as gas, water, sewer, telecommunications, electric.

The proposed project’s impacts to utilities, such as gas, water, sewer, telecom, electric, have been analyzed in Section 3.14 of the Draft Environmental Impact Report (EIR). As discussed in this section, the project would not create additional demands in the areas of natural gas, electricity, or telecommunications facilities and therefore no impacts to these utilities would occur. In addition, impacts to water and wastewater would be less than significant.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-14

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1 **EXTERNAL EMAIL**
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Hi Nick,
Thanks for our brief phone discussion today regarding the Project DEIR. Please ensure that UP received a copy of the report for any comment. You may forward it to Ms. Peggy Ygbuhay at [email protected].

Sincerely,
Oliver Garcia, PE
Utilities Engineer
Rail Crossings & Engineering Branch ‐ Rail Safety Division California Public Utilities Commission
320 West 4th Street, Suite 500 | Los Angeles, CA  90013  Cell (213) 369‐4674
Comment Letter S2
S2-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-16

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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-17
Response to Comment Letter S2
California Public Utilities Commission
Oliver Garcia, PE
April 1, 2021
S2-1 The commenter requests that the City ensures that Union Pacific Railroad (UPRR or UP) received a copy of the EIR.

The City, UPRR, and the project engineer have been working together for the past year on an easement and encroachment agreement for the proposed bridge over-crossing of the UPRR corridor. City Public Works notified UPRR of the availability of the EIR and provided a link to download the document from the City’s website. The UPRR project contact has also been added to the project notification list for all future meetings, document releases, etc.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-18

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STATE OF CALIFORNIA— CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION SOUTH CENTRAL COAST DISTRICT OFFICE 89 SOUTH CALIFORNIA STREET, SUITE 2000
VENTURA, CA 93001
VOICE (805) 585-1800
April 26, 2021
Nick Bobroff, Principal Planner
Community Development Department
5775 Carpinteria Avenue
Carpinteria, CA 93013
RE: Draft Carpinteria Rincon Trail Project Environmental Impact Report Dear Mr. Bobroff,
Commission staff has reviewed the Draft Carpinteria Rincon Trail Project Environmental Impact Report (DEIR) regarding the proposed realignment and redesign of the Carpinteria Rincon Trail located within the City of Carpinteria and Santa Barbara County, and we appreciate the opportunity to provide comments for your consideration.

The originally circulated Mitigated Negative Declaration (MND) for the Rincon Trail, which was subsequently approved by the City through CDP No. 15-1760, included a 12 foot wide and 4,000 foot long shared-use trail, a 110 foot long clear- span bridge over the Union Pacific Rail Road (UPRR) alignment, 17 public parking spaces and a rest area with three picnic tables, signage, lighting and a storm drainage collection system including an on- site bioswale and a 5,000 gallon cistern to provide water for native landscaping during dry months. That project also included 30,000 cubic yards of cut, 7,000 cubic yards of fill and 23,000 cubic yards of export. In 2019 a Subsequent MND (SMND) was prepared, because the project was proposed to be modified to avoid areas with historic landslides, to eliminate the need for retaining walls, to shorten the path length, and to ensure accessibility of the trail for persons with disabilities pursuant to Americans with Disabilities Act (ADA) and Architectural Barriers Act requirements. The modified project included a 16 foot wide and approximately 2,800 foot long shared-use trail, a 160 foot long clear-span bridge over the UPRR alignment, and a storm drainage collection system including new drain outlets to the ocean. That project also included 104,000 cubic yards of cut, 10,300 cubic yards of fill and 94,100 cubic yards of export.

The SMND was approved by the Carpinteria Planning Commission, but that decision was appealed to the City Council. Although the appeal of the Planning Commission’s approval of the SMND was never heard by the City Council, the City Council decided to move forward with the preparation of a focused EIR.

The subject DEIR is the product of the focused EIR effort and includes the analysis of four project alternatives: no project/no build (Alternative 1), maximize existing benchwork/topography alternative (Alternative 2), steeper slopes/reduced earthwork alternative (Alternative 3), and freeway adjacent trail avoiding bluff face alternative (Alternative 4). Alternative 3 is identified as the environmentally superior alternative and Comment Letter S3
S3-1
S3-2
S3-3
2 includes the same alignment and project features as the modified project from the SMND, but would result in 15,000 less cubic yards of earthwork. Despite the improvement in the amount of grading, the proposed project and selected alternative raise issues regarding grading and landform alteration, native vegetation communities, and public access. The entire project is located in the Coastal Zone, but spans both the jurisdiction of the City of Carpinteria (City) and County of Santa Barbara (County).

Because the Commission has certified a LCP for both the City and County, the standard of review for the proposed project would be the respective LCP policies and provisions.

Grading and Landform Alteration
The originally approved project included 30,000 cubic yards of cut, 7,000 cubic yards of fill, and 23,000 cubic yards of export while the modified realignment and redesign analyzed in the SMND included 104,000 cubic yards of cut, 10,300 cubic yards of fill and 94,100 cubic yards of export. Alternative 3 would result in a reduction of 15,000 cubic yards of grading compared to the project proposed in the SMND; however, this is still a 62,300 cubic yard increase in the total amount of grading compared to the original project. The City's LCP contains Coastal Act Section 30251, which requires that the scenic and visual qualities of coastal areas shall be considered and protected and that new development is sited and designed to minimize alteration of natural land forms and also subordinate to the character of its setting. The proposed project will result in a significant amount of grading and landform alteration at the subject site. While grading impacts were analyzed in the DEIR, it was determined that with the incorporation of mitigation measures the proposed project would not result in any significant impacts as a result of grading. However, in order to determine consistency with the certified LCP, additional siting and design alternatives to further minimize grading and landform alteration should be analyzed.

ESHA
Coastal Act Section 30240, which is incorporated into the City's LCP, requires that Environmentally Sensitive Habitat Areas (ESHA) be protected to the maximum extent feasible. The draft DEIR includes an analysis of temporary and permanent impacts to various vegetation communities, including ESHA; however, it appears that the only permanent impacts identified are those impacts specific to the trail footprint and impacts as a result of vegetation removal are considered temporary. The Commission has historically considered temporary impacts to be those where: 1) there is not significant ground disturbance (i.e. earthwork including grading that disturbs seedbank); and 2) vegetation recovers to comparable size/age class within 12 months from the initial disturbance. All other impacts are considered permanent. The EIR should include more information on the expected temporary and permanent impacts consistent with the Commission’s approach and as necessary revise Table 3.3-5 to reflect the totals of temporary and permanent impacts, and required mitigation.

Public Access
The originally approved project included the construction of 17 public parking spaces and a rest area with picnic tables at the western terminus of the Rincon Trail, located along Carpinteria Avenue. However, the selected alternative does not include the S3-3
Cont.

S3-4
S3-5
S3-6
3 construction of these public access amenities, and the DEIR indicates that instead, the existing dirt lot would continue to provide informal parking. However, based upon the information included within the DEIR, it is unclear which portions of the dirt areas along Carpinteria Avenue are intended to function as parking for the proposed trail, and if those areas are actually available for public use. In order to facilitate maximum public access to the Rincon Trail, and to ensure consistency with the public access policies of the LCP, the final EIR should analyze project alternatives that include construction of the previously approved, or similar, public access components.

Each of the issues identified in this letter, as well as other impacts identified in the environmental review process, should be analyzed in the context of alternative project designs. As described above, an analysis of project alternatives is critical to ensure that adverse impacts to coastal resources are avoided to the maximum extent feasible, and that unavoidable impacts are minimized and mitigated. Please note that the comments provided herein are preliminary in nature. More specific comments may be appropriate as the project develops, and Coastal Commission staff requests notification of any future activity associated with this project or related projects. Again, thank you for the opportunity to comment.

Sincerely,
Wesley Horn
Coastal Planner, Southern California Caltrans Liaison
California Coastal Commission
cc: Tami Grove, Statewide Transportation Program Manager, CCC Shannon Fiala, Coastal Program Manager
Jacqueline Phelps, South Central Coast Supervisor, CCC
S3-6
Cont.

S3-7
S3-8
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-20

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Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-21
Response to Comment Letter S3
California Coastal Commission
Wesley Horn
April 26, 2021
S3-1 The City acknowledges the comment as an introduction to comments that follow. No further response is required.

S3-2 The commenter describes the project proposed under the 2015 Mitigated Negative Declaration (MND) and the 2019 Subsequent MND and provides background to the EIR. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR, and therefore, no further response is required.

S3-3 The commenter describes the four alternatives outlined in the EIR as well as the jurisdictions within which the proposed project falls. The commenter states that the standard of review for the proposed project would be the respective local coastal program (LCP) policies and provisions. As described in Section 3.9.4, the proposed project would be consistent with the Carpinteria General Plan/Coastal Land Use Plan and Santa Barbara County Coastal Land Use Plan, that serve as the City’s and County’s Local Coastal Land Use Plan, which ensures that the local government’s land use plans, zoning ordinances, zoning maps, and implementation actions meet the requirements, provisions and polices of the California Coastal Act. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR, and therefore, no further response is required.

S3-4 The commenter expresses concern regarding the aesthetic effects of the grading and landform alternation associated with the proposed project and Alternative 3. The commenter suggests that, in order to comply with Coastal Act Section 30251, referenced in the City’s LCP, additional siting and design alternatives to minimize grading and alternation should be analyzed.

See Global Response GR2, Earthwork/Landform Modification. In short, the EIR authors do not believe that additional alternatives for the purpose of minimizing earthwork volumes would be warranted in order to meet the criteria for sufficiency of alternatives analysis under CEQA Section 15126.6(d). In addition, minor alterations to the project and to Alternative 3 were accomplished to reduce earthwork volumes, including the removal of a previously proposed mid-elevation bench for the trail segment south of the UPRR alignment (project and Alternative 3), a narrower path width for the portion of the trail south of the UPRR alignment (Alternative 3), and slightly steeper slope of 6 percent for a 690 foot portion of the trail segment south of the UPRR alignment (Alternative 3).

S3-5 The commenter provides background information on Environmentally Sensitive Habitat Areas (ESHA), per Coastal Act Section 30240 and the City’s LCP, and states that permanent impacts should expand beyond those specific to the trail footprint and include those that result from vegetation removal. In addition, the commenter requests that the EIR should include more information on the expected temporary and permanent impacts consistent with the Coastal Commission’s approach and revise Table 3.3-5 to reflect the new totals of temporary and permanent impacts and required mitigation.

This comment has been addressed in replacement Section 3.3 Biological Resources, including Table

3.3-5 and associated text including required mitigation by reclassifying all project impacts upon Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-22
biological resources to permanent impacts. It was determined that the impacts previously defined as temporary were more permanent in nature when associated with impacts to vegetation communities.

Furthermore, the mitigation ratio for impacts to S3 native vegetation communities was updated to 4:1 and the mitigation ratio for impacts to S4 and S5 native vegetation communities was updated to 2:1.

These mitigation ratios apply to the associated vegetation communities and are not altered for on-site versus off-site mitigation involving native habitat restoration.

S3-6 The commenter expresses concern that the proposed project and alternatives do not include the construction of public access amenities previously included in other CEQA documentation, such as 17 parking spaces and a rest area with picnic tables, to be located at the western terminus of the proposed trail, along Carpinteria Avenue. The commenter is also unclear as to which portions of the dirt areas along Carpinteria Avenue would function as parking for the proposed trail, and if those areas are available for public use.

As discussed in Chapter 2 of the EIR, vehicle parking at the trailhead on the western end would be provided via an existing dirt lot adjacent to the Carpinteria Avenue terminus and available on-street parking in the area; no improvements to the existing informal dirt parking lot are proposed under the Carpinteria Rincon Trail project. However, as part of a separate, future project, the City of Carpinteria intends to provide parking spaces for visitors to the Rincon Bluffs Preserve property that is located immediately adjacent to the western end of the trail, which also would be available for recreationalists to access the trail at this point. It should also be noted that the proposed trail would close a gap in the existing regional bicycle path system, thus allowing access to the trail for pedestrians and cyclists without the need for vehicular use and reducing potential parking demands. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR, and therefore, no further response is required.

S3-7 The commenter suggests that all issues identified in this letter (see responses S3-1 through S3-6, above), should be analyzed for each proposed alternative, to ensure that adverse impacts to coastal resources are avoided to the maximum extent feasible, and that unavoidable impacts are minimized and mitigated.

Per CEQA Guidelines Section 15126.6(d), an EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed. (County of Inyo v. City of Los Angeles (1981) 124 Cal.App.3d 1). The analysis of the project did not identify any unavoidable significant impacts, which is the paramount consideration for the development of alternatives to the proposed action. However, given potentially significant impacts were identified, the EIR included four distinct alternatives to the project, each with an intent to lessen or avoid the significant impacts of the proposal. Information on each alternative, including involved grading quantities, has been provided in Section 6.0; the relative severity of each impact is also compared to the project, and the necessity under each alternative for implementation of mitigation measures identified for project impacts is identified. Therefore, per CEQA Guidelines Section Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-23
15126.6(d), a full analysis of each proposed alternative, including specific mitigation measures to address unique impacts of such an alternative, is not required.

S3-8 The commenter states that comments provided in this letter are preliminary and that more specific comments may be appropriate as the project develops. The commenter states that Coastal Commission staff requests notification of any future activity associated with the project or related projects.

The Coastal Commission will be notified of any future activity associated with the project. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR, and therefore, no further response is required.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-24

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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director South Coast Region 3883 Ruffin Road
San Diego, CA 92123
(858) 467-4201
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
April 28, 2021
Nick Bobroff
Principal Planner
City of Carpinteria
5775 Carpinteria Avenue
Carpinteria, CA 93013
[email protected]
Subject: Comments on the Draft Environmental Impact Report for the Carpinteria Rincon Multi-Use Trail, SCH #2020060534, Santa Barbara County Dear Mr. Bobroff:

The California Department of Fish and Wildlife (CDFW) has reviewed the Draft Environmental Impact Report (DEIR) for the Carpinteria Rincon Multi-Use Trail (Project). The City of Carpinteria (City) is the lead agency preparing a DEIR pursuant to the California Environmental Quality Act (CEQA; Pub. Resources Code, § 21000 et. seq.) with the purpose of informing decision-makers and the public regarding potential environmental effects related to the Project.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW’s Role
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State [Fish & Game Code, §§ 711.7, subdivision (a) & 1802; Public Resources Code, § 21070; California Environmental Quality Act (CEQA) Guidelines, § 15386, subdivision (a)]. CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect state fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Public Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteration regulatory authority (Fish & Game Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in “take” (see Fish & Game Code, § 2050) of any species protected under the California Endangered Species Act (CESA; Fish & Game Code, § 2050 et seq.) or the Native Plant Protection Act (NPPA; Fish & Game Code, § 1900 et DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 Comment Letter S4
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City of Carpinteria
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seq.), CDFW recommends the Project proponent obtain appropriate authorization under the Fish and Game Code.

Project Location: The Project would extend from the eastern end of Carpinteria Avenue, in the City of Carpinteria, to Rincon Beach County Park, in unincorporated Santa Barbara County. The Carpinteria Bluffs Nature Preserve lies to the east of the Project and the Project is bordered by the Rincon Bluffs Preserve.

Project Description/Objectives: The proposed Project includes the construction of a paved 16-foot-wide trail (10-foot-wide path with 3-foot-wide paved shoulder along both sides); an approximately 2,800-feet-long clear-span bridge over the Union Pacific Railroad alignment; parking facilities; fencing; signage; and, a storm drainage collection system, with new drain outlets to the ocean. The bridge would be approximately 160-feet-long, with a width of between 14-feet and 16-feet.

COMMENTS AND RECOMMENDATIONS
CDFW offers the following comments and recommendations to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

Comment 1: Adequacy of CEQA-Evaluation for Rare Plants
Issue: The DIER states cliff malacothrix (Malacothrix saxatilis var. saxatilis), south coast branching phacelia (Phacelia ramosissima var. austrolitoralis), and woolly seablite (Suaeda taxifolia) plants will be impacted by the Project. The loss of locally rare species was not fully analyzed in the DEIR.

Specific impact: The removal of individuals of these three species will contribute to their local and overall decline.

Why impact would occur: The DEIR discloses the total number of individuals present but does not specify how many will be impacted by the project. The DEIR concluded impacts to these three species, with no mitigation proposed, would not be significant. The DEIR does not contain sufficient analysis to support this conclusion for the following rare plants:
 Cliff malacothrix is ranked 4.2 (fairly endangered in California), limited distribution by the California Native Plant Society (CNPS). There are only 18 recent (1980-present) observations of this plant documented in Santa Barbara County.  South coast branching phacelia is ranked 3.2 (fairly endangered in California) by CNPS.

This plant is known from only 39 records (1980-present) in Santa Barbara County.  Woolly seablite is ranked 4.2 (fairly endangered in California) by CNPS. This plant is known from only 23 recent records (1980-present) in Santa Barbara County.

Many of the plants listed by the CNPS as California Rare Plant Rank 3 and 4 meet the definitions of the California Endangered Species Act of the California Fish and Game Code and are eligible for state listing. Many California Rare Plant Rank 3 and 4 plants are significant locally, and CDFW recommends that they be evaluated for impact significance during DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 S4-2
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City of Carpinteria
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preparation of environmental documents relating to CEQA, based on CEQA Guidelines §15125 (c) and/or §15380. Impacts to these species or their habitat must be analyzed during preparation of environmental documents relating to CEQA, as they meet the definition of Rare or Endangered under CEQA Guidelines §15125 (c) and/or §15380 (CEQA-rare). To assist botanists in evaluating California Rare Plant Rank 3 and 4 species for CEQA consideration the California Native Plant Society (CNPS) has prepared a technical memorandum titled Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact Analysis (https://www.cnps.org/wp-content/uploads/2020/02/crpr4_technical_memo.pdf).

This Project contains rare vegetation alliances and The Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact Analysis indicates List 4 plants that are associated with rare vegetation alliances should be fully evaluated in CEQA.

Evidence impact would be significant: The DEIR analysis does not acknowledge the limited number of occurrences of these plant species in Santa Barbara County. Given the limited number of occurrences for these species, the DEIR should acknowledge the significance of these impacts. For example, this Project would impact one of 18 occurrences of Cliff malacothrix documented in the last 40 years in the county and provide no mitigation for this impact. CDFW asserts impacting one of 18 known recent occurrences should be considered significant without mitigation.

This information is necessary to allow CDFW to comment on alternatives to avoid impacts, as well as to assess the significance of the specific impact relative to the species (e.g., current range, distribution, population trends, and connectivity).

The Project may result in impacts to CEQA-rare species without including any specific avoidance and minimization measures
Given the current number of recent documented occurrences of each of these plants in Santa Barbara County, impacts to cliff malacothrix, south coast branching phacelia, and woolly seablite plants should be considered significant under CEQA unless they are clearly mitigated below a level of significance.

Inadequate avoidance, minimization, and mitigation measures for impacts to these CEQA-rare plant species will result in the Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS.

Recommendation #1: When analyzing the current range and extent of CNPS rank 3 and 4 plants, current status and trends for each species should be assessed in context to the local distribution and recent (last 20 years per the Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact Analysis recommendations) population status.

Comment 2: Mitigation for Impacts to Rare Plants
Issue: Mitigation that would replace individuals or occupied land directly impacted by the Project was not proposed.

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City of Carpinteria
April 28, 2021

Specific impact: The removal of individuals of these three species will contribute to their local and overall decline.

Why Impact Would Occur: Project implementation includes grading, vegetation clearing, trail/road construction, soil compaction, utilities construction, road maintenance, and other activities that may result in direct mortality, population declines, or local extirpation of vegetation communities.

Evidence impact would be significant: The DEIR does not provide any specific requirements to replace the number of cliff malacothrix, south coast branching phacelia, and woolly seablite plants impacted. CEQA Guidelines, sections 15070 and §15071 require the document to analyze if the Project may have a significant effect on the environment as well as review if the Project will ‘avoid the effect or mitigate to a point where clearly no significant effects would occur’. This information is necessary to allow CDFW to comment on alternatives to avoid impacts, as well as to assess the significance of the specific impact relative to the species (e.g., current range, distribution, population trends, and connectivity).

Mitigation Measure #1: CDFW recommends the DEIR include mitigation that addresses the loss of these individual plants as well as the land/habitat in which they grow. The specific habitat that supports rare plants, and the current density per acre of these plants, should be assessed when formulating mitigation strategies.

Mitigation Measure #2: Given the current status of these rare plants, CDFW recommends the Project be redesigned to avoid impacts to these rare plant species. If avoidance cannot be achieved, CDFW recommends conserving a currently unprotected occurrence of these plant species, including a conservation easement and funding to manage the species in perpetuity.

CDFW recommends due to the limited number of recent occurrences of cliff malacothrix (18) and woolly seablite (23) in Santa Barbara county, that the number of individuals as well as the acreage of land that supports them (density) be conserved at a 3:1 ratio. Given South coast branching phacelia has a slightly higher number of occurrences (39) in Santa Barbara County, CDFW recommends that the number of individuals as well as the acreage of land that supports them (density) be conserved at a 1.5:1 ratio.

Recommendation #1: Any mitigation for CEQA-rare plant impacts should include specific, measurable criteria for success. Monitoring for CEQA-rare vegetation communities should occur for a sufficient period to allow trends to be analyzed and demonstrate the occurrence is stable over time. No negative trend in CEQA-rare plant individuals (counted separately as flowering, seed set and non-flowering individuals), and no positive trend in non-native plant cover should occur over the monitoring period.

Recommendation #2: When considering mitigation options, CDFW does not recommend topsoil salvage or transplantation as viable mitigation options. Several studies have documented topsoil salvage had no effect on the recolonization of the target plant species (Hinshaw, 1998, Dixon, 2018). Based on the scientific literature available, relying on topsoil salvage alone to mitigate impacts to CEQA-rare plant species does not appear to provide any value to mitigate impacts to the plant.

Transplantation is rarely successful in establishing rare plants at new locations. A study by CDFW (Fiedler, 1991) found that, even under optimum conditions with ample time for planning, DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 S4-7
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City of Carpinteria
April 28, 2021

transplantation was effective in only 15% of cases studied. Other reviews (e.g. Allen, 1994; Howald, 1996) have found similar problems digging up, transporting, and replanting plants, bulbs, rhizomes or seeds imposes a tremendous stress on a plant. They can easily die in the process. Scientifically-tested, reliable methods for salvage, propagation, translocation or transplantation are not available for many rare species. Transplantation can also cause problems at the target site. Genetic contamination can occur if the plant being transplanted can exchange genetic material with local taxa. Disturbance at the target site may facilitate invasion by non-native invasive species (CNPS, 1991).

Recommendation #3: CDFW recommends a Documented Conservation Seed Collection of the impacted rare plant species be made and deposited at either Santa Barbara Botanic Garden or the California Botanic Garden (formerly known as Rancho Santa Ana Botanic Garden). A Documented Conservation Seed Collection is when seed from CNPS ranked 1-4 plants, CEQArare, and/or CESA-listed plant species is collected and stored as part of a permanent genetic collection in a protected location. This collection preserves the genome, and any unique alleles that are present in any given occurrence, for future study and reintroduction projects.

Funding should be provided to maintain the collection, as well as conduct periodic germination and viability tests, in perpetuity. Documented conservation collections (long-term storage) are important for conserving rare, gene pool representative germplasm designated for long-term storage to provide protection against extinction and as a source material for future restoration and recovery.

Recommendation #4: A weed management plan should be developed for the Project area and implemented during the duration of this Project. On-going soil disturbance promotes establishment and growth of non-native weeds. As part of the Project, non-native weeds should be prevented from becoming established. The Project area should be monitored via mapping for new introductions and expansions of non-native weeds.

Comment 3: Mitigation for Sensitive Vegetation Communities Issue: The DEIR states approximately 3.55 acres of CDFW/county/city sensitive vegetation community habitats would be temporarily impacted due to construction and an additional 0.76- acres CDFW/county/city habitats would be permanently impacted due to construction. The DEIR states the temporary impacts would be mitigated at a 1:1 ratio and permanent impact at a 3:1 ratio. The DEIR states a future plan will be prepared to further address this mitigation.

Sensitive vegetation communities are a defined by their dominant plant species, such as California Brittle Bush –Ashy Buckwheat Scrub Alliance and have a separate ranking system than that of individual rare plants, which are covered in Comment 1, above.

CDFW is concerned the 1:1 ratio for “temporary impacts” may not be adequate.

