Agenda packet — Carpinteria City Council, January 22, 2024 (part 3 of 3)

process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.

HCD appreciates the assistance the City’s housing element team provided during the course of our review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Reid Mille, of our staff, at [email protected].

Sincerely,
Melinda Coy
Proactive Housing Accountability Chief
Enclosure
City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 1 June 12, 2023

APPENDIX

CITY OF CARPINTERIA
The following changes are necessary to bring the City’s housing element into compliance with Article

10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-andcommunity-development/housing-elements/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A)) Enforcement: While the element was revised on pg. III-12 to 16 of the technical report to demonstrate compliance with state and federal law regarding special needs housing and adds program activities that will bring City into compliance with state and federal law if not already compliant, it must still analyze the City’s capacity to provide enforcement and outreach. Please see HCD’s prior review.

Outreach: While the element was revised to include an updated stakeholder list that includes more groups that could be inferred to serve lower-income communities, there is no added analysis describing efforts to reach out to neighborhoods with relatively concentrated poverty for input related to housing and community development needs and access to opportunities. Additionally, while the element was revised to demonstrate some outreach was conducted in Spanish, this appears to be limited to one community survey. The element should be revised to include programs for more thorough outreach to this population.

Integration and Segregation: While the element was revised to provide additional regional analysis, this analysis is largely limited to comparing City trends to County data. A complete regional analysis must compare the City to the surrounding region, including other jurisdictions that border or are in close proximity to the City.

Additionally, while further analysis added on geographic concentrations for race and ethnicity and familial status, this analysis must also be applied to disability and income.

Future analysis should also address potential causes for geographic concentrations based on familial status, disability, and income. Finally, while the element was revised to discuss and analyze data for trends over time and patterns across census tracts for race, disabilities, and familial status, it must also do so for income.

City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 2 June 12, 2023
Disparities in Access to Opportunity: While the element was revised to provide sufficient local and regional analysis for access to economic and transit opportunities, it must provide further information and analysis for access to educational and environmental opportunities. Specifically, while the adopted element provides further information on educational opportunities within the City, it does not provide any analysis on disparities in access to opportunities in different parts of the City. It also does not provide a regional comparison in access educational opportunities.

Additionally, while additional information has been added to explain local and regional environmental opportunities, there must be additional analysis for potential causes of variations in scoring from local and regional data.

Specifically, the element must provide a more detailed analysis of concentrations substandard housing within the City and include details on what contributes to overcrowding in certain areas of the City and how it relates to other fair housing factors. Additionally, the adopted element should be revised to provide additional local analysis of persons experiencing homelessness, including any demographics or characteristics for impacts on protected characteristics (e.g., race and disability) and access to shelter and services. Finally, the adopted element was not revised to analyze displacement risk both locally and regionally including displacement due to investment, disinvestment, and disaster driven displacement. Please see HCD’s prior review.

Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element was largely not revised to address this requirement. For example, while the adopted element was revised to provide TCAC opportunity maps in relation to sites and their location in high to low resource areas, it must analyze the location of these sites and their impact on improving access to educational opportunities, transit, jobs, and a healthy environment for all income levels. Additionally, the element states that sites are all in “moderate” resource areas and cites this as evidence for a lack of concentration of sites to accommodate lower income in low resource areas. The element should be revised to include analysis of affordable opportunities in high resource areas and include programs as necessary to encourage housing mobility. Please see HCD’s prior review.

Local Data and Knowledge, and Other Relevant Factors: While the adopted element was revised to include some historical context and analysis on local and regional land use policies and market trends’ effect on housing mobility and opportunities in the City, some of the information seems to be anecdotal and sources are not cited. The element should be revised to clearly show how the City utilized knowledge from local and regional advocates, service providers and other planning documents or processes to inform its analysis, policies, and programs.

Contributing Factors to Fair Housing Issues: While the adopted element was revised to add priority levels, all contributing factors are listed as “high” priorities. The element City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 3 June 12, 2023
should re-assess contributing factors upon completion of analysis and make revisions as appropriate, including clearer prioritization.

2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress in Meeting the Regional Housing Needs Allocation (RHNA): While Table B-2 and B-3 have been revised to provide more detailed information as to the status and anticipated completion date of each pending and approved project, analysis should also address any barriers to development and other relevant factors such as build out horizons, phasing, and dropout rates to demonstrate the availability or likelihood of development in the planning period. Additionally, Table B-3 appears to list multiple projects as “approved” that are still in the review process. In order to be counted as an approved project, a project must be issued a building permit. The element should be revised to separate completed projects and approved projects and provide additional evidence to support the assertion that the pending projects will be completed in the planning period.

Parcel Listing: While Table B-4 has been revised to add the parcel number and parcel size for each site, and Table B-6 has been revised to clarify that all sites listed in it are to address lower-income RHNA, Table B-5 still appears to assume a density bonus will be applied to Site 5, and this assumes a capacity of 32 dwelling units per acre. As stated in HCD’s prior review, unless this site is a pending or approved project, the table should revise its capacity assumptions for this site to reflect the underlying zoning, which is 20 dwelling units per acre.

Realistic Capacity: While the realistic capacity analysis has been revised to cite pending and approved projects as evidence for capacity on nonvacant sites, it does not link the characteristics of sites in Table B-2 and B-3 to the sites in the inventory in Tables B4 and B-5. More analysis is needed connecting developed projects to sites in the inventory in terms or size, affordability level and other similar characteristics, and this analysis should also address how land use controls and site improvements were factored into capacity calculations. Please see HCD’s prior review for more information.

Suitability of Nonvacant Sites: While the element includes specific information on each nonvacant site in the inventory including various characteristics about the site and existing uses, it only includes a general description of the methodology used to select these sites but does not describe how these factors relate to the potential to redevelop in the planning period. To support these factors, the element could relate the characteristics of example projection on Table B-2 to the characteristics outlined in the site descriptions and include market conditions or trends that support the assumptions.

Small and Large Sites: The element was not revised to meet this requirement. While the adopted element seems to indicate that no sites larger than ten acres or smaller than half an acre are being used to accommodate lower income RHNA, analysis in City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 4 June 12, 2023
Figure 3 appears to indicate that sites 1, 2, 6, 11, 14, 15, 16, 18 and 20 are all larger than ten acres or smaller than half an acre and are being used to accommodate lowerincome units. Since the City relies on both large and small site to accommodate its RHNA, the element must provide specific examples of past development in the City on similar site, with the densities, affordability and, if applicable, circumstances leading to consolidation. Additionally, while Program 8 was revised to include incentives for consolidating small parcels and subdividing large parcels and implement SB 9 requirements by 2024, it should be more specific as to what incentives will be offered and provide quantifiable objectives to match or exceed RHNA expectations.

Accessory Dwelling Units (ADU): While the adopted element provides some additional analysis stating its updated ADU ordinance will increase ADU production, and Program 2 (Accessory Dwelling Units) was revised to include monitoring of ADU production throughout the planning period, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs. Please see HCD’s prior review.

Environmental Constraints: The adopted element was not revised to meet this requirement. Please see HCD’s prior review. In addition, as stated in third party comments from the Coastal Commission sites expected to be rezoned may be inconsistent with the City existing Local Coastal Plan and sites located in proximity to the Carpinteria Salt Marsh raise issues with flooding and other coastal hazards, particularly with anticipated sea level rise. The Coastal Commission also raised concerns related potential sites that contain or are adjacent to creeks or other environmentally sensitive areas, raise issue with regard to ESHA protection, water quality, and flooding hazards in consideration of sea level rise. The element must describe and analyze these and other known conditions that preclude development (e.g., size, shape, easements, contamination, coastal policies).

Sites with Zoning for a Variety of Housing Types:
• Emergency Shelter Capacity: While the adopted element appears to indicate that new emergency shelter requirements brought on by AB 2339 will be addressed through Program 11 (Special Needs Housing), it is not clear in the program language that this is the case. The element must be revised to provide adequate emergency shelter capacity analysis, as well as program actions as necessary to accommodate the needs of the community. Please see HCD’s prior review for more information.
• By-Right Permanent Supportive Housing: While the adopted element appears to indicate that Program 11 will adopt zoning amendments pursuant to Government Code section 65651 regarding by-right permanent supportive housing, the element must indicate exactly how the City’s current policies do not align with state law, and what the program will change to bring them into compliance.

3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 5 June 12, 2023
building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). (Gov. Code, § 65583, subd. (a)(5).) Land-Use Controls: While the adopted element was revised to provide additional analysis on density, lot coverage, building height, lot size and site requirements, floor area ratio, setbacks, and open space requirements, the analysis is generalized and does not provide any determination stating if these controls constitute constraints in any particular areas of the City. Additionally, while the element was revised to add additional analysis on the 30-foot height limit for buildings up to three stories, program actions must still be added to address height limits as constraint.

R-Residential Overlay: The element was not revised to meet this requirement. Please see HCD’s prior review.

Processing and Permit Procedures: While the element was revised to provide adequate analysis of the conditional use permit (CUP) and development plan process, it must still describe coastal zone regulations and provide an analysis of whether the City’s coastal preservation policies will impact future or existing housing development within the coastal zone, particularly for sites that require rezoning.

Building Codes and Enforcement: The element was not revised to meet this requirement.

Please see HCD’s prior review.

Constraints on Housing for Persons with Disabilities: While the adopted element was revised to state that group homes of six or fewer are allowed by-right, and group homes of seven or more require a CUP, it does not state that this differentiation is a constraint and commit to amending it as part of Program 11 (Special Needs Housing).

Program 11 must also be revised to commit to removing the reasonable accommodations findings mentioned in HCD’s prior review.

Zoning, Development Standards and Fees: The element was revised to add a commitment in Program 1 to “post and update all zoning regulations and fees on the City website annually”, this does not address the requirements of this finding. Please see HCD’s prior review.

4. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 6 June 12, 2023
65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)
Approval Time and Requests Lesser Densities: While the element was revised to state that time from project approval to receiving a building permit is 3-4 months, the element does not include adequate analysis of requests to develop housing at densities below those identified. Specifically, while the element states that projects have been developed at densities lower than those identified, it provides no analysis as to what the projects consisted of or why they developed at lower densities.

5. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Special Housing Needs: While the adopted element was revised to provide an adequate analysis for female-headed households, it must still be revised to provide an estimate as to the number of permanent and seasonal farmworkers and provide the number of persons with developmental disabilities within the City.

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).) To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

Program 5 (Affordable Rental Housing): The program was not revised to address this finding. Please see HCD’s prior review.

Program 8 (Facilitate Lot Consolidation): While the program was revised to state that lot consolidations would be implemented on a “project-by-project basis”, it must City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 7 June 12, 2023
provide a more specific timeline of how actions and incentives to encourage lot consolidation will be put in place and implemented.

Program 9 (Regulatory Concessions and incentives for Affordable Housing): The program was not revised to adequately address this requirement. Specifically, it must provide a clearer implementation timeframe, and state if concessions are already in place or if they are still being developed.

Program 11 (Special Needs Housing): The program was not revised to address this requirement. Please see HCD’s prior review.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing.
(Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A2, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. Additionally, the element should be revised as follows:

Program 1 (Adequate Site to Accommodate RHNA): While the element was revised to provide the acreage of sites that will be rezoned to accommodate RHNA, it must provide a quantifiable metric of the number of units that will be rezoned to demonstrate the City is addressing its RHNA shortfall. Additionally, this program must still be revised to provide definitive implementation timelines for each activity.

The program must also include specific commitments and timing related to required Coastal Commission Approvals for amendments to the Local Coastal Plan. HCD encourages the City to coordinate with Coastal Commission staff on revisions to the housing element to ensure sites to be rezoned are consistent with the Local Coastal Plan and free from potential constraints.

City of Carpinteria’s 6th Cycle (2023-2031) Adopted Housing Element Page 8 June 12, 2023
In addition, please be aware, the recent California appellate decision in Martinez v.

City of Clovis.
1 found that while overlays can be used in a rezone, when the base zone allows residential development, both the base zone and the overlay zone must comply with the minimum density requirements of Government Code section 65583.2, subdivision (h). The City should analyze how this decision may impact its current rezone strategy using the R-Residential Overlay and may need to adjust accordingly.

Nonvacant Sites Reliance to Accommodate RHNA: The element was not revised to specifically address this requirement. Please see HCD’s prior review.

3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).) While Program 5 (Affordable Rental Housing Development Assistance) was revised to state that projects with extremely low-income units would receive “priority processing”, it must specify what this process entails, and what the requirements are to qualify for it.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Findings A3 and A4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov.

Code, § 65583, subd. (c)(5).)
As noted in Finding A1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs.

Additionally, the adopted element did not revise other program actions to address the City’s obligation to AFFH including how programs address housing mobility 1 Martinez v. City of Clovis (2023) 90 Cal.App.5th 193, 307 Cal.Rptr.3d 64.

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enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Program 5A also was not revised to describe how all the City’s housing programs comply with and further the requirements and goals of Government Code section 8899.50, subdivision (b).

C. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
While the element was revised to include units to be constructed, rehabilitated, and conserved in the planning period, the number of mobile homes must still be broken down by income category.

D. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element was revised to add additional information as to the number of groups that were contacted to take part in the public participation process, it still does not describe who participated in the public participation process, nor does it describe where the comments in Table C-2 come from. Additionally, while Program 17 commits to reaching out to special needs groups and neighborhoods of more concentrated lower-income residents, it must still describe what methods of outreach will be employed, and how often they will be carried out.

Attachment C.

City Responses to June 12, 2023 HCD Comment Letter
Carpinteria Housing Element Re-adoption
January 22, 2024 City Council Meeting
City of Carpinteria Response to June 12, 2023 HCD Review Letter All page references included herein refer to page numbers of the November 2023 redline version of the Housing Element.

HCD Comments City Response
A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A))
N/A
Enforcement: While the element was revised on pg. III-12 to 16 of the technical report to demonstrate compliance with state and federal law regarding special needs housing and adds program activities that will bring City into compliance with state and federal law if not already compliant, it must still analyze the City’s capacity to provide enforcement and outreach. Please see HCD’s prior review.

Appendix D, page D-15 has been updated to explain that because the City does not have in-house capacity to provide fair housing outreach and enforcement, it contracts with the Santa Barbara Rental Housing Mediation Program (RHMP) to provide these services to Carpinteria residents. Pages D14 to 16 also describe the capacity and capabilities of RHMP and another local fair housing organization that serves the City, the Legal Aid Foundation of Santa Barbara County, with respect to enforcement and outreach.

As discussed on Appendix D, pages D-34 to 35, there are no R/ECAP or RCAA areas in the city. Analysis has been added on page D-34 indicating poverty status throughout the city is less than 10 percent and the city is generally racially integrated.

As discussed in Appendix C, page C-1, the city worked to ensure individuals and groups representing lower-income populations and special needs groups were involved in the housing element process by direct mail and/or email to its list of stakeholders, which included housing advocates and non-profit organizations representing the interests of lower-income persons and special needs groups. Information has been added to indicate public outreach meetings were held both in-person and online to enable those with mobility difficulties to conveniently participate. The in-person location of most meetings was the Carpinteria City Hall. Given the city’s small size and City Hall’s location on a bus line, this location is readily accessible to residents throughout the city.

The comment regarding outreach conducted in Spanish mischaracterizes the City’s outreach efforts. Appendix C, pages C-1 to C-2 state that all housing City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
element materials were published on the city website in both English and Spanish and transcription of meetings in real-time and meeting minutes were made available. A summary of this information and a cross reference to Appendix C has also been added to outreach discussion on Appendix D, page D-10.

Program 17 includes expansion of specific outreach efforts related to fair housing education, including to the Spanish-speaking community. (See Housing Plan, pages 31-39.)
Integration and Segregation: While the element was revised to provide additional regional analysis, this analysis is largely limited to comparing City trends to County data. A complete regional analysis must compare the City to the surrounding region, including other jurisdictions that border or are in close proximity to the City. Additionally, while further analysis added on geographic concentrations for race and ethnicity and familial status, this analysis must also be applied to disability and income. Future analysis should also address potential causes for geographic concentrations based on familial status, disability, and income. Finally, while the element was revised to discuss and analyze data for trends over time and patterns across census tracts for race, disabilities, and familial status, it must also do so for income.

The regional analysis of integration and segregation has been expanded to include analysis of the cities of Goleta and Santa Barbara and the reasons for similarities and differences in trends in these two cities also located on the south coast of Santa Barbara County. (See Appendix D, pages D-23 to 24.) Potential causes for the somewhat lower rate of people with disabilities in the northern portion of the city (<10% versus 10-20% in the rest of the city) is discussed on page D-26 to 27: “The lower rates of persons with disabilities in the northern portion of the City may be due to the lack of availability of housing that is both affordable and accessible and well as there being fewer public transit options in this area.”
The percentage of children in married couple households is over 60% throughout the city and conversely, female-headed households are less than 20% throughout the city. Analysis has been added on pages D-29 to 31 comparing the relatively homogenous familial status in Carpinteria to the more varied rates in the nearby cities of Goleta and Santa Barbara. One reason for this difference may be that female-headed households, which have a greater need for accessible child and health care and other services choose to live in these larger cities where more of these services are available.

Potential causes for the higher concentration of lower-moderate income population in the southwest portion of the city is that there is a higher City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
percentage of rental housing in this area. A discussion of income trends over time and across census tracts has also been added. Generally, measures of income in the city have remained fairly consistent over time and throughout the city. This analysis has been added to pages D-31 to 33.

Disparities in Access to Opportunity: While the element was revised to provide sufficient local and regional analysis for access to economic and transit opportunities, it must provide further information and analysis for access to educational and environmental opportunities. Specifically, while the adopted element provides further information on educational opportunities within the City, it does not provide any analysis on disparities in access to opportunities in different parts of the City. It also does not provide a regional comparison in access educational opportunities.

Appendix D, Figure D-22 and pages D-37 to 39 indicate that the entire City has uniform and relatively high educational opportunity scores. The analysis has been updated to clarify that residents are served by two elementary schools and one middle and high school. Given the small size of the city, there are not disparities in access to educational opportunities.

Figure D-21 shows the regional trends in access to educational opportunity.

Additional information comparing the city of Carpinteria to the cities of Santa Barbara and Goleta has been added to the regional analysis. (See page D-38.)
Additional analysis has been added regarding the potential causes of variations in local and regional environmental opportunity scores on pages D-44 to 47.

Disproportionate Housing Needs Including Displacement: While a sufficient regional analysis and analysis of patterns over time was added to the adopted element for displacement risk, overpayment, overcrowding, and persons experiencing homelessness, further analysis is needed to meet the requirements of this finding. Specifically, the element must provide a more detailed analysis of concentrations substandard housing within the City and include details on what contributes to overcrowding in certain areas of the City and how it relates to other fair housing factors. Additionally, the adopted element should be revised to provide additional local analysis of persons experiencing homelessness, including any demographics or characteristics for impacts on protected characteristics (e.g., race and disability) and access to shelter and services. Finally, the adopted element was not revised to analyze displacement risk both locally and There are no substantial concentrations of substandard housing in the city.

Analysis has been added to state this and to provide additional information on factors that may affect substandard housing in certain areas of the city. (See Appendix D, pages D-56 to 57.)
Santa Barbara County recently published an online Homeless Management Information System (HMIS) dashboard which provides demographic and other information regarding people experiencing homelessness. Additional local and regional analysis has been added on pages D-57 to 60.

Additional information has been added regarding displacement risk and causes of displacement on a local and regional level on pages D-60 to 63.

The city added discussion of City Council Resolution No. 6235, which directed staff to evaluate six additional anti-displacement measures within the City on City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
regionally including displacement due to investment, disinvestment, and disaster driven displacement. Please see HCD’s prior review. pages D-8 to 9 and included the resolution as Attachment D-3. Appendix D also includes discussion of the City’s adoption of City Council Ordinance No. 770 which establishes additional protections for tenants in the event of a nofault just cause termination of their residential tenancy. (See pages D-62 and Attachment D-4.)
Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element was largely not revised to address this requirement. For example, while the adopted element was revised to provide TCAC opportunity maps in relation to sites and their location in high to low resource areas, it must analyze the location of these sites and their impact on improving access to educational opportunities, transit, jobs, and a healthy environment for all income levels. Additionally, the element states that sites are all in “moderate” resource areas and cites this as evidence for a lack of concentration of sites to accommodate lower income in low resource areas. The element should be revised to include analysis of affordable opportunities in high resource areas and include programs as necessary to encourage housing mobility. Please see HCD’s prior review.

Additional analysis has been added to Appendix D, pages D-63 to 67 regarding the location of sites relative to AFFH factors. The city is relatively homogenous in terms of many AFFH factors including educational and economic opportunity, access to transit, poverty rate, and integration.

Nonetheless, the city’s criteria for identifying sites for the sites inventory included measures intended to affirmatively furthering fair housing by prioritizing proximity to transit, services, and employment and avoiding areas with significant environmental constraints.