Specific Impact: CEQA Guidelines sections 15070 and 15071 require the DEIR to analyze if the Project may have a significant effect on the environment as well as review if the Project will “avoid the effect or mitigate to a point where clearly no significant effects would occur.” The DEIR states the 1:1 mitigation may occur on “other properties” due to the lack of available area on the Project site for mitigation. Due to the rare nature of these vegetation communities, and the land which supports them, CDFW is concerned about the deferral of mitigation to other, DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 S4-9
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City of Carpinteria
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unidentified properties that may or may not be suitable or even available for appropriate mitigation. Given that most coastal bluff habitat is rare in nature, it is unclear if rare habitats at other properties will be impacted to provide mitigation for this Project.

The DEIR does not indicate if the rare plants mentioned in Comment 1 above, will be impacted by trying to fit all the required sensitive vegetation community mitigation on non-impacted parts of the Project site. The DEIR should disclose if any sensitive vegetation community mitigation will occur within or around areas occupied by cliff malacothrix, south coast branching phacelia, and woolly seablite plants.

In order to analyze if a project may have a significant effect on the environment, the location, species composition, and success criteria of proposed mitigation information is necessary to allow the Department to comment on alternatives to avoid impacts, as well assess the adequacy of the mitigation proposed.

Why Impact Would Occur: Project implementation includes grading, vegetation clearing, trail/road construction, soil compaction, utilities construction, road maintenance, and other activities that may result in direct mortality, population declines, or local extirpation of vegetation communities.

Evidence Impact would be significant: Removing a perennial plant from the ground is a permanent impact resulting in its death, replacing it is considered mitigation. All impacts that remove perennial plants from the ground should be considered under the same lens whether the restoration occurs in the same area as the impacts or in new areas. Both scenarios may or may not produce successful new individuals or the targeted vegetation community assemblage.

Both scenarios result in: 1) the loss of established individuals; and, 2) the replacement planting of new individuals. Both scenarios incur temporal losses as well as intensive management to ensure the desired habitat is re-created. Both are at risk for failure and are a community of same-aged individuals lacking the age stratification and complexity of the original habitat.

Inadequate avoidance, minimization, and mitigation measures for impacts to these CEQA-rare vegetation communities will result in the Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or USFWS.

Mitigation Measure #1: CDFW recommends avoiding any sensitive natural communities found on the Project. If avoidance is not feasible, the Project proponent should mitigate at a ratio sufficient to achieve a no-net loss for impacts to special status plant species and their associated habitat. CDFW recommends all impacts to the S3 sensitive vegetation communities (California Brittle Bush –Ashy Buckwheat Scrub Alliance, Encelia californica Association and Lemonade Berry Scrub Alliance, Rhus integrifolia Association) (0.59-acres) should be mitigated at a 4:1 ratio and impacts to the S4 and S5 communities (3.73-acres) be mitigate at a 2:1 ratio due to the overall decline of coastal bluff/scrub habitats region wide.

All revegetation/restoration areas that will serve as mitigation should include preparation of a restoration plan, to be approved by CDFW prior to any ground disturbance. The restoration plan should include restoration and monitoring methods; annual success criteria; contingency actions should success criteria not be met; long-term management and maintenance goals; and a funding mechanism for long-term management. Areas proposed as mitigation should have a DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 S4-12
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recorded conservation easement and be dedicated to an entity which has been approved to hold/manage lands (AB 1094; Government Code, §§ 65965-65968).

Mitigation Measure #2: Success criteria should be based on the specific composition of the vegetation communities being impacted. Success should not be determined until the site has been irrigation-free for at least 5 years and the metrics for success have remained stable (no negative trend for richness/diversity/abundance/cover and no positive trend for invasive/nonnative cover for each vegetation layer) for at least 5 years. In the revegetation plan, the success criteria should be compared against an appropriate reference site, with the same vegetation alliance, with as good or better-quality habitat. The success criteria shall include percent cover (both basal and vegetative), species diversity, density, abundance, and any other measures of success deemed appropriate by CDFW. Success criteria shall be separated into vegetative layers (tree, shrub, grass, and forb) for each alliance being mitigated, and each layer shall be compared to the success criteria of the reference site, as well as the alliance criteria in MCV2, ensuring one species or layer does not disproportionally dominate a site but conditions mimic the reference site and meets the alliance membership requirements.

CDFW does not recommend topsoil salvage or transplantation as viable mitigation options.

Several studies have documented topsoil salvage had no effect on the recolonization of the target plant species (Hinshaw, 1998, Dixon, 2018). Based on the scientific literature available, relying on topsoil salvage alone to mitigate impacts to CEQA-rare plant species does not appear to provide any value to mitigate impacts to the plant.

Filing Fees
The Project, as proposed, would have an impact on fish and/or wildlife resources, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying Project approval to be operative, vested, and final. (California Code of Regulations, tit. 14, § 753.5; Fish and Game Code, § 711.4; Public Resources Code, § 21089).

Conclusion
CDFW appreciates the opportunity to comment on the DEIR to assist the City of Carpinteria in identifying and mitigating Project impacts on biological resources. If you have any questions or comments regarding this letter, please contact Kelly Schmoker, Senior Environmental Scientist, at (626) 335-9092 or by email at [email protected].

Sincerely,
Erinn Wilson-Olgin
Environmental Program Manager I
South Coast Region
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Nick Bobroff
City of Carpinteria
April 28, 2021

ec: CDFW
Steve Gibson, Los Alamitos – [email protected] Sarah Rains, Los Alamitos – [email protected] Susan Howell, San Diego – [email protected]
CEQA Program Coordinator, Sacramento – [email protected] State Clearinghouse, Sacramento – [email protected] CNPS Channel Islands Chapter – [email protected]
References
Allen, W. H. 1994. Reintroduction of endangered plants: biologists worry that mitigation may be considered an easy option in the political and legal frameworks of conservation.

Bioscience 44(2): 65-8.

California Native Plant Society Rare Plant Scientific Advisory Committee. 1991.

Mitigation Guidelines Regarding Impacts to Rare, Threatened and Endangered Plants.

California Native Plant Society, Sacramento, CA.

Dixon, P. 2018. Assessment of Topsoil Salvage and Seed Augmentation in the Restoration of Coastal Sage Scrub on Santa Catalina Island, California. Western North American Naturalist, 78(4), 711-721.

Fiedler, P. 1991. Mitigation related transplantation, translocation and reintroduction projects involving endangered and threatened and rare plant species in California.

California Department of Fish and Game, Sacramento, CA. 82 pp.

Hinshaw, J., Holmstead, G., Cypher, B., & Anderson, D. (1998). Effects of simulated oil field disturbance and topsoil salvage on Eriastrum hooveri (Polemoniaceae). Madroño, 45(4), 290- 294. Retrieved May 19, 2020, from www.jstor.org/stable/41425279 Howald, A.M. Translocation as a mitigation strategy: lessons from California. In: D.A. Falk, C.I. Millar, and M. Olwell eds. Restoring Diversity: Strategies for Reintroduction of Endangered Plants. Island Press, Washington, DC.

DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 Nick Bobroff
City of Carpinteria
April 28, 2021

CDFW recommends the following language to be incorporated into a future environmental document for the Project.

Biological Resources
Mitigation Measure Timing Responsible
Party
REC-Bio-1-
CEQA-Rare
Plants
When analyzing the current range and extent of CNPS rank 3 and 4 plants, current status and trends for each species should be assessed in context to the local distribution and recent (last 20 years per the Considerations for Including CRPR 4 Plant Taxa in CEQA Biological Resource Impact
Analysis recommendations) population status.

Prior to
Finalizing
the EIR
City of
Carpinteria
MM-Bio-1-
CEQA-Rare
Plants
CDFW recommends the DEIR include mitigation that
addresses the loss of these individual plants as well as the land/habitat in which they grow. The specific habitat that supports rare plants, and the current density per acre of these plants, should be assessed when formulating
mitigation strategies.

Prior to
Finalizing
the EIR
City of
Carpinteria
MM-Bio-2-
CEQA-Rare
Plants
Given the current status of these rare plants, CDFW
recommends the Project be redesigned to avoid impacts to these rare plant species. If avoidance cannot be achieved, CDFW recommends conserving a currently unprotected
occurrence of these plant species, including a conservation easement and funding to manage the species in perpetuity.

CDFW recommends due to the limited number of recent
occurrences of cliff malacanthix (18) and woolly seablite (23) in Santa Barbara county, that the number of individuals as well as the acreage of land that supports them (density) be conserved at a 3:1 ratio. Given South coast branching
phacelia has a slightly higher number of occurrences (39) in Santa Barbara County, CDFW recommends that the number
of individuals as well as the acreage of land that supports them (density) be conserved at a 1.5:1 ratio.

Prior to
Finalizing
the EIR
City of
Carpinteria
MM-Bio-3-
CEQA- Rare
Plants
Any mitigation for CEQA-rare plant impacts should include specific, measurable criteria for success. Monitoring for CEQA-rare vegetation communities should occur for a
sufficient period to allow trends to be analyzed and
demonstrate the occurrence is stable over time. No negative trend in CEQA-rare plant individuals (counted separately as flowering, seed set and non-flowering individuals), and no positive trend in non-native plant cover should occur over the monitoring period.

Prior to
Finalizing
the EIR
City of
Carpinteria
REC-Bio-2-
CEQA-Rare
Plants
Any mitigation for CEQA-rare plant impacts should include specific, measurable criteria for success. Monitoring for CEQA-rare vegetation communities should occur for a
sufficient period to allow trends to be analyzed and
demonstrate the occurrence is stable over time. No negative trend in CEQA-rare plant individuals (counted separately as Prior to
Finalizing
the EIR
City of
Carpinteria
DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 Nick Bobroff
City of Carpinteria
April 28, 2021

flowering, seed set and non-flowering individuals), and no positive trend in non-native plant cover should occur over the monitoring period.

REC-Bio-3-
CEQA-Rare
Plants
When considering mitigation options, CDFW does not
recommend topsoil salvage or transplantation as viable
mitigation options. Several studies have documented topsoil salvage had no effect on the recolonization of the target plant species (Hinshaw, 1998, Dixon, 2018). Based on the scientific literature available, relying on topsoil salvage alone to mitigate impacts to CEQA-rare plant species does not appear to provide any value to mitigate impacts to the plant.

Transplantation is rarely successful in establishing rare plants at new locations. A study by CDFW (Fiedler, 1991) found that, even under optimum conditions with ample time for planning, transplantation was effective in only 15% of cases studied. Other reviews (e.g. Allen, 1994; Howald, 1996) have found similar problems digging up, transporting, and replanting plants, bulbs, rhizomes or seeds imposes a tremendous stress on a plant. They can easily die in the process. Scientifically-tested, reliable methods for salvage, propagation, translocation or transplantation are not
available for many rare species. Transplantation can also cause problems at the target site. Genetic contamination can occur if the plant being transplanted can exchange genetic material with local taxa. Disturbance at the target site may facilitate invasion by non-native invasive species (CNPS, 1991).

Prior to
Finalizing
the EIR
City of
Carpinteria
REC-Bio-4-
CEQA-Rare
Plants
CDFW recommends a Documented Conservation Seed
Collection of the impacted rare plant species be made and deposited at either Santa Barbara Botanic Garden or the California Botanic Garden (formerly known as Rancho Santa Ana Botanic Garden). A Documented Conservation Seed
Collection is when seed from CNPS ranked 1-4 plants,
CEQA-rare, and/or CESA-listed plant species is collected and stored as part of a permanent genetic collection in a protected location. This collection preserves the genome, and any unique alleles that are present in any given
occurrence, for future study and reintroduction projects.

Funding should be provided to maintain the collection, as well as conduct periodic germination and viability tests, in perpetuity. Documented conservation collections (long-term storage) are important for conserving rare, gene pool
representative germplasm designated for long-term storage to provide protection against extinction and as a source material for future restoration and recovery.

Prior to
Finalizing
the EIR
City of
Carpinteria
REC-Bio-5-
CEQA-Rare
Plants
A weed management plan should be developed for the
Project area and implemented during the duration of this Project. On-going soil disturbance promotes establishment Prior to
Finalizing
the EIR
City of
Carpinteria
DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 Nick Bobroff
City of Carpinteria
April 28, 2021

and growth of non-native weeds. As part of the Project, nonnative weeds should be prevented from becoming established. The Project area should be monitored via
mapping for new introductions and expansions of non-native weeds.

MM-Bio-4-
CEQA- Rare
Plants
Sensitive
Vegetation
Communities
CDFW recommends avoiding any sensitive natural
communities found on the Project. If avoidance is not
feasible, the Project proponent should mitigate at a ratio sufficient to achieve a no-net loss for impacts to special status plant species and their associated habitat. CDFW recommends all impacts to the 5 sensitive vegetation
communities (4.32-acres) should be mitigated at a 3:1 ratio due to the overall decline of coastal bluff/scrub habitats region wide. All revegetation/restoration areas that will serve as mitigation should include preparation of a restoration plan, to be approved by CDFW prior to any ground
disturbance. The restoration plan should include restoration and monitoring methods; annual success criteria;
contingency actions should success criteria not be met; longterm management and maintenance goals; and a funding mechanism for long-term management. Areas proposed as
mitigation should have a recorded conservation easement and be dedicated to an entity which has been approved to hold/manage lands (AB 1094; Government Code, §§ 65965-
65968).

Prior to
Finalizing
the EIR
City of
Carpinteria
MM-Bio-5-
CEQA
Sensitive
Vegetation
Communities
Success criteria should be based on the composition of the vegetation communities being impacted. Success should not be determined until the site has been irrigation-free for at least 5 years and the metrics for success have remained stable (no negative trend for
richness/diversity/abundance/cover and no positive trend for invasive/non-native cover for each vegetation layer) for at least 5 years. In the revegetation plan, the success criteria should be compared against an appropriate reference site, with the same vegetation alliance, with as good or betterquality habitat. The success criteria shall include percent cover (both basil and vegetative), species diversity, density, abundance, and any other measures of success deemed
appropriate by CDFW. Success criteria shall be separated into vegetative layers (tree, shrub, grass, and forb) for each alliance being mitigated, and each layer shall be compared to the success criteria of the reference site, as well as the alliance criteria in MCV2, ensuring one species or layer does not disproportionally dominate a site but conditions mimic the reference site and meets the alliance membership
requirements.

CDFW does not recommend topsoil salvage or
transplantation as viable mitigation options. Several studies Prior to
Finalizing
the EIR
City of
Carpinteria
DocuSign Envelope ID: DF08E299-85B5-488B-8842-1100692EE7A0 Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-26
Response to Comment Letter S4
California Department of Fish and Wildlife
Erinn Wilson-Olgin
April 28, 2021
S4-1 The commenter provides an introduction, background information, and gives thanks for the opportunity to comment; however, the comment does not pertain to the adequacy of the EIR.

No response needed.

S4--2 The commenter identifies themselves, their jurisdiction, and divulges their responsibility by law to provide, as available, biological expertise during public agency environmental review efforts. The commenter describes that they are also submitting comments as a Responsible Agency under CEQA.

The commenter describes that they have regulatory authority as provided by the Fish and Game Code, including lake and streambed alteration regulatory authority, and recommends the City obtain appropriate authorization under the Fish and Game Code. Additionally, if the project may result in “take” of species protected under the California Endangered Species Act or the Native Plant Protection Act, the commenter again recommends the City obtain appropriate authorization under the Fish and Game Code. The comments do not pertain to the adequacy of the EIR.

No response needed.

S4-3 The commenter acknowledges the project location and project description/objectives. The commenter explains that their comments and recommendations are offered to assist the City in identifying the project’s impacts and mitigation on fish and wildlife (biological) resources. The comments do not pertain to the adequacy of the EIR.

No response needed.

S4-4 The commenter raises the issue of adequacy of the CEQA evaluation for rare plants which lacks the number of individuals that would be impacted and falls short of a sufficient analysis on the significance of the impacts on each species. The commenter recommends that evaluating California Native Plant Society (CNPS) plants listed as California Rare Plant Rank (CRPR) 3 and 4 be evaluated for impact significance during preparation of the CEQA EIR. The commenter includes the CEQA Guidelines, §15125 (c) and/or §15380, for which the rare plants should be evaluated. The three plant species:
cliff malacothrix (Malacothrix saxatilis var. saxatilis; CNPS CRPR 4.2), south coast branching phacelia (Phacelia ramosissima var. austrolitoralis; CNPS CRPR 3.2), and woolly seablite (Suaeda taxifolia; CNPS CRPR 4.2) are not considered locally rare in Santa Barbara County as they are not included on the Rare Plants of Santa Barbara County list (Wilken 2018); however they are considered locally rare in Ventura County as they are included on the Checklist of Ventura County Rare Plants (Magney 2020).

Section 3.3 Biological Resources has been updated to include a resource impact analysis for each of these plant species, notwithstanding that the entire project is located within Santa Barbara County.

Research was conducted to define CEQA Guidelines §15125 (c) and/or §15380 as included below.

CEQA Guidelines §15125 Environmental Setting (c) states:

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-27
Knowledge of the regional setting is critical to the assessment of environmental impacts. Special emphasis should be placed on environmental resources that are rare or unique to that region and would be affected by the project. The EIR must demonstrate that the significant environmental impacts of the proposed project were adequately investigated and discussed, and it must permit the significant effects of the project to be considered in the full environmental context.

CEQA Guidelines §15380 Endangered, Rare, or Threatened Species states:
(a) “Species” as used in this section means a species or subspecies of animal or plant or a variety of plant.
(b) A species of animal or plant is:
(1) “Endangered” when its survival and reproduction in the wild are in immediate jeopardy from one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, disease, or other factors; or
(2) “Rare” when either:
(A) Although not presently threatened with extinction, the species is existing in such small numbers throughout all or a significant portion of its range that it may become endangered if its environment worsens; or
(B) The species is likely to become endangered within the foreseeable future throughout all or a significant portion of its range and may be considered “threatened” as that term is used in the Federal Endangered Species Act.
(c) A species of animal or plant shall be presumed to be endangered, rare, or threatened, as it is listed in:
(1) Sections 670.2 or 670.5, Title 14, California Code of Regulations; or (2) Title 50, Code of Federal Regulations Section 17.11 or 17.12 pursuant to the Federal Endangered Species Act as rare, threatened, or endangered. (d) A species not included in any listing identified in subdivision (c) shall nevertheless be considered to be endangered, rare or threatened, if the species can be shown to meet the criteria in subdivision (b).
(e) This definition shall not include any species of the Class Insecta which is a pest whose protection under the provisions of CEQA would present an overwhelming and overriding risk to man as determined by:
(1) The Director of Food and Agriculture with regard to economic pests; or (2) The Director of Health Services with regard to health risks.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-28
Neither Section 670.2, Title 14 California Code of Regulations nor Section 670.5, Title 14 California Code of Regulations include cliff malacothrix, south coast branching phacelia, or woolly seablite.

Neither Section 17.11, Title 50 Code of Federal Regulations nor Section 17.12 Code of Federal Regulations include cliff malacothrix, south coast branching phacelia, or woolly seablite.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each California Native Plant Society (CNPS) California Rare Plant Rank (CRPR) 3 and 4 plant species based on the number of documented occurrences in Santa Barbara County and Ventura County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S. Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate.

S4-5 The commenter raises the issue that the DEIR does not acknowledge the limited number of occurrences of the CNPS CRPR 3 and 4 species in Santa Barbara County and that this information is needed to assess the significance of the specific impact relative to each species.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each CNPS CRPR 3 and 4 plant species based on the number of documented occurrences in Santa Barbara County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S.

Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate.

S4-6 The commenter recommends that when analyzing the current range and extent of CNPS CRPR 3 and 4 plants, current status and trends for each species should be assessed in context with the local distribution and population status in the last 20 years.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each CNPS CRPR 3 and 4 plant species based on the number of documented occurrences in Santa Barbara County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S.

Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate.

S4-7 The commenter raises the issue that the DEIR does not provide any specific requirements to replace the number of cliff malacothrix, woolly seablite, and south coast branching phacelia individuals impacted.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each CNPS CRPR 3 and 4 plant species based on the number of Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-29
documented occurrences in Santa Barbara County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S.

Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate. Since the evaluation for impact significance for each CNPS CRPR 3 and 4 plant species concluded that impacts would be less than significant, no mitigation is required for CNPS CRPR 3 and 4 plant species.

S4-8 The commenter recommends the DEIR include mitigation that addresses the loss of CNPS CRPR 3 and 4 plant species as well as the land/habitat in which they grow.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each CNPS CRPR 3 and 4 plant species based on the number of documented occurrences in Santa Barbara County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S.

Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate. Since the evaluation for impact significance for each CNPS CRPR 3 and 4 plant species concluded that impacts would be less than significant, no mitigation is required for CNPS CRPR 3 and 4 plant species. Mitigation is included for native coastal bluff scrub and coastal scrub vegetation communities.

S4-9 The commenter recommends the project be redesigned to avoid impacts to CNPS CRPR 3 and 4 plant species. If avoidance cannot be achieved, the commenter recommends conserving a currently unprotected occurrence of these plant species, including a conservation easement and funding to manage the species in perpetuity.

This comment has been addressed in Section 3.3 Biological Resources including an updated evaluation for impact significance for each CNPS CRPR 3 and 4 plant species based on the number of documented occurrences in Santa Barbara County, the type locality, occurrences at the periphery of a species’ range, areas where the taxon is especially uncommon, areas where the taxon has sustained heavy losses (declining), occurrences exhibiting unusual morphology or occurring on unusual substrates, species maintained on Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S.

Forest Service sensitive species lists, and taxa associated with a habitat that is declining in California at a significant rate. Since the evaluation for impact significance for each CNPS CRPR 3 and 4 plant species concluded that impacts would be less than significant, no mitigation is required for CNPS CRPR 3 and 4 plant species.

S4-10 The commenter recommends a weed management plan should be developed for the project area and implemented during the duration of the project.

Section 3.3 Biological Resources includes MM-BIO-4, a Habitat Mitigation and Monitoring Plan that includes a detailed maintenance plan to include removal of invasive non-native species within areas with native plant restoration. Since the project includes impacts to areas not included in the Habitat Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-30
Mitigation and Monitoring Plan, a new mitigation measure MM-BIO-6 Weed Management Plan was added to Section 3.3 Biological Resources to address invasive weed establishment and spread.

S4-11 The commenter raises concern that the 1:1 ratio for “temporary impacts” may not be adequate.

This comment has been addressed in Section 3.3 Biological Resources including Table 3.3-5 and associated text including required mitigation by updating all impacts to permanent impacts. It was determined that the impacts previously defined as temporary were more permanent in nature when associated with impacts to vegetation communities; therefore, all project impacts were updated to be permanent impacts. Furthermore, mitigation ratios for impacts to S3 native vegetation communities was updated to 4:1 and mitigation ratios for impacts to S4 and S5 native vegetation communities were updated to 2:1. These mitigation ratios apply to the associated vegetation communities and are not altered for on-site versus off-site mitigation native habitat restoration.

S4-12 The commenter raises a concern regarding the potential future need for mitigation outside of the project boundaries, and the lack of specific identification of other non-project properties that may or may not be suitable or even available for appropriate mitigation. Additionally, the commenter raised concerns that the previously mentioned CNPS CRPR 3 and 4 plant species may be impacted by establishing habitat restoration mitigation on non-impacted parts of the project site.

This comment has been addressed in Section 3.3 Biological Resources within MM-BIO-5 Habitat Mitigation and Monitoring Plan. Text has been updated to state that prior to identifying habitat restoration mitigation areas, both within the project area and adjacent lands, the habitat shall be surveyed for sensitive vegetation communities and special-status plant species, to ensure avoidance of impacts during habitat restoration implementation. Additionally, potential adjacent mitigation lands shall be assessed to ensure sites are suitable and appropriate for implementation of habitat restoration for the impacted native vegetation communities.

S4-13 The commenter states that to analyze if a project may have a significant effect on the environment, the location, species composition, and success criteria of proposed mitigation information is necessary to allow the commenter to comment on alternatives to avoid impacts, as well as assess the adequacy of mitigation proposed.

This comment has been addressed in Section 3.3 Biological Resources within MM-BIO-5 Habitat Mitigation and Monitoring Plan. The text has been updated to state that prior to grading, the project related native coastal bluff scrub and coastal scrub vegetation communities shall be assessed by vegetation community type for species composition, associated plant cover, and dominant plant species. This project site native vegetation community data shall be used to define performance standards for native habitat restoration by vegetation community type and for non-native plant species.

S4-14 The commenter states that removing a perennial plant from the ground is a permanent impact resulting in its death, replacing it is considered mitigation. All impacts that remove perennial plants from the ground should be considered under the same lens whether the restoration occurs in the same area as the impacts or in a new area.