Nearly the entire city is designated as moderate resource area. As stated on pages D-64 to 67 and depicted in Figure D-41, the only areas designated high resources in the city are small portions of census tracts that are largely outside of the city. Within the city, the high resource areas contain Carpinteria High School and Sandpiper Mobile Home Park. There is no undeveloped or underdeveloped land available for additional residential development in high resource areas within the city. Therefore, there is no opportunity for potential housing development in the city in any areas other than moderate resource areas.

Additional information on participants involved in the Housing Element update process has been added on pages D-1 to 2. Participants in the Housing Element update included affordable housing developers including People’s Self Help Housing; fair housing organizations including the Rental Housing Mediation Program and Gray Panthers Network of Santa Barbara; housing advocates including Californians for Homeownership, YIMBY Law, and California Housing Defense Fund; and community-based and faith-based organizations, including family service agencies, senior programs, and health and human services; and residents. The city also directly worked with People’s Self Help Housing, which serves the interests of lower-income City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
households and special needs groups and has several successful lowerincome housing projects in the City, to solicit comments and recommendations on housing needs, barriers to fair and affordable housing, and opportunities for development. (See email from People’s Self Help Housing in Appendix C, pages C-52 to 53.) All comments received and how those comments were incorporated into the Housing Element are detailed in Appendix C, paged C-15 to 78. Additional discussion of outreach efforts is included in Appendix D, pages D-9 to 12.

Citations to data sources are included where available throughout the Housing Element and where information is based on staff observations/local knowledge this has been noted.

Contributing Factors to Fair Housing Issues: While the adopted element was revised to add priority levels, all contributing factors are listed as “high” priorities. The element should re-assess contributing factors upon completion of analysis and make revisions as appropriate, including clearer prioritization.

The analysis has been revised to prioritize the fair housing contributing factors as follows: (1) Housing affordability, (2) Homelessness, (3) Fair housing education. See Appendix D, pages D-68 to 76.

While Table B-2 and B-3 have been revised to provide more detailed information as to the status and anticipated completion date of each pending and approved project, analysis should also address any barriers to development and other relevant factors such as build out horizons, phasing, and dropout rates to demonstrate the availability or likelihood of development in the planning period. Additionally, Table B-3 appears to list multiple projects as “approved” that are still in the review process.

In order to be counted as an approved project, a project must be issued a building permit. The element should be revised to separate completed The discussion of completed, approved, and pending projects on Appendix B, pp. B-2 to 3 has been updated to provide additional analysis regarding the likelihood of development of approved and pending projects during the planning period.

The “Status” columns in Tables B-2 and B-3 have also been updated to clarify projects that are completed, under construction, have building permits issued, have planning permit approval, or are pending planning review. A new column has been added to Table B-3 indicating the anticipated completion date for projects that are not yet completed.

City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
projects and approved projects and provide additional evidence to support the assertion that the pending projects will be completed in the planning period.

Two additional projects for which formal applications have recently been submitted have been added to Table B-3. These projects are located on sites that had been identified as candidate sites for rezoning in Table B-6, specifically Candidate Sites 5 and 17. Therefore these sites have been removed from Table B-6.

Table B-5 has been revised to indicate the anticipated capacity of Site 5 is 31 units based on the underlying zoning of 20 units per acre.

Linking Characteristics of Sites in Trends Analysis to Site Inventory. The analysis of Completed, Approved and Pending Projects (Table B-3) determined sites allowing 100% multi-family residential uses (i.e., those sites in with PRD zoning) are being developed on average at 78% of the maximum allowed density. The PRD zoned sites in Tables B-3 and B-4 are of similar size, with an average size of 0.21 and 0.24 acres, respectively. Columns have been added to Table B-3 indicating the site identification criteria applicable to each site (see discussion of site identification criteria below). For the purposes of calculating realistic development potential of vacant multifamily residential sites, the city conservatively assumed they would be developed at 75% of allowed density. For single-family zoned sites, the analysis assumes one unit per lot. No vacant site is anticipated to yield more than 3 units. (See analysis of Completed, Approved, and Pending Projects and Vacant Sites in Appendix B, pages B-2 to 3.)
To identify potentially developable sites on non-residentially zoned land, the City reviewed development trends on non-residentially zoned properties from 2015 to March 2023 to identify the common characteristics of these sites. Based on the common characteristics identified, the city developed a City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
list of site criteria that was used to identify potentially developable nonvacant sites. (See list of criteria on page B-4.) Columns have been added to Tables B-2, B-3, B-5, and B-6 indicating the criteria applicable to each of the sites.

Affordability Assumptions. The city generally used the default density provisions of state law (Gov. Code, § 65583.2(c)(3)(B)) for the affordability assumptions in the site inventory analysis. However, in some cases, the city used more conservative assumptions regarding affordability. The specific affordability assumptions used for each type of site (e.g., vacant, underutilized, etc.) are specified in the footnotes of Tables B-3 through B-6.

Land Use Controls & Site Improvements. Discussion has been added to indicate how land use controls and site improvement requirements have been incorporated into build out assumptions. (See page B-5.) Suitability of Nonvacant Sites: While the element includes specific information on each nonvacant site in the inventory including various characteristics about the site and existing uses, it only includes a general description of the methodology used to select these sites but does not describe how these factors relate to the potential to redevelop in the planning period. To support these factors, the element could relate the characteristics of example projection on Table B-2 to the characteristics outlined in the site descriptions and include market conditions or trends that support the assumptions.

As stated above, the City developed a list of site identification criteria based on characteristics of recently developed sites. Columns have been added to Tables B-2, B-3, B-5, and B-6 indicating the criteria applicable to each of the sites.

Small and Large Sites: The element was not revised to meet this requirement. While the adopted element seems to indicate that no sites larger than ten acres or smaller than half an acre are being used to accommodate lower income RHNA, analysis in Figure 3 appears to indicate that sites 1, 2, 6, 11, 14, 15, 16, 18 and 20 are all larger than ten acres or smaller than half an acre and are being used to accommodate lower-income units. Since the City relies on both large and small site to accommodate its RHNA, the element must provide specific examples of past development in the City on similar site, with the densities, ½ Acre Threshold. Parcels were grouped into “sites” listed in Tables B-5 and B-6 when they were adjacent and had the potential for lot consolidation. All of the sites listed in Table B-5 are larger than one-half acre. However, some sites include multiple adjacent parcels that are less than one-half acre individually. Government Code Section 65583.2(c)(2)(A) does not define “site” for purposes of the half acre threshold, nor limit the definition of site to one parcel. The city has revised the analysis to assign all sites smaller than one acre and all individual parcels smaller than one-half acre to the moderate-income category for purposes of the sites inventory analysis. (See City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
affordability and, if applicable, circumstances leading to consolidation.

Additionally, while Program 8 was revised to include incentives for consolidating small parcels and subdividing large parcels and implement SB 9 requirements by 2024, it should be more specific as to what incentives will be offered and provide quantifiable objectives to match or exceed RHNA expectations.
discussion on Appendix B, page B-11 and footnotes in Tables B-5 and B-6 which reference this change.)
10 Acre Threshold. One parcel included in the inventory, a portion of Candidate Site 2 (Table B-6) is larger than 10 acres. Per Government Code Section 65583.2(c)(2)(B), for the purposes of the 10 acre threshold, “’site’ means that portion of a parcel or parcels designated to accommodate lower income housing needs pursuant to this subdivision.” The city revised the analysis to consider only a 10 acre portion of the 14.09 acre parcel as a candidate for rezoning with the R Overlay to accommodate lower income housing. (See footnote and changes to Table B-6.)
Lot Consolidation & Subdivision. Program 8 has been revised to list specific incentives to encourage lot consolidation and commits the city to establishing the lot consolidation incentive program by December 2024.

Further, Program 8 includes a quantified objective of approving 5 residential or mixed use projects involving lot consolidations during the planning period.

Program 8 also includes a commitment to amend the zoning code to implement SB 9 to promote urban lot splits by December 2024. As the city has only identified one site in its site inventory that exceeds 10 acres and has adequate buffer such that it is not reliant on this site to meet its RHNA shortfall, it is not proposing a separate incentives program for subdivisions but is committed to continuing to encourage subdivisions through discussions with developers during preliminary project reviews. (See Housing Plan, pages 18-19.)
Accessory Dwelling Units (ADU): While the adopted element provides some additional analysis stating its updated ADU ordinance will increase ADU production, and Program 2 (Accessory Dwelling Units) was revised to include monitoring of ADU production throughout the planning period, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs. Please see HCD’s prior review.

Based on methodology described in HCD’s Site Inventory Guidebook, the city conducted an analysis of regional production of ADUs to estimate the number of ADUs that would be produced in Carpinteria in the current planning period. Given the lack of historic ADU production in the city, the city used estimated ADU production in the city of Santa Barbara to estimate a “base” ADU production rate.

Regional ADU Trends Analysis
City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
City of Santa Barbara
Estimated ADUs in planning period 629
ADUs per capita .007
ADUs per housing unit .016
Trend applied on per capita and per housing unit
basis to Carpinteria for planning period
Approx. 90-100 total or
12 annually
Based on Census 2020 ACS data for population and housing units.

Based on trends in the nearby city of Santa Barbara, the city estimates a “base” ADU production of 12 units per year or 96 units for the planning period.

In addition, there is deferred demand for ADU development in Carpinteria as compared to the city of Santa Barbara where State law changes that expanded ADU production went into effect in January 2017. This deferred demand is evidenced by the fact that in the first six months the city’s current ADU regulations have been in place, the city has received 20 permit applications and has issued seven building permits. Given the current trend of pending and approved ADUs over the past six months, the city conservatively estimates that in addition to the base ADU production, the annual rate of production in 2023 and 2024 will include an additional 8 units per year. Therefore, estimated ADU projection during the planning period is as follows:
96 base units + 16 deferred demand units = 112 ADUs
(See ADU analysis on Appendix B, pages B-12 to 13.)
Environmental Constraints: The adopted element was not revised to meet this requirement. Please see HCD’s prior review. In addition, as stated in third party comments from the Coastal Commission sites expected to be rezoned may be inconsistent with the City existing Local Coastal Plan and sites located in proximity to the Carpinteria Salt Marsh raise issues with flooding and other coastal hazards, particularly with anticipated sea level rise. The Coastal Commission also raised concerns related potential sites that contain or are adjacent to creeks or other environmentally sensitive The Housing Element describes site specific environmental constraints in Figures B-3 and B-4. The city added additional analysis of how environmental constraints, particularly those identified by the Coastal Commission, could impact housing development on identified sites. (See Appendix B, page B15.) The City’s RHNA shortfall is 292 lower income units. Based on realistic development assumptions for these non-vacant sites (described in Appendix City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
areas, raise issue with regard to ESHA protection, water quality, and flooding hazards in consideration of sea level rise. The element must describe and analyze these and other known conditions that preclude development (e.g., size, shape, easements, contamination, coastal policies).

Prior Comment: While the element generally describes a few environmental conditions within the City (p. II-26), it must describe how these conditions relate to identified sites including any other known environmental or other constraints within the City that could impact housing development in the planning period.

B, pages B-3 to 6) candidate sites for rezoning listed in Table B-6 can accommodate 1,932 lower income units. The city identified this surplus of seven times the RHNA shortfall such that if the Coastal Commission determines certain sites cannot be rezoned due to Local Coastal Plan inconsistency, there are adequate other sites to meet the RHNA shortfall.

Please see HCD’s prior review for more information.
• By-Right Permanent Supportive Housing: While the adopted element appears to indicate that Program 11 will adopt zoning amendments pursuant to Government Code section 65651
regarding by-right permanent supportive housing, the element must indicate exactly how the City’s current policies do not align with state law, and what the program will change to bring them into compliance.

The analysis of compliance with emergency shelter requirements brought on by AB 2339 has been expanded. (See Technical Report, pages III-14 to 15.) The city’s zoning ordinance complies with the requirement that emergency shelters be allowed by right in a zone that also allows residential uses. The city has objective development standards for emergency shelters consistent with Gov. Code Sec. 65583(a)(4)(B). And the city has adequate vacant sites included in its site inventory to accommodate the needed emergency shelter capacity in addition to its RHNA shortfall. Based on the most recent point in time survey multiplied by 200 square feet per person of land area, the city needs 4,200 square feet (0.096 acre) of land for emergency shelters. The city has 7.86 acres of vacant land zoned to meet this requirement and additional underutilized acreage that could also accommodate emergency shelters by right.

Program 11 has been updated to specify in the Actions & Timeframes, under the Emergency Shelters subheading, that the city will amend regulations for emergency shelters consistent with AB 139 and AB2339 by April 2024. (See Housing Plan, pages 21-24.)
Program 11 commits the city to amending regulations to comply with state law. The city has not yet completed analysis to identify exactly what sections of its code must be amended to comply with state law. This will be part of City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
the code amendment process. The program action has been revised to commit the city to both analyzing and amending regulations as necessary for consistency with AB 2162 by April 2024. (See Housing Plan, pages 21-24, Actions & Timeframes section under Transitional and Supportive Housing subheading.)

3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). (Gov. Code, § 65583, subd. (a)(5).)
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Land-Use Controls: While the adopted element was revised to provide additional analysis on density, lot coverage, building height, lot size and site requirements, floor area ratio, setbacks, and open space requirements, the analysis is generalized and does not provide any determination stating if these controls constitute constraints in any particular areas of the City. Additionally, while the element was revised to add additional analysis on the 30-foot height limit for buildings up to three stories, program actions must still be added to address height limits as constraint.

Tables III-3 and III-4 on Technical Report, pages III-9 to 11 list the development standards applicable to residential and non-residential zones, respectively. The development controls discussed on Technical Report, pages III-1 to 7 apply throughout the city in the zones described. Additional analysis has been added on page III-2 describing where specific zone districts are generally located within the city and on page III-7 discussing how the cumulative effect of development standards could be a constraint to residential development in certain zone districts and areas within the city.

Program 1 has been amended to specifically address the 30-foot height limit and includes the following action: “Adopt General Plan and Zoning Code amendments and submit Local Coastal Plan amendments to the Coastal Commission, including rezoning of at least 14.6 acres of land to provide adequate sites to accommodate the city’s RHNA allocation, amendments to City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
development standards including 30-foot height limit, and establishment of affordability requirements consistent with statutory deadlines.” (See Housing Plan, pages 6-9.)
R-Residential Overlay: The element was not revised to meet this requirement. Please see HCD’s prior review.

Prior Comment: R-Residential Overlay: The element relies on sites in commercial and industrial zones that allow residential through the Residential Overlay. While some information was provided on how the overlay allows residential uses, the element must include a complete description and analysis of the Overlay, including a breakdown of affordability requirements if applicable.

Discussion of the R Overlay has been updated to specify maximum density, applicable development standards, and that there is currently no affordability requirement applicable to the R Overlay other than through the inclusionary housing program which encourages the development affordable for-sale units in the above-moderate income category in an effort to provide housing for middle-income and critical workforce households. The inclusionary program applies to subdivisions of 5 or more lots. (See Technical Report, pages III-3 to 4.)
Also note, per Program 1, the city has committed to modify the R Overlay to allow a minimum density of 20 units per acre and will review development standards in consultation with local architects and developers and amend standards as necessary to ensure that allowable densities can be achieved and that standards do not pose unreasonable constraints on the cost and supply of housing. Program 1 also includes a commitment to establish affordability requirements as part of the R Overlay zoning amendment for candidate sites. (See Housing Plan, pages 6-9.)
Processing and Permit Procedures: While the element was revised to provide adequate analysis of the conditional use permit (CUP) and development plan process, it must still describe coastal zone regulations and provide an analysis of whether the City’s coastal preservation policies will impact future or existing housing development within the coastal zone, particularly for sites that require rezoning.

The processing and permit procedures analysis have been updated to explicitly state that because the city is located entirely within the coastal zone, all development is subject to applicable coastal zone regulations including the city’s certified Coastal Land Use Plan, which is combined with the city’s General Plan and its certified Implementation Programs, including the city’s Zoning Code. The analysis of coastal resource preservation policies has also been expanded to further address how these policies impact housing development, particularly for sites in the site inventory. (See Technical Report, pages III-23 to 24.)
Building Codes and Enforcement: The element was not revised to meet this requirement. Please see HCD’s prior review.

The Housing Element states on Technical Report, page III-19 that the city utilizes the California Building Code with amendments primarily related to geotechnical review and provisions for adequate drainage. The analysis City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
Prior Comment: Building Codes and Enforcement: The element must describe and analyze which building code is enforced, any local amendments to the building code and their enforcement for impacts on housing supply and affordability. For additional information and a sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planningand-community- development/housing-elements/building-blocks/codesand-enforcement-and-onsite-offsite- improvement-standards. states that these modifications to state regulations do not pose unreasonable constraints to housing supply or affordability.

Program 11 has been revised to clarify the city’s commitment to amending regulations to (1) amend permit requirements and necessary findings for residential care facilities serving seven or more persons and (2) remove subjective findings for approval of reasonable accommodation requests.

These are listed in the actions section of Program 11 under the subheadings Residential Care Facilities and Reasonable Accommodation, respectively. (See Housing Plan, pages 21-24.)
Zoning, Development Standards and Fees: The element was revised to add a commitment in Program 1 to “post and update all zoning regulations and fees on the City website annually”, this does not address the requirements of this finding. Please see HCD’s prior review.

Prior Comment: Zoning, Development Standards and Fees: The element must clarify compliance with new transparency requirements for posting all zoning, development standards and fees on the City’s website and add a program to address these requirements, if necessary.

The Actions & Timeframes portion of Program 1 has been updated as follows: “Continue to post and update all zoning regulations, development standards, and fees on the City website annually throughout the planning period.” (See Housing Plan, page 9.)

4. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove N/A
City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) Approval Time and Requests Lesser Densities: While the element was revised to state that time from project approval to receiving a building permit is 3-4 months, the element does not include adequate analysis of requests to develop housing at densities below those identified.

Specifically, while the element states that projects have been developed at densities lower than those identified, it provides no analysis as to what the projects consisted of or why they developed at lower densities.

The analysis has been expanded to discuss the reasons projects have been developed at lower than maximum allowed densities. (See Technical Report, page III-26.)

5. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) N/A
Special Housing Needs: While the adopted element was revised to provide an adequate analysis for female-headed households, it must still be revised to provide an estimate as to the number of permanent and seasonal farmworkers and provide the number of persons with developmental disabilities within the City.

Prior HCD review stated “Specifically, the element should address the total number of permanent, seasonal farmworkers (e.g., USDA county level data).” (Emphasis added.) The city provided county level data on Technical Report, page I-15. The analysis has been updated to state that while the USDA does not provide farmworker data at the city-level and no other source for this data could be located, the proportion of permanent farmworkers in the Carpinteria Valley, including the city, is likely higher than in the county overall given the concentration of greenhouses in the area, which allows for year-round production.

Technical Report, pages I-12 to 13 includes information on people with developmental disabilities. The analysis has been edited to clarify that people in Carpinteria with developmental disabilities are served by TriCounties Regional Center (TCRC). Approximately 164 clients in Carpinteria received services from TCRC, of which 138 lived in the home of a family member or guardian.

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may N/A
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recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov.

Code, § 65583, subd. (c).)
To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

Program 5 (Affordable Rental Housing): The program was not revised to address this finding. Please see HCD’s prior review.

Prior Comment: This program should be revised to provide a specific timeline stating when the assistance and incentive actions will be implemented.

Program 8 (Facilitate Lot Consolidation): While the program was revised to state that lot consolidations would be implemented on a “project-byproject basis”, it must provide a more specific timeline of how actions and incentives to encourage lot consolidation will be put in place and implemented.

Program 9 (Regulatory Concessions and Incentives for Affordable Housing): The program was not revised to adequately address this requirement. Specifically, it must provide a clearer implementation Program 5 has been updated to clarify that the city’s affordable rental housing program is an existing program which will continue. The city provides assistance and incentives to developers of affordable housing on an ongoing basis as projects are proposed and processed. (See Housing Plan, pages 14-15.)
Program 8 has been revised to include specific incentives that may be offered to encourage lot consolidation and to commit the City to establishing the lot consolidation incentive program by December 2024. (See Housing Plan, pages 18-19.)
The action and timeframe language in Program 9 has been revised to clarify that the city will continue to provide concessions and incentives for affordable housing through a program that is already in place. (See Housing Plan, page 20.)
Program 11 has been revised to list the City’s specific commitments to bring policies and procedures into compliance with state law for each category of special needs housing and has include a quantified objective of completing all zoning code amendments by April 2024. (See Housing Plan, pages 21-24.) Program 14 has been updated to indicate the city’s quantified objective to complete two surveys during the planning period, contact property owners City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
timeframe, and state if concessions are already in place or if they are still being developed.

Program 11 (Special Needs Housing): The program was not revised to address this requirement. Please see HCD’s prior review.

Prior Comment: This program should be revised to specifically state what the City will be doing to bring policies and procedures into compliance with state law for each element of housing for special needs listed in the program. Each activity should have accompanying timeline and quantifiable metrics where applicable.

Program 14 (Housing Code Compliance): While the program was revised to commit to proactive outreach, it must still provide a quantifiable objective as to the number of units that will be preserved through code compliance efforts.
and landlords with nonconforming conditions following each survey, and post annual announcements regarding property maintenance and code compliance. (See Housing Plan, pages 27-28.)