This comment has been addressed in Section 3.3 Biological Resources including Table 3.3-5 and associated text including required mitigation by updating all impacts to permanent impacts. It was Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-31
determined that the impacts previously defined as temporary were more permanent in nature when associated with impacts to vegetation communities; therefore, all project impacts were updated to be permanent impacts. Furthermore, the mitigation ratio for impacts to S3 native vegetation communities was updated to 4:1 and the mitigation ratio for impacts to S4 and S5 native vegetation communities was updated to 2:1. These mitigation ratios apply to the associated vegetation communities and are not altered for on-site versus off-site mitigation native habitat restoration.

S4-15 The commenter recommends avoiding any sensitive natural communities found on the project. If avoidance is not feasible, the project proponent should mitigate at a ratio sufficient to achieve a nonet loss for impacts to special status plant species and their associated habitat. The commenter recommends all impacts to the S3 sensitive vegetation communities (California Brittle Bush – Ashy Buckwheat Scrub Alliance, Encelia californica Association and Lemonade Berry Scrub Alliance, Rhus integrifolia Association) should be mitigated at a 4:1 ratio and impacts to the S4 and S5 communities be mitigated at a 2:1 ratio due to the overall decline of coastal bluff/scrub habitat region wide.

This comment has been addressed in Section 3.3 Biological Resources including Table 3.3-5 and associated text including required mitigation by updating all impacts to permanent impacts. It was determined that the impacts previously defined as temporary were more permanent in nature when associated with impacts to vegetation communities; therefore, all project impacts were updated to be permanent impacts. Furthermore, mitigation ratios for impacts to S3 native vegetation communities were updated to 4:1 and mitigation ratios for impacts to S4 and S5 native vegetation communities were updated to 2:1. These mitigation ratios apply to the associated vegetation communities and are not altered for on-site versus off-site mitigation native habitat restoration.

S4-16 The commenter states that all revegetation/restoration areas that will serve as mitigation should include preparation of a restoration plan, to be approved by CDFW prior to any ground disturbance. The commenter recommends that the restoration plan should include restoration and monitoring methods; annual success criteria; contingency actions should success criteria not be met; long-term management and maintenance goals; and a funding mechanism for long-term management. The commenter recommends that the areas proposed as mitigation should have a recorded conservation easement and be dedicated to an entity which has been approved to hold/manage lands (AB 1094; Government Code, § 65965-65968).

This comment has been addressed in Section 3.3 Biological Resources MM-BIO-5 Habitat Mitigation and Monitoring Plan as this is a restoration plan. The text has been updated to state that the Habitat Mitigation and Monitoring Plan shall be approved by CDFW prior to any ground disturbance. The Habitat Mitigation and Monitoring Plan includes requirements for restoration and monitoring methods; annual success criteria; contingency actions should success criteria not be met; long-term management and maintenance goals.

S4-17 The commenter recommends that the success criteria should be based on the specific composition of the vegetation communities being impacted. The commenter recommends that the success should not be determined until the site has been irrigation-free for at least 5 years and the metrics for success have remained stable (no negative trend for richness/diversity/abundance/cover and no positive trend for invasive/non-native cover for each vegetation layer) for at least 5 years. The commenter recommends that in the revegetation plan, the success criteria should be compared against an appropriate reference site, with the same vegetation alliance, with as good or better-quality habitat.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-32
The commenter recommends that the success criteria shall include percent cover (both basal and vegetative), species diversity, density, abundance, and any other measures of success deemed appropriate by the commenter, CDFW. The commenter recommends that success criteria shall be separated into vegetative layers (tree, shrub, grass, and forb) for each alliance being mitigated, and each layer shall be compared to the success criteria of the reference site, as well as the alliance criteria in MCV2, ensuring one species or layer does not disproportionally dominate a site but conditions mimic the reference site and meet the alliance membership requirements.

This comment has been addressed in Section 3.3 Biological Resources MM-BIO-5 Habitat Mitigation and Monitoring Plan. The text has been updated to state that the success criteria shall include percent cover (both basal and vegetative), species diversity, density, and abundance. This project site native vegetation community data shall be used to define performance standards for native habitat restoration by vegetation layers (tree, shrub, grass, and forb) for each vegetation community type and for non-native plant species. The text remains that the restoration areas shall be irrigation free for at least 3 years and the performance standards have remained stable (no negative trend for richness/ diversity/ abundance/ cover of native species and no positive trend for invasive/non-native cover for each vegetation layer) for at least 3 years.

S4-18 The commenter states that they, CDFW, do not recommend topsoil salvage or transplantation as viable mitigation options.

Comment noted. Proposed mitigation does not include topsoil salvage or transplantation.

S4-19 The commenter states that the project, as proposed, would have an impact on fish and/or wildlife resources, and assessment of filing fees is necessary. The fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by the commenter, CDFW. Payment of the fee is required in order for the underlying project approval to be operative, vested, and final. (California Code of Regulations, tit. 14, § 753.5; Fish and Game Code, § 711.4; Public Resources Code, § 21089).

Comment noted. No response necessary.

S4-20 The commenter states that they, CDFW, appreciate the opportunity to comment on the DEIR to assist the City of Carpinteria in identifying and mitigating project impacts on biological resources.

Comment noted. No response necessary.

1 **EXTERNAL EMAIL**
CAUTION: This email originated from outside the City of Carpinteria. DO NOT OPEN attachments or CLICK on links unless you are sure they are safe. Remember, reputable vendors, banks, etc. will not ask you to disclose passwords or other sensitive information.

Hello Nick,
NCTC supports the local tribal governments recommendations, thank you.

Fred Collins
NCTC
From: Nick Bobroff [mailto:[email protected]]
Sent: Thursday, March 11, 2021 4:43 PM
To: Nick Bobroff
Subject: Public Release of the Draft Environmental Impact Report for the Carpinteria Rincon Trail Project Good afternoon,
The City of Carpinteria will be releasing the Draft Environmental Impact Report (DEIR) prepared for the Carpinteria Rincon Trail project for a 45‐day public review and comment period beginning on Friday, March 12, 2021 and ending at 5:00 p.m. on Monday, April 26, 2021.

The DEIR will be considered by the City of Carpinteria Environmental Review Committee (ERC) at a public meeting to be held Tuesday, April 13, 2021, beginning at 4:00 p.m. Note, due to COVID 19 social distancing protocols, the scheduled ERC meeting will be held virtually on Zoom Webinar.

Information on how to access the DEIR, submit comments, and attend the virtual ERC meeting are provided in the attached Rincon Trail EIR Notice of Availability document (“NOA Rincon Trail EIR_final.pdf”). The documents can also be viewed and accessed at the Rincon Trail Project webpage HERE.

Should you have any questions about the DEIR or the Rincon Trail Project, please contact me at the phone number or email provided below.

Thank you,
Nick Bobroff, Principal Planner
Community Development Department
(805) 755‐ 4407 / [email protected]
Comment Letter T1
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-34

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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-35
Response to Comment Letter T1
Northern Chumash Tribal Council
Fred Collins
April 1, 2021
T1-1 The commenter indicates that the Northern Chumash Tribal Council supports the recommendations identified by local tribal governments.

The City acknowledges receipt of the comment. However, the comment does not address the adequacy or completeness of analysis provided in the EIR. Therefore no response is necessary.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-36

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Friends of Bates Beach
A Non-Profit California Corporation
1072 Casitas Pass Road Suite 427 Carpinteria CA 93013
Email: [email protected]
Website: www.friendsofbatesbeach.org
1 April 26, 2021
Mr. Nick Bobroff, Principal Planner
Community Development Department
City of Carpinteria
5775 Carpinteria Avenue
Carpinteria, CA 93013
Re: Rincon Trail Environmental Impact Report
Dear Mr. Bobroff:

I watched the online public hearing of April 13, 2021 concerning the recently published Environmental Impact Report (March 2021) for the proposed Rincon Trail to be built just south of Carpinteria. I have a few questions and concerns I would like to bring to the Planning Committee’s attention.

1. Draining onto the Beach
These references are Slide 9 of the presentation and section 2.7.3 and 3.8.1 of the EIR Report While the report concludes the five drainage pipes will adequately remove any storm water from the proposed trail, the report is silent about the effect of the water on the beach below. The conversation about an hour into the hearing did not consider you may be creating stream gullies across the sand to the water from the end of the pipes. We believe there is a significant possibility for the Bates Beach (northern) section to be split into several partitions over time from erosion cause by this water runoff, thus harming the enjoyment of that area by future beachgoers. While we concede that in the years when we experience heavier winter storms, sand does rebuild the beach’s sand there, we are concerned there is no discussion about how the long-term “gullification” of the beach cannot be mitigated by this winter sand. We don’t want to lose our future beach use for the convenience of the drainage from above.

2. Removal of Concrete Brik-Brak
Also, in previous proposal versions, the concrete “brik-brak” near drain #5 was slated to be removed as a safety hazard since it is the result of a landslide from above several years ago (see photo, left). It butts up against the retaining wall and eventually we feel it will break through that wall due to further erosion onto the beach. I see no mention of this in the report and the testimony of Mr. Roberts at the hearing indicates this safety hazard is going to be left in place. We think this is a mistake and we ask that it be removed since all the heavy equipment necessary to do so will be right there anyway during the trail construction.

3. Parking Lot ADA Non-Compliance
There is no mention in the EIR report about the potential danger at the terminus of the Alternative 3 Trail, the one most of the committee seems to favor, although there were a few comments made at the hearing about this. This trail alternative empties into the North Rincon (Bates) Beach parking lot, which, when filled, holds approximately 150 cars. During the summer, this lot is filled with overflow spilling into illegal areas and angles and also onto Bates Road below. Anyone who parks there will testify how hard it is to see oncoming or passing cars or bicyclists driving past when pulling out of these right-angled parking spots. Near misses are common. With the anticipated additional traffic from the trail through the parking lot we feel there will be an increased number of accidents and not just near misses.

Comment Letter O1
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2 Our recommendation: the parking lot be restriped so cars park at oblique angles instead of 90 degrees, in such a way as to increase visibility for drivers to see what is behind them. Also, that a designated bike lane be placed against the north side of the parking lot to help keep those exiting the Trail physically separate from the parked cars. This will have the net effect of slightly reducing the number of parking spaces, but it can be mitigated by installing an Uber/Lift pickup area near the restrooms so people can use alternative transport to the beach.

Also as has been noted in a previous hearing, the parking lot is at the top of a steep hill, one which exceeds the recommended slope angle for ADA compliance. The trail is supposed to be ADA-accessible with the idea that the parking lot will act as the connector between the Carpinteria part of the trail and the Ventura County section of the trail that begins at the bottom of the parking lot hill. In our opinion, the steep angle of the hill is unsafe for bikes, skateboards, and people using other motorized scooters who may want to continue on the trail from Carpinteria to Ventura. They wil pick up speed and be a danger to traffic at the intersection where the parking lot meets Bates Road. We have no suggestion for mitigation but feel someone smarter than us address this concern.

We point out that the Alternative 4 trail avoids all parking lot dangers, even though we see the committee members at the hearing wanting to prioritize the ability to see the ocean from the second half of the Alternative #3 option as its highest priority. Therefore, these safety concerns must be addressed.

We wish to add, however, that the EIR (page 2.15) states “Vehicle parking at the trailhead on the western end would be provided via an existing dirt lot adjacent to the Carpinteria Avenue terminus; no improvements to the informal dirt parking lot are proposed.” This might solve the problem of reduced parking slots in the Rincon Beach parking lot, except that we see the city is considering using this area for an “auto camp” of permanent rental trailers. This park is not part of the Trail discussion, but we feel its possible intrusion must be considered as part of the parking lot discussion.

4. Bridge Safety
This references Section 2.7.2 of the EIR and specifically page 2-12.

The EIR says: “...the bridge for the Carpinteria Rincon Trail will have some similar characteristics, except that UPRR requires high “safety fences” for the full length of the bridge to protect the trains from potential objects thrown from the bridge platform.”
There is no further description of these “high” fences, and we have a question about potential suicides from the bridge to the passing trains below. Can the committee please provide more complete information about this fencing and if they are designed to prevent any kind of climbing or jumping as well as the indicated tossing of objects onto the tracks below?

5. Wind Pattern Analysis and the Paragliders
This references Slide 19 of the presentation and also pages 3.3.6 of the EIR and several public speakers.

We sympathize with our friends in the paraglider community who claim that the loss of up to 30% of the wind uplift by Alternative #3 will effectively destroy their ability to exist at this beach. The testimony at the hearing downplayed this conclusion, as I heard at least one member of the panel claim the paragliders can operate safely with winds as low as a 10 to 20% loss (the EIR does not say that). The committee seems determined to ignore these hobbyists in favor of the hikers and bikers and the ocean view. We are sad to see this as the paragliders are a tradition at Bates Beach and definitely add to the ambiance and cultural heritage of the community. We are sorry to see the committee take their concerns so lightly. We want to go on record as supporting our flying friends and hope some compromise can be found.

In conclusion we appreciate the ability to comment on the findings of the Environmental Impact Report and we hope our concerns will be address by the committee at a future hearing.

Sincerely,
Gary Mussell
Director, Friends of Bate Beach
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-39
Response to Comment Letter O1
Friends of Bates Beach
Gary Mussell, Director
April 26, 2021
O1-1 The City acknowledges the comment as an introduction to comments that follow. No further response is required.

O1-2 The commenter expresses concern regarding effects of the water on the beach from the five drainage pipes that will be used to remove stormwater from the proposed trail and concerns regarding creation of stream gullies across the sand to the water from the end of the pipes. The commenter expresses concern that there is no discussion about long-term gullification associated with erosion.

Comment is acknowledged. The creation of drainage gullies across the beach are not anticipated from the project, due to several reasons. First, the drainage area of the trail surface is small compared to the area within the project alignment, and therefore run-off volumes from the trail surface would be limited. Second, the southern portion of the trail would be served by 5 separate drain outlets, thereby dividing the entire volume of trail run-off into one fifth for each of the outlets. Third, each of the drain outlets would have rock rip-rap at the openings to dissipate the energy of the released water, avoiding the creation of gullies on the beach face. Finally, surface water run-off from the trail would primarily occur in winter, when the beach profile is regularly reworked and replenished by winter storm wave action.

O1-3 The commenter suggests that the existing concrete brik-brak should be removed, as it is an existing safety hazard.

Comment is acknowledged; however, the concrete debris mentioned in the comment is associated with a former state highway, and it is not the responsibility of the project to remove these remnants.

O1-4 The commenter expresses safety concerns regarding Alternative 3, associated with cyclists traversing the parking lot located at the eastern terminus of the trail alignment.

It is assumed that the commenter is referencing both the proposed project and Alternative 3, which each involve termination of the proposed trail at the western end of the Rincon Beach County Park parking lot. As discussed in Section 3.12 (Transportation) of the Draft EIR, the City’s consulting traffic engineer determined there would not be a significant hazard associated with introducing additional cyclists traversing the Rincon County Beach Park parking lot. Vehicle maneuvers in the parking lot involve low speeds, and signage in the parking area would alert drivers to cyclists passing through the area. Signage at the terminus of the trail leading into the parking area would also alert cyclists to reduce speed and employ appropriate caution when riding through the parking lot.

O1-5 The commenter provides recommendations for improving safety.

The City acknowledges and appreciates the commenter’s suggestions regarding bicycle safety. See Response 01-4 (above) for a response to bicycle safety concerns. No further response is required Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-40
because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

O1-6 The commenter expresses concern regarding ADA compliance associated with the proposed project.

As discussed in Section 2.5 of the EIR, the existing benched slope with steep surface angle would be regraded in order to achieve compliance with ADA pathway slope requirements, making the project consistent with ADA requirements. It should be noted the refined Alternative 3 would incorporate a trail surface slope that marginally exceeds the maximum acceptable slope of 5 percent (the trail would have a slope of 6 percent) for a 690 foot portion of the segment south of the UPRR alignment. This marginally steeper slope surface may not result in a practical limitation to access by mobility challenged individuals, and an exception may be available in accordance with U.S. Access Board (USAB) guidelines for the 690-foot trail segment exceeding 5%, such that the entire trail could potentially achieve ADA compliance.

O1-7 The commenter expresses support for Alternative 4, in particular relating to safety issues. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR.

The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

O1-8 The commenter states that vehicle parking provided at the trailhead on the western end may solve the problem of reduced parking. However, the commenter expresses concern that the City is considering this location for an auto camp of permanent rental trailers and suggests that possible intrusion is considered in the EIR.

Comment is acknowledged. The informal dirt parking area at the eastern terminus of Carpinteria Avenue is within the City-owned right-of-way for Carpinteria Avenue and would not be affected by potential future development of an auto camp on the adjacent privately-owned parcel.

O1-9 The commenter expresses safety concerns regarding the proposed bridge, especially regarding climbing, jumping, and tossing objects into the tracks below.

As a facility constructed within their right-of-way, UPRR has approval authority for the final bridge design and will ensure it is consistent with their safety standards regarding the expressed concerns of the commenter. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

O1-10 The commenter expresses concern regarding the loss of 30 percent of wind uplift and expresses support for the soaring community and their inability to use this site once the project is approved.

Please refer to Global Response GR1.

O1-11 The commenter provides a concluding statement.

The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. No further response is required or provided.

Board of Directors
Holly Sierra
Chair
City of Buellton
Das Williams
Vice Chair
Santa Barbara
County
1st District
Gregg Hart
Santa Barbara
County
2nd District
Joan Hartmann
Santa Barbara
County
3rd District
Bob Nelson
Santa Barbara
County
4th District
Steve Lavagnino
Santa Barbara
County
5th District
Charlie Uhrig
City of Solvang
Al Clark
City of Carpinteria
Alice Patino
City of Santa Maria
Ariston Julian
City of Guadalupe
Jenelle Osborne
City of Lompoc
Cathy Murillo
City of Santa
Barbara
Paula Perotte
City of Goleta
Ex-Officio Members
Tim Gubbins
Director
Caltrans District 5
Staff
Marjorie Kirn
Executive Director
Rachel Van Mullem
Agency Counsel \
l
April 15, 2021
City of Carpinteria
c/o: Matt Roberts, Parks & Recreation Director
5775 Carpinteria Avenue
Carpinteria, CA 93013
Subject: Support of the Steeper Slopes/Reduced Earthwork Alternative (Alternative 3) as the environmentally superior alternative in the Carpinteria Rincon Multi-Use Trail Draft Environmental Impact Report (DEIR).

Dear Mr. Roberts:

Thank you for the opportunity to review and provide comment on the DEIR for the Carpinteria Rincon Multi-Use Trail project (project). SBCAG appreciates its partnership with the City of Carpinteria to advance this project to complete a long-standing gap in the statewide California Coastal Trail, improve public safety, and enhance non-vehicular travel alternatives along the Highway 101 corridor that connects communities and regional coastal resources. SBCAG respectfully submits the following comments in support of Steeper Slopes/Reduced Earthwork Alternative (Alternative 3), as the environmentally superior alternative as expressed in the project’s DEIR.

SBCAG agrees that Alternative 3 meets stated project objectives while reducing overall environmental impacts, including reducing the volume of earthwork required for the project i.e., 15,000 less cubic yards (approximately an eight percent reduction) translating to fewer haul trucks and greenhouse gas emissions during construction. It also reduces construction-related noise impacts and has less of an impact upon recreational options, specifically in regard to concerns expressed for paragliding and hang-gliding activities occurring on private properties above the trail alignment. In addition to the DEIR, SBCAG recognizes that Alternative 3 reflects a design that has advanced and gained approvals from Union Pacific Railroad, California Public Utilities Commission, and other stakeholders. It is also the only alternative that can be delivered within the timeline for construction to meet a funding deadline of June 2022, since other alternatives are more preliminary in nature and would require significant re-design efforts.

Again, SBCAG appreciates the opportunity to provide comments on the DEIR and looks forward to reviewing the Final Environmental Impact Report. SBCAG has long valued coordination with partner agencies like the City of Carpinteria to bring about important multi-use opportunities in our region and along the Highway 101 corridor. If you have any questions regarding this response, please call Fred Luna, SBCAG Director of Project Delivery and Construction, at (805) 961-8926 or by email at [email protected].

Sincerely,
Marjie Kirn, Executive Director
Santa Barbara County Association of Governments
Comment Letter L1
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-42

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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-43
Response to Comment Letter L1
Santa Barbara County Association of Governments
Marjie Kirn
April 15, 2021
L1-1 The City acknowledges the comment as an introduction to comments that follow. No further response is required.

L1-2 The commenter provides general support for Alternative 3 and agrees that it would reduce potential environmental impacts. The comment does not raise any issue concerning the adequacy of the Draft EIR. No response is required.

L1-3 The City acknowledges the comment as conclusionary remarks. No further response is required.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-44

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Hi Nick –
The Carpinteria Sanitary District commented on this project in late 2019.  Refer to the attached letter, which we suggest be added to the record for CEQA purposes.  Based on the critical nature of sewer infrastructure in the vicinity of the City’s proposed project, we offer the following additional comments on the DEIR.  Extension of the trail on the freeway side of the bluff east of the railroad crossing, if this is the selected or preferred alternative, must not interfere with or in any way compromise the District’s existing 4‐inch diameter HDPE force main in this location.  Civil design should be coordinated to ensure this outcome.  Within the entire project area, the trail design should ensure that the District has continued access to the 4‐inch diameter HDPE force main located parallel to US 101 and approximately 5 feet south of the southbound shoulder.  The proposed trail should not inhibit or impair future access, up to and included excavation for repair and/or replacement of the existing pipeline.
 DEIR Appendix K evaluates extended routes through the Rincon Beach Park.  Aerial images for the graphics in this appendix do not show the District’s wastewater lift station. Although this critical infrastructure is mentioned in the narrative, it is unclear how the City intends to construct a pathway in proximity to this facility.  It is crucial that this facility remain accessible at all times for emergency response and that pipelines and buried infrastructure be protected.   The District has a legal easement from the County of Santa Barbara in this vicinity for both buried and surface improvements.

Thank you for the opportunity to comment on this project.

Craig Murray, P.E.

General Manager
Carpinteria Sanitary District
5300 Sixth Street
Carpinteria, CA 93013
P 805.684.7214 x112
C 805.451.7804
NOTE: Our Administration Office has temporarily relocated to 1110 Eugenia Place.  Please continue to use 5300 Sixth Street as our mailing address.

Comment Letter L2
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5300 Sixth Street
Carpinteria, CA 93013
CARPINTERIA Phone (805) 684-7214 * Fax (805) 684-7213
Sanitary District
October 31, 2019
Nick Bobroff
Community Development Department
City of Carpinteria
5775 Carpinteria Avenue
Carpinteria, California 93013
Subject: Project No. 19-2015-CUP/CDP
Carpinteria Rincon Trail Project
Dear Mr. Bobroff;
Thank you for the opportunity to provide comments on the subject project. The project applicant proposes to construct a 2,800-foot long paved multi-use trail extending from the eastern terminus of Carpinteria Avenue in the City of Carpinteria to Rincon Beach Park in the County of Santa Barbara, near the Ventura County line. The proposed trail would be 16 feet in width (comprised of a 10-wide path with a 3-foot paved shoulder along each side of the trail). The trail project includes a new 160-foot long clear span pre-fabricated bridge crossing over the UPRR alignment. Grading and earthwork quantities necessary to cut the trail bench and stabilize slopes in the project area estimated at 104,000 cubic yards of cut, 10,300 cubic yards of which would be used for fill on-site. The remaining 94,000 cubic yards of cut material would be exported offsite.

A storm drain collection system is proposed for the trail alignment, with new drain outlets to the ocean.

The Carpinteria Sanitary District (District) has the following initial comment:
• The District has a 4-inch diameter HDPE sewer force main that is located immediately north (5 feet to 30 feet) of the proposed trail alignment. At stations 21 through 23.5, the proposed trail is approximately five (5) horizontal feet from the force main. It also appears the proposed trail is 5 to 10 vertical feet from the force main. This force main is a high priority subsurface installation that provides sewer service to the Rincon Point community.
• Contractors excavating, boring, drilling, sinking fenceposts or other subsurface work must take extreme precaution to ensure the force main is protected during the construction of the trail. The District should be notified when excavation activities are occurring between stations 21 through 24. This should be noted on the construction drawings.

ENVIRONMENTAL LEADERSHIP IN CARPINTERIA SINCE l 928
www.carpsan.com
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-46

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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-47
Response to Comment Letter L2
Carpinteria Sanitary District
Craig Murray, PE
March 15, 2021

L2-1 The comment references a previous letter, provided to the City by Carpinteria Sanitary District.