Code, §65583, subd. (c)(1).)
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As noted in Finding A2, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a Program 1 has been updated to include the quantified objective that the program will “[p]rovide adequate sites to accommodate the City’s entire 2023-2031 RHNA allocation of 901 units including rezoning land to City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
shortfall of sites or zoning available to encourage a variety of housing types. Additionally, the element should be revised as follows:

In addition, please be aware, the recent California appellate decision in Martinez v. City of Clovis1 found that while overlays can be used in a rezone, when the base zone allows residential development, both the base zone and the overlay zone must comply with the minimum density requirements of Government Code section 65583.2, subdivision (h). The City should analyze how this decision may impact its current rezone strategy using the R-Residential Overlay and may need to adjust accordingly.
accommodate a shortfall of 292 lower-income units.” (See Housing Plan, pages 6-9.)
Program 1 states that city will submit a rezone application to CCC its General Plan and Zoning Code amendments consistent with statutory deadlines.

Implementation timeframes specific to the other actions included in Program 1 have also been added and/or clarified. (See Housing Plan, pages 6-9.)
As HCD is aware, the city has been coordinating with Coastal Commission and HCD staff to address Coastal Commission concerns regarding consistency of rezone candidate sites with the Local Coastal Plan as well as potential site constraints. Based on coordination to date and revisions to the site inventory, the city believes the site inventory substantially complies with the statutory requirements of State Housing Element law and provides an adequate buffer of potential sites to accommodate the City’s RHNA shortfall even if the Coastal Commission ultimately does not support rezoning of some of the sites.

The city will continue to work expeditiously to process Local Coastal Plan amendments to implement the Housing Element Programs. However, the city has no authority to dictate the Commission’s schedule since it is an independent state agency and therefore cannot commit to specific timing related to Coastal Commission approvals in the Housing Element.

The city is aware of and intends to implement Program 1 consistent with Martinez v. City of Clovis. Program 1 states that “consistent with Government Code Section 65583.2(h) and (i), the Zoning Code amendment will ensure that sites rezoned with the R Overlay District to accommodate the city’s RHNA shortfall do not retain underlying residential densities lower than 20 units per acre.” (See Housing Plan, page 7.)
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Nonvacant Sites Reliance to Accommodate RHNA: The element was not revised to specifically address this requirement. Please see HCD’s prior review.

Prior Comment: Nonvacant Sites Reliance to Accommodate RHNA: As the element relies upon nonvacant sites to accommodate the regional housing need for lower-income households, it should include a program(s) to promote residential development of those sites. The program(s) could commit to provide financial assistance, regulatory concessions, or incentives to encourage and facilitate new, or more intense, residential development on the sites. Examples of incentives include identifying and targeting specific financial resources and reducing appropriate development standards.

The Housing Element includes several programs that promote residential development of nonvacant sites by providing financial assistance, regulatory concessions, and incentives and reducing development standards to encourage new, or more intense, lower-income residential development on these sites.

Specifically, Program 1 (Adequate Sites to Accommodate RHNA) commits the city to amending development standards as necessary to ensure allowable densities can be achieved including amending the 30-foot height limit to allow 3-story development, and reducing parking standard. (See Housing Plan, pages 6-9.)
Program 8 (Lot Consolidation and Subdivision) has been revised to include specific examples of incentives for lot consolidation to encourage consolidation of smaller lots which can improve the feasibility of lowerincome housing development and to commit the city to implement the incentive program by December 2024. These incentives will increase the feasibility of redevelopment of nonvacant sites at maximum densities, particularly those smaller than 0.5 acres. (See Housing Plan, pages 18-19.) Cost is one of the biggest constraints to housing development in the city and region. Program 5 (Affordable Rental Housing Development Assistance) is an existing program that will be continued, which offers assistance to nonprofit housing developers including fee reductions, waivers, or deferrals; reduced parking or other modifications to development standards; the provision of surplus property at no cost; funding support through the city’s Housing Trusts fund; and support in funding applications for tax credits or other housing grant programs. (See Housing Plan, pages 14-15.) Program 10 (Fee Mitigation) is an existing program that encourages redevelopment or more intense use of nonvacant lots by providing fee deferrals, reductions and waivers for projects with minimal public service City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
impacts, retrofit projects, and projects that include affordable housing. (See Housing Plan, pages 20-21.)

3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)
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While Program 5 (Affordable Rental Housing Development Assistance) was revised to state that projects with extremely low-income units would receive “priority processing”, it must specify what this process entails, and what the requirements are to qualify for it.

The list of involvement and assistance offered to nonprofit developers in Program 5 has been updated to specify that priority processing means that city staff prioritizes projects with ELI units over other projects while balancing workload with competing deadlines. As stated in Program 5, priority processing is provided for all projects that include ELI units. (See Housing Plan, pages 14-15.)

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) N/A
As noted in Findings A3 and A4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

The city identified the cumulative effect of development standards (e.g., parking, height limits, setback requirements) as a constraint to mixed use development, a 30-foot height limit in all zone districts as a potential constraint to achieving allowed densities, and potential inconsistencies with state law related various types of special needs housing as potential constraints to development of housing for persons with disabilities and/or special needs. (See Constraints Analysis, Technical Report, pages III-5 to 7.) Program 1 (Adequate Sites to Accommodate RHNA) includes a commitment to evaluate and amend development standards as necessary to ensure allowable densities can be achieved, including the current 30-foot height limit. Program 1 also includes a commitment to review and amend the development review process to improve certainty and objectivity. (See Housing Plan, pages 6-9.)
City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
Program 11 (Special Needs Housing) includes a commitment to amend zoning regulations by April 2024 to comply with state laws related to emergency shelters, low barrier navigation centers, and SRO housing. It also commits the city to amending reasonable accommodation regulations to remove subjective findings for approval and amending permit requirements and required findings for residential care facilities of seven or more persons to ensure consistency with state law and fair housing requirements by April 2024. (See Housing Plan, pages 21-24.)
In addition, the city’s existing Density Bonus program (Program 7) and fee mitigation programs (Programs 5 & 10) help to reduce or remove governmental and non-governmental constraints to housing by allowing modifications to development standards to achieve allowed densities (including bonus density) and reducing the cost of housing development.

Depending upon the results of that analysis, the City may need to revise or add programs.

Additionally, the adopted element did not revise other program actions to address the City’s obligation to AFFH including how programs address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Program 5A also was not revised to describe how all the City’s housing programs The AFFH analysis has been expanded and revised based on the comments under Finding A1. Based on the revisions and as described below, the city does not believe revisions or additions to programs are necessary to substantially comply with state housing element law.

As discussed in Appendix D, pages D-64 to 65, there is no land available for residential development in the very limited high opportunity areas that exist in the city. Further, the city is relatively homogenous in terms of many AFFH factors including educational and economic opportunity, access to transit, low poverty rate, and integration. Nevertheless, the city’s criteria for City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
comply with and further the requirements and goals of Government Code section 8899.50, subdivision (b).
identifying sites for the sites inventory included measures intended to affirmatively furthering fair housing opportunities and mobility. The criteria prioritizes sites in close proximity to public transit, grocery stores, health care services, schools, recreation, and employment and avoids sites with significant environmental constraints. Site identification criteria is discussed in detail in Appendix B, page B-4.

The Housing Element does not have a Program 5A. This statement appears to have been inadvertently included in HCD’s letter.

N/A
While the element was revised to include units to be constructed, rehabilitated, and conserved in the planning period, the number of mobile homes must still be broken down by income category.

A footnote has been added to Table H-1 describing the breakdown of conservation units by income category as follows: 177 units through Section 8 Rental Assistance (Program 4) in extremely low and very low income categories. 861 units through Conservation of Mobile Home Parks & Rent Stabilization (Program 12), assumes 33% in extremely low and low, 33% in low, and 33% in moderate income categories. (See Housing Plan, page 41.) D. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, 65583, subd. (c)(9).)
N/A
While the element was revised to add additional information as to the number of groups that were contacted to take part in the public participation process, it still does not describe who participated in the public participation process, nor does it describe where the comments in Table C-2 come from. Additionally, while Program 17 commits to reaching out to special needs groups and neighborhoods of more concentrated lower-income residents, it must still describe what Participants in the Housing Element update included affordable housing developers including People’s Self Help Housing; fair housing organizations including the Rental Housing Mediation Program and Gray Panthers Network of Santa Barbara; housing advocates including Californians for Homeownership, YIMBY Law, and California Housing Defense Fund; and community-based and faith-based organizations, including family service agencies, senior programs, and health and human services; and residents. The City also directly worked with People’s Self Help Housing, which serves the City of Carpinteria Response to June 12, 2023 HCD Review Letter HCD Comments City Response
methods of outreach will be employed, and how often they will be carried out.
interests of lower-income households and special needs groups and has several successful lower-income housing projects in the City, to solicit comments and recommendations on housing needs, barriers to fair and affordable housing, and opportunities for development. (See Appendix D, p.

D-1 to 2 and email from People’s Self Help Housing in Appendix C, pages C-52 to 53.)
All written public comments received on the Housing Element are all included in Appendix C. Table C-2 (pages C-15 to 31) lists each comment received and how those comments were addressed in the Housing Element.

The names of speakers providing comments at the initial Planning Commission and City Council Housing Element update study sessions were not recorded and instead a summary of the comments made by one or more stakeholders was prepared. Table C-2 has been updated to indicate that general public comments were from first three housing element meetings.

All other public comments are attributed to specific commenters.

As the city does not have concentrated areas of lower-income residents, outreach efforts are generally citywide with a focus on fair housing issues specific to renters and people with disabilities. Program 17 has been updated to clarify that outreach will be through:
• Printed materials available at City Hall on an ongoing basis and updated annually by April each year,
• Workshops and other in-person gatherings facilitated by the Rental Housing Mediation Program at least once per year, and
• Information posted on the City website and updated annually by April each year. (See Housing Plan, pages 31-39.)
Attachment D.

January 8, 2024 HCD “Substantial Compliance” Letter
Carpinteria Housing Element Re-adoption
January 22, 2024 City Council Meeting
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
January 8, 2024
Nick Bobroff, Director
Community Development Department
City of Carpinteria
5775 Carpinteria Avenue
Carpinteria, CA 93013
Dear Nick Bobroff:

RE: City of Carpinteria’s 6th Cycle (2023-2031) Revised Draft Housing Element Thank you for submitting the City of Carpinteria’s (City) revised draft housing element received for review on November 14, 2023. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from Peter Grace and Victor and Susan Schaff pursuant to Government Code section 65585, subdivision (c).

The revised draft element meets the statutory requirements described in HCD’s June 12, 2023 review. This finding was based on, among other reasons, actions in Program 1 (Adequate Sites to Accommodate Regional Housing Needs) to expand the City’s Residential Overlay District to accommodate the City’s 6th Cycle Regional Housing Needs Allocation (RHNA). The housing element will comply with State Housing Element Law (Article 10.6 of the Gov. Code) when it is adopted, submitted to, and approved by HCD in accordance with Government Code section 65585, subdivision (g).

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), as the City did not adopt a compliant housing element within 120 days of the statutory deadline (February 15, 2023), Program 1 (Adequate Sites to Accommodate Regional Housing Needs) must be completed no later than one year from the statutory deadline.

Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i). Please be aware, if the City fails to adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until rezones to accommodate a shortfall of sites pursuant to Government Code section 65583, subdivision (c), paragraph (1), subparagraph (A) and Government Code section 65583.2, subdivision (c) are completed.

Nick Bobroff, Director

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Additionally, the City should continue to coordinate with the California Coastal Commission to expeditiously amend a certified Local Coastal Plan and make sites available with zoning and development standards to accommodate the City’s RHNA.

HCD urges the City to complete certification of to the Local Coastal Plan in a manner consistent with statutory deadlines. If the City’s adopted rezones are not submitted to and certified by the Coastal Commission in a timely manner, or if the Coastal Commission does not certify the rezoning of adequate sites to meet the City’s RHNA, HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

HCD appreciates the hard work and dedication the City’s housing element team provided in preparation of the City’s housing element and looks forward to receiving the City’s adopted housing element. If you have any questions or need additional technical assistance, please contact Reid Miller, of our staff, at [email protected].

Sincerely,
Melinda Coy
Proactive Housing Accountability Chief
Attachment E.

Draft CEQA Notice of Exemption for
2023-2031 Housing Element
Carpinteria Housing Element Re-adoption
January 22, 2024 City Council Meeting
202 CEQA Transmittal Memorandum
County of Santa Barbara - Clerk of the Board of Supervisors 105 E. Anapamu St. Room 407 Santa Barbara CA 93101 (805) 568-2240
Complete this form when filing a Notice of Determination (Negative Declaration, Mitigated Negative Declaration, Environmental Impact Report) or Notice of Exemption.

A scanned copy of the Department of Fish and Wildlife Receipt, Transmittal Memorandum and the CEQA filing including the date/time of posting will be emailed to the Lead Agency and Project Applicant. If you would like a return copy, please submit an extra copy along with a pre-addressed, stamped envelope.

Contact Person Phone
Lead Agency Lead Agency Email
Project Title
Project Applicant Email Phone
Project Applicant Address City State Zip
DOCUMENT BEING FILED:
տ Notice of Determination - Environmental Impact Report (EIR) .......................................................................................... տ 202 Filing Fee ............................................................................................................................................. $, տ Previously Paid (must attach receipt) ................................................................................................................ $0.00 տ No Effect Determination (must be attached) ...................................................................................................... $0.00 Environmental Filing Fees will be collected only for projects that are approved. The Applicant must attest to the following:
տ This project has been approved. Date of Approval: Click or tap to enter a date. տ Notice of Determination - Negative Declaration (ND) or Mitigated Negative Declaration (MND).................................... տ 202 Filing Fee ............................................................................................................................................ $2,
տ Previously Paid (must attach receipt) ................................................................................................................ $0.00 տ No Effect Determination (must be attached) ...................................................................................................... $0.00 Environmental Filing Fees will be collected only for projects that are approved. The Applicant must attest to the following:
տ This project has been approved. Date of Approval: Click or tap to enter a date. տ Notice of Exemption…………………………………………………………………………………………………..$0.00 տ County Administrative Handling Fee (required for all filings, effective 7/19/18) ……………………………….…$50.00 TOTAL:

PAYMENT METHOD: ALL APPLICABLE FEES MUST BE PAID AT THE TIME OF FILING ܆ Cash ܆ Credit ܆ Check #______________________ ܆ Journal Entry #_________________________ In person only In FIN send to ‘COB CEQA’ in CEO Dept
2 Nick Bobroff (805) 755-4407
City of Carpinteria [email protected]
City of Carpinteria 2023-2031 Housing Element Update
City of Carpinteria [email protected] (805) 755-4407 5775 Carpinteria Ave. Carpinteria CA 93013
50 ■
Statutory Exemptions. State code number:
_______________________________________________
Print Form
Notice of Exemption Appendix E
To: Office of Planning and Research From: (Public Agency): ____________________________ P.O. Box 3044, Room 113 _______________________________________________ Sacramento, CA 95812-3044 County Clerk
(Address)
___________________________
___________________________
County of: __________________
Project Title: ____________________________________________________________________________ Project Applicant: ________________________________________________________________________ Project Location - Specific:

Project Location - City: ______________________ Project Location - County:

Description of Nature, Purpose and Beneficiaries of Project:
_____________________
Name of Public Agency Approving Project: _____________________________________________________ Name of Person or Agency Carrying Out Project: ________________________________________________ Exempt Status: (check one):

Ministerial (Sec. 21080(b)(1); 15268);
Declared Emergency (Sec. 21080(b)(3); 15269(a));
Emergency Project (Sec. 21080(b)(4); 15269(b)(c));
Reasons why project is exempt:

Lead Agency
Contact Person: ____________________________ Area Code/Telephone/Extension: _______________ If filed by applicant:
Attach certified document of exemption finding.
Has a Notice of Exemption been filed by the public agency approving the project? Yes No Signature: ____________________________ Date:
6LJQHG E\ /HDG $JHQF\ 6LJQHGE\ $SSOLFDQW
Authority cited: Sections 21083 and 21110, Public Resources Code. Date Received for filing at OPR:

Reference: Sections 21108, 21152, and 21152.1, Public Resources Code. _______________
Categorical Exemption. State type and section number: ____________________________________ ______________________________________________
______________ Title: _______________________
Revised 2011
City of Carpinteria
5775 Carpinteria Avenue
Carpinteria, CA 93013
Santa Barbara
105 East Anapamu Street
Santa Barbara, CA 93101
City of Carpinteria 2023-2031 Housing Element Update
City of Carpinteria
City of Carpinteria
Carpinteria Santa Barbara
On January 22, 2024, the City of Carpinteria ("City") re-adopted the 2023-2031 Housing Element ("Housing Element"). It was previously adopted on April 10, 2023, but had to be revised per comments from the California Department of Housing and Community Development. The Housing Element provides a background of housing in the City and sets forth the City's "blueprint" for how it will plan to accommodate local housing needs.

City of Carpinteria
City of Carpinteria
x Cal. Code Regs., tit. 14 § 15061(b)(3)
Re-adoption of the Housing Element is exempt pursuant to the "common sense exemption" (Section 15061(b)(3) of the CEQA Guidelines). Given the Housing Element's nature and scope, it can be seen with certainty that there is no possibility that the Housing Element could have a significant effect on the environment because it does not approve any development project or other physical change to the environment. Rather, the Housing Element is a document that sets forth the City's policies to plan for the City's regional housing needs allocation. Additionally, the housing Element does not grant any development entitlements or authorize development beyond what is allowed under the City’s current General Plan and Zoning Code. Approval of any subsequent zoning amendments or housing development projects in accordance with the policies set forth in the Housing Element will comply with CEQA. Based on these factors, it can be seen with certainty that the programs and policies set forth in the Housing Element would not have a significant effect on the environment. Accordingly, the Housing Element is exempt from CEQA pursuant to the common sense exemption.

Nick Bobroff (805) 755-4407
Community Development Director, City of Carpinteria
■
City of Carpinteria
Cour.rcrl Acrruoa Srnrr Reponr
January 22,2024

ITEM FOR COUNCIL CONSIDERATION
Presentation on the Carpinteria Shoreline Continuing Authorities Program by U.S. Army Corps of Engineers

STAFF RECOMMENDATION
Receive and file presentation.

Sample Motion:

I move to receive and file presentation.

BACKGROUND
The United States Army Corps of Engineers (ACOE) has been working on a sturdy for the Carpinteria Shoreline since 2003. The Study has amassed a wealth of data related to the geomorphology, environmental, economic and possible solutions to reduce the frequency of storm wave damage along the Carpinteria City Beach.

The City received a Division of Boating & Waterways (DBAW) grant in 2019 for the USACE study and match requirements. The City still has $600,000 remaining. ln addition, the City is seeking additional grant funding for a continuing match of the project. Previously, this project was a special study, and in 2022 was reclassified under the Continuing Authorities Program (CAP), granting ACOE dedicated funding for the project.

On July 2,2020, the Feasibility Study as constituted under that ACOE program was recommended for termination. Termination was recommended principally due to the findings that the maximum cost of a proposed solution to reduce storm wave damage was within the limits of the Continuing Authorities Program (CAP) and the study could be more readily completed under the CAP program terms.

Presentation on the carpinteria shoreline continuing Authorities program January 22,2024
Page2
This study is being conducted under CAp Section 103
o The secretary of the Army, acting through the chief of Engineers, is authorized to plan, design, and imprement certain types oiwater resou rces projects without add itiona I project specific cong ressional authorization.
o Section 103 of the CAp
o Projects implemented under this authority are formulated for protecting utilities, roadways and other public infrasiructure, private properties, a-nd facilities against damages caused by storm driven waves'and currents. o The U.S. Army Corps of Engineers Los Angeles District (USACE), along with the non-federal sponsor, the City of Carpinteria (City), have undertaken the Carpinteria Shoreline Feasibility Study to determine if feasible alternatives exist to reduce storm damages along the Carpinteria shoreline in Santa Barbara, County, California.

The purpose of this agenda matter is to receive a presentation (Attachment A) from the AIOE and to provide the City Council and public with a briefing on recent program efforts, including:
. Study Authority
. Study Area and Scope
. CAP Funding Requirements per phase
o CAP Feasibility Study Timeline
o Public lnvolvement Plan
o Questions and Discussion

POLICY SISTENCY
The Study results will define acceptable local solutions to reduce or stabilize shoreline erosion. The pursuit of this goal is consistent with the Safety Etement of the City's General Plan.
a
Objective S-4; Minimize the potential risks and reduce the loss of life, property and the economic and social dislocations resulting from flooding.

Policy S-4f; Programs and regulations should be developed that are appropriate to respond to the need to protect existing and future private property improvements from winter ocean wave action.

Policy 13 states: The City shall support and facilitate the current Army Corps of Engineers (ACOE) feasibility study and othenryise pursue longterm solutions for beach nourishment and establishment of a vegetated dune system at City Beach a
a
a
G:\CC Staff Reports\2024 0122\Final\Carpinteria Shoreline Presentation\Carpinteria Shoretine Presentation.docx
Presentation on the Carpinteria Shoreline Gontinuing Authorities Program January 22,2024

Page 3 ends

As an interim measure, and with permission from the Coastal Commission and US Army Corps of Engineers, the City may construct a sand berm on the City Beach parallel to the homes fronting on the beach.

FINANCIAL CONSIDERATIONS
There are no financial consideration associated with receipt of this presentation

LEGAL AND RISK MANAGEM ENT CONSIDERATIONS
No legal issues are presented in this report.

OPTIONS

1. Receive and file presentation.

PRINCIPAL PARTIES EXPECTED AT MEETING
U.S. Army Corps of Engineers

ATTACHMENTS
Attachment A: Presentation (Slides)
Staff contact: Erin Maker, Environmental Program Manager (805) 880-341 5, [email protected]
Reviewed by: Michael Ramirez, City Manager
(805) 7 55-4450, [email protected]
G:\CC Staff ReportsV024 0122\Final\Carpinteria Shoreline Presentation\Carpinteria Shoreline Presentation.docx

City of Carpinteria

COUNCIL AGENDA STAFF REPORT
January 22, 2024

ITEM FOR COUNCIL CONSIDERATION
Informational Report on the City's Emergency Services Management Program for 2023

STAFF RECOMMENDATION
Receive and file the report
Sample Motion: I motion to receive and file the report

BACKGROUND
The City has established a comprehensive emergency services program aimed at enhancing its capacity to prepare for, respond to, and recover from disasters and emergencies. Covering all phases of emergency management-mitigation, preparedness, response, and recovery-this program ensures the City's compliance with legal requirements related to emergency management practices. It also maintains alignment with recognized emergency response systems, including the Standardized Emergency Management System (SEMS) and the National Incident Management System (NIMS).

Situated within the Public Safety division of the General Government Department, the City's Emergency Services Management program is overseen by the Program Manager in collaboration with Department Heads and under the supervision of the City Manager.

This program actively implements the emergency services provisions outlined in the Carpinteria Municipal Code (Chapter 2.40).

Success in the emergency services program is reliant on robust partnerships and collaborative relationships. This includes active cooperation with the Santa Barbara County Office of Emergency Management (SBCOEM), and participation in the Operational Area Council for regional coordination. Emphasizing the significance of partnerships, the City actively collaborates with residents, non-profit organizations, private industry, and other governmental agencies in various emergency servicesrelated activities. This collaborative approach ensures a comprehensive and effective response to emergency situations. Additional partners include:
• Carpinteria-Summerland Fire Protection District
Informational Report on the City's Emergency Services Management Program for 2023 January 22, 2024

Page 2 ends

• Santa Barbara County Sheriff's Office
• Santa Barbara County Emergency Managers Council
• Aware and Prepare Public Education Committee
• Santa Barbara County CERT Committee
• Carpinteria Unified School District Safety Committee
• Emergency Public Information Communicators (EPIC)
• Local Businesses
• Public Utilities and Special Districts
• State & Federal Agencies
Annually, emergency services projects are identified and prioritized based on Department goals and objectives. The following emergency services goals currently drive programming:

1. Strengthen community emergency preparedness outreach and identify opportunities to foster relationships among individuals, communities, and organizations to encourage trust and build consensus.

2. Develop and implement a training program to ensure City staff are prepared to lead community response efforts and cooperate with other agencies in the event of an emergency.

3. Enhance the City's ability to respond to emergencies and reach residents and visitors with vital information on severe weather and other emergencies.

While there are many actions that take place on a regular basis to move towards the achievement of these goals, there are three main programmatic areas that the majority of work performed falls into:

1. Emergency Response Capacity Building

2. Training, Drills & Exercises

3. Community Preparedness
In 2020-2022 all Community Emergency Response Team (CERT), LISTOS and Emergency Preparedness trainings, drills and exercises were canceled due to the declared state of emergency followed by Executive Order N-33-20 instructing all individuals living in the State to stay home due to the COVID-19 pandemic.

All City efforts were redirected towards COVID-19-related activities and response. On February 28, 2023, California Governor Newsom issued a proclamation officially ending the COVID-19 State of Emergency in the state.

G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx Informational Report on the City's Emergency Services Management Program for 2023 January 22, 2024

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DISCUSSION
On January 9, 2023, Carpinteria faced a storm that led to flooding, necessitating evacuations and activating the Emergency Operations Center along with the emergency shelter at the Veteran's Hall.

Thankfully there was no loss of life or property; however, the city did incur damages, including tidal waters depositing wood debris onto Carpinteria Beach. Carpinteria Creek experienced issues, conveying upstream sediment debris and fallen trees or branches.

Creek bank erosion caused pavement damage to the bike path, undermining its structure.

Addressing these challenges involved repairing approximately 480 square feet of concrete pavement on the bike path. Citywide drainage inlets were impacted, and approximately 32, 194 square feet of asphalt concrete pavement on the streets deteriorated due to the emergency debris basin clearing haul route. As a result, City staff engaged in recovery efforts for the accepted amount of $113,896.60 with the Federal Emergency Management Agency (FEMA). and California Governor's Office of Emergency Services (Cal OES) which are still underway.

Throughout 2023, additional but less severe rainstorms occurred. Each event prompted swift actions by public works staff and others. CERT volunteers responded to a request from Sandpiper Mobile Home Park residents to help sort and organize the emergency shed after their experience with a tornado on March 21, 2023.

An After-Action Report/Improvement Plan, developed and reviewed by involved emergency response City staff, identified opportunities for improvement in the City's response capabilities. These insights guided actions taken in 2023 to prepare for El Nino-related storms expected from December 2023 to April 2024.

Emergency Response Capacity Building
As part of our efforts to reduce risks, the City Council approved the update of the Local Hazard Mitigation Plan (LHMP) on April 3, 2023, following FEMA's approval on August 8, 2022. We are currently awaiting FEMA's approval to include it in the Safety Element and General Plan, and we are actively working on the associated grant closeout, which is expected to be completed by April 2, 2024.

The Emergency Operation Center (EOC) Organization Chart has undergone a comprehensive update. Due to staff changes and advancements in best practice, the document has become antiquated. It has now been revised to accurately reflect recent staff changes and will be consistently reviewed, to ensure compliance with best practices.

Alongside updating the organizational chart, we've created a schedule assigning City staff to roles for EOC or Emergency Shelter activation. The revised schedule now aligns G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx Informational Report on the City's Emergency Services Management Program for 2023 January 22, 2024

Page 4 ends

with current needs and best practices, extending operational periods from 8 to 12 hours, in accordance with County and state incident command guidelines.

Crucially, staff members have undergone the necessary EOC trainings to effectively respond to incidents requiring an EOC activation. Most staff have completed either basic EOC training and/or specific EOC section training relevant to their assignments in areas such as Management, Planning, Logistics, Operations, and Finance. Three of these trainings were conducted by Roy Dugger, the Emergency Services manager for the City of Santa Maria, who brings extensive training experience and emergency response expertise. Other trainings were provided by SBCOEM. For the two remaining sections yet to undergo training, additional sessions have been scheduled and assigned for the first quarter of 2024.

The City Manager participates in quarterly Operational Area Council meetings. The City's Program Manager attends the monthly Santa Barbara County Operational Area Emergency Managers committee meetings conducted by County OEM. These meetings include discussions around topics that may be hazards relevant to the various agencies, as well as strategies and mitigation topics. Additionally, this year we participated in:
• Introduction with Chief Robert Kovach
• CalOES webinar designed to discuss lessons learned in Monterey and Merced Operational Areas related to flooding during the 2023 Winter Storms • Santa Barbara County and OA El Nino Shelter Planning Meeting • Protective Action Coordination and Communications Meeting • CalOES DR-4683 & 4699 Applicant's Briefing
Training, Drills & Exercises
Completed Training Initiatives in 2023:
/CS 100 and National Incident Management System /CS 700:

The full-time staff successfully underwent the Incident Command System (ICS) 100 and National Incident Management System (NIMS) ICS 700 training, ensuring compliance with FEMA requirements for the training of all emergency personnel.

Red Cross Emergency Shelter Training:

Emergency shelter training conducted by the Red Cross was held in Carpinteria and extended to staff, CERT volunteers, and community partners, including Girl's Inc. Training was also provided to neighboring jurisdictions, including the City of Goleta and the Santa Barbara County. Fifteen Carpinteria-based individuals and over 30 nearby partners are now trained to respond to and lead an emergency shelter activation.
2023 Shakeout:

In October, the City participated in the statewide California Shakeout earthquake preparedness drill for the first time in over three years. City Hall staff participated in the exercise, received instruction on best practices from Anthony Rodriguez G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx Informational Report on the City's Emergency Services Management Program for 2023 January 22, 2024

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the Operations & Disaster Services Specialist for the Foodbank of Santa Barbara County, and all participants in the 60-second drill received shake coupons compliments of IHOP.

Fire Extinguisher Training:

In November, a fire extinguisher training session was held at the City Hall campus with a dozen staff members participating. The training was provided by the Carpinteria-Summerland Fire District.

CPRIAED Training:

A CPR/AED staff training session is scheduled for February 21st and will be conducted by the Carpinteria-Summerland Fire District.

NWS Training:

A training at the National Weather Service office in Oxnard is being scheduled for key staff, as well as the City Manager (who acts as EOG Director) to better understand weather data, predictions, and potential impacts.

Tabletops:

City Manager Michael Ramirez and Program Manager Uribe Mutal observed the City of Goleta's El Nino Storm Series Tabletop Exercise on October 5, 2023, and actively participated in the Santa Barbara County Emergency Operations Plan Tabletop Exercise on December 19, 2023.

Additionally, in 2023, Program Manager Olivia Uribe Mutal successfully completed three training programs and attended an additional presentation, including:
• MGT 4126V Continuity of Government Operations Planning, provided by the Rural Domestic Preparedness Consortium.
• Lessons Learned from the Route 91 Harvest Music Festival Shooting, provided by Lyrasis.
• AWR319 Leveraging Tools for Conducting Damage Assessments, provided by the National Disaster Preparedness Training Center.
• Southern California Edison Wildfire Mitigation Activities presentation.

Community Preparedness
CERT volunteers diligently reviewed and updated the Carpinteria Community Emergency Response Team Program (CERT) phone list, ensuring it reflects individuals keen on responding to emergencies and seeking additional training. Volunteers have also diligently maintained and prepared the Red Cross trailer, ensuring it is stocked, cleaned, and ready for immediate response to any emergency. Additionally, a group of CERT program members actively participated in the "Local's Day" at the opening of the 2023 Avocado Festival. Looking ahead, a CERT training session is scheduled for the first quarter of 2024.

G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx Informational Report on the City's Emergency Services Management Program for 2023 January 22, 2024

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Community Emergency Preparedness presentations were held at Kinderkirk Preschool Parent Education Night, San Roque Mobile Home Park, Rancho Granada Mobile Home Parks, and Head Start in Carpinteria.

LISTOS an emergency preparedness program of the City of Carpinteria participated in emergency preparedness education at the City's inaugural Together We Thrive Community Resource Fair.

To address critical emergency response actions, the following plans have been identified as priorities to develop and/or update:
• Emergency Operations Plan (EOP): The EOP addresses the City's planned response to extraordinary emergency situations by establishing operational concepts, responsibilities and procedures. Demonstrates compliance with the SEMS and NIMS. The EOP update process is ongoing.
• Employee Notification & Reporting Plan: Outlines employee roles, responsibilities, and reporting requirements during an emergency. • EOC Activation Handbook: Clearly outlines the steps involved in the activation of the City EOC, including key procedures and functional checklists. This plan is based on the EOP.
• Continuity of Operations Plan (COOP): A COOP is crucial to maintain municipal services and operations during disruptions, emergencies, or disasters.

The COOP encompasses aspects such as service resilience, legal compliance, resource management, emergency response coordination, communication strategies, financial stability, and employee safety and well-being, among other considerations.
• Tsunami Response Plan: Provides information and guidance specific to receiving information that a tsunami watch, advisory, or warning is in effect.

Required component to receive TsunamiReady designation by the National Weather Service.

Additional actions for this year include:
• Resuming Safety Council meetings as outlined by CMC 2.40.040 • Establishing agreements for emergency response and collaboration with other partners in the city including: Girls Inc. of Carpinteria, Animal Medical Clinic, and restaurants and hotels for City staff, evacuees, and shelter users. • Updating agreement with Carpinteria-Summerland Fire Protection District related to the ownership, maintenance and joint use of an EOC generator.

POLICY CONSISTENCY
The City's Emergency Services Management Program aligns with the purpose and policies of the City's General Plan Safety Element including reducing death and injuries, property damage and economic and social dislocation from natural and man-made disasters.

G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx Informational Report on the City's Emergency Services Management Program for 2023 .

January 22, 2024

Page 7 ends

FINANCIAL CONSIDERATIONS
The Emergency Services Program is funded through the General Fund - Annual budget of $13,950, excluding staff time.

Staff contact: Olivia Uribe Mutal, Program Manager
805-755-4401; [email protected]
Reviewed by: Michael Ramirez, City Manager
(805) 755-4450, [email protected]
G:\CC Staff Reports\2024 0122\Final\Emergency Services 2024 Staff Report.docx City of Carpinteria

COUNCIL AGENDA STAFF REPORT
January 22, 2024

ITEM FOR COUNCIL CONSIDERATION
2023 Annual Integrated Pest Management Report.

STAFF RECOMMENDATION
Receive and file the 2023 Annual Integrated Pest Management Report.

Sample Motion: I move to receive and file the 2023 Annual Integrated Pest Management Report.

BACKGROUND
On January 9, 2012, the City Council adopted Resolution No. 5355, establishing an Integrated Pest Management (1PM) policy. The 1PM policy is intended to manage environmental pests by reducing or eliminating the use of pesticides at City facilities or improvements including buildings, grounds, open spaces, parks, and streets. The implementation of the 1PM policy provides for long term beneficial effects on the overall public health. The 1PM policy does not completely prohibit the use of pesticides. Rather, it requires the establishment of pesticide free zones where no pesticides are to be used within park play structures and picnic areas unless an emergency arises. The 1PM policy references the use of pest intervention options and tactics from the University of California, Davis; California Invasive Plant Council; and California Department of Pesticide Regulation.

The 1PM policy comprises of the following tenets:

1. Establishes the goal of reducing or eliminating the use of toxic pesticides through the use of common-sense principals of 1PM. Use of 1PM tactics, such as eliminating habitat, eliminate food sources, mulching, hand or mechanical weeding and rodent trapping, will be the first line of defense.

2. Establishes the use of 1PM methodology for selecting the appropriate pest intervention options. Observation, identification and monitoring are three keys to early actions.
2023 Annual Integrated Pest Management Report
January 22, 2024

Page 2 ends

3. Commits the City to establish pesticide free zones where no pesticides will be used unless an emergency arises. These areas will include park play structures and picnic areas.

4. References the use of 1PM tactics from reputable mainstream sources; specifically, the University of California at Davis, the California Invasive Plant Council and the California Department of Pesticide Regulation.

5. Avoids whenever possible the contamination of buildings, soil, air, and water and protects people, animals and beneficial plants and insects from toxic exposures.

6. Establishes the requirement that all personnel involved in pest management at the City receive training and continuing education on the use of pesticides.

7. Requires cooperation and communication between City departments and City Contractors by setting standard operating procedures for the control of pests.

8. Establishes an 1PM Advisory Committee (IPMAC) with up to nine members that includes representation from the Parks, Recreation, and Community Services Department, Public Works Department, Carpinteria Open Space Management Advisory Board, and at least two at large community members that can make recommendations to the City Council on implementation and amendment of the 1PM policy.

9. Establishes a public outreach and information program to help others in the community reduce the use of pesticides.

10. Establishes that effective public notification will be implemented when pesticides are used. The utilization of a Pesticide Hazard and Exposure Reduction (PHAER) Zone system is to be utilized to help accomplish the public notification objective. The PHAER Zone system also includes the creation of a color metric pesticide list potentially used by the City which groups pesticides into three groups with low (green) medium (yellow) and high (red) toxicity.

The purpose of this agenda matter is for the City Council to receive and file the 2023 Annual Integrated Pest Management Report.

DISCUSSION
The 1PM policy requires year-round management including an annual report of any pesticide use, pest intervention options and tactics, and any recommendations for the ensuing year. Pursuant to the 1PM policy, the 2023 Annual Integrated Pest Management Report is submitted herein as shown as Attachment A. In brief, the 2023 Annual Integrated Pest Management Report discloses information about issues and control tactics regarding the following encountered pests:
► Weed and invasive plants ► Insects ► Rodents
Any established pesticide free zones are also disclosed. 2023 Annual Integrated Pest Management Report
January 22, 2024

Page 3 ends

The 2023 Annual Integrated Pest Management Report does not include cost information, and cost-per-incident varies depending on the type of pest. Since the establishment of the 1PM policy, implementation has-is shown to avoid or reduce the public health, financial, and legal risks of environmental cleanup and/or abatement.

POLICY CONSIDERATIONS
The recommendation is consistent with the 1PM policy.

The recommendation may be found consistent with the National Pollutant Discharge Elimination System Phase II Municipal Small Separate Storm Sewer System Permit for stormwater quality.

The recommendation may also be found consistent with the City's Mission Statement, in part:

Government shall make judicious use of the City's limited resources to promote the highest possible quality of life for all of Carpinteria's residents. This includes providing services consistent with community needs as well as protecting the social and physical environment.

FINANCIAL CONSIDERATIONS
No Additional Funding Requested.

LEGAL AND RISK MANAGEMENT CONSIDERATIONS
The recommendation is exempt from the environmental review requirements of the California Environmental Quality Act (CEQA) pursuant to Section 15061 (b)(3) of Title 14 of the California Code of Regulations because it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment. Further, recommendation is exempt from CEQA on the separate and independent ground that it is an action of a regulatory agency (i.e., City) for the protection of the environment because, among other things, it will regulate the use chemical pesticides. Thus, the recommendation is categorically exempt from the requirements of CEQA under Section 15308 of Title 14 of the California Code of Regulations as an action by a regulatory agency for the protection of the environment.

OPTIONS

1. Receive and file the 2023 Annual Integrated Pest Management Report. (Staff recommendation)

2. The City Council could choose to not approve the recommendation and direct staff as determined appropriate.
2023 Annual Integrated Pest Management Report
January 22, 2024
Page4

ATTACHMENTS
Attachment A: 2023 Annual Integrated Pest Management Report Staff contact:

Tiffany Smith, Parks and Facilities Supervisor
(805) 755-4431; [email protected]
Reviewed by:

John L. Ilasin, Public Works Director
(805) 880-3402; [email protected]
Reviewed by:

Michael Ramirez, City Manager
(805) 755-4450; [email protected]

ATTACHMENT A
2023 Annual Integrated Pest Management Report

THIS PAGE INTENTIONALLY LEFT BLANK

CITY OF CARPINTERIA
Annual Integrated Pest Management Report
2023
Prepared by:

Tiffany Smi
Parks and Facilities S ervisor
ISA Certified Arborist WE-10226A

TABLE OF CONTENTS
Introduction 1
Pest Issues and Control Tactics 3
Appendix 9
Safety Data Sheets
List of Trained Personnel
Glyphosate Fact Sheet

INTRODUCTION
On January 9, 2012, the City Council adopted Resolution No. 5355, establishing an Integrated Pest Management (1PM) policy. The 1PM policy is intended to manage pests by reducing or eliminating the use of pesticides at City facilities or improvements including buildings, grounds, open spaces, parks, and streets. The implementation of the 1PM policy provides for long term beneficial effects on the overall public health. The 1PM policy does not completely prohibit the use of pesticides. Rather, it requires the establishment of pesticide free zones where no pesticides are to be used within park play structures and picnic areas unless an emergency arises. The 1PM policy references the use of pest control options and tactics from the University of California, Davis; California Invasive Plant Council; and California Department of Pesticide Regulation.

The 1PM policy comprises of the following tenets:

2. Establishes the use of 1PM methodology for selecting the appropriate pest intervention options. Observation, identification and monitoring are three keys to early actions.

3. Commits the City to establish pesticide free zones where no pesticides will be used unless an emergency arises. These areas will include park play structures and picnic areas.

5. Avoids whenever possible the contamination of buildings, soil, air, and water and protects people, animals and beneficial plants and insects from toxic exposures.

6. Establishes the requirement that all personnel involved in pest management at the City receive training and continuing education on the use of pesticides.

7. Requires cooperation and communication between City departments and City Contractors by setting standard operating procedures for the control of pests.

9. Establishes a public outreach and information program to help others in the community reduce the use of pesticides.

10. Establishes that effective public notification will be implemented when pesticides are used. The utilization of a Pesticide Hazard and Exposure Reduction (PHAER) Zone system is to be utilized to help accomplish the public notification objective. The PHAER Zone system also includes the creation of a 1 color metric pesticide list potentially used by the City which groups pesticides into three groups with low (green) medium (yellow) and high (red) toxicity.