Responses to the referenced letter are provided in comments L2-6 through L2-9, below. The comment also introduces comments that follow. No further response is required.

L2-2 The comment expresses concern regarding potential interference with Carpinteria Sanitary District’s 4- inch high-density polyethylene (HDPE) force main associated with extension of the proposed trail on the freeway side of the bluff, east of the railroad crossing.

The location of the force main and the need to exercise extreme caution during project construction located in close proximity to the force main will be noted on plans; in order to heighten overall awareness, the sewer force main location will be surveyed and flagged in the field for those sections immediately adjacent to project construction work zones..

L2-3 The comment expresses concern regarding access to the 4-inch HDPE force main.

The location of the force main and requirements to preserve access to this force main location following project construction will be noted on plans; in order to heighten overall awareness, the sewer line location will be surveyed and flagged in the field for those sections immediately adjacent to project construction work zones. The City will also make compliance with the comments in this letter a project condition of approval of the CUP/CDP.

L2-4 The comment expresses concern regarding the Carpinteria Sanitary District’s wastewater lift station and ensuring that this facility remains accessible at all times for emergency response and that pipelines and buried infrastructure are protected.

Comment is noted. The existing wastewater lift-station along the north side of the Rincon Beach County Park would only be within the potential alignment for Alternative 4. Should Alternative 4 be implemented for development of the trail, the final trail engineering design would be required to avoid impacts to the wastewater lift station and connected sewer lines.

L2-5 The City acknowledges the comment as conclusionary remarks. No further response is required.

L2-6 This comment provides an accurate summary of the project and does not raise any issue concerning the adequacy of the Draft EIR. No response is required.

L2-7 This comment outlines the location of the 4-inch HDPE force main.

Thank you for identifying the location of District sewer collection lines in the project vicinity.

L2-8 The comment expresses concern regarding the existing HDPE force main and requests that the City takes precaution during construction in this area. The commenter requests that the City notifies the Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-48
Carpinteria Sanitary District when excavation occurs between stations 21 through 24 and requests the location of these facilities be identified on construction drawings.

The location of sewer lines and the need to contact the District for work near these lines will be noted on plans. In order to heighten overall awareness, the sewer line location will be surveyed and flagged in the field for those sections immediately adjacent to project construction work zones. The City will also make compliance with the comments in this letter a project condition of approval of the CUP/CDP.

L2-9 The City acknowledges the comment as conclusionary remarks. No further response is required. 123 E. Anapamu Street, Santa Barbara, CA 93101 ∙ Phone: (805) 568-2000 ∙ FAX: (805) 568-2030 624 W. Foster Road, Santa Maria, CA 93455 ∙ Phone: (805) 934-6250 ∙ FAX: (805) 934-6258 www.sbcountyplanning.org
County of Santa Barbara
Planning and Development
Lisa Plowman, Director
Jeff Wilson, Assistant Director
Steve Mason, Assistant Director
May 3, 2021
Nick Bobroff, City of Carpinteria
5775 Carpinteria Avenue,
Carpinteria, CA 9301
Email: [email protected]

Re: Carpinteria Rincon Multi-Use Trail Notice of Preparation for an Environmental Impact Report – Public Comment
Dear Mr. Bobroff:

The County of Santa Barbara Planning and Development Department reviewed the City of Carpinteria’s Rincon Multi-Use Trail Environmental Impact Report (EIR) and appreciates the opportunity to provide the comments listed below.

1. Alternatives Analysis
 The County of Santa Barbara requests that the alternatives in the EIR are analyzed such that any alternative can be approved during the County of Santa Barbara’s permitting process. Specific analysis, such as project information, grading quantities, and mitigation measures for each project alternative, is requested to be included in the EIR.

2. Trail Location
 The alternatives analysis should discuss the ocean views visible from the trail and access to coastal resources as well as the required earthwork for the proposed alignment and for all alternative alignments.

3. Policy Consistency
 The County’s permit will include a policy consistency analysis with the County’s Comprehensive Plan. It is recommended that the EIR provide information throughout the document, and specifically in the Land Use section, to address the relevant County policies, including:

Recreation
 Coastal Land Use Plan Policy 7-33: To encourage walking and biking as alternatives to travel by automobile, the County shall strongly encourage development of Comment Letter L3
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County of Santa Barbara Planning and Development Department Comments City of Carpinteria Rincon Multi-Use Trail Draft EIR – Public Comment

new pedestrian and/or bicycle-friendly paths along the highway corridor.

Improvements to Highway 101 shall not remove existing bikeways or pedestrian paths or preclude the development of proposed bikeways or pedestrian paths that are identified in the County’s Comprehensive Plan, Coastal Land Use Plan and community plans, without providing comparable or better replacement facilities.  Coastal Act 30211. Development shall not interfere with the public’s right of access to the sea where acquired through use, custom, or legislative authorization, including, but not limited to, the use of dry sand and rocky coastal beaches to the first line of terrestrial vegetation.
 Coastal Act Policy 30252. The location and amount of new development should maintain and enhance public access to the coast by: (1) facilitating the provision or extension of transit service; (2) providing commercial facilities within or adjoining residential development or in other areas that will minimize the use of coastal access roads; (3) providing non-automobile circulation within the development; (4) providing adequate parking facilities or providing substitute means of serving the development with public transportation; (5) assuring the potential for public transit for highintensity uses such as high-rise office buildings, and by (6) assuring that the recreational needs of new residents will not- overload nearby coastal recreation areas by correlating the amount of development with local park acquisition and development plans with the provision of on-site recreational facilities to serve the new development.
 Coastal Act Policy 30210. In carrying out the requirement of Section 4 of Article X of the California Constitution, maximum access, which shall be conspicuously posted, and recreational opportunities shall be provided for all the people consistent with public safety needs and the need to protect public rights, rights of private property owners and natural resource areas from overuse.
 Coastal Act Policy 30212.5 Wherever appropriate and feasible, public-facilities, including parking areas or facilities, shall be distributed throughout an area so as to mitigate against the impacts, social and otherwise, of overcrowding or overuse by the public of any single area.
 Coastal Act Policy 30213. Lower cost visitor and recreational facilities shall be protected, encouraged, and, where feasible, provided. Developments providing public recreational opportunities are preferred.
 CLUP Policy 7-8: Increased opportunities for beach access shall be provided in the Carpinteria planning area.

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Cont.

County of Santa Barbara Planning and Development Department Comments City of Carpinteria Rincon Multi-Use Trail Draft EIR – Public Comment

Geologic:
 CLUP Policy 3-13: Plans for development shall minimize cut and fill operations. Plans requiring excessive cutting and filling may be denied if it is determined that the development could be carried out with less alteration of the natural terrain.  CLUP Policy 3-14: All development shall be designed to fit the site topography, soils, geology, hydrology, and any other existing conditions and be oriented so that grading and other site preparation is kept to an absolute minimum. Natural features, landforms, and native vegetation, such as trees, shall be preserved to the maximum extent feasible. Areas of the site which are not suited for development because of known soil, geologic, flood, erosion or other hazards shall remain in open space.

Environmentally Sensitive Habitat:
 Coastal Act Policy 30240 (b). Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade such areas, and shall be compatible with the continuance of such habitat areas.

Visual:
 Coastal Act Policy 30251. The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas.
 CLUP Policy 4-3: In areas designated as rural on the land use plan maps, the height, scale, and design of structures shall be compatible with the character of the surrounding natural environment, except where technical requirements dictate otherwise. Structures shall be subordinate in appearance to natural landforms; shall be designed to follow the natural contours of the landscape; and shall be sited so as not to intrude into the skyline as seen from public viewing places.

Transportation:
 Circulation Element Policy 5C: The County shall continue to develop programs that encourage the use of alternative modes of transportation including, but not limited to, an updated bicycle route plan, park and ride facilities, and transportation demand management ordinances.

5. Future Notices
When they become available, please send a copy of all notices of City decision-maker hearings regarding the project and the Final EIR Notice of Determination to:

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Cont.

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County of Santa Barbara Planning and Development Department Comments City of Carpinteria Rincon Multi-Use Trail Draft EIR – Public Comment

o Dan Klemann, Deputy Director of Long Range Planning, via email at [email protected] or mail at 123 E. Anapamu Street, Santa Barbara, CA 93101.
o Ciara Ristig, Senior Planner, via email at [email protected] or mail at 123 E. Anapamu Street, Santa Barbara, CA 93101
o Tess Harris, Supervising Planner, via email at [email protected] or mail at 123 E. Anapamu Street, Santa Barbara, CA 93101
Thank you for the opportunity to provide comments on the Draft EIR. If you have any questions or require further information, please contact me at (805) 568-2086 or Mr. Seawards at (805) 568-2518.

Regards,
Lisa Plowman, Director
Planning & Development Department
cc: Travis Seawards, Deputy Director, Development Review Division Dan Klemann, Deputy Director, Long Range Planning Division Tess Harris, Supervising Planner, Development Review Division Ciara Ristig, Senior Planner, Development Review Division File
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Cont.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-51
Response to Comment Letter L3
County of Santa Barbara Planning and Development
Lisa Plowman
May 3, 2021
L3-1 The City acknowledges the comment as an introduction to comments that follow. No further response is required.

L3-2 The commenter requests that the City analyzes each alternative outlined in the DEIR, and includes specifics such as project information, grading quantities, and mitigation measures.

Per CEQA Guidelines Section 15126.6(d), an EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed. (County of Inyo v. City of Los Angeles (1981) 124 Cal.App.3d 1). The analysis of the project did not identify any unavoidable significant impacts, which is the paramount consideration for the development of alternatives to the proposed action. However, given potentially significant impacts were identified, the EIR included four distinct alternatives to the project, each with an intent to lessen or avoid the significant impacts of the proposal. Information on each alternative, including involved grading quantities, has been provided in Section 6.0; the relative severity of each impact is also compared to the project, and the necessity under each alternative for implementation of mitigation measures identified for project impacts is identified. Therefore, per CEQA Guidelines Section 15126.6(d), a full analysis of each proposed alternative, including specific mitigation measures to address unique impacts of such an alternative, is not required.

Rather, the alternatives analysis is intended to identify whether the proposed project, or an alternative to the proposal, has the greatest potential for minimization of environmental impacts, while achieving the primary objectives of the proposed project. Insofar as several alternatives appear to offer opportunities to reduce impacts as compared to the proposed project, as much detail as possible is provided regarding the impacts and mitigations associated with each of the alternatives, although subsequent environmental review to satisfy CEQA may need to be performed in some issue areas if one of the alternatives is selected for implementation in favor of the proposed project.

L3-3 The commenter requests that the alternative analysis discusses ocean views visible from the trail, access to coastal resources, and required earthwork for the proposed alignment and all alternative alignments.

See response L3-2, above. The alternative analysis included an analysis of aesthetic and recreational impacts, as they compare to the proposed project, consistent with CEQA Guidelines Section 15126.6(d). In addition, per Section 6.6 of the Draft EIR, Alternative 2 would result in 46,000 cubic yards (CY) of cut and 10,500 CY of fill; Alternative 3 would result in 96,077 CY of cut and 10,570 CY of fill, and Alternative 4 would result in 105,300 CY of cut and 710 CY of fill.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-52
L3-4 The commenter suggests that various policies from the County of Santa Barbara (County’s) Comprehensive Plan should be included in the EIR. These policies have been added in Section 3.9.2 of the EIR (see Chapter 3, Errata).

L3-5 The commenter requests that future notices are sent to addresses for County representatives provided in this comment. The City will provide notices to the County representatives at addresses indicated in this comment. No further response is required.

Comment Letter L4
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-54

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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-55
Response to Comment Letter L4
County of Ventura Community Development Department
Paolo Quinto
April 27, 2021

L4-1 The City acknowledges the comment as an accurate overview of the project and an introduction to comments that follow. No further response is required.

L4-2 The commenter states that weekly testing shall be conducted for the new stormwater drainage outlets, which should be coordinated with the State Water Resources Control Board, Ocean Standards Unit.

This comment does not raise any issue concerning the adequacy of the Draft EIR. Testing and sampling of proposed stormwater drainage outlets shall be performed in accordance with all existing laws and regulations. No further response is required.

L4-3 The commenter expresses concern regarding the proliferation of vectors, including mosquitoes, associated with new stormwater drainage outlets and recommends monitoring and controlling mosquito activities from these sites to reduce exposure to vector-borne diseases.

This comment does not raise any issue concerning the adequacy of the Draft EIR. The City appreciates the recommendation regarding monitoring and control of mosquitos; it is anticipated that the City and County will both follow guidelines and practices established by the Mosquito and Vector Management District of Santa Barbara County in the maintenance procedures for their respective portions of the trail alignment. No further response is required.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-56

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1 **EXTERNAL EMAIL**
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Thanks Nick, it must wrench on your soul to know you are killing a magical recreational activity (paragliding/hang gliding) for so many people in our beautiful, unique little town. I think you are a surfer and can relate. Hope you get outside and play more than you dont, life is short.

Aaron LaPlante
Comment Letter I1
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-58
Response to Comment Letter I1
Aaron LaPlante
March 12, 2021

I1-1 The City acknowledges the comment as general opposition to the project. No further response is required.
1 **EXTERNAL EMAIL**
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Mr.Nick
8 very much disturbs me. That the EIR, still does not have the monarch butterfly habitat that is there. It doesn't have the migratory bird act.

The monarchs are in the eucalyptus trees on the East Side of the freeway there as well as the multi million dollar homes each year. The migratory birds fly up-and-down that cliff face by weekly to Tri weekly from the carpenter Rhea salt March to the Venter a salt marsh all of these are going to be affected drastically! The endangered species of plant life on the front of that cliff face isn't even being considered. How is this possible under federal law? How is this no concern to your environmental impact report? Comment Letter I2
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-60
Response to Comment Letter I2
E. Arciniega
April 9, 2021
I2-1 The commenter expresses concern regarding the presence of monarch butterfly habitat, stated in the comment letter to be present in eucalyptus trees on the East Side of the freeway and the absence of discussion regarding the Migratory Bird Treaty Act.

As discussed in Section 3.3.4, impacts to monarch butterfly individuals and monarch butterfly overwintering sites would be less than significant. Although monarch butterflies are known to occur near the project site along Bates Road just north of U.S. Highway 101 in a eucalyptus stand associated with Rincon Creek, no impacts to this monarch overwintering site are anticipated since the overall height of the slope within Rincon Beach County Park south of Highway 101 will not be reduced, as work includes proposed terraces to stabilize the hill but will not decrease its overall height, and therefore no changes to the wind conditions at the overwintering site are expected. Additionally, this overwintering site is largely protected by the hill below the single residential development at 637 Bates Road, and any possible changes to weather and wind patterns due to project implementation would not affect the protective contour this hill independently provides. In addition, as discussed in Section 3.3.4, 22 species of native birds were detected on site, including several with the potential to nest there. Nests, eggs and nestlings of all native bird species are protected by the Migratory Bird Treaty Act and the California Fish and Game Code, as discussed in Section 3.3.4 of the Draft EIR. Vegetation clearing and grading, if occurring during the nesting season (typically mid-February to August), have the potential to destroy nests, eggs and nestlings, which could violate these regulations. However, with implementation of MM-BIO-1, MM-BIO-2, and MM-BIO-6, project impacts to nesting and migratory birds would be reduced to less than significant.

I2-2 The commenter expresses concern regarding endangered plant species on the cliff face.

As discussed in Section 3.3.4, no special-status plant species were observed; thus, impacts to specialstatus plant species would be less than significant. 1 **EXTERNAL EMAIL**
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Ok so....

Mr.Nick
It still very much disturbs me. That the EIR, still does not have the monarch butterfly habitat that is there. It doesn't have the migratory bird act. It doesn't even have a true Wind report on it! The monarchs are in the eucalyptus trees on the East Side of the freeway there as well as the multi million dollar homes each year. That will be highly affected by your committees ignorance. The migratory bird act, that fly up-and-down that cliff face bi to Tri weekly from the Carpinteria salt Marsh. to the Ventera salt marsh all of these are going to be affected drastically! The endangered species of plant life on the front of that cliff face isn't even being considered. How is this possible under federal law? How is this no concern to your environmental impact report?
How is this Committee Bypassing FEDERAL LAW? How are you ignoring a nearly endangered Species monarch butterfly flies?
The TUFFEST migratory bird acts known thruout the USA? Based here in CA? Endsngered plant life Species that a big growing on the front of that Hill for well since the old highway was there they've been there for decades one of very few areas they actually grow in our whole state Turning a blind eye, to these things, will get you nowhere. Want you start your gonna have to replace at all.

Costing you hundreds of millions of dollars. For the 6 million dollars year after.

To top it off this trail is not Ada compliant. Simply because it is Ada compliant from highway 150 down to the park it does not meet Ada compliancy down through the parking lot to connect to the other trail. That is also not Ada compliant coming out of the parking lot.

Comment Letter I3
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-62
Response to Comment Letter I3
E. Arciniega
April 9, 2021
I3-1 The commenter expresses concern regarding an absence of reference in the EIR to monarch butterfly habitat and the Migratory Bird Treaty Act.

See response I2-1, above.

I3-2 The commenter states that no true wind report was included.

A detailed analysis of the alterations to air flow patterns above the bluffs resulting from project implementation was completed for the EIR; the Airflow Analysis report was provided as Appendix I of the Draft EIR. The comment does not pertain to the adequacy of the EIR. No further response is required.

I3-3 The commenter expresses concern regarding the presence of monarch butterfly habitat, stated in the comment letter to be present in eucalyptus trees on the East Side of the freeway; the Migratory Bird Treaty Act; and endangered plant species. The commenter believes that the project does not comply with federal law regarding monarch butterflies and the Migratory Bird Treaty Act.

See response I2-1, above.

I3-4 The commenter expresses concern regarding endangered plant species.

See response I2-2, above.

I3-5 The commenter expresses general opposition to the project and economic concerns. The comment does not pertain to the adequacy of the EIR. No response is required.

I3-6 The commenter expresses concern that the proposed trail is not compliant with the Americans with Disabilities Act of 1990 (ADA).

As discussed in Section 2.5 of the EIR, the existing benched slope would be regraded in order to achieve compliance with ADA pathway slope requirements, making the project consistent with ADA requirements. It should be noted the refined Alternative 3 would incorporate a trail surface slope that marginally exceeds the maximum acceptable slope of 5 percent (the trail could have a slope of 6 percent) for a 690 foot portion of the segment south of the UPRR alignment. This marginally steeper slope surface may not result in a practical limitation to access by mobility challenged individuals, and an exception may be available in accordance with USAB guidelines for the 690-foot trail segment exceeding 5 percent, such that the entire trail could potentially achieve ADA compliance. The comment does not pertain to the adequacy of the EIR. No further response is required. 1 **EXTERNAL EMAIL**
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Hi Nick, I encourage you to take a progressive approach to parks and rec and embrace the unique sport of paragliding and hang gliding in Carpinteria.

There are no federal rules that prevent free flight on the bluff and any local rules would be superceded by the Federal Aviation Administration.

Dubai built a 1200 foot high mini mountain just for free flight that people come to from all over the world. I am sure you can create a one of a kind flight park at the Bluff and have a bike path too. What a tourist attraction that would be!
Love ya mahn!
Aaron
------------------------------------------------
Aaron LaPlante
Carpinteria Unified School District
805-886-1435
[email protected]
Comment Letter I4
I4-1
I4-2
I4-3
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-64
Response to Comment Letter I4
Aaron LaPlante
March 12, 2021

I4-1 The commenter expresses general opposition to the project, which does not pertain to the adequacy of the EIR. No further response is required.

I4-2 The commenter states that no existing federal rules prevent free flight at the project site and local rules would be superseded by the Federal Aviation Administration. This comment does not pertain to the adequacy of the EIR. No further response is required.

I4-3 The commenter provides a description of an artificial 1,200-foot high mountain that was constructed to support free flight opportunities and suggests that the City consider creating something like this instead of the proposed project. This comment does not pertain to the adequacy of the EIR. No further response is required.
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It still very much disturbs me. That the EIR, still does not have the monarch butterfly habitat that is there. It doesn't have the migratory bird act. It doesn't even have a true Wind report on it! The monarchs are in the eucalyptus trees on the East Side of the freeway there as well as the multi million dollar homes each year. That will be highly affected by your committee's ignorance. The migratory bird act, that fly up-and-down that cliff face bi to Tri weekly from the Carpinteria salt Marsh. to the Ventera salt marsh all of these are going to be affected drastically! The endangered species of plant life on the front of that cliff face isn't even being considered. How is this possible under federal law? How is this no concern to your environmental impact report? How is this Committee Bypassing FEDERAL LAW? How are you ignoring a nearly endangered Species monarch butterfly flies?
The TOUGHEST migratory bird acts known throughout the USA? Based here in CA? Endangered plant life Species that a big growing on the front of that Hill for well since the old highway was there they've been there for decades one of very few areas they actually grow in our whole state Turning a blind eye, to these things, will get you nowhere. Once you start you're gonna have to replace it all. Costing you hundreds of millions of dollars. For the 6 million dollars a year after.

To top it off this trail is not Ada compliant. Simply because it is Ada compliant from highway 150 down to the park it does not meet Ada compliance down through the parking lot to connect to the other trail. That is also not Ada compliant coming out of the parking lot. This trail is a True FAILURE on Both ends!!! It is going to cost the city Millions of dollars in the end.

The Air flow report IS Not one done in that area. It does not even correspond to the project. OUR MILLION Dollar homes are going to be SEVERELY AFFECTED! Once this hill is CUT away at such a slope. The perfect Wind Shadow that is built by Nature and the Current slope. SHIELDs our Homes from MOST of the 40-50MPH winds post frontal with each storm. Allowing the Monarchs to be here throughout the winter protected in all of our trees.

A true Fallacy, is being pushed in search of exactly what? A State ruling that is not in compliance with Regulations and FEDERAL LAW!~! All being ignored!~! On Thu, Apr 8, 2021, 3:34 PM Nick Bobroff <[email protected]> wrote:

Good afternoon,
This is a reminder that the Draft Environmental Impact Report (DEIR) will be considered by the City of Carpinteria Environmental Review Committee (ERC) at a public meeting to be held Tuesday, April 13, 2021, beginning at 4:00 p.m. Note, due to COVID 19 social distancing protocols, the scheduled ERC meeting will be held virtually on Zoom Webinar.

Information on how to access the DEIR, submit comments, and attend the virtual ERC meeting are provided in the attached Rincon Trail EIR Notice of Availability document (“Revised_NOA Rincon Trail EIR_final.pdf”). *Note, the NOA has been updated to identify Matt Roberts, City of Carpinteria Parks and Recreation Department, as the project applicant.

Comment Letter I5
I5-1
I5-2
I5-3
I5-4
I5-5
I5-6
I5-7
I5-8
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-66
Response to Comment Letter I5
E. Arciniega
April 14, 2021
I5-1 The commenter expresses concern regarding the presence of monarch butterfly habitat and an apparent neglect of requirements of the Migratory Bird Treaty Act.

See response I2-1, above.

I5-2 The commenter states that no wind report was included.

See response to I3-2, above.

I5-3 The commenter expresses concern regarding the presence of monarch butterfly habitat, stated in the comment letter to be present in eucalyptus trees on the East Side of the freeway; the Migratory Bird Treaty Act; and endangered plant species. The commenter believes that the project does not comply with federal law regarding monarch butterflies and the Migratory Bird Treaty Act.

See response I2-1, above.

I5-4 The commenter expresses concern regarding endangered plant species.

See response I2-2, above.

I5-5 The commenter expresses general opposition to the project and economic concerns. The comment does not pertain to the adequacy of the EIR. No response is required.

I5-6 The commenter expresses concern that the proposed trail is not compliant with ADA and expresses economic concerns associated with the project.

As discussed in Section 2.5 of the EIR, the existing benched slope would be regraded in order to achieve compliance with ADA pathway slope requirements, making the project consistent with ADA requirements. The proposed project would terminate at the west (north) end of the parking lot for Rincon Beach County Park, and would not modify conditions present in the parking lot or the roadway segment at the south end of the parking lot; as such, the concerns expressed by the commenter regarding ADA compliance of the parking lot and southern vehicle exit to the parking area are not applicable to the proposed project. In addition, the City acknowledges that this comment raises economic issues that do not appear to relate to any physical effect on the environment. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. No further response is required.