The 1PM policy requires year-round management including an annual report of any pesticide use, pest intervention options and tactics, and any recommendations for the ensuing year. Pursuant to the 1PM policy, this report discloses information about issues and control tactics regarding the following encountered pests in year 2023:
► Weed and invasive plants ► Insects ► Rodents
Copies of safety data sheets of pesticide products and list of trained personnel of administering pesticides, respectively, are shown in the Appendix.

The 2023 Annual Integrated Pest Management Report does not include cost information, and cost-per-incident varies depending on the type of pest. Since the establishment of the 1PM policy, implementation is shown to avoid or reduce the public health, financial, and legal risks of environmental cleanup and/or abatement.

A copy of this report is filed with the City Clerk for public inspection. 2 PEST ISSUES AND CONTROL TACTICS

1. Weeds and Invasive Plants
All weed and invasive plant control used manual methods including hand-hoeing or pulling, mower and weedeater equipment, and mulching. Herbicides were used for excessive infestation on an as-needed basis in the following areas:
► Viola Fields ► El Carro Park ► Franklin Creek Park
Pesticide free zones were also establised in the aforementioned areas.

Although glyphosate is determined to be safe based on independent scientific research, no glyphosate was used during the current reporting period. See Glyphosate Fact Sheet in the Appendix.

Broadleaf Weeds
Sometimes, broad leaf weeds can be controlled by simply altering the cultural practices to favor the grass plants rather than the weeds. Cultural controls may include raising or lowering the mowing height, changing the frequency of mowing, lengthening or shortening the period between irrigations, and/or increasing the application of fertilizer and aeriation of the soil to ameliorate compaction.

Clover is the primary broad leaf weed. A dense infestation of broadleaf weeds such as clover will out compete the desired Bermuda grass but does not stand up to the rigors of sports play. As the turf weakens, the broadleaf weeds will readily invade the open areas that remain.

Due to the continuing growth of broadleaf weeds in sports fields, herbicides are recommended for use in order to improve turf conditions. Applications must be performed by trained personnel. A combination of proper cultural practices and herbicide is sometimes necessary to effectively control broadleaf weeds in turf.

Turf Encroachment
Another issue experienced in sports fields is the encroachment of turf into the softball and baseball infields. Turf that has encroached into the "skinned" area must be removed. Mechanical removal method is the only method to eliminate turf that has encroached because herbicides are not effective in these instances. The cost of mechanical removal method is higher, but the mechanical removal method is very effective.
3 Mulching
Mulching provides for the following benefits in controling weeds:
✓ Reduces weed growth thereby reducing the need for herbicides or mowing. ✓ Holds in soil moisture and conserves water.
✓ Helps to keep the root zone temperatures at a beneficial level. ✓ Organic mulch such as wood chips adds nutrition as it breaks down.

Wood chips from tree grindings are regularly stockpiled on the City Hall Campus and are used as mulch for City parks, open spaces, and parkways. The wood chips are also made available to Carpinteria residents. The wood chips were used in the following areas:
►Carpinteria Community Garden ►
El Carro Park ►
Heath Ranch Park ►
Monte Vista Park ►
Seaside Park ►
T omol Interpretive Play Area

2. Insects
California Oak Moths
The California oak moth (Phryganidia californica) is a native insect of coastal California.

Oak month caterpillars voraciously feed upon the leaves of native Coast Live Oak trees and also some deciduous trees. The tan brown adult moths are commonly seen as they hover around infested trees. They prolifically mate and lay eggs for the next generation of caterpillars. The next generation of caterpillars feed on oak leaves. Extreme oak worm outbreaks occur approximately every eight to ten years. In the most extreme conditions, the infestation may lead to severe oak defoliation. During these outbreaks caterpillars are often seen suspending from silk strands, dropping to the ground, and congregating on surfaces such as benches, drinking fountains, and sidewalks. The infestation of the California oak moth was reduced.
lmidacloprid injections were used on the majority of Coast Live Oak trees in the following areas:
►Eighth Street (Street Trees) ►
Franklin Creek Park ►
Heath Ranch Park ►
Memorial Park ►
Ogan Road (Street Trees)
Pesticide free zones were established in the following areas:
4 ► Franklin Creek Park ► Heath Ranch Park ► Memorial Park The imidacloprid is taken up by the tree relatively slow and starts killing chewing insects after a few days. The imidacloprid continues to kill chewing bugs in the tree for up to a year with one injection. Direct injection of pesticides into the trunk of trees is an environmentally sound and economical way of treating for many kinds of insects that feed on trees. With injection into the circulatory system of a tree, a much lower dosage is needed because it all goes into the tree as opposed to spraying which deposits pesticide on the ground and adjacent areas for exposure to unintended receptors. Trunk injection was efficient and worked fast for insect damage control.

Aphids
Ash trees and magnolia trees experienced aphid infestations. Aphids exude a sticky residue that was causing unpleasant staining and stickiness on sidewalks and other surfaces. The infestation can be detrimental to the health of the tree and can spread to other landscape plants. lmidicloprid injections were used in the following areas:
► Malibu Drive (Street Trees) ► Sterling Avenue (Street Trees) Sprays with neem oil were also used. Trilogy is the brand name for a clarified hydrophobic extract of neem oil. Neem oil is a naturally occurring pesticide found in seeds from the neem tree. It has been used for hundreds of years to control pests and diseases. Components of neem oil can be found in many products today. These include toothpaste, cosmetics, soaps, and pet shampoos. Neem products do not necessarily provide absolute insect control. However, frequent applications can reduce aphid populations by repelling them and inhibiting their larval development, growth, fertility, mating, and egg laying as well as deterring feeding. Sprays were used in the following areas:
► Carpinteria Community Garden (Grounds) ► Carpinteria Community Library (Grounds) ► City Hall (Grounds) ► Veterans Memorial Building (Grounds) Public education of aphid prevention was conducted by the Carpinteria Community Garden.

Ants
EcoVia was used for ants. It contains thyme oil and rosemary oil, and it is compliant with the National Organic Program. It is also an EPA exempt, FIFRA25-b organic essential oil insecticide. EcoVia was used in the following areas:
5 ► Carpinteria Community Library (Building) ► City Hall (Building) ► Veterans Memorial Building In addition, Suspend Polyzone was used for ants. Suspend Polyzone contains the active ingredient Deltamethrin. It is an insecticide belonging to the pyrethroid family.

Pyrethroids are the man-made versions of pyrethrins, natural insecticides from chrysanthemum flowers. Suspend Polyzone was used in the following areas:
► Carpinteria Community Library (Building) ► Carpinteria Community Pool (Building) ► City Hall (Building) ► Veterans Memorial Building Onslaught FastCap was used for ants. Onslaught FastCap contains Exponent brand synergist, Esfenvalerate, and Prallethrin. It targets multiple insects and can be applied in a number of areas- both indoor and outdoor. These products were selected for low toxicity. Onslaught FastCap was used in the following areas:
► City Hall (Building)
The Carpinteria Community Garden makes compost which is used to amend garden beds for ensuring rich soil provides plants with healthy defenses against insect pests. In addition, the cultivation of many "insectary" plants (i.e. plants especially attractive to beneficial insects) provides a robust ecosystem of insects that feed on common garden pests such as aphids, scale, and white flies. Bat boxes were also installed at the Carpinteria Community Garden in an effort to control invasive insects.

3. Rodents
Rats and Mice
Terad3 Rodenticide bait and Contrac Blox (bromadiolone) were used for rats and mice.

Terad3 Rodenticide bait was used in the following areas:
► City Hall (Building) ► Carpinteria Community Pool (Building) ► Carpinteria Community Library (Building) ► Veterans Memorial Building Cholecalciferol was used as a single feeding bait. Cholecalciferol is also known as vitamin 03. Once the rat or mouse eats a lethal dose, their blood calcium begins to rise to a level that is lethal to the rodent. It is a type of vitamin D which is made by the skin when exposed to sunlight. It is found in some foods, and it is also manufactured and sold as a dietary supplement. Cholecalciferol was used in the following areas:
► Carpinteria Community Pool (Building)
6 ► City Hall (Building)
Gophers
Another area of constant effort is in the control of gophers. Gophers can pose a serious threat to turf areas, especially sports fields. Gopher holes in sports fields and parks pose a solemn risk of injury to athletes and park goers. Gophers continue to be a major concern at El Carro and Viola playing fields. Gophers use their forepaws and incisor teeth to burrow and tunnel into the earth. Plant eaters by nature, they uproot and feed upon plants. Gophers are considered solitary rodents, yet dozens can infest an open field if no control program is in place. Gopher mounds are often built in a line, indicative of a deeper tunnel system. Pocket gophers invade parks, yards and gardens, feeding on many garden crops, ornamental plants, vines, shrubs, and trees. A single gopher can inflict considerable damage in a very short time. Gophers gnaw and damage plastic water lines and irrigation systems. Their tunnels may divert and carry off irrigation water, which leads to soil erosion and inefficient water use. Mounds on turf areas interfere with mowing equipment and collapsing tunnels can create tripping and injury hazards. Sports fields suffer extensive damage when gopher infestations occur. It is unclear if plant stress from lack of irrigation has worsened the damage to sports field due to gophers.

Irrigated turf areas commonly attract gophers because moist soils have more succulent root systems required for food. Non-irrigated areas surrounding the sports fields may be unable to support gopher populations so the animals migrate to greener pastures.

The California Fish and Wildlife Code classifies pocket gophers as non-game mammals.

This means that if a gopher is causing property damage you can control them at any time and in any legal manner. The City continues to use a trapping service to help control gopher populations. It was effective, but it is not ideal. Since trapping techniques require observing active gophers, field damage continues to occur but with minimal damage.

Gopher trappings were used in the following areas:
► City Hall (Grounds) ► El Carro Park ► Franklin Creek Park ► Heath Ranch Park ► Memorial Park ► Veterans Memorial Building (Grounds) ► Viola Fields In addition, carbon dioxide gas was used for gophers. The carbon dioxide gas settles into gopher tunnels and displaces breathable air causing suffication. Carbon dioxide gas was used in the following areas:
► Carpinteria Creek Park ► City Hall (Grounds) ► El Carro Park 7 ► Franklin Creek Park ► Heath Ranch Park ► Memorial Park ► Monte Vista Park ► Veterans Memorial Building (Grounds) ► Viola Fields 8 APPENDIX
9 ◄==~~~
,R~S. INC. CONTRAC BLOX ~
SAFETY DATA SHEET I ACCORDING TO REGULATION EC: I DATE OF ISSUE: I PREPARED BY:

Regulation (EU) 2015/830 July2017 CAR
SECTION 1. Identification of the substance/mixture and of the company /undertaking

1. 1. Product Identifier:

CONTRAC BLOX

1.2. Relevant identified uses of the substance or mixture and uses advised against

1.2.1 Relevant identified uses
USE: Anticoagulant Rodenticide - Ready to use (RB)
FORM: Wax block bait (BB)

1.2.2 Uses advised against
Use only for the purpose detailed in Section 1.2.1

1.3. Details of the supplier of the safety data sheet
MANUFACTURER: AUTHORISATION HOLDER:

Bell Laboratories, Inc. Bell Laboratories, Inc.
3699 Kinsman Blvd. Madison, WI 53704, USA Chaucer House, Chaucer Rd. t: + I 608 241 0202 Sudbury, Suffolk
e: [email protected] COIO ILN, UK
e: [email protected]

1.4. Emergency telephone number: +l-952-852-4636-Available 24h English language phone service or Local or Regional Poison Control Centre.

SECTION 2. Hazards identification

2.1. Classification of the substance or mixture
Classification according to Regulation (EC) No. 1272/2008 [CLP]:

STOR RE2 H373: May cause damage to the blood through prolonged or repeated exposure

2.2 Label Elements
Labelling according to Regulation (EC) 1272/2008
Hazard Pictogram:
~
Signal Word: Warning
Hazard Statement(s) (CLP):

H373: May cause damage to the blood through prolonged or repeated exposure.

Precautionary Statements:

Pl 02: Keep out of reach of children.

PI 03: Real label before using
P314: Get medical attention if you feel unwell.

P50 I: Dispose of contents/container in accordance with national regulations

2.3. Other Hazards
None
SECTION 3. Composition/information on ingredients

3.1 Substances: No substances fulfill the criteria set forth in Annex II Section A of the REACH regulation (EC) No 1907/2006

3.2. Mixtures: Description of the mixture: Formulated dry rodenticide bait containing Bromadiolone Trade Name: Contrac Blox
Supplier: Bell Laboratories, Inc.

Date Created: July 2017
Page I of5
Chemical name* (IUP AC) % By weight' CAS No. EC No. Classification** Bromadiolone [3-[3-( 4' -Bromo- 0.005 % 28772-56-7 249-205-9 Regulation 1272/2008 Acute Tox. I (oral) H300 [I, I' -biphenyl]-4-yl)-3-hydroxy- l- Acute Tox. I (dermal) H310 phenylpropyl]-4-hydroxy-2H- l- Acute Tox I (Inhalation) H330 benzopyran-2-one] STOT RE I H372
Aquatic chronic I H410
'Unlisted components not listed are non-hazardous
SECTION 4. First aid measures

4.1. Description of first aid measures
General Advice: Please refer to the instructions below for each specific way of exposure.

Ingestion: Rinse mouth carefully with water. Do not give anything by mouth or induce vomiting unless instructed by physician.

Inhalation: Not applicable.

Eye contact: Flush with cool water for at least 15 minutes. If irritation develops, obtain medical assistance.

Skin contact: Wash with soap and water. If irritation develops, obtain medical assistance.

4.2. Most important symptoms and effects, both acute and delayed Ingestion of excessive quantities may cause nausea, vomiting, loss of appetite, extreme thirst, lethargy, diarrhea, bleeding.

4.3. Indication of any immediate medical attention and special treatment needed Advice to physician: If ingested, administer Vitamin K1 intramuscularly or orally as indicated for bishydroxycoumarin overdoses. Repeat as necessary as based upon monitoring of prothrombin times.

Antidote: Phytomenadione, Vitamin K1 is antidotal
SECTION 5. Firefighting measures

5.1. Extinguishing media
Suitable Extinguishing Media: water, foam or inert gas.

Unsuitable Extinguishing Media: None known.

5.2. Special hazards arising from the mixture: High temperature decomposition or burning in air can result in the formation of toxic gases, which may include carbon monoxide and traces of bromine and hydrogen bromide.

5.3. Advice for firefighters: Wear protective clothing and self-contained breathing apparatus.

SECTION 6. Accidental release measures

6.1. Personal precautions, protective equipment and emergency procedures

6.1.1 For non-emergency personnel: Protective equipment should be worn when handling the bait. Collect spillage without creating dust.

6.1.2 For emergency responders: Protective equipment should be worn when handling the bait. Collect spillage without creating dust.

6.2. Environmental precautions: Do not allow bait to enter drains or water courses. Where there is contamination of streams, rivers, or lakes contact the appropriate respective authorities.

6.3. Methods and materials for containment and cleaning up

6.3.1 For Containment: Sweep up spilled material immediately. Place in properly labeled container for disposal.

6.3.2 For Cleaning Up: Wash contaminated surfaces with detergent. Dispose of all wastes in accordance with all local, regional and national regulations.

6.3.3 Other Information: Not applicable

6.4. Reference to other sections: Refer to Sections 7, 8 & 13 for further details of safe handling, personal protective equipment, and disposal considerations.

SECTION 7. Handling and storage

7.1. Precautions for safe handling

7.1.1 Protective Measures: Keep product in the original container. Do not handle the product near food, animal foodstuffs or drinking water.

Keep out of reach of children. Do not use near heat sources, open flame, or hot surfaces.

7.1.2 Advice on general occupational hygiene: Do not eat, drink or smoke whilst handling. Wash thoroughly with soap and water after handling.

7.2. Conditions for safe storage, including any incompatibilities Store only in original container in a cool, dry place, inaccessible to pets and wildlife. KEEP OUT OF REACH OF CHILDREN. Keep container tightly closed when not in use.

7.3. Specific end uses(s)
Rodenticide - ready to use
Trade Name: Contrac Blox
Supplier: Bell Laboratories, Inc.

Date Created: July 2017

Page 2 ends

SECTION 8. Exposure controls/personal protection

8.1. Control Parameters
Occupational exposure limits: Not established

8.2. Exposure Controls

8.2.1 Appropriate engineering controls: Not required

8.2.2 Personal Protection
Respiratory protection: Not required
Eye protection: Not required
Skin protection: Wear rubber gloves (for example, EN 374 or disposable latex gloves) Hygiene recommendations: Wash thoroughly with soap and water after handling.

8.2.3 Environmental exposure controls: Prevent the substance from entering drains and water-courses.

SECTION 9. Physical and chemical properties

9. 1. Information on basic physical and chemical properties Appearance/Colour: Blue solid wax blocks
Odour: Sweet grain-like
Odour Threshold: No data
pH: Not applicable, not dispersible with water
Melting point: No data (melting point for Bromadiolone is 192.6 - 193 .9°C) Boiling point: No data
Flash point: Not applicable
Evaporation rate: Not applicable, is a solid
Upper/lower flammability or explosive limits: No data
Vapour Pressure: Not applicable
Relative Density: 1.12 g/mL@ 20°C
Solubility (water): Not water soluble
Partition coefficient: n-octanol/water: No data
Auto-ignition temperature: Not applicable
Decomposition temperature: No data
Explosive properties: Not applicable
Oxidising properties: Not applicable

9.2. Other Information: None known
SECTION 10. Stability and reactivity

10.1. Reactivity: Stable when stored in original container in a cool, dry location. There are no particular risks ofreaction with other substances in normal conditions of use.

10.2. Chemical stability: Stable when stored in original container in a cool, dry location.

10.3. Possibility of hazardous reactions: Please refer to 10.6 (Hazardous decomposition products).

10.4. Conditions to avoid: Avoid extreme temperatures (below 0°C or above 40°C).

10.5. Incompatible materials: Avoid strongly alkaline materials.

10.6. Hazardous decomposition products: High temperature decomposition or burning in air can result in the formation of toxic gases, which may include carbon monoxide and traces of bromine and hydrogen bromide.

SECTION 11. Toxicological information

11.1. Information on toxicological effects

11.1.1 Substances : Not applicable

11.1.2 Mixtures - Not applicable

11.1.2.1 (a) Acute Toxicity
LDS0, oral (ingestion): >5000 mg/kg (rats) (Bromadiolone Rat LOSO oral: <Smg/kg bw).

LOSO, dermal (skin contact):> 5001 mg/kg (rats) (Bromadiolone Rat LDS0 dermal: 7.48 mg/kg bw (female rats).

LCS0, inhalation: Not applicable

11.1.2.1 (b) Skin corrosion/irritation : Not irritating to skin.

11.1.2.1 ( c) Serious eye damage/Irritation: Not irritating to eyes.

11.1.2.1 (d) Respiratory or skin sensitization: Dermal sensitization: Not a Sensitizer (Buehler test method).

11.1.2.1 (e) Germ cell mutagenicity: Not considered to have a mutagenetic effect.

11.1.2.1 (f) Carcinogenicity: Contains no components known to have a carcinogenetic effect.

11.1.2.1 ( g) Reproductive Toxicity: No data available.

Trade Name: Contrac Blox
Supplier: Bell Laboratories, Inc.

Date Created: July 2017

Page 3 of 5 ends

11.1.2.1 (h) STOT-Single Exposure: No data available.

11.1.2.1 (i) STOT Repeated Exposure: Specific Target organ toxicity - Repeated exposure, Category 2

11.1.2.1 U) Aspiration Hazard: Not relevant.

SECTION 12. Ecological information
General Information: The environmental risk assessment shows that Bromadiolone does not cause unacceptable risk in the aquatic environment, terrestrial environment or in the atmosphere. Bromadiolone is neither expected to accumulate in sediment nor contaminate groundwater. Predatory and scavenging mammals and birds might be poisoned if they have eaten the bait. Use a bait station to minimize these risks. Please note, the data below reflects the active ingredient Bromadiolone. This product is formulated @0.005% or 50ppm Bromadiolone.

When compared to the data relevant to the active ingredient, ecological effects should be significantly lower for this product.

12.1. Toxicity
For Bromadiolone:

Fish: 96h LC50 ((Oncorhynchus mykiss)) = 4.33 mg/I
Invertebrates: 48h EC50 (Daphnia magna) 0.222 mg/I
Algae: 72h EbC50 Selenastrum capricornutum = >ErC50 = 7.31 mg/I Microorganisms (activated sludge): EC50 > I 00 mg/L (based on water solubility at pH 7 and T = 20°C)

12.2. Persistence and degradability: For Bromadiolone: Not readily biodegradable under normal conditions. However, photolysis of Bromadiolone is rapid with a half-life 0.5 hours or less (pH7 and 9, 25°C). In addition Bromadiolone is not volatile and therefore would not be expected to be present in the air in significant quantities.

12.3. Bioaccumulative potential: For Bromadiolone: Log Pow is >3, which indicates a potential to bioaccumulate BCF: For Bromadiolone, estimated for freshwater fish= 1750 (QSAR by Vieth et al ( 1979))

12.4. Mobility in Soil: KOC: 1223 to 36011 mL/g (advanced adsorption test). Mobility ofBromadiolone in soil is considered to be limited ..

12.5. Results of PBT and vPvB assessment: Other than the active ingredient, this mixture does not contain any substances that are assessed to be PBT or vPvB.

12.6. Other adverse effects: None.

SECTION 13. Disposal considerations

13.1. Waste Treatment Methods

13.1.1 Product/packaging disposal: Wastes resulting from use may be disposed of on-site or at an approved waste disposal facility. Dispose of all wastes in accordance with all local, regional and national regulations.

13.1.2 Waste treatment-relevant information: Wastes resulting from the use of this product may be disposed of on site or at an approved waste disposal facility.

13.1.3 Sewage disposal-relevant information: Not applicable

13.1.4 Other disposal recommendations: None
SECTION 14. Transport information

14.1. UN number: Not applicable

14.2. UN proper shipping name: ADR/RID (Road/Rail): Not applicable

14.3. Transport hazard class(es): Not applicable

14.4. Packing group: Not applicable

14.5. Environmental hazards
ADR/RID (Road/Rail): Not considered hazardous by ADR/RID Regulations for transportation via road/rail.

IMDG (Maritime): Not considered hazardous by IMO Regulations for transportation via vessel.

IA TA (Air): Not considered hazardous by IA TA Regulations for transportation via air.

14.6. Special precautions for user: Not applicable
SECTION 15. REGULATORY INFORMATION

15.1. Safety, health and environmental regulations/legislation specific for the substance or mixture: Regulated under Regulation (EU) 528/2012
Substances in Candidate list (Art 59 REACH) : None
Substances subject to authorization (Annex XIV REACH): None Restrictions (Annex XVII REACH): None

15.2. Chemical safety assessment: Exempt, CONTRAC BLOX is regulated under Regulation (EU) 528/2012 Trade Name: Contrac Blox
Supplier: Bell Laboratories, Inc.

Date Created: July 2017

Page 4 of 5 ends

SECTION 16. OTHER INFORMATION
CLASSIFICATION AND PROCEDURES USED IN PREPARATION OF THIS SDS: Regulation (EU) 2015/830, Regulation 528/2012,

16.1. Abbreviations and acronyms
Not applicable

16.2. Key literature references and sources of data
Assessment Report (Inclusion of active substances in Annex I to Directive 98/8/EC, 17 September 2009, revised 16 December 2010. EU Regulation 2015/830 and 528/2012

16.3. Classification and procedure used to derive the classification for mixtures according to Regulation (EC) 1272/2008 [CLP] Classification according to Regulation (EC) No. 1272/2008: Not classified on the basis of available test data.

Classification according to Directive 1999/45/EC: Not classified on the basis of available test data.

16.5. Further Information: This Safety Data Sheet has been compiled in accordance with Regulation (EU) 2015/830, (EC) No 1907/2006 (as amended by Regulation (EU) No 453/20 I 0), and Regulation (EC) 1272/2008. For additional information, please contact the manufacturer noted in Section I. The information provided in this Safety Data Sheet has been obtained from sources believed to be reliable. Bell Laboratories, Inc. provides no warranties; either expressed or implied, and assumes no responsibility for the accuracy or completeness of the data contained herein. This information is offered for your consideration and investigation. The user is responsible to ensure that they have all current data relevant to their particular use.

Trade Name: Contrac Blox
Supplier: Bell Laboratories, Inc.

Date Created: July 2017

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t,Rockwell Labs Ltd.
creating the future of pest control
EcoVia™ EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1

1. PRODUCT IDENTIFICATION

1.1. Product Identifiers
Product name Eco Via™ EC Emulsifiable Concentrate - Diluted with water at 6 fl oz/gal
Other Means of Identification
Product synonyms none

1.2. Recommended Uses/Restrictions to Use
Uses FIFRA 25(6) exempt "minimum risk" pesticide product for the control of various pest species per label - ready to use dilution(s) Restrictions

1.3. Supplier Details
Company
See product label for details
Rockwell Labs Ltd
1257 Bedford Avenue
North Kansas City, MO 64116-4308
USA
Telephone

1.4. Emergency Contact
Outside normal business hours
Emergency Phone #
1 816-283-3167
1 800-424-9300 (USA & Canada)
1 703-527-3887 (Outside USA & Canada)

2. HAZARDS IDENTIFICATION

2.1. Classification of Substance or Mixture
none

2.2. GHS label elements, including precautionary statements Pictogram(s) none
Signal word none
Hazard statement(s)
H226
Precautionary statement(s)
P210
none
none
Rockwell - RP0020RTU

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t Rockwell Labs Ltd.
creating the future of pest control
EcoVia™ EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1

2.3. Other hazards which do not result in classification none

3. COMPOSITION/INFORMATION ON INGREDIENTS

3.1. Substances
No data available

3.2. Mixtures
Hazardous component(s) or components of note:

Chemical Identity Contains(% w/w) CAS-No. Hazard Classification none

4. FIRST AID MEASURES

4.1. Description of first aid measures
General advice
Consult a physician or poison control center. Provide this safety data sheet to medical personnel. Move out of hazardous areas.

If inhaled
Move person to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth to mouth if possible. Call a poison control center or doctor for further treatment advice.

In case of skin contact
Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control center or doctor for treatment advice.

In case of eye contact
Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first five minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice.

If swallowed
Call a poison control center or doctor for treatment advice. Have person sip a glass of water if able to swallow.

Do not induce vomiting unless told to do so by a poison control center or doctor. Do not give anything by mouth to an unconscious person.

4.2. Most important symptoms and effects, both acute and delayed No data available

4.3. Indication of any immediate medical attention and special treatment needed, if necessary None known

5. FIRE FIGHTING MEASURES

5.1. Extinguishing media
Suitable extinguishing media: use water spray, alcohol-resistant foam, dry chemical or carbon dioxide.

5.2. Specific hazards arising from the chemical
Rockwell - RP0020RTU

Page 2 of 8 ends

t, Rockwell Labs Ltd.
creating the future of pest control
EcoVia™ EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1
Oxides of carbon, nitrogen, and sulfur.

5.3. Special protective equipment and precautions for fire fighters Wear self contained breathing apparatus for firefighting if deemed necessary.

Additional information: none.

5.4. Further information
No data available

6. ACCIDENTAL RELEASE MEASURES

6.1. Personal precautions, protective equipment and emergency procedures Avoid contact with spilled product and contaminated surfaces. Evacuate personnel to safe areas during emergencies. For safe handling instructions see section 7. For proper PPE see section 8.

6.2. Environmental precautions
Prevent further leakage or spillage if safe to do so.

6.3. Methods and materials for containment and cleaning up Wipe up any spilled material and dispose of according to instructions in section 13. Wash contaminated surfaces with soap and water.

7. HANDLING AND STORAGE

7.1. Precautions for safe handling
Handle in accordance with good industrial hygiene practices. Wash hands before eating, drinking, chewing gum, using tobacco or using the toilet. For additional precautions see section 2.2 7 .2. Conditions for safe storage, including any incompatibilities Store upright in original container. Do not store where children or animals may gain access.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION

8.1. Control parameters
Components with workplace parameters
Component CAS-No. Value
Control Basis
parameters
TWA 400 ppm

NIOSH REL
Isopropyl alcohol 67-63-0 ST 500 ppm
T\VA 400 ppm OSHA PEL

8.2. Appropriate engineering controls
Ensure relevant engineering controls are employed to prevent exceeding threshold values for the listed control parameters in section 8.1.

8.3. Individual protection measures, such as personal protective equipment In normal use and handling conditions refer to the product label for required PPE. In all other cases the following recommendations would apply.

Rockwell - RP0020RTU

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I
1 E, Rockwell Labs Ltd. creating the future of pest control Eco Via TM EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1
Eye/face protection
Safety glasses or other similar eye protection conforming to ANSI Z87 .1 standards recommended when handling product.

Skin protection
Chemical resistant nitrile rubber or similarly compatible gloves recommended when handling product. Dispose of contaminated gloves after use in accordance with applicable local and state regulations. Wash exposed skin with soap and water immediately. Wash all contaminated clothing prior to reuse.

Respiratory protection
Not required under normal use conditions. Chemical cartridge respirator with organic vapor cartridge recommended when risk assessment shows need for air-purifying respirators.

Thermal hazards
None known

9. PHYSICAL AND CHEMICAL PROPERTIES

9.1. Information on basic physical and chemical properties Appearance;
Odor;
Odor threshold;
pH;
Melting point/ freezing point;
Initial boiling point and boiling
range;
Flash point;
Evaporation rate;
Flammability (solid, gas);
Upper/lower flammability or
explosive limits;
Vapor pressure;
Vapor density;
Relative density;
Solubility;
Partition coefficient: noctanol/ water;
Auto-ignition temperature;
White liquid
Thyme
No data available
No data available
No data available
No data available
> 200 °F (93 °C)
No data available
No data available
No data available
No data available
No data available

0.99 g/ml
Soluble in water
No data available
No data available
Rockwell - RP0020RTU

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£, Rockwell Labs Ltd,
creating the future of pest control
EcoVia™ EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
PrintDate: 9/18/2020
Version 1.1
Decomposition temperature;
Viscosity;

9.2. Additional Information
No data available
No data available
Similar to that of water

10. STABILITY AND REACTIVITY

10.1. Reactivity
No dangerous reactions known.

10.2. Chemical stability
Stable under recommended storage conditions.

10.3. Possibility of hazardous reactions
No data available

10.4. Conditions to avoid
No data available
Incompatible materials
Strong oxidizing agents. Strong reducing agents.

10.5. Hazardous decomposition products
Other decomposition products - no data available
In the event of a fire: see Section 5

11. TOXICOLOGICAL INFORMATION

11.1. Information on toxicological effects
Acute Toxicity Estimate (ATE)
LD50 Oral- Rat - > 5000 mg/kg
LD50 Dermal- Rat-> 5000 mg/kg
LD50 Inhalation - Rat- no data available
Skin corrosion/ irritation
No data available
Serious eye damage/irritation
No data available
Respiratory or skin sensitization
No data available
Germ cell mutagenicity
No data available
Carcinogenicity
IARC: No component of this product presents at levels greater than or equal to 0.1 % is identified as probable, possible or confirmed human carcinogen by IARC.

ACGIH: No component of this product presents at levels greater than or equal to 0.1 % is identified as probable, possible or confirmed human carcinogen by ACGIH.

Rockwell - RP0020RTU

Page 5 of 8 ends

t, Rockwell Labs Ltd.
creating the future of pest control
Eco Via TM EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1
NTP: No component of this product presents at levels greater than or equal to 0.1 % is identified as probable, possible or confirmed human carcinogen by NTP.

No component of this product presents at levels greater than or equal to 0.1 % is identified as probable, possible or confirmed human carcinogen by OSHA.

Reproductive toxicity
No data available
OSHA:

Specific target organ toxicity - single exposure
No data available
Specific target organ toxicity - repeated exposure
No data available
Aspiration hazard
No data available

11.2. Other information
No data available

12. ECOLOGICAL INFORMATION

12.1. Toxicity
Toxicity to fish
Toxicity to daphnia
and other aquatic
LCS0 - Pimephales promelas (fathead minnow) - >200 mg/1 (96 hr) ECS0 - Daphnia magna (Water flea) - >100 mg/1 (48 hr)
invertebrates

12.2. Persistence and degradability
No data available

12.3. Bioaccumulative potential
No data available

12.4. Mobility in soil
No data available

12.5. Other adverse effects
No data available

13. DISPOSAL CONSIDERATIONS

13.1. Disposal Methods.

The best disposal method is to use the entire quantity per label directions. If it is necessary to dispose of unused material then follow the label instructions and relevant local, state and federal waste disposal guidelines.

Product Disposal:

Do not contaminate water, food or feed by storage or disposal.

Packaging Disposal:

If empty: Place in trash or offer for recycling if available. If partly filled: Call your local solid waste agency or 1- 800-CLEANUP which is managed as a public-private partnership.

Rockwell - RP0020RTU

Page 6 ends

£, Rockwell Labs Ltd
creating the future of pest control
Eco Via TM EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1
See section 8 for proper PPE and precautionary handling measures.

14. TRANSPORT INFORMATION
DOT
Not dangerous goods
IMDG
Not dangerous goods
IATA
Not dangerous goods

15. REGULATORY INFORMATION
This chemical is a FIFRA 25(6) Exempt pesticide product that is not registered by the Environmental Protection Agency but is subject to certain labeling requirements under various state pesticide laws. These requirements differ from the classification criteria and hazard information required for safety data sheets, and for workplace labels of non-pesticide chemicals. Following is the hazard information as required on the pesticide label:

KEEP OUT OF THE REACH OF CHILDREN

CAUTION
SARA 302 Components
No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302.

SARA 313 Components
The following components are subject to reporting levels established by SARA Title III, Section 313:

Isopropyl alcohol- CAS-No. 67-63-0
SARA 311/312 Hazards
None
California Proposition 65 Components
This product does not contain any chemicals known to the state of California to cause cancer, birth defects, or reproductive harm.

TSCA
All components of this product are listed, exempted, or excluded from listing on the U.S. Toxic Substances Control Act chemical substance inventory.

16. OTHER INFORMATION
Acronyms and abbreviations used
LD 50 Lethal Dose, 50%
OECD
IARC
ACGIH
Organization for Economic Cooperation and Development
International Agency for Research on Cancer
American Conference of Industrial Hygienists
Rockwell - RP0020RTU

Page 7 of 8 ends

£, Rockwell Labs Ltd.
creating the future of pest control
Eco Via TM EC Emulsifiable Concentrate - RTU
Safety Data Sheet
Release Date: 9/18/2020
Print Date: 9/18/2020
Version 1.1
NTP
OSHA
DOT
IMDG
IATA
SARA
TSCA
CAS-No.

PPE
HMIS
NFPA
PPM
ANSI
1WA
PEL
REL
ST
National Toxicology Program
Occupational Safety and Health Administration
Department of Transportation
International Maritime Dangerous Goods
International Air Transport Association
Superfund Amendments and Reauthorization Act
Toxic Substances Control Act
Chemical Abstract Services - Number
Personal Protective Equipment
Hazardous Materials Identification System
National Fire Protection Association
Parts Per Million
American National Standards Institute
Time Weighted Average
Permissible Exposure Limit
Recommended Exposure Limit
Short Term
Hazard Rating System Crossover
HMIS Rating
Health Hazard:

Flammability:

Reactivity:
0 0
0 NFPA Rating
Health Hazard:

Flammability:

Reactivity:
0 0
0 Preparation information
Prepared by: Rockwell Labs Ltd
Version: 1.1
Revision Date: September 18, 2020
Reason for revision: Minor reformatting changes
Notice to Reader: The information provided in this Safety Data Sheet has been obtained from sources believed to be reliable. Rockwell Labs Ltd provides no warranties, express or implied, and assumes no responsibility for the accuracy and completeness of the data contained herein. The customer assumes all responsibility for safety and use not in accordance with label instructions. The product names are trademarks of Rockwell Labs Ltd.

Rockwell - RP0020RTU

Page 8 ends

MGK SAFETY DATA SHEET
Insect Control Sol11tions
Issue Date: 21-0ct-2020 Revision Date: 21-0ct-2020 Version:

1. PRODUCT AND COMPANY IDENTIFICATION
Product identifier
Product Name: Onslaught® FastCap Spider & Scorpion Insecticide EPA Registration Number: 1021-2574
Other means of identification
Part Code: 2964B, 2964C
Recommended use of the chemical and restrictions on use Recommended Use: Insecticide.

Details of the supplier of the safety data sheet
Manufacturer Address:

McLaughlin Gormley King Company
7325 Aspen Lane North
Minneapolis, MN 55428
USA
Telephone Number: (800) 645-6466, or (763) 544-0341
e-Mail Address: [email protected]
FAX#:
(763) 544-6437
Emergency telephone number
24 Hour TRANSPORTATION Emergency: CHEMTREC®: (800) 424-9300 International: (703) 527-3887
24 Hour MEDICAL Emergency: SafetyCall®: (888) 740-8712, or (952) 852-9509 Comments: MGK® Hours of operation are 8:00 a.m. to 4:30 p.m. CST, 14:00 to 22:30 GMT.

For MEDICAL EMERGENCIES or PESTICIDE INCIDENTS, call 24 hours a day to (888) 740-8712, or (952) 852-9509.

2. HAZARDS IDENTIFICATION
Classification:

OSHA Regulatory Status:

This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200) lAcute toxicity - Oral Category 4
~cute toxicity - Inhalation (Dusts/Mists) Category 4
Skin corrosion/irritation Category 2
Label elements
ARNING
Hazard statements
• H302 - Harmful if swallowed

Page 1 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 • H332 - Harmful if inhaled
• H315 - Causes skin irritation
ppearance: cream , light yellow /
brown
Physical state: Liquid Odor Slight - Swee
Precautionary Statements - Prevention:

P261 - Avoid breathing dust/fume/gas/mist/vapors/spray
P264 - Wash face, hands and any exposed skin thoroughly after handling P270 - Do not eat, drink or smoke when using this product P271 - Use only outdoors or in a well-ventilated area
P280 - Wear protective gloves
Precautionary Statements - Response:

P321 - Specific treatment (see Section 4/ First Aid).

P302 + P352 - IF ON SKIN: Wash with plenty of soap and water P332 + P313 - If skin irritation occurs: Get medical advice/attention P362 - Take off contaminated clothing and wash before reuse P304 + P340 - IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing P312 - Call a POISON CENTER or doctor/physician if you feel unwell P301 + P312 - IF SWALLOWED: Call a POISON CENTER or doctor/physician if you feel unwell P330 - Rinse mouth
Precautionary Statements - Storage:

P404 - Store in a closed container
Precautionary Statements - Disposal:

P501 - Dispose of contents/container to an approved waste disposal plant Hazards not otherwise classified (HNOC):

Do not use this product in or on electrical equipment due to the possibility of shock hazard.

3. COMPOSITION/INFORMATION ON INGREDIENTS
Chemical name CAS No. Weiaht-%
Esfenvalerate 66230-04-4 6.40
Prallethrin (ETOC®) 23031-36-9 1.60
Piperonyl Butoxide (PBO) 51-03-6 8.00
Petroleum distillates, hvdrotreated liqht 64742-47-8 <10 * *The exact percentage (concentration) of composition has been withheld as a trade secret Comments: Ingredients not identified are proprietary or non-hazardous. Values are not product specifications.

4. FIRST AID MEASURES

Page 2 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 Aspiration pneumonia hazard: • Not applicable
Description of first aid measures
Eye contact:

Skin Contact:

Ingestion:

Inhalation:

Self-protection of the First
Responder:

Note to physicians:

Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice.

Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control centeror doctor for treatment advice.

If swallowed, IMMEDIATELY call a poison control center or doctor for treatment advice. DO NOT give any liquid to the person. Do not induce vomiting unless told to do so by a poison contol center or a doctor. Never give anything by mouth to an unconscious person.

Remove affected person to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth-to-mouth if possible.

Call a poison control center or doctor for further treatment advice.

Use personal protective equipment as required.

For skin effects, a highly efficient therapeutic agent for Pyrethrin/ Pyrethroid exposure is topical application of tocopherol acetate (Vitamin E).

5. FIRE-FIGHTING MEASURES
Suitable extinguishing media
Use extinguishing measures that are appropriate to local circumstances and the surrounding environment.

Unsuitable extinguishing media:

Caution: Use of water spray when fighting fire may be inefficient.

Hazardous combustion products: Carbon monoxide, Carbon dioxide (CO2), Hydrogen cyanide.

Specific hazards arising from the chemical
In the event of fire and/or explosion do not breathe fumes. May cause sensitization by inhalation and skin contact.

Thermal decomposition can lead to release of irritating and toxic gases and vapors.

Explosion data
Sensitivity to Mechanical Impact: None.

Sensitivity to Static Discharge: None.

Protective equipment and precautions for firefighters:

As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear.

6. ACCIDENTAL RELEASE MEASURES
Personal precautions, protective equipment and emergency procedures Personal precautions: Avoid contact with skin, eyes or clothing. Use personal protective equipment as required. Evacuate personnel to safe areas. Keep people away from and upwind of spill/leak.

Page 3 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 Environmental precautions: Prevent entry into waterways, sewers, basements or confined areas. Do not flush into surface water or sanitary sewer system. Prevent further leakage or spillage if safe to do so. Prevent product from entering drains. See Section 12 for additional ecological information.

Methods and material for containment and cleaning up
Methods for containment:

Methods for cleaning up:

Prevent further leakage or spillage if safe to do so.

Cover liquid spill with sand, earth or other non-combustible absorbent material.

Cover powder spill with plastic sheet or tarp to minimize spreading. Pick up and transfer to properly labeled containers. Soak up with inert absorbent material. Dam up.

7. HANDLING AND STORAGE
Precautions for safe handling
Advice on safe handling: Avoid contact with skin, eyes or clothing. Wash contaminated clothing before reuse. Use personal protective equipment as required. Do not breathe dust/fume/gas/mist/vapors/spray. Do not eat, drink or smoke when using this product. Use with local exhaust ventilation. For more information, see product label.