I5-7 The commenter expresses concern regarding the Airflow Analysis provided as part of the Draft EIR and states that this Airflow Analysis does not correspond to the project. In addition, the comment expresses economic concerns associated with proposed cut slopes, and concerns regarding the monarch butterfly.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-67
Refer to global response GR1 regarding the air flow analysis and determination of project impacts on existing soaring opportunities. Regarding the commenter’s economic concerns, the City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. Regarding monarch butterfly concerns, please refer to response I2-1, above. No further response is required.

I5-8 The commenter express general opposition to the project and states that the project is not in compliance with federal law.

The comment does not pertain to the adequacy of the EIR. Regarding the commenter’s previous concerns associated with compliance with federal law regarding monarch butterflies and the Migratory Bird Treaty Act, please see response I2-1, above. No further response is required. 1 **EXTERNAL EMAIL**
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Nick, I understand their are some changes to the Bates soaring hill in Carpenteria. I’ve traveled to Carpenteria many times to bike and also fly Bates, with the proposed changes to accommodate a bike trail.  I must tell you that the bike trail would probably be best on the other side to avoid the congestion of a parking lot and as a pilot I believe the change to the Bates hill will significantly reduce the available lift.

With Bates soaring ruined I’ll no longer visit Carpenteria. I hope you value the input from pilots who love Bates and select an alternative bike path  Thank you for your attention  S. Wuebber Belgrade, MT Comment Letter I6
I6-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-69
Response to Comment Letter I6
Scott Wuebber
April 16, 2021
I6-1 The commenter expresses support for the construction of the proposed trail on the freeway side of the ridge-top (Alternative 4) to avoid congestion of the parking lot and to prevent project-related reductions in the existing available lift along the bluff-top for soaring activities.

It is assumed that the commenter supports Alternative 4 instead of the proposed project. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided. 1 EXTERNAL EMAIL
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Hi Nick, I’ve written to you before but wanted to reach out again and ask that you consider all proposals that would allow all users of the area under discussion to enjoy this magic spot.

As an active cyclist living in Ojai, I have to tell you that the section of 101 that we take from the overpass down to the offramp is a stretch I look forward to as I can coast and hit decent speed, oftentimes giving me a nice break before that long exposed stretch past Rincon and La Conchita.

Paragliding is another passion of mine and Bates is a world class site.  Surely we can find a way that works for everyone.

Please do everything you can to help ensure that we don’t lose this site.

I’m happy to discuss at any time and appreciate your consideration and time.

Best,
M.

Myles Connolly
International Mobile:  +1 949 338 2987
Email:  [email protected]
Skype:  mylesconnolly
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Comment Letter I7
I7-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-71
Response to Comment Letter I7
Myles Connolly
April 16, 2021
I7-1 The City acknowledges the comment and notes that it expresses opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

Comment Letter I8
I8-1
I8-2
I8-3
I8-4
I8-5
I8-6
I8-6
Cont.

I8-6
Cont.

I8-6
Cont.

I8-6
Cont.

I8-6
Cont.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-73
Response to Comment Letter I8
Ottis Gillespie
April 16, 2021
I8-1 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I8-2 The commenter states that questions were left unanswered during the meeting held on April 13, 2021, pertaining to the adequacy and conclusions of the Draft EIR. The commenter hopes that these questions are answered and that conclusions are adjusted.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not identify specific questions left unanswered from the environmental review committee hearing, nor does it raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I8-3 The commenter suggests that the width of the proposed bike route should be no wider than 8 feet, with the exceptions of switchbacks. The commenter explains potential benefits associated with limiting the proposed trail width to 8 feet.

The City acknowledges the comment and notes that it raises issues, including economic issues, that do not appear to relate to any physical effect on the environment. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I8-4 The commenter states that no existing, functional pipes are present at certain locations depicted in the Draft EIR, based on photographs shown in comment I8-6. The drainage pipes referenced in this comment are represented as drains #2, #4, and #5 in Illustration 6 of the Draft EIR.

The City notes that the comment provides background information relative to the existing condition of drainage structures identified in the EIR. The project description indicates that existing drainage structures would be repaired/replaced, and three new drainage outlets would be developed under the proposed project. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. No further response is required or provided.

I8-5 The commenter states that they will provide additional comments during the public review period.

The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I8-6 The commenter provides illustrations of current conditions of the existing drain pipes on site compared to excerpts taken from the Draft EIR. Please refer to response I8-4, above. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.
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Good afternoon Nick,
I hope this email finds you well. I have recently joined the paragliding community here in Santa Barbara but have been enjoying outdoor recreation up here my entire life. As a cyclist and someone that loves to ride the route from Santa Barbara down to Ventura, I was excited to hear of a route that would keep me off the freeway.  I greatly appreciate all the work that has gone in to planning this bike route, but I would love to see some small changes. I am also someone who has dreamed of paragliding off Bates since I first saw some pilots there 5 years ago when officially moving to Santa Barbara. It was not until taking up the sport myself that I realized how important air flow is to the sport of flying. Without the right air flow, it is either unsafe or impossible to stay up in the air. I hope that the new bike path being constructed can keep both of my hobbies safe and possible in the future.

I did sign the petition that was created with approximately 2000 signatures, but I wanted to do more in reaching out to you. I loved that ten environmental review committee recommended the alternate 4 route that would build a bike path on the North side of bates. Coastal soaring at bates makes Carpinteria truly special and unique and should not be lost due to this bike route. I appreciate the cities consideration in reaching out to the soaring community to truly understand the impact that this bike route could potentially create. I look forward to a bike route that is safe for bikers as well as the soaring community.

Thank you for your time and consideration,
Laura Davalos, PT, DPT
[email protected]
805-569-8900 ext. 82238
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Comment Letter I9
I9-1
I9-2
I9-3
I9-4
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-75
Response to Comment Letter I9
Laura Davalos
April 19, 2021
I9-1 The commenter provides personal background and introductory remarks regarding the proposed project. The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I9-2 The commenter expresses the importance of airflow in paragliding and expresses hope that implementation of the proposed project would not hinder both bicycling and paragliding.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I9-3 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I9-4 The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. No further response is required or provided.
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It still very much disturbs my self and others in our small group of houses. That the EIR, still does not have the monarch butterfly habitat that is here and across the freeway in the Eucalyptus trees. It doesn't have the migratory bird act. The sea birds fly up an down our coast multiple times a week! It doesn't even have a true Wind report on it! As a life time pilot (Private,military, commercial) The wind report is 100% wrong! WE have a perfect wind shadow. Created by the Current bluff/cliff face.

Think of putting a 800-1000' horse shoe over the freeway and our homes! You will DESTROY it. Creating a Extremely large Coriolis spin to the air that will come straight off the back of the 45° bluff, across the freeway 2 times! Right through our homes. Potentially even causing car accidents as cars swerve vack an forth passing thru it!
The monarchs are in the eucalyptus trees on the East Side of the freeway there as well as within our multi million dollar homes each year. Harbored here all Winter throught our trees! That will be highly affected by your committee's ignorance.

The migratory bird act, that all fly up-and-down the current cliff face bi to Tri weekly from the Carpinteria salt Marsh. to the Ventera salt marsh all of these are going to be affected drastically! The endangered species of plant life on the front of that cliff face isn't even being considered. I ask you, How is this possible under federal law? How is this no concern to your environmental impact report? How is this Committee Bypassing FEDERAL LAW? How are you ignoring a nearly endangered Species monarch butterflies? The TOUGHEST migratory bird acts known throughout the USA? Based here in CA? Endangered plant life Species that are growing on the front of that Cliff/Hill since the old highway was there. They have been there for decades one of very few areas they actually grow in our whole state.

Turning a blind eye, to these things, will get you nowhere. Once you start you're gonna have to replace it all. Costing you hundreds of millions of dollars. For the 6 million dollars a year that you are all after.

To top it off this trail is not of Ada compliance. Simply because it is Ada compliant from highway 150 down to the park it does not meet Ada compliance down through the parking lot! Or to connect to the other trail that goes Behind our homes!. That is also not Ada compliant coming out of the parking lot. This trail is a True FAILURE on Both ends!!! It is going to cost the city Millions of dollars in the end.

The Air flow report IS Not one done in that area. It does not even correspond to the project. OUR MILLION Dollar homes are going to be SEVERELY AFFECTED! Once this hill is CUT away at such a slope. The perfect Wind Shadow that is built by Nature and the Current slope. SHIELDs our Homes from MOST of the 40-50MPH winds post frontal with each storm. Allowing the Monarchs to be here throughout the winter protected in all of our trees.

A true Fallacy, is being pushed in search of exactly what? FAILURE? Trail 4 is the only proposal that virtually eliminates all the Above!! Yet still not compliant down through the parking lot.

A State ruling that is not in compliance with Regulations and FEDERAL LAW!~! How is your one little rule book ignoring all the Above?!
I truly question this boards actions. That will not meet the objectives! Or finances On Thu, Apr 8, 2021, 3:34 PM Nick Bobroff <[email protected]> wrote:

Good afternoon,
Comment Letter I10
I10-1
I10-2
I10-3
I10-4
I10-5
I10-6
I10-7
I10-8
I10-9
I10-10
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-77
Response to Comment Letter I10
E. Arciniega
April 20, 2021
I10-1 The commenter expresses concern regarding the presence of monarch butterfly habitat and the neglect of requirements under the Migratory Bird Treaty Act.

See response I2-1, above.

I10-2 The commenter states that no wind report was included; states that the wind report is incorrect; and expresses concern regarding impacts to freeways, homes, and car accidents associated with wind.

See response to I3-2, above. In addition, please refer to Global Response GR1, Air Flow Analysis.

I10-3 The commenter expresses concern regarding the presence of monarch butterfly habitat, stated in the comment letter to be present in eucalyptus trees on the East Side of the freeway; the Migratory Bird Treaty Act; and endangered plant species. The commenter believes that the project does not comply with federal law regarding monarch butterflies and the Migratory Bird Treaty Act.

See response I2-1, above.

I10-4 The commenter expresses concern regarding endangered plant species.

See response I2-2, above.

I10-5 The commenter expresses general opposition to the project and economic concerns. The comment does not pertain to the adequacy of the EIR. No response is required.

I10-6 The commenter expresses concern that the proposed trail is not compliant with the ADA and expresses economic concerns associated with the project.

See response I5-6, above.

I10-7 The commenter expresses concern regarding the Airflow Analysis provided as part of the Draft EIR and states that this Airflow Analysis does not correspond to the project. In addition, the comment expresses economic concerns associated with proposed cut slopes, and concerns regarding the monarch butterfly.

Please refer to Global Response GR1, Air Flow Analysis; Global Response GR2, Landform Modification; and response I2-1 regarding monarch butterfly impacts.

I10-8 The commenter expresses general opposition to the project. The City acknowledges the comment and notes that it expresses opposition to the proposed project, but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I10-9 The commenter expresses support for Alternative 4, but states that Alternative 4 is still not ADAcompliant through the parking lot.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-78
The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. Regarding ADA compliance, see response I5-6, above. Alternative 4 would not route any portion of the trail through the Rincon Beach County Park parking lot, instead aligning the path along the northern side of the parking lot, and achieving a trail slope that is ADA compliant. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I10-10 The commenter states that the project is not in compliance with federal law and states that the project will not meet objectives or finances.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

Regarding the commenter’s previous concerns associated with compliance with federal law regarding monarch butterflies and the Migratory Bird Treaty Act, please see response I2-1, above. No further response is required.

Comment Letter I11
I11-1
I11-2
I11-3
I11-4
I11-5

I11-6
I11-6
Cont.

I11-6
Cont.

I11-6
Cont.

I11-6
Cont.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-80
Response to Comment Letter I11
Ottis Gillespie
April 21, 2021
I11-1 The commenter states that the April 13, 2021 presentation omitted details regarding construction and costs. The commenter asks if various components associated with construction of the project would occur within the two-year construction window.

Regarding the construction window, as stated in Section 3.2.4, it was assumed that construction would commence in March 20221 and would be completed by approximately March 2024. This construction schedule includes site preparation (2 months); grading (11 months); trail construction (5 months); bridge construction (1 month); paving (2 months); and architectural Coating (1 month).

Regarding the commenter’s economic concerns, the City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I11-2 The comment pertains to Illustrations 4, 5, and 6 of the Draft EIR, which have been included in this letter (see comments I11-6). The commenter asks what the complete proposed trail would look like and expresses economic concerns regarding the proposed project. The commenter suggests implementation of traffic barriers to protect cyclists and asks if the Southbound U.S. 101 off ramp would be realigned to account for the proposed project.

Visual simulations of the proposed project have been included as Figure 3.1-2 of the Draft EIR.

Regarding the commenter’s economic concerns, the City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. The City also acknowledges and appreciates the commenter’s suggestions regarding traffic barriers and notes there are no plans for realignment of the Southbound U.S. 101 off ramp at this time. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I11-3 The comment expresses concern regarding lack of an ocean view associated with a portion of Alternative 4.

The City acknowledges that a portion of the trail proposed under Alternative 4 would not have an ocean view. Although it could affect Alternative 4’s ability to meet all or most project objectives, this does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I11-4 The comment expresses concern regarding the loss of wind and velocity associated with the proposed project.
1 The analysis assumes a construction start date of March 2022, which represents the earliest date construction would initiate.

Assuming the earliest start date for construction represents the worst-case scenario for criteria air pollutant emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-81
See Global Response GR1, Air Flow Analysis.

I11-5 The commenter states that they will provide additional comments during the public review period.

The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I11-6 The comment provides illustrations of several existing benches used informally as a pedestrian path and excerpts of the Draft EIR. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. No further response is required or provided.

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Hello Nick, having just heard the good news, I just wanted to extend my heartfelt thanks to you and the environmental review committee for choosing the bike path extension alternative which allows both paragliding the Little Diamondhead bluff and biking or walking on the bike path to coexist, a very wise choice indeed. Many thanks to you all.

Sent from my iPad
Comment Letter I12
I12-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-83
Response to Comment Letter I12
Desmond
April 23, 2021
I12-1 The commenter expresses support for Alternative 4 and would like to thank the City for choosing this alternative. As a clarification, the Environmental Review Committee voted to recommend approval of the EIR to the Planning Commission with revisions, and expressed a preference for Alternative 4. This vote by the ERC does not constitute a decision for the City to move forward on approval of the project or any of the alternatives in the EIR. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. It should be noted that the City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided. 1 **EXTERNAL EMAIL**
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Hi Nick,
Writing again to let you know I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation. We'd be thrilled to see the city also support this compromise solution.

Thank you!
--
Caleb
On Wed, Nov 25, 2020, 3:25 PM Caleb Phillips <[email protected]> wrote:

Hi Nick,
I live in Colorado but visit Santa Barbara to paraglide. It's where I learned, and is one of the best places for the sport in the country. The Bates beach ridge is a world class location for ridge soaring. A bike path is a great addition to the area and would be enjoyed by many, but there certainly must be a way to add a bike path and save this renowned free flying site? Appreciate your consideration and thanks for recieving input from the community.

Cheers,
Caleb Phillips
Comment Letter I13
I13-1
I13-2
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-85
Response to Comment Letter I13
Caleb Phillips
April 23, 2021
I13-1 The commenter expresses support for Alternative 4 and would like to thank the City for choosing this alternative. As a clarification, the Environmental Review Committee voted to recommend approval of the EIR to the Planning Commission with revisions, and expressed a preference for Alternative 4. This vote by the ERC does not constitute a decision for the City to move forward on approval of the project or any of the alternatives in the EIR. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. It should be noted that the City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided. 1 **EXTERNAL EMAIL**
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Good morning Nick,
Mike Hilbreath here. I am an avid hang gliding pilot and have frequented the Bates flying site in the past. I have stayed local and spent money at the local restaurants and businesses. I feel that the Bates Flying Site could be preserved, and the cycling community could be served with proper design of the changes to the Bates Site. And, Carpinteria would retain a facility that brings in revenue to the city and the business people who live and work in Carpinteria.

If you would like to discuss this subject more, I could be available at any time. Thank you Nick. ‐
Best regards,
Michael
Comment Letter I14
I14-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-87
Response to Comment Letter I14
Michael Hilbreath
April 23, 2021
I14-1 The City acknowledges the comment and notes that it expresses general opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

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Good morning,
I appreciate the work that the city is attempting to do to put in a new bike path. I realize that planning this is a lot of work and I appreciate the work on this to help bikers. However, I would like the city to follow the recommendation of the Environmental Review committee to use Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.

Free flight is a very special sport that does not have a ton of locations where it can be done. Biking on the other hand can be done basically anywhere. Please do not destroy the coastal soaring site with the initial bike path route.

Coastal soaring sites in California draw thousands of pilots from all over the globe who want to experience the magical costal soaring sites. It would be unwise to destroy this form of tourism and reduce the cash inflows to the city and reduce the business that soaring tourists bring.

Please follow the recommendation for Alternate 4 and preserve free flight soaring at Bates! Sincerely,
Brandon Stringham
Comment Letter I15
I15-1
I15-2
I15-3
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-89
Response to Comment Letter I15
Brandon Stringham
April 23, 2021
I15-1 The commenter expresses appreciation to the City regarding planning a new bike path and expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I15-2 The commenter expresses the importance of free flight and expresses general opposition towards the proposed project. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I15-3 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

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Dear Nick,
The draft EIR for the Rincon Trail Project dismisses the significant impact of the project on recreation. Pilots leave no trace and have been using the ridge as-is for decades. The extensive earth moving on the south face of the bluff will significantly change wind flow and cancel flying.

Rather than reach out to any local pilots, the City of Carpinteria paid for a wind study that estimates a maximum 30% reduction in velocity - and then asserts that 30% is insignificant. That magnitude of change is quite significant to those who use the ridge for soaring.

The City is brushing aside pilots to muscle through a project involving soil removal, concrete and chain link fences, all to maintain an ocean view for cyclists for a mere few tenths of a mile. The draft EIR downplays the blight this will create for millions of motorists.

A bike path on the north side of Bates bluff would safely link the bike paths and preserve free flight. I agree with the Environmental Review Committee’s decision to recommend Alternative 4.

It seems a big waste of taxpayer funds to try and prop up a lot more concrete on the south facing side of the Bates bluff, and downright unnecessary to destroy a coastal soaring site.

Coastal soaring at Bates makes Carpinteria truly special and unique. I'm writing to express hopes for a compromise on an ocean view for the short stretch of the bike path extending along Bates bluff, and for the City to proceed with Alternative 4.

Thank you for your time and consideration.

Sincerely,
Jamie Bishop, Santa Barbara Soaring Association member, Santa Barbara resident, and cyclist Comment Letter I16
I16-1
I16-2
I16-3
I16-4
I16-5
I16-6
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-91
Response to Comment Letter I16
Jamie Bishop
April 23, 2021
I16-1 The commenter states that the Draft EIR dismisses significant impacts to recreation resulting from wind flow. The proposed project’s impacts to recreation, associated with wind flow, have been analyzed in Section 3.11. As discussed in this section, impacts to recreation would be less than significant. In addition, see Global Response GR1.

I16-2 The commenter states that the maximum 30 percent reduction in velocity is significant to soaring.

See Global Response GR1.

I16-3 The comment expresses general opposition towards the proposed project. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR.

No further response is required or provided.

I16-4 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I16-5 The comment expresses concern regarding tax-payer funds to be expended on construction and maintenance associated with the proposed project. The City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. No further response is required or provided.

I16-6 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

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Dear Nick, et.al.,
Thank you for your detailed study and continued planning of the bike path reroute along Bates Ridge.  I am a long time hang‐glider pilot and recently signed the petition to maintain Bates Ridge in a manner to preserve the hang‐gliding activities that have been enjoyed there for decades.  I hope you appreciate the special place this is, and support it's preservation.

Hang‐gliding is suffering a loss of flying sites all over the country.

Mainly this is due to development around the sites and the associated loss of landing zones and access to launches.  In some situations, it is a result of changing geography and impact to wind conditions.  Please help preserve the few remaining sites.  This is true for special sites like Bates Ridge.

Thank you,
Wayne Michelsen
USHPA pilot #72939
Comment Letter I17
I17-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-93
Response to Comment Letter I17
Wayne Michelsen
April 23, 2021
I17-1 The comment expresses general opposition towards the proposed project. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR.

No further response is required or provided.

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I am a paraglider pilot who lives in Los Angeles (Woodland Hills, to be exact). I have been coming up to Bates to fly for twenty years. I appreciate your hard work on improving this area for cyclists, as I am also a cyclist who rides here. I would absolutely prefer to use a bike path on the north side of Bates bluff (Alternate 4), as recommended by the Environmental Review Committee. I believe this will best serve everyone's needs.

Sincerely,
Randall McCormick
Comment Letter I18
I18-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-95
Response to Comment Letter I18
Randall McCormick
April 23, 2021
I18-1 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

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The new bike trail will be great, but it needs to be alternative number 4 please. The completely inaccurate assessment of what will occur with airflow, and dismissal of our recreational flying use of that sight will forever negatively impact our flying future there. Please consider us, the flying community. We have a huge stake in this. And please reconsider which plan you move forward with, and choose an alternative which does not destroy our flight park.

Thank you for your consideration.

Mike Harrington
Activities Director
SBSA
Mike Harrington
[email protected]
Cell 805‐452‐6162
Store 805‐962‐9511
Fax 805‐962‐7290
Comment Letter I19
I19-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-97
Response to Comment Letter I19
Mike Harrington
April 23, 2021
I19-1 The commenter expresses support for Alternative 4 and also provides the opinion that the air flow analysis is completely inaccurate.

The City acknowledges the commenter’s preference for Alternative 4; the City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided. With regard to the comment on accuracy of the air flow analysis, please refer to global response GR1. 1 **EXTERNAL EMAIL**
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Hello thank you for taking the time to consider with care your impactful work plans. I signed a petition to preserve Bates Ridge that has over 2,000 signatures and 60 comments.

It’s actually an important matter to get right for our future.

The communities can complement each other .

I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.

I don’t understand why the City is planning alienate the soaring community.

It seems like the EIR draft authors refuse to listen to the pilots who have been recreating at Bates for over 40 years.

Coastal soaring at Bates makes Carpinteria truly special and unique, don’t diminish that.

Let’s build a better path. I believe building a bike path on the North side of Bates bluff is best for all recreational users, it is a safer, more direct path for cyclists.

It also keeps picketing protests off your news cycle.

Please be reasonable.

Save Bates!
Comment Letter I20
I20-1
I20-2
I20-3
I20-4
Adam Zerkel
(213)924-4693
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-99
Response to Comment Letter I20
Adam Zerkel
April 23, 2021
I20-1 The commenter thanks the City for consideration of the commenters’ petitions.

The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I20-2 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I20-3 The commenter states that the City is alienating the soaring community by not giving consideration to statements about the history of soaring at the site.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The recreation section of the Draft EIR (3.11) describes existing soaring activities above the project alignment, including an indication that these soaring activities have occurred over a substantial time span. No further response is required or provided.

I20-4 The commenter expresses support for Alternative 4. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

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Hello again Nick,
Just saw this on youtube. Hard to "imagine," that this route, with a Pacific Ocean View exists. https://youtu.be/s_bm_VFaPfM
Incredible!
Ottis Gillespie
Comment Letter I21
I21-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-101
Response to Comment Letter I21
Ottis Gillespie
April 23, 2021
I21-1 The commenter provides a link to a video. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

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Hello Nick!
I am one of the people who is concerned about the development the city of Carpinteria is planning for the Bates Bluff area.  I wanted to reiterate my support for preserving this area and moving the proposed bike path out closer to the highway.  Below are some of my thoughts and concerns on this topic.  I appreciate the work that has gone into planning this bike trail, but I want to see it improved.  I am devastated that the Draft EIR considers the impact to my flying recreation to be ‘insignificant’.  I signed a petition to preserve Bates Ridge that now has 2,000 signatures and over 60 comments.  I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.  I believe building a bike path on the North side of Bates Bluff is best for all recreational users, as it is a safer, more direct path for cyclists, giving them a path that avoids the crowded, steep, and dangerous Rincon parking lot.
 I am a cyclist and want a direct route on the North side, rather than an Ocean view. Seeing the Ocean shouldn't be a requirement for this project because I get plenty of views along the whole bike path to Ventura.  You are concerned the current plan will require maintenance against rising seas as it is being built near an eroding seawall. Relocating to the other side of the ridge is financially responsible given this concern.  I appreciate the wind study done by the engineers, however this study specifically states that it is based on theory and not intended for this purpose. Even if accurate, 20‐30% loss of lift is very significant to me, especially on average wind days where lighter wind flow will be exponentially impacted by this project.  I feel its inappropriate for the EIR to discuss free flight rules or launches, as this is outside the scope of the document and project.  The focus of the EIR and CEQA is preserving recreation at the project site.  I don’t understand why the City continues to brush me aside and has failed to reach out to the soaring community. There are inaccurate statements in the Draft EIR because the authors refuse to listen to the pilots who have been recreating at Bates for over 40 years. Let’s build a better path together.  Coastal soaring at Bates makes Carpinteria truly special and unique.  I can bike almost anywhere, but I travel to Carp for the flying at Bates and spend my money there.  I have spent money in Carpinteria restaurants, coffee shops, grocery stores, and motels, due to the flying there.

Many thanks for your favorable consideration on this issue! Regards,
Comment Letter I22
I22-1
I22-2
I22-3
I22-4
I22-5
I22-6
I22-7
I22-8
I22-9
I22-10
Robin Cushman

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-103
Response to Comment Letter I22
Robin Cushman
April 24, 2021
I22-1 The City acknowledges the comment and notes that it expresses opposition to the proposed project and support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I22-2 The comment expresses concern that impacts to recreation associated with the proposed project were determined to be insignificant in the Draft EIR.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I22-3 The comment references the petition to preserve Bates Ridge.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided
I22-4 The City acknowledges the comment and notes that it expresses support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I22-5 The commenter states that an ocean view should not be a requirement for the project and provides support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I22-6 The commenter expresses concern regarding the impacts rising sea level and erosion would have on the proposed project and states that Alternative 4 is more financially responsible.

The sea level rise comment is acknowledged; the hydrology section of the Draft EIR (3.8) discusses impacts associated with potential sea level rise, while the Alternatives Section (6.0) addresses such impacts for each of the identified project alternatives. Regarding the commenter’s economic concerns, the City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. No further response is required or provided.

I22-7 The commenter expresses concern regarding 20-30 percent loss of wind and states that this is significant.

See Global Response GR1.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-104
I22-8 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and states the focus of the EIR should be to preserve recreation.

See Global Response GR1.

I22-9 The commenter states that the City has failed to reach out to the soaring community, resulting in inaccurate statements in the Draft EIR.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. Therefore, no further response is required or provided.

I22-10 The commenter explains the uniqueness of the project site with respect to existing soaring opportunities afforded above the project trail alignment.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided. 1 **EXTERNAL EMAIL**
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Dear Nick,
I appreciate the work that has gone into planning this bike trail, but want to see it improved and am in shock how the flying community is being ignored during this process. I travel from Fresno to fly this site and spend money in YOUR community.

If flying becomes interrupted or impeded, I will choose to fly somewhere else, thus taking my money I spend in your area elsewhere.

The wind study specifically states that it is based on theory and not intended for this purpose. Even if accurate, 20-30% loss of lift is very significant, especially on average wind days where lighter wind flow will be exponentially impacted by this project.

I don’t understand why the City continues to brush me aside and has failed to reach out to the soaring community. There are inaccurate statements in the Draft EIR because the authors refuse to listen to the pilots who have been recreating at Bates for over 40 years. Let’s build a better path together.

Coastal soaring at Bates makes Carpinteria truly special and unique, I can bike almost anywhere, but I travel to Carp for the flying at Bates and spend my money there.

Please consider this in your decision making process.

Ryan Soares
E.D.G.E. Challenge Course Director
Department of Recreation Administration
California State University, Fresno
5310 North Campus Drive m/s PH103
Fresno, CA 93740-8019

Phone: 559-301-6356
Fax: 559-278-5267
Email: [email protected]
Web site and Video: http://www.fresnostate.edu/chhs/recreation/about/edge/index.html Facebook: www.facebook.com/fresnostaterecadmin
Comment Letter I23
I23-1
I23-2
I23-3
I23-4
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-106
Response to Comment Letter I23
Ryan Soares
April 24, 2021
I23-1 The commenter expresses appreciation to the City regarding planning a new bike path; states they would like to see improvements; expresses concerns regarding involvement of the soaring community; and states they will not spend their money in the City if the project were to be approved.

The City acknowledges the comment as an introduction to comments that follow. Regarding economic concerns, the City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. Regarding involvement of the soaring community, the City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I23-2 The commenter expresses concern regarding 20-30 percent loss of wind and states that this is significant.

See Global Response GR1.

I23-3 The commenter states that the City has failed to reach out to the soaring community, resulting in inaccurate statements in the Draft EIR. The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. Therefore, no further response is required or provided.

I23-4 The commenter explains the uniqueness of the project site with respect to existing soaring opportunities afforded above the project alignment.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided. 1 **EXTERNAL EMAIL**
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This email contains my overall comments regarding the Carpinteria Rincon Trail Project Draft EIR of March, 2021 and are provided subsequently to the Carpinteria Environmental Review Committee (ERC) meeting of April 13, 2021.

As a Carpinteria resident, bluffs user, active cyclist, and inactive paraglide pilot, I support the ERC's recommendation of Alternative Four as the preferred trail alternative. It has the least impact to recreational soaring, eliminates massive beachside earthworks, eliminates installation of beachside storm drainage and piping, and removes the resultant permanent visual impacts of such to views of the area from viewpoints near the Harbor Seal Sanctuary RR crossing and the Seal Sanctuary overlook, and eliminates potential bicycle/pedestrian/vehicle conflicts in the Rincon County Park parking lot by routing cyclists directly to Bates Rd. It also provides additional security to the park in terms of eliminating access and resulting potential vandalism from direct after-hours bike-to-park trail access. In terms of lifecycle costs, it is likely that the cost of maintaining the cycling trail within the 101 corridor would be much less than maintaining the trail along the southern beachside bluffs exposed to wind and rainstorm erosion.

I do understand that the primary purpose of the original Alternative 2 and the modified "less cut/fill" Alternative 2 was to provide "...a sweeping view of the ocean, beach, and Channel Islands'', and that cycling within the Highway 101 Corridor would not be nearly as pleasant and not much of an "Instagram" photo op except from the bridge crossing. It is, however, a relatively short section of highway-adjacent trail on a longer trail that to the East/South runs almost entirely along the ocean to Ventura. Views are still available from the Rincon Bluffs, and of course from Rincon Beach Park for those cyclists who care to stop to seek them out.

While it is unfortunate that the Santa Barbara Soaring Association and local pilots were not initially contacted and consulted in the preparation of the EIR, I think that their concerns have been heard and the City now has a better understanding of the impacts of modification of the bluffs having the real potential to eliminate this recreational soaring site that is regarded as a jewel of flying along the California coast. I am personally aware of this site's reputation in the soaring community and have met many pilots at the launch site who have come specifically to Carpinteria and this site to practice their skills and learn from and enjoy the company of experienced local pilots who provide encouragement and support to the soaring community and openly answer questions from curious visitors.

One small concern that will have to be addressed with Alternative Four is that there will be a strong desire for people to develop an informal short-cut trail from either end of the bridge down Comment Letter I24
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2 to the existing RR/ocean cutbank bluff trail. Both pedestrians and more fearless mountain bikers will likely want to use that short-cut to access the Rincon Beach parking lot and facilities. The trail near the bridge will need to be designed and built to dissuade that behavior.

Alternative Four has some great potential for creative, inviting design that would mitigate the 101 corridor downsides. Even without the direct ocean and beach views on this particular trail segment, it is still a wonderful addition to the area and the coastal bike path. Kudos to the City of Carpinteria for bringing the vision of the trail to a reality while threading the needle in this complex multi-faceted project.
/s/ Jon Lewis, Carpinteria CA
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Cont.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-108
Response to Comment Letter I24
Jon Lewis
April 24, 2021
I24-1 The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I24-2 The comment provides support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I24-3 The comment provides an overview of Alternative 2 and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I24-4 The commenter states that the soaring community was not initially contacted but states they believe the City has heard the soaring community’s concerns. The comment also provides background on the project site, as it relates to soaring activities.

The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I24-5 The commenter states that, with implementation of Alternative 4, people will want to develop informal shortcuts and suggests the trail is designed to dissuade that behavior.

The City appreciates the commenter’s recommendations. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I24-6 The commenter expresses support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.
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Dear Mr. Bobroff:

Is it true the City is working to override the decision of the Environmental Review Committee's decision regarding Bates?
I fully agree with the ERC's decision to recommend alternate 4, building on the north side of Bates Ridge, preserving the soaring recreation.

It's outside the scope of the EIR to discuss free flight rules or launches. Shouldn't the focus be preserving recreation at the project site?
Bates makes Carpinteria unique because of coastal soaring. I can bike anywhere.

Sincerely,
Betty Winholtz
Comment Letter I25
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-110
Response to Comment Letter I25
Betty Winholtz
April 24, 2021
I25-1 The commenter asks if the City is working to override the decision of the Environmental Review Committee regarding Bates.

The commenter is seeking verification of whether the City Planning Department will follow the recommendation of the ERC to implement Alternative 4 for approval of the Rincon Trail project. The City acknowledges receipt of the comment; the City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I25-2 The commenter expresses support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I25-3 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and states the focus of the EIR should be to preserve recreation.

See global response GR1.

I25-4 The commenter explains the uniqueness of the project site with respect to the existing soaring opportunities it affords.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided. 1 **EXTERNAL EMAIL**
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Greetings,
Firstly; thank you for the fantastic work you've been doing to build infrastructure for our communities. We know it's never straightforward. I'm reaching out to suggest strong reconsideration by touching on a couple of points regarding the Bates bike path project.

My name is Riebeeck van Niekerk and I'm a relatively new paragliding pilot. I've spent time going through some of the public information and EIR briefly covered by DUDEK and the engineering teams overseeing the development work for the Bates bike path.

My ultimate input on the matter echoes much of what you are probably hearing from the rest of the Flying community. Please consider the following points below:

1. Significance of Impact: I am a mechanical engineer by trade and from the pure perspective being both a cyclist and a pilot; I see quite a few shortgivings with the primary design option/options presented over zoom a couple weeks ago. Alternative 4 should be given the priority OR another alternative should be engineered to ensure no impact is had on recreational flying in the area. A designation of 'no significant impact' as far as recreational activities are concerned stems from the lack of engagement with the flying community and from either a lack of insufficient design, engineering, or worse, both.

2. Lift Technicals - From a technical standpoint I have serious reservations about the reported average "20-30% change in wind speed" as well as the reported loss of lift/wind speed/venturi effect based on changing slope gradient. I would like to see the CFD models used to report those average changes in wind speed. I would like to request plan/side/front/geometric projections for vector distribution plots of wind speed for varying wind direction (60 deg to 290 deg would be sufficient if you don't have a full 360 CFD/EFA study) and wind velocity for all design alternatives. o If a full CFD/EFA analysis of the terrain was not conducted, I would strongly advise this be done before any considerations are made.
o Even if that reported average value is accurate; how was the determination made that this has 'no significant effect'?
o Wind velocity has a squared (quadratic) relationship to drag force which ultimately holds a relationship to lift and therefore a small change in wind velocity has a significant impact on lift. The point here is that if; 20-30% reduction is being reported, this will have a massive/significant/noticeable impact on lift and our ability to practice our sport and draw in eco/adventure tourism dollars (discussed more in point 4 below).

3. Cyclist Sentiment - We have surveyed over 100 cyclists who travel through the area regularly somewhere around 2%-3% responded with a desire to have an ocean view on that stretch. The rest just want a direct route - there's plenty of ocean views on the majority of the other sections.

Comment Letter I26
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2 4. Tourism and Economics - from a pure travel and tourism perspective; there's a huge international community of pilots who specifically travel to this area each year to specifically paraglide at bates and other areas around the Ventura/Santa Barbara area.

5. Flying Community - I'm surprised that in a first world country we still have to point this out but; the engineering/development teams should be working together with the flying community to come up with a workable solution. We stand ready to lean in to provide SME input on the matter but have yet to hear a word from anyone involved with development of this project.

6. Heritage - We have few places to practice our sport and this is one that is world renowned for being a classic ridge soaring location. This project has the potential to seriously ruin this site for flying forever and it would be a national shame within our community and for our wider global community abroad.

Again we understand the challenges and my main expectation is that these very real implications are properly considered; and efforts are made to reach out and work with the flying community to converge on a workable solution that will benefit everyone.

Thank you for hearing me out and look forward to seeing where we can assist.

Kind Regards,
Riebeeck van Niekerk
+1.832.235.0531
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Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-112
Response to Comment Letter I26
Riebeeck van Niekerk
April 25, 2021
I26-1 The comment expresses appreciation to the City regarding planning a new bike path, provides an introduction for the comments to follow, and provides personal background on the commenter.

The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I26-2 The commenter expresses support for Alternative 4 and states that the significance determination for recreational impacts stems from lack of engagement with the flying community and the lack of sufficient design, engineering, or both.

Regarding Alternative 4, the City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. Regarding recreational impacts, the City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise any specific issue related to the adequacy of any particular section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I26-3 The commenter expresses concern regarding the 30 percent change in wind speed and requests computational fluid dynamics (CFD) models as well as plan/side/front/geometric projections for vector distribution plots of wind speed. Fluid dynamics is the study of the motion of fluids, usually in the presence of an object. Typical fluid flows of interest to engineers and scientist include flow in pipes, through engines, and around objects, such as buildings, automobiles, and airplanes.

Computational fluid dynamics (CFD) is the study of these flows using a numerical approach. The commenter advises the preparation of a full CFD study. The commenter asks for clarification of why impacts to recreation were considered not significant and states that a small change in wind velocity would have a significant impact on lift.

See Global Response GR1. As described in the airflow analysis report, the analysis provided predictions based on existing data from field measurements of air flow over large-scale topographic features, from aerodynamic experiments conducted with scaled models in wind tunnels, from engineering standards for wind stress on buildings, and from published literature addressing wind flow over topography as related to soaring activities.

Through careful examination of this existing research, appropriate physically-based equations have been applied in order to predict the reduction in horizontal and vertical wind velocities from modification of the bluff face as proposed. The range in predicted wind velocity reduction represents the application of two modeling approaches, one using the mean slope angle across the entire slope face, and the other employing the mean slope angle for the upper portion of the slope. The EIR uses the greater predicted wind velocity reduction for the project and for Alternative 3, as the more conservative conclusion.

For context, Computational Fluid Dynamics (CFD) modeling is typically employed in engineering to address critical operational parameters during design development of equipment, systems and Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-113
structures. CFD provides results that are most reliable when examining flow over streamlined and smooth objects, such as an aircraft wing. CFD also requires numerous assumptions, including choices of computational grid size, boundary conditions, and turbulence modeling; to avoid erroneous conclusions, CFD requires careful validation against experimental measurement when applied to a new problem. Validation studies have shown that CFD of complex terrain can provide inaccurate predictions under some atmospheric conditions (see for example El Bahlouli et al. 2020). Relatively more reliable computational approaches (such as Large Eddy Simulation, LES) require vastly greater computational power, and are currently in the domain of research rather than commercial use (see Pirooz & Flay 2018). Due to the scale and complexity of the ocean bluffs along the project alignment, development of a CFD model to evaluate air flow conditions from project changes was not considered suitable or cost-effective.

In order to consider a worst-case scenario, the air flow analysis is based upon the grading plan cross-section of the bluff face with the greatest alteration from existing slope profile to projectresultant slope. The air flow analysis examines incoming horizontal wind that is perpendicular to the bluff crest. Although numerous effects are considered, it may be helpful to recap here the two main effects, namely: (1) amplification in wind magnitude as the flow is constrained to pass over the bluff (the “Venturi” mentioned by the question), and (2) the induction of a vertical wind component as the air must flow at an upward angle over the bluff.

Wind tunnel experiments and field measurements on bluffs have shown that, as long as the mean slope remains above approximately 30 degrees, the amplification in wind magnitude (combining both horizontal and vertical components) will not change significantly (see for example Bowen & Lindley 1977; Bowen 1980). However, the extent and location of the Venturi region, as well as the vertical component of the wind will of course change. The simplest estimate of the vertical velocity component is obtained by multiplying the wind magnitude by the sine of the bluff angle; this approach is used for example in the book on soaring by Pagen (1992), to compile his figure 139.

More refined methods of estimation are described in the Air Flow Analysis report. (Luzzatto-Feliz, January 2021).

Reductions in the vertical wind speed associated with changes to the topography are expected to be maximal in the perpendicular wind scenario. This is due to the fact that, when the wind is at a yaw angle to the bluff crest, the bluff will deflect it further along the crosswind direction, implying that the flow that travels over the bluff will be reduced. This effect will decrease ridge lift, as shown by the wind tunnel experiments of Crawley & Schmanske (1994); for an illustration in the soaring literature, see p. 336 of Pagen (2001).

Gentler slopes induce a smaller crossflow deflection, and therefore produce a smaller decrease in ridge lift through this crossflow mechanism (this is also illustrated in fig. 142 of Pagen 1992).

Percentage differences between the vertical wind velocities associated with the existing versus proposed bluff profiles would therefore also be smaller than for the analyzed condition with wind perpendicular to the bluff face. Finally, it should be noted that lift for aircraft results from the horizontal wind speed flowing over the wing (or the sail), and that horizontal wind speed over the bluff top is not anticipated to be altered by the proposed regrading. Consequently, horizontal wind conditions that support launching of hang-gliders and para-gliders adjacent to the project alignment would not be affected by the project.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-114
The wind flow analysis and EIR discussion include no attempts to estimate future climatic conditions, including localized wind patterns that could influence the number of days on an annual basis when air flow conditions above the property would support soaring activities, for either the existing bluff profile or those resultant from the proposed project or Alternative 3.

I26-4 The commenter presents the results of a survey stating that cyclists don’t mind not having an ocean view on a certain stretch.

It is assumed that this comment provides support for Alternative 4, which would not include an ocean view for a small stretch. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I26-5 The comment relates to travel and tourism associated with the existing project site.

The City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I26-6 The commenter suggests that the engineering/development teams should be working together with the flying community and states that they have yet to hear from anyone involved in the project.

The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I26-7 The comment explains the importance of the site when it comes to soaring. The City acknowledges the comment and notes that it expresses opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I26-8 The commenter would like to see all implications properly considered and efforts made to reach out and work with the flying community.

The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. Regarding coordination with the soaring community, please refer to response I26-6. No further response is required or provided.
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Hi Nick,
Thanks for your hard work in overseeing the planning and designing of the Rincon Trail. I know it's difficult coordinating with all the stakeholders involved in this complex project. I'm hopeful we can find a solution for everyone.

As a cyclist and a pilot, I believe we can build a better bike path together. The first step is considering flying recreation to be significant in the EIR, and addressing the outpouring of concern from the community about losing this recreation. On the day the Draft EIR was released for public comment, we started a petition to preserve the ridge at Bates which now has over 2,000 signatures and more than 60 comments. The metrics and comments are provided below for public record. This clearly demonstrates significant recreation under CEQA.

I was heartened to hear the Environmental Review Committee’s decision to recommend Alternate 4. Building on the North side of Bates ridge will save soaring at Bates and create a safer, more direct path for cyclists that avoids the crowded and steep Rinon parking lot. Seeing the Ocean shouldn't be a requirement for this project because there are plenty of views along the way like the whole bike path to Ventura.

I appreciate the wind study, however, this document specifically states that it is based on theory and not intended for this purpose. Even if there is a correlation with reality, 20-30% loss of lift is very significant for pilots, especially on average wind days where the vertical lift component of lighter winds will be exponentially impacted by the benches and grades of this project. There are many days when the existence of this ridge is the sole reason pilots are able to maintain flight. It is the last natural remaining feature in this corridor and a truly unique recreational area that should be protected because it makes Carpinteria special.

I believe the goal of the EIR is to address the impacts of the project, including a review of how recreation will be changed. Under CEQA, all recreation is valued equally if it exists. It is inappropriate for the EIR to impose judgements on recreational users or analyze rules governing their sport or how they gain access. All of these things are outside of the scope of the document and the project itself. Why does the EIR discuss flying rules, launch locations, and wing practices? Not only are these comments frequently inaccurate, something the Santa Barbara Soaring Association attempted to correct with a detailed letter submitted 8 months ago, but they are not relevant to preserving recreation. It seems the City is more concerned with marginalizing our recreation, repeating these vague technicalities, than supporting us. As a tax paying citizen of Carpinteria who moved here from across the country to paraglide, I don't understand why the City is ignoring this opportunity to save a special place and its continued recreation. When will the City start listening to the pilots who have been recreating here for over 40 years? Let's build a better bike path together and explore the possibilities of Alternate 4 on the North side of the ridge. Thank you!
Comment Letter I27
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2 Petition metrics and comments:

DAVID RAYBOURN
3 days ago
I can ride my bike anywhere but there are only a few special and rare places to participate in foot-launched Aviation.

If the Historic Launch at Bates cannot be saved, then an alternative site should be created just for hang gliding and paragliding as mitigation.

The Wright Bros. were Hang Glider Pilots!
0 Jeffrey Gritsch
3 days ago
I like flying there!!!
0 Howard Tarpey
4 days ago
Ridge soaring and flying non powered aircraft like paragliders requires these beautiful and unique sites to be able to fly. Since these type of craft were designed people have been enjoying the purest for of flight without interfering with the land. There flying sites are a geographical creation of nature taking hundreds of not thousands of years in their making. A bike path can be laid almost anywhere and anytime. Let’s preserve what nature has provided for us and build the bike path elsewhere. Thank you �� 0 I27-8
3 Bradley Whittemore
4 days ago
I support safe free flight and there are so few available today and don’t want to lose one. 0 Tanner McMullen
1 week ago
What a tremendous environmental insult to move over a quarter billion pounds of earth so bikers can agro-pass each other with a bit more ease. I learned how to fly at this site, I will be devastated if it's destroyed. 0 Robert Jacobs
2 weeks ago
Massively changing topography for allowing one recreational activity to occur in the area at the expense of the other doesn't make any sense, just let the land be as it is, preserve what is already beautiful and useful, we don't need to dig up this place!
0 James E. Stelzer
2 weeks ago
This isca greatly needed site
0 Aaron Sagin
2 weeks ago
Flying the CA coast is one of the greatest expressions of joy that exists 0 Jordan Zweig
2 weeks ago
Im signing this petition because I am a local who frequently recreates in the area and because I am passionate about conservation. This area and the recreation opportunities it represents are very important to me. 0 Jake Spoelstra
2 weeks ago
Paragliding is cool!
0 Charles Gieser
2 weeks ago
I am signing to protect this beautiful land
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4 0
Scott Ball
2 weeks ago
Please dont destroy this world class recreational resource 0 Kiernan O Donovan
2 weeks ago
Preserve free flight.
0 Ronit Corry
3 weeks ago
Please save Bates!!!
0 Maximilienne Giannelli
3 weeks ago
This is an awesome paragliding site that should be preserved. 0 James Stubbs
Mar 21, 2021
because flying!
0 Robin Lang
Mar 21, 2021
Too much of Florida has been lost, destoryed and replaced by much worse than a bike trail. However, digging up hundreds of thousand pounds of soil that will ruin airflow? Playing with mother earth in this manner has got to stop. Heck, I won't even pick up a rock in a rivier because I worry about disrupting the flow of water. We must be more responsible, less greedy with an aware ego. Good luck TJ! 0 Jack Klim
Mar 21, 2021
#savethebates
0 Kevin Lamkin
Mar 20, 2021
As a resident of Carpinteria, an avid Hang Glider and cyclist, I urge the City Of Carpinteria to do the right thing I27-8
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5 and preserve this priceless soaring site while still providing cyclists with a route through the bluffs. 0 Mary-Elizabeth Prosser
Mar 19, 2021
I want to protect natural watershed. This site is important to many people, too. 0 Andrzej Rusztowicz
Mar 18, 2021
I bike much more often than I paraglide, and we need more bike paths everywhere. But it's also very hard to find good paragliding sites and we should not have one at the cost of the other. Let's work together! 0 Steven Garman
Mar 16, 2021
This is important.
0 Carolyn LaDuke
Mar 16, 2021
For a friend
0 Lee Eisler
Mar 16, 2021
I love flying and I love bates beach. It's a very special place. Not only do the paragliders love it but people come to watch all the time. It's exciting and beautiful to everyone! It's one of the things that makes Carpinteria special!
0 Genese Izuno
Mar 16, 2021
There are tons of trails around Carpinteria. There is only one paragliding area. Please let them have the natural lift provided by Bates Ridge.
0 Adrien Spiegel
Mar 16, 2021
let's make our outdoors more accessible for all people participating in an assortment of different activities 0 Adam Zerkel
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6 Mar 15, 2021
Haven’t we paved enough?
why not a lower impact plan to support the current use community? If more development is important here for someone, who is that someone and what is the value of this project for them?
0 Alexander Hoffman
Mar 15, 2021
I grew up in this community and know how special it is to advocate for this. As an avid cyclist I see no need for more concrete to be poured ANYWHERE to make cycling paths, especially when they will damage the ecosystem so heavily. Animals depend on the shoreline for life, we depend on the living to live, the more you build the more you turn the living zones into dead zones. So Please Dont Build this!! 0 Patrick Blackburn
Mar 15, 2021
We need to do everything we can to preserve all existing foot launched flying sites in the U.S.!!! 0 Chien Dinh
Mar 15, 2021
Please keep Bates open.
0 Lawrence Chamblee
Mar 15, 2021
Development has gobbled up most of the historic hang gliding sites, leaving practically no place to enjoy our passion for flying. I love cycling too, but cycling opportunities are blossoming, while silent soaring sites disappear. Please reconsider this bike path plan so it doesn’t destroy a unique coastal flying site. 0 william hetzel
Mar 15, 2021
Bates is treasured flying site! Please keep it intact.
0 Josh Heater
Mar 15, 2021
Flying sites are very difficult to come by. I hope the bike route plans not negatively impact the flying site. 0 I27-8
Cont.
7 Randolph Ruffin
Mar 15, 2021
I love flying at Bates. There must be a way to make a bike path and not destroy the hill. 0 Keith Smith
Mar 15, 2021
I hate to see this awesome site lost when there are better optios. 0 Hugh Cartmill
Mar 15, 2021
There are better alternatives which will allow flying to continue. 0 topher mira
Mar 14, 2021
I'm a paragliding pilot and I support this
0 Scott Schoenfeld
Mar 14, 2021
I’m a Carp local and want to continue flying at one of the most beautiful coastal sites in CA. 0 John Fritsche
Mar 14, 2021
This is one of the few unique sites that make soaring hang gliders and paragliders possible in coastal California! 0 Colin Beach
Mar 14, 2021
Hang gliding as a sport is diminishing. We need to preserve the limited flying sites we still have 0 Judith Hutchinson
Mar 13, 2021
Please don't destroy this site.
0 Derek Mckee
Mar 13, 2021
Theres always another way and 40 years deserves respect I27-8
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8 0
Zachary Majors
Mar 13, 2021
When the conditions are good for flying at Bates, there are usually no other good options for that day. Bates is a treasure of a flying site and I usually spend money 8n Carpenteria after flying there. 0 karim salsbury
Mar 13, 2021
Would be a shame to close this
0 michael holden
Mar 13, 2021
I have always enjoyed the location, for surf, paddling, and zero construction/obstruction for its natural location.