Conditions for safe storage, including any incompatibilities Storage Conditions: Keep container tightly closed in a dry and well-ventilated place. Keep out of the reach of children. Keep containers tightly closed in a cool, well-ventilated place.

Keep in properly labeled containers. For more information, see product label.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Control parameters
Exposure Guidelines:

Chemical name ACGIH TLV OSHA PEL NIOSH IDLH Supplier OEL Petroleum distillates, - - - TWA: 100 ppm
hydrotreated light TWA: 525 mg/m3
64742-47-8
Appropriate engineering controls
Engineering Controls: Safety showers
Eyewash stations
Ventilation systems
Individual protection measures, such as personal protective equipment Eye/face protection:

Skin and body protection:

Respiratory protection:

Protective eyewear is recommended, but is not required.

Wear protective gloves and protective clothing.

If exposure limits are exceeded or irritation is experienced, NIOSH/MSHA approved respiratory protection should be worn. Positive-pressure supplied air respirators may be required for high airborne contaminant concentrations.

Respiratory protection must be provided in accordance with current local

Page 4 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 General Hygiene
Considerations:
regulations.

When using do not eat, drink or smoke. Wash contaminated clothing before reuse.

Regular cleaning of equipment, work area and clothing is recommended.

9. PHYSICAL AND CHEMICAL PROPERTIES
Information on basic physical and chemical properties:

Physical state:

Appearance:

Odor
Odor threshold:

Color (Gardner Scale):

Property:
pH:

Melting point/ freezing point:

Boiling point/ boiling range:

Flash point:

Evaporation rate:

Flammability (solid, gas):

Upper flammability limit (UEL):

Lower flammability limit (LEL):

Vapor pressure:

Vapor density:

Specific Gravity:

Water solubility:

Partition coefficient; n-Octanol/
Water:

Autoignition temperature:

Decomposition temperature:

Kinematic viscosity:

Dynamic viscosity:

Refractive Index:

Other Information:

Density
voe Content(%):

Miscibility/ Solubility:

Water:

Alcohol:

Aromatic solvents:

Petroleum distillates:

Liquid
cream , light yellow I brown
Slight - Sweet
No information available
No information available
Values:

5.5 No information available
No information available
> 93.3 °C / > 200.0 °F
No information available
No information available
No information available
No information available
No information available
No information available
No information available
No information available
No information available
No information available
No information available
No information available
1,446 cPs
No information available
Comment: • Method
@5% in H2O.

Tag Closed Cup.
@21.3 °C

1.011 g/cm3 @ 20.0 °C

1.95 Immiscible
Immiscible
Immiscible
Immiscible

10. STABILITY AND REACTIVITY
Reactivity
No data available
Chemical stability
Stable under recommended storage conditions.

Possibility of Hazardous Reactions

Page 5 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 None under normal processing.

Hazardous polymerization: Hazardous polymerization does not occur.

Conditions to avoid
Extremes of temperature and direct sunlight.

Incompatible materials:

Incompatible with strong acids and bases. Incompatible with oxidizing agents.

Hazardous Decomposition Products
Carbon monoxide, Carbon dioxide (CO2), Hydrogen cyanide.

11. TOXICOLOGICAL INFORMATION
Numerical measures of toxicity - Product Information
Oral LDso
Dermal LDso
Inhalation LCso
Eye contact:

Skin Contact:

Skin Irritation Index:

Sensitization:

Piperonyl Butoxide:

Carcinogenicity/ Oncogenicity:

Carcinogenicity
Reproductive toxicity:

Developmental Toxicity
Teratogenicity:

STOT - single exposure:

STOT - repeated exposure:
1,750 mg/kg (rat)
>5,000 mg/kg (rabbit)
>2.04 mg/L, (rat; 4 hours)
Slightly irritating. Irritation clearing in 72 hours. (rabbit).

Moderate irritation at 72 hours. (rabbit).

2.4 Negative. (guinea pig).

Marginally higher incidences of benign liver tumors in mice were observed following lifetime high dose exposures to PBO. The significance of these observations is questionable and under review. The doses at which tumors were observed for PBO greatly exceeded potential human exposure from labeled uses.

Doses at which these effects were observed greatly exceeded anticipated human dietary intake. At anticipated dietary exposure levels, it is highly unlikely that this product will result in carcinogenic effects.

This product does not contain any carcinogens or potential carcinogens as listed by OSHA, IARC or NTP
No information available.

No information available.

12. ECOLOGICAL INFORMATION
Ecotoxicity:

Persistence and degradability
No information available.

Bioaccumulation
No information available.

Chemical name Partition coefficient· n-Octanol/ Water:

Prallethrin (ETOC®) 4.49
23031-36-9

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Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 Other adverse effects: No information available
Environmental hazards (EPA):

Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.

13. DISPOSAL CONSIDERATIONS
Waste treatment methods
Disposal of wastes:

Contaminated packaging:

Disposal should be in accordance with applicable regional, national and local laws and regulations. For more information, see product label.

For more information, see product label.

14. TRANSPORT INFORMATION
DOT (Department of Transportation)
Proper Shipping Name:

Hazard Class:

Other DOT Shipping
Information:

Air (IATA/ ICAO)
Proper Shipping Name:

Hazard Class:

Vessel (IMO/ IMDG)
UN/ID Number:

Proper Shipping Name:

Hazard Class:

Packing Group:

Marine Pollutant:

Insecticides, Insect or Animal Repellent, Liquid
This material is not hazardous.

This material is not regulated by the DOT as a hazardous material when shipped in Non-Bulk quantities (i.e., less-than 119 Gallons/ 450 Liters).

When shipping in Bulk-quantities (i.e., more than 119 Gallons/ 450 Liters), please contact MGK® for the proper shipping description.

Insecticides, Insect or Animal Repellent, Liquid
This material is not hazardous.

UN3082
Environmentally hazardous substance, Liquid, n.o.s.(Esfenvalerate, Prallethrin) 9 Ill
Yes

15. REGULATORY INFORMATION
US Federal Regulations
SARA 313
Section 313 of Title Ill of the Superfund Amendments and Reauthorization Act of 1986 (SARA). This product contains a chemical or chemicals which are subject to the reporting requirements of the Act and Title 40 of the Code of Federal Re ulations, Part 372
Chemical name SARA 313 -Threshold Values%

Page 7 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 IPiperonyl Butoxide (PBO) - 51-03-6 1.0
SARA 311/312 Hazard
Categories
Acute health hazard
Chronic Health Hazard
Fire hazard
Sudden release of pressure hazard
Reactive Hazard
Yes
No
No
No
No
CWA (Clean Water Act)
This product does not contain any substances regulated as pollutants pursuant to the Clean Water Act (40 CFR 122.21 and 40 CFR 122.42)
CERCLA
This material, as supplied, does not contain any substances regulated as hazardous substances under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40 CFR 302) or the Superfund Amendments and Reauthorization Act (SARA) (40 CFR 355). There may be specific reporting requirements at the local, regional, or state level pertaining to releases of this material US State Regulations:

California Proposition 65:

This product does not contain any intentionally added Proposition 65 chemicals U.S. EPA Label Information:

EPA Registration Number: 1021-2574
Difference between SDS and EPA (FIFRA) Pesticide label:

This chemical is a pesticide product registered by the United States Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for Safety Data Sheets (SOS), and for workplace labels of non-pesticide chemicals.

The pesticide label also includes other important information, including directions for use. The hazard information required on the pesticide label is reproduced below:

Signal word: CAUTION
Precautionary Statements:
• Harmful if swallowed
• Causes moderate eye irritation
International Inventories:

TSCA

DSL/NDSL

EINECS/ELINCS
ENCS
IECSC
KECL
PICCS
AICS
Complies
Complies
Does not comply
Does not comply
Complies
Complies
Does not comply
Does not comply
Legend:

TSCA - United States Toxic Substances Control Act Section 8(b) Inventory

Page 8 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 DSL/NDSL - Canadian Domestic Substances LisUNon-Domestic Substances List EINECS/ELINCS - European Inventory of Existing Chemical Substances/European List of Notified Chemical Substances
ENCS - Japan Existing and New Chemical Substances
IECSC - China Inventory of Existing Chemical Substances KECL - Korean Existing and Evaluated Chemical Substances PICCS - Philippines Inventory of Chemicals and Chemical Substances AICS - Australian Inventory of Chemical Substances
I 16. OTHER INFORMATION, INCLUDING DATE OF PREPARATION OF THE LAST REVISION I NFPA Health hazards 2
Health hazards 2
Flammability
Flammability
Instability O Physical and
Chemical Properties
Physical hazards O Personal protection
X
Chronic Hazard Star Legend * = Chronic Health Hazard
Issue Date:
21-0ct-2020
Revision Date:
21-0ct-2020
Revision Note:
- Product Code Changed
- SDS sections updated
- 1
-4
-9
- 11
- 12
- 14
SDS Prepared By:
e-Mail Address:

Disclaimer:

Troy Azzivitto, MGK® Chemistry Department.
[email protected]
The information provided in this Safety Data Sheet (SDS) is provided in good faith and believed to be accurate at the time of preparation of the SDS. However, to the extent consistent with applicable law, MGK® and its subsidiaries or affiliates extend no warranties, make no representations, and assume no responsibility as to the accuracy, suitability, or completeness of such information. Additionally, to the extent consistent with applicable law, neither MGK® nor any of its subsidiaries or affiliates represents or guarantees that this information or product may be used without infringing the intellectual property rights of others. Except to the extent a particular use and particular information are expressly stated on the product label, it is the users' own responsibility to determine the suitability of this information for their own particular use of this product. If necessary, contact MGK® to confirm that you have the most current product label and SDS.

This Safety Data Sheet (SDS) serves different purposes than and DOES NOT REPLACE OR MODIFY THE EPA-APPROVED PRODUCT LABEL (attached to and accompanying the product container). This SDS provides important health, safety, and environmental information for employers, employees, emergency responders and others handling large quantities of the product in activities generally other than product use as required by the Occupational Health and Safety Act (29 CFR 1910.1200, "Hazcom"). The product label provides information specifically for product use in the ordinary course. Use, storage and disposal of pesticide products is regulated by the EPA under the authority of FIFRA through the product label. All necessary hazard classification and appropriate

Page 9 ends

Onslaught® FastCap Spider & Scorpion Insecticide Revision Date: 21-0ct-2020 precautionary use, storage, and disposal information is set forth on that label or labeling accompanying the pesticide or to which reference is made on the label. It is a violation of federal law to use an EPA-registered pesticide product in any manner inconsistent with its labeling.

End of Safety Data Sheet

Page 10 ends

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
1/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
SECTION 1: IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE

COMPANY/UNDERTAKING
Product identifier
Trade name
Product code (UVP)
SDS Number
EPA Registration No.

SUSPEND® POL YZONE®
84493910
102000030997
432-1514
Relevant identified uses of the substance or mixture and uses advised against Use Insecticide
Restrictions on use
Information on supplier
Supplier
Responsible Department
Emergency telephone no.

Emergency Telephone
Number (24hr/ 7 days)
Product Information
Telephone Number
See product label for restrictions.

Bayer Environmental Science
A division of Bayer CropScience LP
500 Centregreen Way, Suite 400
Cary, NC 27513
USA
Email: [email protected]
1-800-334-7577
1-800-331-2867
SECTION 2: HAZARDS IDENTIFICATION
Classification in accordance with regulation HCS 29CFR §1910.1200 Skin irritation: Category 2
Labelling in accordance with regulation HCS 29CFR §1910.1200 ~
Signal word: Warning
Hazard statements
Causes skin irritation.

Precautionary statements
-j

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
2/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
Wash thoroughly after handling.

Wear protective gloves.

IF ON SKIN: Wash with plenty of water/ soap.

Specific treatment (see supplemental first aid instructions on this label).

If skin irritation occurs: Get medical advice/ attention.

Take off contaminated clothing and wash before reuse.

Hazards Not Otherwise Classified (HNOC)
No health hazards not otherwise classified.

No physical hazards not otherwise classified.

SECTION 3: COMPOSITION/INFORMATION ON INGREDIENTS
Hazardous Component Name
Deltamethrin
CAS-No.
52918-63-5
Concentration% by weight

4.75 SECTION 4: FIRST AID MEASURES
Description of first aid measures
General advice When possible, have the product container or label with you when calling a poison control center or doctor or going for treatment.

Move to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration, preferably mouth-to-mouth if possible.

Call a physician or poison control center immediately.

Take off contaminated clothing and shoes immediately. Wash off immediately with plenty of water for at least 15 minutes. Call a physician or poison control center immediately.

Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a physician or poison control center immediately.

Call a physician or poison control center immediately. Rinse out mouth and give water in small sips to drink. DO NOT induce vomiting unless directed to do so by a physician or poison control center. Never give anything by mouth to an unconscious person. Do not leave victim unattended.

Most important symptoms and effects, both acute and delayed Symptoms To date no symptoms are known.

Inhalation
Skin contact
Eye contact
Ingestion
Indication of any immediate medical attention and special treatment needed Treatment Appropriate supportive and symptomatic treatment as indicated by the patient's condition is recommended.

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
3/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
SECTION 5: FIREFIGHTING MEASURES
Extinguishing media
Suitable
Unsuitable
Special hazards arising
from the substance or
mixture
Advice for firefighters
Special protective
equipment for firefighters
Further information
Flash point
Auto-ignition temperature
Lower explosion limit
Upper explosion limit
Explosivity
Carbon dioxide (CO2), Dry chemical, Foam, Water
High volume water jet
Dangerous gases are evolved in the event of a fire.

Firefighters should wear NIOSH approved self-contained breathing apparatus and full protective clothing.

Keep out of smoke. Fight fire from upwind position. Cool closed containers exposed to fire with water spray. Do not allow run-off from fire fighting to enter drains or water courses.

No data available
No data available
No data available
No data available
Not applicable
SECTION 6: ACCIDENTAL RELEASE MEASURES
Personal precautions, protective equipment and emergency procedures Precautions Keep unauthorized people away. Isolate hazard area. Avoid contact with spilled product or contaminated surfaces.

Methods and materials for containment and cleaning up
Methods for cleaning up Dike area to prevent runoff. Soak up with inert absorbent material (e.g. sand, silica gel, acid binder, universal binder, sawdust). Collect and transfer the product into a properly labelled and tightly closed container. Clean contaminated surface thoroughly. Decontaminate tools and equipment following cleanup.

Additional advice Use personal protective equipment. If the product is accidentally spilled, do not allow to enter soil, waterways or waste water canal.

Reference to other sections Information regarding safe handling, see section 7.

Information regarding personal protective equipment, see section 8.

Information regarding waste disposal, see section 13.

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
4/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
SECTION 7: HANDLING AND STORAGE
Precautions for safe handling
Advice on safe handling Handle and open container in a manner as to prevent spillage. Use only in area provided with appropriate exhaust ventilation.

Wash hands thoroughly with soap and water after handling and before eating, drinking, chewing gum, using tobacco, using the toilet or applying cosmetics.

Remove Personal Protective Equipment (PPE) immediately after handling this product. Remove soiled clothing immediately and clean thoroughly before using again. Wash thoroughly and put on clean clothing.

Conditions for safe storage, including any incompatibilities Hygiene measures
Requirements for storage
areas and containers
Store in a cool, dry place and in such a manner as to prevent cross contamination with other crop protection products, fertilizers, food, and feed. Store in original container and out of the reach of children, preferably in a locked storage area.

SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION
Control parameters
Components CAS-No. Control parameters Update Basis
Deltamethrin 52918-63-5 0.01 mg/m3 OES BCS*
(TWA)
*OES BCS: Internal Bayer AG, Crop Science Division "Occupational Exposure Standard" Exposure controls
Personal protective equipment
In normal use and handling conditions please refer to the label and/or leaflet. In all other cases the following recommendations would apply.

Respiratory protection
Hand protection
Eye protection
Skin and body protection
General protective measures
When respirators are required, select NIOSH approved equipment based on actual or potential airborne concentrations and in accordance with the appropriate regulatory standards and/or industry recommendations.

Chemical resistant nitrile rubber gloves
Tightly fitting safety goggles
Wear long-sleeved shirt and long pants and shoes plus socks.

Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables, use detergent and warm/tepid water.

Keep and wash PPE separately from other laundry.

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
5/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Appearance white to light beige
Physical State suspension
Odor characteristic
Odour Threshold No data available
pH <= 7.0 (100 %) (23 °C)
Viscosity, kinematic No data available
Vapor Pressure No data available
Vapor Density (Air= 1) No data available
Density ca. 1.05 g/cm3 (20 °C)
Evaporation rate No data available
Boiling Point No data available
Melting / Freezing Point No data available
Water solubility dispersible
Minimum Ignition Energy Not applicable
Decomposition Stable under normal conditions.
temperature
Self-accelarating No data available
decomposition temperature
(SADT)
Partition coefficient: n- Not applicable
octanol/water
Viscosity
Flammability
Flash point
Auto-ignition temperature
Lower explosion limit
Upper explosion limit
Explosivity
Particle size
700 - 1,700 cps (25 °C)
No data available
No data available
No data available
No data available
No data available
Not applicable
No data available

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
6/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
SECTION 10: STABILITY AND REACTIVITY
Reactivity
Thermal decomposition Stable under normal conditions.

Chemical stability Stable under recommended storage conditions.

Possibility of hazardous No dangerous reaction known under conditions of normal use. reactions
Conditions to avoid Extremes of temperature and direct sunlight. freezing
Incompatible materials No incompatible materials known.

Hazardous decomposition No decomposition products expected under normal conditions of use. products
SECTION 11: TOXICOLOGICAL INFORMATION
Exposure routes
Immediate Effects
Eye
Skin
Eye contact, Skin contact, Inhalation
May cause eye irritation.

Causes skin irritation.

Information on toxicological effects
Acute oral toxicity LD50 (female Rat) > 5,000 mg/kg
Acute inhalation toxicity LC50 (male/female combined Rat) > 2.08 mg/I Exposure time: 4 h
Determined in the form of liquid aerosol.

Highest attainable concentration.

No deaths
LC50 (male/female combined Rat) > 8.32 mg/I
Exposure time: 1 h
Determined in the form of liquid aerosol.

Extrapolated from the 4 hr LC50.

LD50 (male/female combined Rat) > 5,000 mg/kg
Moderate skin irritation. (Rabbit)
Moderate eye irritation. (Rabbit)
Acute dermal toxicity
Skin corrosion/irritation
Serious eye damage/eye
irritation
Respiratory or skin
sensitisation
Assessment STOT Specific target organ toxicity - single exposure Skin: Non-sensitizing. (Guinea pig)

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
7/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
Deltamethrin: Based on available data, the classification criteria are not met.

Assessment STOT Specific target organ toxicity - repeated exposure Deltamethrin caused neurobehavioral effects and/or neuropathological changes in animal studies. The toxic effects of Deltamethrin are related to transient neurobehavioral effects typical for pyrethroid neurotoxicity.

Assessment mutagenicity
Deltamethrin was not mutagenic or genotoxic in a battery of in vitro and in vivo tests.

Assessment carcinogenicity
Deltamethrin was not carcinogenic in lifetime feeding studies in rats and mice.

ACGIH
None.

NTP
None.

IARC
Deltamethrin
OSHA
None.
52918-63-5 Overall evaluation: 3
Assessment toxicity to reproduction
Deltamethrin did not cause reproductive toxicity in a two-generation study in rats.

Assessment developmental toxicity
Deltamethrin caused developmental toxicity only at dose levels toxic to the dams. The developmental effects seen with Deltamethrin are related to maternal toxicity.

Aspiration hazard
Based on available data, the classification criteria are not met.

Further information
Acute toxicity studies have been bridged from a similar formulation(s).

The non-acute information pertains to the active ingredient(s).

SECTION 12: ECOLOGICAL INFORMATION
Toxicity to fish
Toxicity to aquatic
invertebrates
LC50 (Oncorhynchus mykiss (rainbow trout)) 0.15 µg/I
Exposure time: 96 h
The value mentioned relates to the active ingredient deltamethrin.

EC50 (Daphnia magna (Water flea)) 0.0131 µg/I
Exposure time: 48 h
The value mentioned relates to the active ingredient deltamethrin.

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
8/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
Toxicity to aquatic plants EC50 (Algae)> 9.1 mg/I
Exposure time: 96 h
The value mentioned relates to the active ingredient deltamethrin.

Biodegradability Deltamethrin:

Not rapidly biodegradable
Koc Deltamethrin: Koc: 10240000
Bioaccumulation Deltamethrin: Bioconcentration factor (BCF) 1,400 Does not bioaccumulate.

Mobility in soil Deltamethrin: Immobile in soil
Environmental precautions Do not allow to get into surface water, drains and ground water.

Do not contaminate surface or ground water by cleaning equipment or disposal of wastes, including equipment wash water.

Do not apply when weather conditions favor runoff or drift.

Do not apply this product or allow it to drift to blooming crops or weeds if bees are visiting the treatment area.