My son and I have just now gotten into flying and had hoped to utilize this location. 0 Houser Ron
Mar 13, 2021
Ron Houser
0 Neal Michaelis
Mar 13, 2021
As a cyclist and pilot, it would be nice to have a solution that respects both pursuits. Please don’t destroy this amazing flying resource.
0 doria wosk
Mar 13, 2021
JUSTICE FOR WE THE PEOPLE. SAVE BATES-CARPINTERIA HISTORIC FLYING SITE 0 Warren Flatte
Mar 13, 2021
To help preserve free flight, especially when there are alternatives to explore 0 Bro Childs
Mar 13, 2021
As a Mtn biker and pilot I value both activists greatly. However, soaring sites in the air required a special I27-8
Cont.
9 combination of geography and airflow which can be rare to find. Please preserve this rare treasure, and relocate and/or redesign the Mtn bike trail that both activities may be enjoyed. 0 Norma Ryan
Mar 12, 2021
Please allow this beautiful sport to continue. To those of us traveling north up the coast it is the most awesome sight to see the paragliders and the hang gliders flying like butterflies above the bluff and welcoming us to Carpinteria. The surfers, the sunbathers, the people who just come to watch this amazing show of athletic achievement, all appreciate the beauty. Keep this area multi-use and if a better bike path needs to be built I’m sure the cyclists would be in favor.
0 Sandy Minitello
Mar 12, 2021
Sandy Minitello
0 Cyndia Zumpft
Mar 12, 2021
I want to fly there someday! It is a beautiful spot!
0 Harvey Levine
Mar 12, 2021
Everyone needs a chance follow their passion. And though I would not volunteer to soar, I enjoy the beauty created by those who do!
0 Alexander Tchourbanov
Mar 12, 2021
This site is unique and deserves preservation. So many flying sites in CA have been forever ruined by development.
0 Lincoln Kroll
Mar 12, 2021
Hang Gliding sites are rapidly disappearing across California. We need to preserve all remaining sites that are safe and accessible, for today and future pilots..
0 Gordon Cayce
Mar 12, 2021
In the late seventies Seagull Aircraft moved their factory from Santa Monica to Carpinteria. Their shop was I27-8
Cont.
10 located in the small industrial park literally minutes away fro Bates Road. We used Rincon Mt. for test flying new gliders, but Bates was one of our favorite sites. With the Seagull shop so close it felt like our personal site.

I spent many long hours waiting for the wind to come in off the ocean and spent many hours soaring with Tom Peghiny, Glenn Hackett, Paul Hobson, Tom Haddon, Darrell Bibby and so many great Santa Barbara pilots. It would be a great disappointment to lose this classic small site that has been flown for so many years. 0 Rick Warner
Mar 12, 2021
I want the Bates flying site preserved. Please design a bike path that does not impact the topographical features of this area.
0 Shirley Docken
Mar 12, 2021
I want to support keeping this unique topography as is. Other bike paths can be used. 0 Calvin Grier
Mar 12, 2021
We need to preserve the area for all recreational use, not just hiking and biking. 0 Kim Browder
Mar 12, 2021
This is a truly unique and rare site for paragliding pilots. Pilots come from all over the world to fly Bates...do cyclist? Save Bates...it is a treasure!!
0 Дмитрий Хайруллин
Mar 11, 2021
All sports are important! I believe there are plenty bike paths there. 0 Jennifer Lauritzen
Mar 11, 2021
Paragliding is a beautiful sport for both spectators and pilots. Ruining a historical recreational site for a bike path, especially when alternate bike path options exist, is irresponsible land management. 0 robert sporrer
Mar 11, 2021
This project will disrupt the airflow that make it possible to fly paragliders and hang gliders. There are other options
I27-8
Cont.
11 0
David Hunt
Mar 11, 2021
I travel frequently to Santa Barbara solely to paraglide and support efforts to keep this flying site and tourist income viable.
0 Daniel Redding
Mar 11, 2021
Super important site! Please keep it open for all!
0 Daniel Vallieres
Mar 11, 2021
Don’t lose this valuable site. It is part of what makes me want to drive down south for vacations 0 Vinay Shah
Mar 11, 2021
I live in Boulder, CO but I spend significant time in this area during the winter specifically for the flying. Bates offers a type of flying (ridge soaring) that is difficult to find in CO, and being able to practice here has helped me and others become better, safer pilots flying in an environment where we can safely build up flight hours. 1 Daniel Garcken
Mar 11, 2021
I want to preserve the flying site at Bates but also wish to see the bike bath be reimagined in a way that doesn't impact the flying at the site.
0 I27-8
Cont.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-116
Response to Comment Letter I27
Jeffrey A Longcor
April 25, 2021
I27-1 The comment expresses appreciation to the City regarding planning a new bike path, provides an introduction for the comments to follow, and provides personal background on the commenter.

The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I27-2 The comment expresses that, based on the petition to preserve the site that gained over 2,000 signatures and more than 60 comments, impacts to recreation should be considered significant under CEQA.

See Global Response GR1. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I27-3 The commenter expresses support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I27-4 The commenter expresses concern regarding the wind study and believes that 20-30 percent loss of wind should be considered significant.

See Global Response GR1.

I27-5 The commenter states that it is inappropriate for the EIR to impose judgements on recreational uses or analyze rules governing the sport or how they gain access.

Please see Global Response GR1 regarding the inclusion of soaring fundamentals, existing launch practices, and FAA regulations in the Recreation Section of the EIR. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I27-6 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and that this has been described incorrectly in the Draft EIR. The comment also provides general dissatisfaction with the City and the project.

Regarding the discussion of flight rules or launches, see Global Response GR1. In addition, the City acknowledges the comment and notes that it expresses the opinions of the commenter and general opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-117
I27-7 The City acknowledges the comment and notes that it expresses general opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I27-8 The commenter provides a sample of the approximately 2,000 responses to a survey they circulated regarding “preservation of the ridge at Bates.” The City acknowledges the survey responses submitted with the comment, and notes they expresses general opposition for the proposed project but do not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

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Hi Nick, I’m a Colorado native and have been  spending my winters here in SB I for some time now mostly because of the variety, and quality of the paragliding it offers. It’s a very special place with an amazing history of free flight. Bates is one of the top spots in the country for coastal soaring offering a very rare opportunity for the pilot to “climb out” in the lift where the wind sock is located and fly cross country south towards Ventura. I don’t know of any coastal sites in the US where paragliders and hangliders are that blessed! Kind of similar to surfing Rincon, it’s just that special. Thanks for reading Nick, I share the same feelings of many others that the history of free flight there should be saved and the bike path on the 101 side makes sense.

Cheers,
Jason Lombard
Comment Letter I28
I28-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-119
Response to Comment Letter I28
Jason Lombard
April 26, 2021
I28-1 The comment provides general background on the opportunities for recreation the project site provides for paragliders and hang gliders.

See Global Response GR1. The City acknowledges the comment and notes that it expresses general opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided. 1 **EXTERNAL EMAIL**
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4‐25‐2021
Thank you for the opportunity to comment on the draft EIR for the path.

It should by now be quite obvious to all that the plan to have the path on the ocean side of the main bluff will never be permitted, as there simply is no mitigation possible for the very significant impact to existing recreation.

The focus from this point forward should ONLY go towards some version of ALTERNATIVE 4 that does not remove any aspect of the south‐west or west area of the main bluff. Not transitioning to a more acceptable design NOW will only delay the permitting process and cost taxpayers more unnecessary expense.

Instead of just using the current design on the north side of the RR tracks for the start of alt 4, please re‐ design/engineer the alternative 4 concept to have the north side of the bridge closer to the freeway and then rotate the bridge about 10 degrees counter‐clockwise‐‐moving the south end of the bridge to the east.

Although the repositioning would likely require more substantial bridge supports to accommodate the slightly longer span on the cuts above the RR tracks if using the same length of pre‐fab bridge, moving the south‐side bridge terminus further to the east would result in a considerable reduction of the earthwork needed as compared to what is stated in the current EIR draft for alternative 4.

Please don’t be misled by the conclusions within the draft that are primarily derived from statements from the preceding MMD that are most likely from the input of just one person, the applicant.     Consider the reasons why public entities often save money and time when they contract with private planning/permitting services for projects that can be cumbersome.

Thank You,
John Greynald
805 886‐6160
Comment Letter I29
I29-1
I29-2
I29-3
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-121
Response to Comment Letter I29
John Greynald
April 26, 2021
I29-1 The commenter states that the project cannot be permitted as there is no mitigation possible for the very significant impact to recreation.

See Global Response GR1. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I29-2 The commenter expresses support for Alternative 4 over the proposed project but proposes certain revisions to the design of Alternative 4.

The City appreciates the commenter’s recommendations. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I29-3 The commenter states that the Draft EIR conclusions are derived from the previous MND that were based only on the opinions of the applicant.

It is assumed that the commenter is referencing the 2015 MND and the 2019 Subsequent MND, prepared for the proposed trail. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided. 1 **EXTERNAL EMAIL**
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Greetings,
My name is Ajay Rajamani and I am a local paraglider pilot and cyclist. Having biked the entire pacific coast from SF to LA, I really appreciate the effort to allow cyclists to keep off the highway between Carpinteria and Ventura. However, after attending the town hall meeting last week I strongly feel that Alternate 4 is the best plan to move forward with the project. That is, building the path on the north side of Bates Ridge to preserve freeflight and limit erosion damage to the cliff face.

While seeing the ocean is nice, there are already miles of oceanside bike paths between SB and Ventura, in particular immediately after the proposed extension there is ~4 miles of prime oceanside bike path from the Rincon parking lot to Mussel Shoals. I don't think it's worth destroying a nationally renowned flying site that attracts pilots from all over the country for less than 400m of additional seaside views. In addition, I am highly concerned over the erosion and construction impact of building on the south side, which would likely wash tons of soil and chemicals into the ocean.

Thank you for considering my comments. I hope we can arrive at a solution for this project that satisfies all user groups.
-Ajay Rajamani
Comment Letter I30
I30-1
I30-2
I30-3
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-123
Response to Comment Letter I30
Ajay Rajamani
April 26, 2021
I30-1 The commenter expresses support for Alternative 4. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I30-2 The commenter expresses concern regarding erosion and construction impacts of building on the south side, which could wash soils and chemicals into the ocean.

The proposed project’s impacts to erosion have been analyzed in Section 3.5.4. As discussed in this section, implementation of mitigation measure MM-GEO-3, which includes recommendations from the geotechnical report regarding slope construction, would reduce impacts to less than significant with mitigation. In addition, the project’s impacts to water quality have been analyzed in Section 3.8.4. As discussed in this section, with implementation of mitigation measures MM-WAT-1 through MM-WAT-5, potential project impacts to surface water quality would be reduced to less than significant. In addition, per Section 3.8.4, release of project storm drainage along the beach would not result in substantial erosion, as the introduction of impervious surfaces would be minimal compared to the overall project drainage area and the trail drainage will be divided into 6 separate outlets to minimize the discharge volume from any of the outlets.

I30-3 The commenter provides appreciation to the City for considering their comments. The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. No further response is required or provided.

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Hello Nick,
The current plans for the Carpinteria‐Rincon Trail project will impact paragliding and hang gliding in the Carpinteria, Santa Barbara and greater SoCal areas.  I am a representative of the paragliding and hang gliding community in Santa Barbara County, and myself and other members from this community were sad to find that the new plans for the trail will involve significantly cutting into Bates Ridge, which would effectively end paragliding and hang gliding in the area.

We are asking the city to consider putting the trail on the north side of Bates Ridge (between the highway and the ridge), rather than cut into the ocean‐facing side where the lift for flying is generated. The planned grading profile on the ocean‐facing side of the ridge will decrease the steepness of the ridge, reducing or eliminating the strong upward draft necessary to fly. The grading will also decrease the distance between pilots and pedestrians/obstacles/the ground, making for dangerous conditions. Additional grading shelves will likely disrupt airflow and/or make it too turbulent.

Ninety percent of the flying at Bates occurs on this ridge, which is one of only three ridges available for flying between San Diego and Big Sur. Hang gliders and paragliders have been flying here for 30‐plus years—it is a historic site with hundreds of pilots flying here every year. Pilots have moved to Carpinteria specifically for the flying. Many paragliders and hang gliders are also cyclists, roller bladers or runners—we think the bike path is a great idea. We would like to work with the city to find an option that does not destroy this beautiful, historic site.

I appreciate the work that has gone into planning this bike trail, but want to see it improved.

I am devastated that the Draft EIR considers the impact to my flying recreation to be ‘insignificant’

I signed a petition to preserve Bates Ridge that has 2,000 signatures and over 60 comments.

I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.

I believe building a bike path on the North side of Bates bluff is best for all recreational users, it is a safer, more direct path for cyclists, giving them a path that avoids the crowded, steep, and dangerous Rincon parking lot.

Comment Letter I31
I31-1
I31-2
I31-3
I31-4
I31-5
I31-6
2 I am a cyclist and want a direct route on the North side, rather than an Ocean view. Seeing the Ocean shouldn't be a requirement for this project because I get plenty of views along the way like the whole bike path to Ventura.

I am concerned the current plan will require maintenance against rising seas as it is being built near an eroding seawall. Relocating to the other side of the ridge is financially responsible.

I appreciate the wind study done by the engineers, however, this study specifically states that it is based on theory and not intended for this purpose. Even if accurate, 20‐30% loss of lift is very significant to me, especially on average wind days where lighter wind flow will be exponentially impacted by this project.

I feel it’s inappropriate for the EIR to discuss free flight rules or launches, this is outside the scope of the document and project, the focus of the EIR and CEQA is preserving recreation at the project site.

I don’t understand why the City continues to brush me aside and has failed to reach out to the soaring community. There are inaccurate statements in the Draft EIR because the authors refuse to listen to the pilots who have been recreating at Bates for over 40 years. Let’s build a better path together.

Coastal soaring at Bates makes Carpinteria truly special and unique, I can bike almost anywhere, but I travel to Carp for the flying at Bates and spend my money there.

Thank you
Rob Sporrer
Santa Barbara Resident since 1995
I31-6
Cont.

I31-7
I31-8
I31-9
I31-10
I31-11
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-125
Response to Comment Letter I31
Rob Sporrer
April 26, 2021
I31-1 The commenter expresses concern regarding the loss of paragliding and hang gliding associated with the project.

Please see Global Response GR1. The City acknowledges the comment and notes that it expresses opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I31-2 The commenter expresses support for Alternative 4, providing the opinion that the proposed recontouring of the ocean-facing side of the ridge would reduce or eliminate the strong upward draft necessary to fly.

Please see Global Response GR1 that discusses the air flow analysis and project impacts on existing soaring opportunities. The comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I31-3 The comment provides background on the project site, as it relates to soaring activities, and states the site is a historic site.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The project’s impacts on historic resources were analyzed in Section 3.4.4. As discussed in this section, no historical built environment resources exist within or near the proposed project site. Therefore, no further response is required or provided.

I31-4 The comment expresses concern that impacts to recreation associated with the proposed project were determined to be insignificant in the Draft EIR.

See Global Response GR1. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I31-5 The commenter states that they signed a petition that had 2,000 signatures and more than 60 comments to preserve the site.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I31-6 The commenter expresses support for Alternative 4 over the proposed project but proposes certain revisions to the design of Alternative 4.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-126
The City appreciates the commenter’s recommendations. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I31-7 The commenter expresses concern regarding eroding seawalls and rising sea levels, and states that Alternative 4 is more financially responsible.

See response I22-6, above.

I31-8 The commenter expresses concern regarding the accuracy of the wind study and believes that 20- 30 percent loss of wind should be considered significant.

See Global Response GR1.

I31-9 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and states the focus of the EIR should be to preserve recreation.

See Global Response GR1.

I31-10 The commenter states that the City has failed to reach out to the soaring community, resulting in inaccurate statements in the Draft EIR.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. Therefore, no further response is required or provided.

I31-11 The commenter explains the uniqueness of the project site relative to soaring opportunities afforded by existing conditions within the project alignment.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

Nick Bobroff                                                                                                                       April 25, 2021 Principal Planner
Community Development Department
City of Carpinteria 5775 Carpinteria Ave.  Carpinteria, CA 93013 Hello Mr. Bobroff and readers of this letter,
This is my third reply to the Zoom webinar meeting on April 13, 2021 of the Environmental Review Committee concerning the Multi Use Trail (M.U.T.).  The M.U.T. has certain uses that will be banned.

The presented proposal will not provide; improved public coastal access, recreational opportunities, or add to regional coastal resources.  The “shared‐use,” trail will be limited to less than, “multiple,” or “shared,” uses.

The ever increasing, electric powered bicycles, already “illegal,” (as mentioned, by Matt Roberts), on any bike path in the City of Carpinteria, are to be specifically banned. They are currently in use on all bike routes, within the City.  What about skateboards?  Electric powered skateboards?  Roller blades/skates? Radio controlled cars?  Street Luge?  Sidewalk surfers? Scooters?  Minibikes?  Wagons?  Horses (ten foot wide “path,” with 3‐foot‐wide paved shoulder?)?  Are the primary users, bicyclists, relegated to the shoulder? (see attachments 3.1, 3.2,3.3)?   The proposed sixteen‐foot width of the M.U.T. will attract these, and other users, and result in substantial conflicts with primary users and pedestrians.

The proposed removal of 92,526 cubic yards of the existing Little Diamondhead Bluff, will be an elimination of a regional coastal resource (see attachments 3.4, 3.5.).  An average dump truck can haul 10 cubic yards of dirt.  If there are 10 dump trucks, per day removing dirt and debris, seven days a week, it would take almost three years, to remove.  The resulting traffic, inevitable debris removal complications, cultural resource discovery and preservation, aesthetics, biological and environmental issues, equipment exhaust and staging, noise, freeway lane, road, bike path, parking lot, and beach closures will expand the expected costs, and timeline to complete.   More and larger dump trucks will be the City’s most likely response to shorten the debris removal and construction timetable.  Where will 14,860 cubic yards of dirt and debris, be staged, on the construction site? A survey of road bicyclists (see attachment 3.6) agrees with the Committee.  Alternative #4, should have an external width (except for two switchbacks, to reduce speed of bicyclists crossing Bates Road) of no more than eight feet.   Final grade, and accessibility, will follow ADA requirements.  This will substantially lessen the costs, and construction timeline, and environmental impact.    It should continue to be constructed by the California Department of Transportation.  No private contractors should be used.  Preserve Little Diamondhead!
Respectfully,
Ottis Gillespie
Comment Letter I32
I32-1
I32-2
I32-3
I32-4
I32-5
I32-6
I32-7
I32-7
Cont.

I32-7
Cont.

I32-8
I32-8
Cont.

I32-9
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-128
Response to Comment Letter I32
Ottis Gillespie
April 25, 2021
I32-1 The commenter notes his letter is in response to the April 13, 2021 presentation on the proposed project. The commenter believes that certain uses would be banned under the project and that the project would not provide adequate recreational uses.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I32-2 The commenter expresses concern that the proposed project would attract electric bikes, skateboards, roller blades/skates, horses, wagons, and other uses.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I32-3 The commenter states that the removal of the bluff would be a removal of a regional coastal resource and references attachments 3.4 and 3.5 (see response I32-8).

Please refer to Global Response GR1 for discussion regarding the air flow analysis and project impacts upon recreation (soaring opportunities). The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I32-4 The comment expresses concern regarding the environmental impacts associated with earth materials removal.

The environmental impacts associated with export of the soils on-site have been analyzed throughout Chapter 3 of the Draft EIR. The commenter does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I32-5 The commenter states that the City will likely require more and larger trucks to shorten debris removal and the construction schedule and asks where staging of debris would occur.

The City acknowledges the comment and notes that it expresses the opinions of the commenter.

The project’s construction schedule and number of haul trips associated with the project are outlined in Section 3.2.4 of the Draft EIR. Excavated soil materials would loaded into haul trucks simultaneous with the grading activity; a limited volume of soil stock-piling would occur in the vicinity of active grading (within the project site) between the loading operations for individual haul trucks.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-129
I32-6 The commenter expresses general support for Alternative 4. The commenter suggests that the width of the proposed bike route should be no wider than 8 feet, with the exceptions of switchbacks.

The comment provides additional recommendations for Alternative 4.

The City acknowledges the comment and appreciates the commenter’s suggestions regarding the 8-foot path width. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I32-7 The commenter provides illustrations of sports activities referenced in comment I32-2. The comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I32-8 The commenter provides photographs of the ridge area commonly called “Little Diamond Head.” See response I32-3. The comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I32-9 The comment provides the results of a survey. The comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided. 1 **EXTERNAL EMAIL**
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Hi Nick,
I am writing to comment about the bike path that could potentially destroy a natural resource for the flying community in SB county. I am very appreciative of the work that has been done thus far and am hopeful that you will look beyond the Draft EIR which stated that the impact would be "insignificant." As a pilot for almost 20 years, I can attest that removing earth on the South Side of the bluff to build the bike path would ruin our ability to soar those bluffs. I agree with the Environmental Review Committee's decision to recommend "Alternate 4" in order to preserve our soaring ability on the South Side of the bluff.

As an avid bike rider, I also agree with building on the North side of the bluff. I can't imagine the craziness in the summer of trying to negotiate the busy parking lot. It makes sense for fluidity and speed to route the path on the North side of the bluff.

I hope that as we move forward in this plan, you reach out and listen to our community of pilots and professionals. We are fighting to save this place because it is special in the hearts of hundreds of pilots nationwide and a real treasure in our area. Please make the best choice for all involved.

Respectfully,
Tim Barker
--
Tim Barker
5th grade Hope School
“You cannot teach a man [woman] anything; you can only help him find it within himself.” Galileo Galilei (1564-1642)
Comment Letter I33
I33-1
I33-2
I33-3
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-131
Response to Comment Letter I33
Ottis Gillespie
April 25, 2021
I33-1 The commenter expresses the opinion that the bike path could destroy a natural resource for the flying community.

Please see Global Response GR1. Further, the City acknowledges the comment and notes that it expresses general opposition to the project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I33-2 The commenter opines that removing earth on the south side of the bluff would ruin the ability to soar these bluffs and expresses general support for Alternative 4.

Please see Global Response GR1. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I33-3 The commenter makes general remarks about future coordination with the City and the soaring community. The comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

1 @
Date: Mon, Apr 26, 2021 at 4:34 PM
Subject: Bates bike path
To: <[email protected]>, Karl Cameron <[email protected]> Im sending this email in protest of the Draft EIR statement that there is an insignificant impact to the flying at the Bates Launch.
30 % reduction in lift will ruin the flying on the hill as that small margin of lift is needed for soaring flight.

I have contacted Dennis Page, whose work and calculations were used in the Draft EIR and he pointed some flaws in the study. I have asked him to draw up some drawing to show why there is such a big impact. I have known Dennis for 35 years and so he is willing to draft them up for us.

I was happy to hear that the community is willing to look at the North side path that works to not affect the flying on the south side of the hill
There is a Petition to preserve Bates Ridge that 2000 people have now signed it will be presented to the city. . I believe this shows a strong desire to preserve flying while still being able to get a bike path down to the beach.

We have spoken with many bike groups and they are in support of running the trail down to connect with the other trail.

Thanks Karl Cameron
-- To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.

Karl Cameron
Product Manager
Observables, Inc.

Comment Letter I34
I34-1
I34-2
I34-3
I34-4
2 119 N Milpas Street
Santa Barbara, CA 93103
Office: (805)-272-9255 x722
[email protected]
www.observables.com
The information contained in this E-mail message and its attachments, if any, may be privileged, confidential and protected from disclosure. This information is the property of Observables, Inc. If you are not the intended recipient, any disclosure, copying, distribution, reading, or the taking of any actions in reliance on or in response to this information (except as specifically permitted in this notice) is strictly prohibited. If you have received this transmission and you are not a named recipient, or if you think you have received this E-mail message in error, please E-mail the sender at [email protected] -- To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.

Karl Cameron
Product Manager
Observables, Inc.
119 N Milpas Street
Santa Barbara, CA 93103
Office: (805)-272-9255 x722
[email protected]
www.observables.com
The information contained in this E-mail message and its attachments, if any, may be privileged, confidential and protected from disclosure. This information is the property of Observables, Inc. If you are not the intended recipient, any disclosure, copying, distribution, reading, or the taking of any actions in reliance on or in response to this information (except as specifically permitted in this notice) is strictly prohibited. If you have received this transmission and you are not a named recipient, or if you think you have received this E-mail message in error, please E-mail the sender at [email protected] Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-133
Response to Comment Letter I34
Karl Cameron
April 26, 2021
I34-1 The commenter states the opinion that the proposed project would ruin the opportunity of flying over the bluffs area due to the 30 percent reduction in lift.

Please refer to Global Response GR1.

I34-2 The commenter indicates they will be contacting Dennis Page to create a drawing that illustrates how the air flow analysis is flawed. However, no specific critique of the air flow analysis is provided in the comment.

Please refer to Global Response GR1.

I34-3 The commenter expresses general support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I34-4 The commenter references the petition to preserve the site. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

William C. Prechter
Civil Engineer
PO Box 454 Nevada City, CA 95959
(530) 265-0733

March 3, 2020
RE: Carpinteria Rincon Trail Project
To Whom it may concern:

On a recent trip to the Ventura and Carpinteria area, specifically to the Bates Paragliding site I was told of the proposal to put in a new bike path. After hearing of the proposal and looking at the proposed alignment a letter seemed in order. I am a Professional Civil Engineer, avid bicycle rider, both road and mountain and a paraglider pilot.

I currently live in Nevada City, California and for the past eight years have made several trips each year to the area. If conditions are right each trip involves surfing, flying and bike riding. The Bates flying site represents a very special and unique feature that is found in only a handful of places along the coast of California especially in regards to the accessibility of the site. Not only are the views awe inspiring and incredible, the drive-up nature of the site makes it extremely appealing. As a bicycle rider I also appreciate the bike paths that have been made in an attempt to keep cyclists safe from traffic.

Looking at this proposed path alignment, the main goal of it seems to be maximizing ocean views, which it does well. Other significant factors appear to have been neglected and or overlooked. I’ll list three here. First, this path creates a potential conflicting and hazardous interaction between two recreational activities, paragliding and bike riding. In low wind conditions paraglider pilots often find lift by flying close to hill or mountainsides. Picture a bicyclist descending the path with a paraglider pilot 6’ off the ground in an oncoming direction. Second, this path puts bicyclists directly at the end of an already congested and narrow parking lot. As a road bike rider, myself and most others I know go will go to lengths to avoid riding through busy parking lots. The variability of drivers and non-predictability is high. Riding in a bike lane alongside traffic represents for the most part a more predictable outcome. Drivers are in a lane heading in a particular direction. A parking lot is far more prone to vehicle randomness and thus undesirable and dangerous, to the rider, interaction. Third, tax payer expense both short term and over the course of time. Pursuing this alignment is no small feat in regards to labor, earthwork quantities and the potential building of a bridge. I believe exact earthwork quantities have been presented in other letters. Longevity of the project is questionable as it would be built atop a slope with marginal stability. One need only walk down to the Bates beach and look at the hillside to see what time and environmental factors do the soil at hand. 1/2
Comment Letter I35
I35-1
I35-2
I35-3
I35-4
I35-5
I35-6
William C. Prechter
Civil Engineer
PO Box 454 Nevada City, CA 95959
(530) 265-0733
In my own consulting practice I strive to keep architectural design and aesthetics as a main priority.

As such I can appreciate what this path is attempting to do. There are at times moments where overall functionality, practicality and macro perspective can be forgotten in one’s attempt to hold too firm a grasp to a single idea. This appears to be the case here. I strongly encourage the thorough investigation of other options prior to the approval of this particular path. As it would appear all factors have not been considered.

Sincerely,
William Prechter PE
2/2
No. C-67693
I35-7
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-135
Response to Comment Letter I35
William Prechter
March 3, 2021
I35-1 The commenter provides personal background and explains the uniqueness of the project site. The City acknowledges this comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I35-2 The commenter provides the opinion the trail design appears to maximize the objective of providing ocean views but neglects other important factors. The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I35-3 The comment expresses concern regarding conflicts between paragliding and bike riding, specifically pointing out the potential for collisions between cyclists and low altitude paragliders.

The City acknowledges the comment. As discussed in the Air Flow Analysis (Appendix I of the EIR), the zone of greatest vertical air velocity (i.e., “lift”) occurs above the front edge (windward edge) of the ridge, not along the slope face. The proposed trail would be situated on a bench cut within the slope face, below the elevation of the ridge top. The only area where the trail would be the same elevation as the ridge would be at the bridge over-crossing of the UPRR corridor. The visibility between pedestrians/cyclists and paragliders would be unobstructed in this section of the trail, minimizing any potential for accidents involving conflicts between trail users and soaring activities.

I35-4 The comment expresses additional bicycle safety concerns involving conflicts between cyclists and vehicle maneuvers in the Rincon Beach County Park parking lot.

As discussed in Section 3.12 (Transportation) of the Draft EIR, the City’s consulting traffic engineer determined there would not be a significant hazard associated with introducing additional cyclists traversing the Rincon Beach County Park parking lot. Vehicle maneuvers in the parking lot involve low speeds, and signage in the parking area would alert drivers to cyclists passing through the area.

Signage at the terminus of the trail leading into the parking area would also alert cyclists to reduce speed and employ appropriate caution when riding through the parking lot.

I35-5 The comment expresses concerns regarding expenditure of tax-payer funds to construct and maintain the proposed trail.

The City acknowledges the comment and notes that it raises economic issues that do not appear to relate to any physical effect on the environment. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR.

I35-6 The comment expresses concern regarding landform alteration.

See Global Response GR2.
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Good afternoon Mr. Nick,
I appreciate the work that has gone into planning this bike trail, but want to see it improved.

I am devastated that the Draft EIR considers the impact to my flying recreation to be ‘insignificant’ I signed a petition to preserve Bates Ridge that has 2,000 signatures and over 60 comments.

I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.

I believe building a bike path on the North side of Bates bluff is best for all recreational users, it is a safer, more direct path for cyclists, giving them a path that avoids the crowded, steep, and dangerous Rincon parking lot.

I am a cyclist and want a direct route on the North side, rather than an Ocean view. Seeing the Ocean shouldn't be a requirement for this project because I get plenty of views along the way like the whole bike path to Ventura.

I am concerned the current plan will require maintenance against rising seas as it is being built near a eroding seawall. Relocating to the other side of the ridge is financially responsible.

I appreciate the wind study done by the engineers, however, this study specifically states that it is based on theory and not intended for this purpose. Even if accurate, 20-30% loss of lift is very significant to me, especially on average wind days where lighter wind flow will be exponentially impacted by this project.

I feel it’s inappropriate for the EIR to discuss free flight rules or launches, this is outside the scope of the document and project, the focus of the EIR and CEQA is preserving recreation at the project site.

I don’t understand why the City continues to brush me aside and has failed to reach out to the soaring community. There are inaccurate statements in the Draft EIR because the authors refuse to listen to the pilots who have been recreating at Bates for over 40 years. Let’s build a better path together.

Coastal soaring at Bates makes Carpinteria truly special and unique, I can bike almost anywhere, but I travel to Carp for the flying at Bates and spend my money there.

Thank you very much.

Kindest regards,
JG
Comment Letter I36
I36-1
I36-2
I36-3
I36-4
I36-5
I36-6
I36-7
I36-8
I36-9
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-137
Response to Comment Letter I36
Jorge Granier
April 26, 2021
I36-1 The commenter expresses appreciation to the City regarding planning a new bike path but would like to see improvements.

The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I36-2 The comment expresses concern that impacts to recreation associated with the proposed project were determined to be insignificant in the Draft EIR.

Please refer to Global Response GR1.

I36-3 The commenter references the petition to preserve the site. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I36-4 The commenter expresses general support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I36-5 The commenter expresses concern regarding eroding seawalls and rising sea levels, and states that Alternative 4 is more financially responsible
See response I22-6, above.

I36-6 The commenter expresses concern regarding the accuracy of the wind study and believes that 20- 30 percent loss of wind should be considered significant.

See Global Response GR1.

I36-7 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and states the focus of the EIR should be to preserve recreation.

See Global Response GR1.

I36-8 The commenter states that the City has failed to reach out to the soaring community, resulting in inaccurate statements in the Draft EIR.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. Therefore, no further response is required or provided.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-138
I36-9 The commenter explains the uniqueness of the project site relative to the existing soaring opportunities afforded by the site.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

Dear Nick,
Please accept this letter in response to the comment period for the Rincon Trail Draft EIR.

The decision to build the Rincon Trail as currently proposed would have an irreversible impact on the paragliding and flying community. From my perspective, having paraglided from Bates County Park Bluff area for over 10 years, constructing the trail on our precious bluff would be akin to draining the ocean, stopping the wave pattern for surfers at Rincon and render this spot use less.

To us pilots who currently utilize the updraft of wind to fly, modifying this wind draft would render our site useless. How harsh and horrible would it be for surfers to lose their ocean? In essence, the currently proposed M.U.T. takes our wind away and obliterates all paragliders recreational activity.

These paragliding flying sites are very rare and to have one in our backyard is an esteemed treasure and a prize recreational attraction for pilots, locals and visitors from all over the world. Every time I fly, I meet someone who has arrived in Carpinteria to paraglide. I’ve met thousands of people, including individuals from Germany, France, Italy, South America and several European and US locations.

Paragliding is a vital part of the Queen of the Coast along with the Rincon surf spot it is a worldrenowned destination which creates millions of dollars of tourist income for the City of Carpinteria and the County of Santa Barbara.

I am constantly asking local community members, cyclists, and visitors what they think of the proposed Rincon Trail Project which cuts into our flying site and takes thousand of tons of dirt from the bluffs.

Nearly 100% of those I spoke with say the project shouldn’t be built if paragliding is lost to gain a bike/pedestrian pathway.

Santa Barbara County is currently surveying local residents as to how they can provide more recreational activities for the community. There are supposedly grant funds available to increase recreational activities for our citizens. Why then is Carpinteria City proposing the Rincon Trail Project which would ultimately take away paraglider’s recreational activity? There is no logical reason for paragliders to lose their last remaining little gem for our recreation and leisure experience. Option number #4, constructing the bike/pedestrian path on the north side of the bluff along the 101-freeway corridor makes sense and preserves recreational activities for cyclists, surfers, paragliders and hikers. This can be a win-win situation. If we spend half the time developing a plan for Option # 4 rather than wasting time, money and efforts on the over complicated, over engineered, and ridiculously costly currently proposed Rincon Trail plan. Our community, including wildlife and fauna will thrive rather than run from the concrete jungle. We need to keep the coast and the bluffs of Carpinteria California open, undeveloped, and undisturbed to all the public for future generations to recreate and enjoy.

Thank-you for the opportunity to respond. Please include this letter in the Draft EIR Public Comments.

Respectfully Submitted,
George Jimenez
April 26, 2021
Comment Letter I37
I37-1
I37-2
I37-3
I37-4
I37-5
I37-6
I37-7
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-140
Response to Comment Letter I37
George Jimenez
April 26, 2021
I37-1 The City acknowledges the comment as general opposition to the project. No further response is required.

I37-2 The comment expresses concern regarding loss of paragliding opportunities above the site as a result of the project.

Please see Global Response GR1.

I37-3 The comment provides background on paragliding and identifies the uniqueness of the project site with respect to the soaring opportunities it currently affords.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided.

I37-4 The comment expresses concern regarding loss of paragliding activity as a result of the project.

Please see Global Response GR1. The City acknowledges the comment and notes that it expresses opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I37-5 The comment provides background on the County’s efforts to increase recreational activities, referencing the existence of grant funding to increase recreational activities, and expressing the opinion the project would take away paragliding opportunities over the project alignment.

Please refer to Global Response GR1. The City acknowledges the comment and notes that it does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

I37-6 The commenter expresses general support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I37-7 The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. No further response is required or provided.
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I am writing as a member of the Santa Barbara Soaring Association and part of the paragliding community. I am writing asking (pleading!) that you chose a bike path plan that will not destroy our flying site at Bates/Rincon.

The change of the face to a 1:1 slope, the inclusion of a wide (18ft?) path, and the removal of vast amounts of dirt will permanently destroy our flying site. While “wind experts” have weighed in on thus there has been no contact made with pilots who actually fly there or the SBSA. I can tell you from experience that the changes proposed in the main plan will destroy our flying site. For that reason I urge you to build the path on the freeway side of the hill for that brief distance. We in the SBSA are in favor of the bike path and would love to see it put in. But please, do not do this at the cost of destroying one of the most amazing flying sites on the California Coast. This will be devastating loss, not only to our community but to the literally thousands of people who travel to Carpinteria to fly the site and the income they bring to the region.

Thank you. Please do not hesitate to contact me if you have any questions.

Mark
Mark Rayburn Patterson, PhD
Comment Letter I38
I38-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-142
Response to Comment Letter I38
Mark Rayburn Patterson, PhD
April 26, 2021
I38-1 The comment expresses general opposition to the project and support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

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Hello,
I just wanted to add my comments about the bike proposed bike path on Rincon bluffs.

We in the flying community have hopefully made it clear by now that the initial bike path proposal is anathema with free flight. It takes away opportunity for flight while at the same time giving cyclists and pedestrians a poorly designed path for their uses.

Nobody wants a bike path that routes directly through a busy parking lot. Not cyclists, not pedestrians, not pilots.

Nobody wants a bike path that is going to unnecessarily remove massive amounts of earth from the bluff face, all for a few more ocean views and way more engineering requirements.

Over 2,000 people, myself included, have signed a petition to save this cherished bluff face. Please see that this is an incredibly important issue that both locals and visitors alike care about.

Option #4 that has been proposed is by far our preference in the flying community, since it is routed on the north side of the slope and avoids the parking lot for cyclists while also preserving the southern bluff face.

The cursory wind study that was done is inaccurate and needs to be reassessed by real experts in the field.

This is just a special bluff face. It must be protected! Please help us protect it! -Derek Musashe
Comment Letter I39
I39-1
I39-2
I39-3
I39-4
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-144
Response to Comment Letter I39
Derek Musashe
April 26, 2021
I39-1 The comment expresses general opposition to the project, indicating it will impact free flight opportunities, that cyclists will need to traverse a parking lot to connect to the regional trail system to the south, and that massive volumes of earthwork would be required.

Please refer to Global Response GR1 for discussion of the air flow analysis and alterations to soaring opportunities from project implementation. Please refer to response to comment I35-4 (above) for discussion regarding the traverse of the Rincon Beach County Park parking lot by cyclists. Please refer to Global Response GR2 for discussion of earth form modification.

I39-2 The comment expresses general support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I39-3 The commenter expresses concern regarding the accuracy of the wind study.

See Global Response GR1.

I39-4 The commenter asserts the bluff face is special and must be preserved. The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft EIR. No further response is required or provided.

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Good afternoon Mr. Nick,
First and foremost we appreciate the work that has gone into planning this bike trail, but want to see it improved.

I am devastated that the Draft EIR considers the impact to my flying recreation to be ‘insignificant’ I signed a petition to preserve Bates Ridge that has 2,000 signatures and over 60 comments.

I fully agree with the Environmental Review Committee’s decision to recommend Alternate 4, building on the North side of Bates ridge, preserving the soaring recreation.

I believe building a bike path on the North side of Bates bluff is best for all recreational users, it is a safer, more direct path for cyclists, giving them a path that avoids the crowded, steep, and dangerous Rincon parking lot.

I am a cyclist and want a direct route on the North side, rather than an Ocean view. Seeing the Ocean shouldn't be a requirement for this project because I get plenty of views along the way like the whole bike path to Ventura.

I am concerned the current plan will require maintenance against rising seas as it is being built near an eroding seawall. Relocating to the other side of the ridge is financially responsible.

I appreciate the wind study done by the engineers, however, this study specifically states that it is based on theory and not intended for this purpose. Even if accurate, 20-30% loss of lift is very significant to me, especially on average wind days where lighter wind flow will be exponentially impacted by this project.

I feel it’s inappropriate for the EIR to discuss free flight rules or launches, this is outside the scope of the document and project, the focus of the EIR and CEQA is preserving recreation at the project site.

I don’t understand why the City continues to brush me aside and has failed to reach out to the soaring community. There are inaccurate statements in the Draft EIR because the authors refuse to listen to the pilots who have been recreating at Bates for over 40 years. Let’s build a better path together.

Coastal soaring at Bates makes Carpinteria truly special and unique, I can bike almost anywhere, but I travel to Carp for the flying at Bates and spend my money there.

Thank you very much.

Kindest regards,
Morgan Granier
Comment Letter I40
I40-1
I40-2
I40-3
I40-4
I40-5
I40-6
I40-7
I40-8
I40-9
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-146
Response to Comment Letter I40
Morgan Granier
April 26, 2021
I40-1 The commenter expresses appreciation to the City regarding planning a new bike path but would like to see improvements.

The City acknowledges the comment as an introduction to comments that follow. No further response is required.

I40-2 The comment expresses concern that impacts to recreation associated with the proposed project were determined to be insignificant in the Draft EIR.

See Global Response GR1.

I40-3 The commenter references a petition to preserve the site. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I40-4 The commenter expresses general support for Alternative 4. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. The City and County will be determining what approval action to take with the benefit of the environmental review contained in the EIR. No further response is required or provided.

I40-5 The commenter expresses concern regarding eroding seawalls and rising sea levels, and states that Alternative 4 is more financially responsible
See response I22-6, above.

I40-6 The commenter expresses concern regarding the accuracy of the wind study and believes that 20- 30 percent loss of wind should be considered significant.

See Global Response GR1.

I40-7 The commenter feels that it is inappropriate for the EIR to discuss flight rules or launches, and states the focus of the EIR should be to preserve recreation.

See Global Response GR1.

I40-8 The commenter states that the City has failed to reach out to the soaring community, resulting in inaccurate statements in the Draft EIR.

The City acknowledges the comment and notes that it does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. The City has received a number of comments from the soaring community on the project’s Notice of Preparation and has accounted for these comments in the preparation of the Draft EIR. Therefore, no further response is required or provided.

Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-147
I40-9 The commenter explains the uniqueness of the project site with respect to the soaring opportunities afforded by existing conditions within the project alignment.

The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft EIR. Therefore, no further response is required or provided. 1 CAUTION: This email originated from outside the City of Carpinteria. DO NOT OPEN attachments or CLICK on links unless you are sure they are safe. Remember, reputable vendors, banks, etc. will not ask you to disclose passwords or other sensitive information.

Dear Sirs,
Coastal soaring at Bates is unique and special for my family and i as we visit from out of town especially to enjoy the beach and the paragliding. We typically visit for a few days and stay in local hotel accommodations and also enjoy dining out at all the local restaurants. If it was not for the paragliding at Bates we would not visit.

Pls preserve this unique soaring site.

Yours sincerely,
Derek Arculli
Comment Letter I41
I41-1
Responses to Comments
Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-149
Response to Comment Letter I41
Derek Arculli
April 26, 2021
I41-1 The comment expresses general opposition to the project. The City notes that the comment does not raise any issue concerning the adequacy of the Draft EIR. No further response is required or provided.

Responses to Comments
Verbal Comments Presented During
Environmental Review Committee Hearing on Draft EIR
April 13, 2021
The Carpinteria Environmental Review Committee (ERC) held a public meeting specifically to discuss the Draft Environmental Impact Report on April 13, 2021. The minutes from the ERC meeting are provided on the following pages.

The minutes reflect three different categories of verbal testimony at the meeting:
(1) Questions presented by ERC members regarding the project or environmental analysis (2) Comments from members of the public on the project and on the adequacy of the environmental analysis (3) Comments from the ERC members on the adequacy of the Draft EIR For the first category (1), staff provided answers in real time at the meeting to ERC member questions that are considered adequate, and which are captured in the minutes. No further responses are necessary or have been provided in regard to answering ERC questions.

For the second category (2), verbal comments presented during the meeting reflect the same content as written comments on the Draft EIR submitted by these individuals. Detailed responses to written comments submitted by these individuals are provided in the immediately preceding sub-section of this chapter and are considered adequate to address both submitted written comments and the verbal comments delivered during the ERC meeting.

Responses to ERC member comments (3) are provided following the ERC meeting minutes.

Carpinteria Rincon Trail Project Final Environmental Impact Report 11032 December 2021 2-150
Carpinteria Rincon Trail
Draft Environmental Impact Report
Environmental Review Committee Minutes
April 13, 2021
4:00 p.m. Virtual Meeting (Zoom Webinar)
The meeting was called to order at approximately 4:00 p.m. by Steve Goggia, Chair.

ROLL CALL
Members present: Steve Goggia, Chair
John Ilasin
Natasha Lohmus
Vince Semonsen
Erin Maker
OTHERS PRESENT: Nick Bobroff, Principal Planner
Matt Roberts, Project Applicant
Scott Onishuk, Project Engineer
Jonathan Leech, Environmental Consultant
Mack Carlson, City Attorney’s Office
Approximately 40 members of the public were in attendance.

PUBLIC COMMENT ON ITEMS NOT ON THE AGENDA
None

PROJECT PRESENTATION
Nick Bobroff and Jonathan Leech described the public review process, provided an overview of the project description, and disclosed the findings of the Draft Environmental Impact Report (DEIR), including all of the identified potentially significant impacts and proposed mitigation measures. The project alternatives considered as part of the DEIR were also described and a brief analysis of their respective impacts compared to the proposed project was provided.

ERC MEMBER QUESTIONS
Erin Maker
• Who will be responsible for maintaining the various elements of the trail, including but not limited to storm drains and drain outlets?
o Staff explained that the details of a City-County Maintenance Agreement are still being worked out, but the proposed arrangement is that the County would be responsible for the bridge structure and the City responsible for the bridge/trail surfacing. For the storm drains, Caltrans would continue to be responsible for maintaining their existing storm drain facilities; the County would take on responsibility for the new outlets on County Parks property. • Where will the storm drain filters be installed? We don’t want them to be located somewhere that would allow them to be clogged with sediments.
o Staff clarified that the filters would be installed in inlets just off the shoulder of the trail. • What is the status of the project proposed for the Bluffs III parcel where the soaring participants launch from?
o Staff explained that a proposal for a private campground/resort was recently considered at a Carpinteria Rincon Trail ERC Meeting
04-13-2021