Apply this product as specified on the label.

SECTION 13: DISPOSAL CONSIDERATIONS
Waste treatment methods
Product
Contaminated packaging
RCRA Information
Do not contaminate water, food, or feed by disposal.

Dispose in accordance with all local, state/provincial and federal regulations.

Follow advice on product label and/or leaflet.

Do not re-use empty containers.

Triple rinse containers.

Puncture container to avoid re-use.

Consult state and local regulations regarding the proper disposal of container.

Follow advice on product label and/or leaflet.

Characterization and proper disposal of this material as a special or hazardous waste is dependent upon Federal, State and local laws and are the user's responsibility. RCRA classification may apply.

SECTION 14: TRANSPORT INFORMATION
49CFR
IMDG
UN number
Class
Packaging group
Marine pollutant
Not dangerous goods I not hazardous material
3082
9 Ill
YES

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
9/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
Proper shipping name
IATA
UN number
Class
Packaging group
Environm. Hazardous Mark
Proper shipping name

ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID,
N.O.S.
(DEL TAMETHRIN SOLUTION)
3082
9 Ill
YES

ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID,
N.O.S.
(DELTAMETHRIN SOLUTION)
This transportation information is not intended to convey all specific regulatory information relating to this product. It does not address regulatory variations due to package size or special transportation requirements.

Freight Classification: INSECTICIDES OR FUNGICIDES, N.O.1., OTHER THAN POISON
SECTION 15: REGULATORY INFORMATION
EPA Registration No.

US Federal Regulations
TSCA list
Water 7732-18-5
1,2-Propanediol 57-55-6
Butoxypolyethylene-/propylene glycol 9038-95-3
US. Toxic Substances Control Act (TSCA) Section 12(b) Export Notification (40 CFR 707, Subpt D) No export notification needs to be made.

SARA Title Ill - Section 302 - Notification and Information Not applicable.

SARA Title Ill - Section 313 - Toxic Chemical Release Reporting None.
432-1514
US States Regulatory Reporting
CA Prop65
This product does not contain any substances known to the State of California to cause cancer.

This product does not contain any substances known to the State of California to cause reproductive harm.

US State Right-To-Know Ingredients
1,2-Propanediol
Pyrogenic (fumed) amorphous silica
None.
57-55-6
112945-52-5
MN, RI
CA, MN
i

SAFETY DATA SHEET
SUSPEND® POLYZONE®
Version 3.0 / USA
102000030997
10/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
EPA/FIFRA Information:

This chemical is a pesticide product registered by the Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets, and for workplace labels of non-pesticide chemicals. Following is the hazard information required on the pesticide label:

Signal word:

Hazard statements:

Caution!
Causes moderate eye irritation.

Contact with product may result in transient tingling and reddening of the skin.

SECTION 16: OTHER INFORMATION
Abbreviations and acronyms
49CFR
ACGIH
ATE
CAS-Nr.

CERCLA
EINECS
ELINCS
IARC
IATA
IMDG
N.O.S.

NTP
OECD
TDG
TWA
UN
WHO
Code of Federal Regulations, Title 49
US. ACGIH Threshold Limit Values
Acute toxicity estimate
Chemical Abstracts Service number
Comprehensive Environmental Response, Compensation, and Liability Act European inventory of existing commercial substances
European list of notified chemical substances
International Agency for Research on Cancer
International Air Transport Association
International Maritime Dangerous Goods
Not otherwise specified
US. National Toxicology Program (NTP) Report on Carcinogens Organization for Economic Co-operation and Development
Transportation of Dangerous Goods
Time weighted average
United Nations
World health organisation
NFPA 704 (National Fire Protection Association):

Health - 1 Flammability - 1 Instability - 0 Others - none HMIS (Hazardous Materials Identification System, based on the Third Edition Ratings Guide) Health - 1 Flammability - 1 Physical Hazard - 0 PPE -
0 = minimal hazard, 1 = slight hazard, 2 = moderate hazard, 3 = severe hazard, 4 = extreme hazard Reason for Revision: The following sections have been revised: Section 11: Toxicological Information.

Reviewed and updated for general editorial purposes.

Revision Date: 05/20/2020
This information is provided in good faith but without express or implied warranty. The customer assumes

SAFETY DATA SHEET
SUSPEND® POL YZONE®
Version 3.0 / USA
102000030997
11/11
Revision Date: 05/20/2020
Print Date: 05/22/2020
all responsibility for safety and use not in accordance with label instructions. The product names are registered trademarks of Bayer.
~
=~~g!~S, INC. TERAD3® BLOX
._..

SAFETY DATA SHEET ACCORDING TO REGULATION: OSHA Hazard I DATE OF ISSUE: I PREPARED BY:

Communication Standard 29 CFR 1910, 1200 January 2020 CAR SECTION 1. PRODUCT AND COMPANY IDENTIFICATION
Product Identifier: TERAD3® BLOX
EPA Registration Number: 12455-106
Relevant identified uses: Acute Rodenticide - Ready to use Uses advised against: Use only for the purpose described above MANUFACTURER/SUPPLIER:

Bell Laboratories, Inc,
3699 Kinsman Blvd.

Madison, WI 53704, USA
Email: [email protected]
Phone: 608-241-0202
Medical or Vet Emergency: 877-854-2494 or 952-852-4636
Spill or Transportation Emergency: 800-424-9300 (CHEMTREC) SECTION 2. HAZARDS IDENTIFICATION
Classification according to Regulation OSHA 1910.1200( d): Not classified Signal Word: None
See Section 15 for information on FIFRA applicable safety, health, and environmental classifications.

SECTION 3. COMPOSITION/INFORMATION ON INGREDIENTS
Component CAS No. % By weight
Cholecalciferol [9, I 0-secocholesta- 5,7, 10( 19)-trien-3-ol] 67-97-0 0.075% Inert and Non-Hazardous Ingredients Proprietary 99.925% (Unlisted components are non-hazardous)
SECTION 4. FIRST AID MEASURES
Description of first aid measures
Ingestion: Call physician or emergency number immediately, Have person sip a glass of water if able to swallow. Do not induce vomiting unless instructed by physician.

Inhalation: Not applicable.

Eye contact: Hold eye open and rinse slowly with water for 15 - 20 minutes, Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. If irritation develops, obtain medical assistance.

Skin contact: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15 - 20 minutes, If irritation develops, obtain medical assistance.

Most important symptoms and effects, both acute and delayed Ingestion of excessive quantities may cause hypercalcemia, anorexia, nausea, vomiting, loss of appetite, extreme thirst, lethargy, diarrhea, profuse sweating, headache.

Advice to physician: There is no specific antidote. If serum calcium levels are elevated, treatment with calcitonin is effective in reducing calcium to normal levels. Continue monitoring serum calcium and treat as necessary for hypercalcemia. (Reference: AMA Drug Evaluations, Third Edition ( 1977) Chapter 16, pp. 248-251)
Advice to Veterinarian: For animals ingesting bait and/or showing poisoning signs, induce vomiting by using hydrogen peroxide or administration of activated charcoal with a cathartic, If clinical signs develop, treatment consisting of saline diuresis combined with the use of furosemide, corticosteroids, and phosphate binders are recommended. Calcitonin or pamidronate may be needed for animals that remain hypercalcemic despite symptomatic treatment
Trade Name: Terad3 Blox
Supplier: Bell Laboratories, Inc.

Date Created: January 2020

Page 1 of 4 ends

SECTION 5. FIRE-FIGHTING MEASURES
Extinguishing media
Suitable Extinguishing Media: water, foam or inert gas.

Unsuitable Extinguishing Media: None known.

Special hazards arising from the mixture: High temperature decomposition or burning in air can result in the formation of toxic gases, which may include oxides of carbon.

Advice for firefighters: Wear protective clothing and self-contained breathing apparatus.

SECTION 6. ACCIDENTAL RELEASE MEASURES
Personal precautions, protective equipment and emergency procedures: Gloves should be worn when handling the bait. Collect spillage without creating dust.

Environmental precautions: Do not allow bait to enter drains or water courses. Where there is contamination of streams, rivers or lakes contact the appropriate environment agency.

Methods and materials for containment and cleaning up
For Containment: Sweep up spilled material immediately. Place in properly labeled container for disposal or re-use.

For Cleaning Up: Wash contaminated surfaces with detergent. Dispose of all wastes in accordance with all local, regional and national regulations.

Reference to other sections: Refer to Sections 7, 8 & 13 for further details of personal precautions, personal protective equipment and disposal considerations.

SECTION 7. HANDLING AND STORAGE
Precautions for safe handling: Do not handle the product near food, animal foodstuffs or drinking water. Keep out of reach of children. Do not use near heat sources, open flame, or hot surfaces. As soon as possible, wash hands thoroughly after applying bait and before eating, drinking, chewing gum, using tobacco, or using the toilet.

Conditions for safe storage, including any incompatibilities: Store only in original container in a cool, dry place, inaccessible to pets and wildlife. Do not contaminate water, food or feed by storage or disposal. Keep containers closed and away from other chemicals.

SECTION 8. EXPOSURE CONTROLS/PERSONAL PROTECTION
Established Limits
I Component I OSHA I ACGIH I Other Limits I
I Cholecalciferol I Not Established I Not Established I Not Established I Appropriate Engineering Controls: Not required
Occupational exposure limits: Not established
Personal Protective Equipment:

Respiratory protection: Not required
Eye protection: Not required
Skin protection: Shoes plus socks, and waterproof gloves.

Hygiene recommendations: Keep and wash PPE separately from other laundry. Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash hands thoroughly after applying bait and before eating, drinking, chewing gum, using tobacco or using the toilet, and change into clean clothing.

Trade Name: Terad3 Blox
Supplier: Bell Laboratories, Inc.

Date Created: January 2020

Page 2 of 4 ends

SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Information on basic physical and chemical properties
Appearance/Color: Blue-grey-beige-brown wax block
Odor: Sweet grain-like
Odor Threshold: No Data
pH: No Data
Melting point: No Data
Boiling point: No Data
Flash point: No Data
Evaporation rate: No Data
Flammability: No Data
Upper/lower flammability or explosive limits: No Data
Vapor Pressure: No Data
Vapor Density: No Data
Relative Density: 1.13 g/mL@20°C
Solubility (water): No Data
Solubility (solvents): No Data
Partition coefficient: n-octanol/water: No Data
Auto-ignition temperature: No Data
Decomposition temperature: No Data
Viscosity: No Data
SECTION 10. STABILITY AND REACTIVITY
Reactivity: Stable when stored in original container in a cool, dry location.

Chemical stability: Stable when stored in original container in a cool, dry location.

Possibility of hazardous reactions: Refer to Hazardous decomposition products Conditions to avoid: Avoid extreme temperatures (below 0°C or above 40°C).

Incompatible materials: Avoid strongly alkaline materials.

Hazardous decomposition products: High temperature decomposition or burning in air can result in the formation of toxic gases, which may include oxides of carbon.

SECTION 11. TOXICOLOGICAL INFORMATION
Information on toxicological effects
Acute Toxicity
LOSO, oral (ingestion): >5001 mg/kg (rats) (Cholecalciferol Rat LOSO oral: 43.6 mg/kg bw).

LOSO, dermal (skin contact):> 5001 mg/kg (rats) (Cholecalciferol not determined).

LCSO, inhalation: Product is a wax block and therefore exposure by inhalation is not relevant.

Skin corrosion/irritation : Not irritating to skin.

Serious eye damage/Irritation: Not irritating to eyes.

Respiratory or skin sensitization: Dermal sensitization: Not a Sensitizer (Guinea pig maximization test).

Germ cell mutagenicity: Contains no components known to have a mutagenetic effect.

Carcinogenicity: Contains no components known to have a carcinogenetic effect.

I Components NTP I IARC I OSHA I
I Cholecalciferol Not listed I Not listed I Not listed I Reproductive Toxicity: No data
Aspiration Hazard: Not applicable. Product is a wax block.

Target Organ Effects: Damage caused by an accumulation of calcium.

SECTION 12. ECOLOGICAL INFORMATION
Ecotoxicity Effects: This product is extremely toxic to birds and mammals. Do not apply this product directly to water, where surface water is present or to intertidal areas below the mean high water mark. Carefully follow label cautions and directions to reduce hazards to children, pets and non-target wildlife.

Persistence and degradability: Product is inherently biodegradable. Cholecalciferol slowly decomposes in water.

Bioaccumulative potential: Not determined. Cholecalciferol water solubility is extremely low(< 0.1 mg/I).

Mobility in Soil: Not determined. Mobility of cholecalciferol in soil is considered to be limited.

Other adverse effects: None.

Trade Name: Terad3 Blox
Supplier: Bell Laboratories, Inc.

Date Created: January 2020

Page 3 of 4 ends

SECTION 13. DISPOSAL CONSIDERATIONS
Do not contaminate water, food or feed by storage or disposal.

Pesticide Storage: Store only in original container in a cool, dry place inaccessible to children and pets. Keep containers closed and away from other chemicals.

Pesticide Disposal: Wastes resulting from the use of this product according to the label instructions must be disposed ofas specified on the product label. RCRA waste status: This product is not regulated as a hazardous waste under Federal law. State and local regulation may affect the disposal of this product. Consult your state or local environmental agency for disposal of waste generated other than by use according to label instructions.

Container Handling: Non-refillable container. Do not reuse or refill this container. [Plastic:] Offer for recycling or reconditioning; or puncture and dispose of in a sanitary landfill; or by incineration. In most states, burning is not allowed. [Paper:] Dispose of empty container by placing in trash, at an approved waste disposal facility or by incineration. In most states, burning is not allowed.

RCRA Waste Status: This product is not regulated as a hazardous waste under Federal law.

SECTION 14. TRANSPORT INFORMATION
UN number: Not regulated
UN proper shipping name: Not regulated
Transport hazard class(es): Not regulated
Packing group: Not regulated
Environmental Hazards
DOT Road/Rail: Not considered hazardous for transportation via road/rail.

DOT Maritime: Not considered hazardous for transportation by vessel.

DOT Air: Not considered hazardous for transportation by air.

Freight Classification: L TL Class 60
Transport in bulk according to Annex II of MARPOL 73/78 and the IBC code: Not applicable Special precautions for user: None
SECTION 15. REGULATORY INFORMATION
Safety, health and environmental regulations/legislation specific for the substance or mixture:

FIFRA: This pesticide product is regulated by the United States Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets (SOS), and for workplace labels of non-pesticide chemicals. The safety, health, environmental, and hazard information required on the pesticide label is listed below and reflected throughout this SDS. The pesticide label also includes other important information, including directions for use.

Signal Word: CAUTION
Precautionary Statements: Contains the calcium mobilizer, cholecalciferol. Harmful if swallowed or absorbed through the skin. Keep away from children, domestic animals and pets. Do not get in eyes, on skin or on clothing.

Potential Health Effects:

Eye Contact: May cause irritation
Skin Contact: Non-irritating to the skin
Ingestion: Harmful if swallowed
TSCA: All components are listed on the TSCA Inventory or are not subject to TSCA requirements CERCLA/SARA 313: Not listed
CERCLA/SARA 302: Not listed
PROPOSITION 65: Contains no components subject to warning requirement.

SECTION 16. OTHER INFORMATION
For additional information, please contact the manufacturer noted in Section I.

I NFPA I Health: I (caution) I Flammability: I (slight) I Reactivity: 0 (stable) I Specific Hazard: None I I HMIS I Health: 2 (moderate) I Flammability: 0 (slight) I Reactivity: 0 (minimal) I Protective Equipment: B I Disclaimer: The information provided in this Safety Data Sheet has been obtained from sources believed to be reliable. Bell Laboratories, Inc. provides no warranties; either expressed or implied, and assumes no responsibility for the accuracy or completeness of the data contained herein. This information is offered for your consideration and investigation. The user is responsible to ensure that they have all current data, including the approved product label, relevant to their particular use.

Trade Name: Terad3 Blox
Supplier: Bell Laboratories, Inc.

Date Created: January 2020

Page 4 of 4 ends

CERTIS USA
Safety Data Sheet (SOS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
SECTION 1: Identification of the substance/mixture and of the company/undertaking

1.1. Product identifier
Product name:

EPA Registration No.

Product Type:

Active Ingredient:

CAS No.:

Trilogy®, Triact®, Neem Oil 70%®, Nimbuz®
70051-2
Emulsifiable Concentrate
Clarified Hydrophobic Extract of Neem Oil
947173-77-5

1.2. Relevant identified uses of the substance or mixture and uses advised against Identified uses: Insecticide, Miticide and Fungicide
Uses advised against: Any use not listed on the label.

1.3. Details of the supplier of the safety data sheet
Name:

Address:

Phone Number:

Website/E-mail:

Certis U.S.A., L.L.C.
9145 Guilford Road, Suite 175
Columbia, Maryland 21046
U.S.A.
+01 (800) 847-5620
www.certisusa.com/ [email protected]

1.4. Emergency telephone number
Emergency number: Chem-Tel: +1 800 255-3924
SECTION 2: Hazards identification

2.1. Classification of the substance or mixture
Hazard Classification:

Signal Word:

Hazard Statements:

Pictogram:

Precautionary
Statements:

Flammable Liquid Cat. 4
Warning
Combustible Liquid
None
• Keep away from flames and hot surfaces. No smoking.
• Wear protective gloves/eye protection/face protection. • In case of fire, use a suitable dry chemical, foam or carbon dioxide to extinguish.
• Store in a well-ventilated place. Keep cool.
• Dispose of contents/container in accordance with all local, regional, national, and international regulations.
• Refer to product label for complete precautionary statements, PPE, and storage and disposal instructions.

Page 1 of 9 ends

CE TIS USA
Safety [J)ata Sheet (SOS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019

2.2 Other Hazards: Not available.

SECTION 3: Composition/information on ingredients

3.1 Substance
Ingredient
Clarified Hydrophobic Extract of Neem Oil
CAS Number
947173-77-5
Specific identity of other components is withheld as a trade secret % by weight

70.0 30.0
SECTION 4: First aid measures

4.1. Description of first aid measures
Generic measures Call a poison control center or doctor for treatment advice. Have the product container or label with you when you calling the poison control center or doctor or going for treatment.

Eye Contact: Hold eye open and rinse slowly and gently with water for 15-20 minutes.

Remove contact lenses after 5 minutes, if present, then continue rinsing eye.

Skin Contact: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes.

Inhalation: Call a poison control center or doctor for treatment advice.

Ingestion: Call a poison control center or doctor for treatment advice.

4.2. Most important symptoms and effects, both acute and delayed May cause moderate skin or eye irritation.

4.3. Indication of any immediate medical attention and special treatment needed Not available.

SECTION 5: Firefighting measures

5.1. Extinguishing media
Suitable Extinguishing Media:

Unsuitable Extinguishing Media:

Dry chemical, foam, or carbon dioxide extinguisher.

Do not extinguish with water.

5.2. Special hazards arising from the substance or mixture Hazardous combustion products: None known.

5.3. Advice for firefighters
Protection of Firefighters: Keep upwind of fire.

Page 2 of 9 ends

CE&TIS USA
Safety Data Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
SECTION 6: Accidental release measures

6.1. Personal precautions, protective equipment and emergency procedures For non-emergency personnel: Keep unauthorized people away from the concerned area. Use personal protections as indicated in Section 8. Evacuate the area and observe emergency procedures.

For emergency respo
nders: Use personal protective equipment as recommended in Section 8.

Isolate the area and deny entry to unnecessary and unprotected personnel.

6.2. Environmental precautions
This product is hazardous to fish and aquatic vertebrates. For terrestrial uses: Do not apply directly to water or to areas where surface water is present, or to intertidal areas below the mean high water mark.

Do not contaminate water when disposing of equipment washwater or rinsate.

This product is toxic to bees exposed to direct treatment. Do not apply this product while bees are actively visiting the treatment area.

6.3. Methods and material for containment and cleaning up Methods for Containment:

Methods for Clean-Up:

Other Information:

Contain and/or absorb with inert material, then place in a suitable container. Do not flush to sewer or allow to enter waterways. Use appropriate PPE.

None specified.

Not available.

6.4. Reference to other sections
Refer to section 8 for further information on protective clothing and section 13 for directions for waste disposal.

SECTION 7: Handling and storage
7 .1. Precautions for safe handling
Applicators and other handlers must wear:
• Long sleeved shirt, long pants,
• chemical resistant gloves (such as barrier laminate, butyl rubber, nitrile rubber, neoprene rubber, or poly vinyl chloride)
• shoes plus socks
Follow manufacturers instructions for cleaning and maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE separately from other laundry. Remove clothing/PPE immediately if pesticide gets inside. Then was thoroughly and put on clean clothing.

Remove PPE immediately after handling this product. Wash the outside of gloves before removing.

Page 3 of 9 ends

CERTIS _JSA
Safety Data Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019

7.2. Conditions for safe storage, including any incompatibilities Keep in original container. Store in a dry place, away from direct sunlight. feed, or foodstuffs. Keep container tightly sealed when not in use. Do not store below 40°F (4 °C).

7.3. Specific end use(s)
Use only as specified on label.

SECTION 8: Exposure controls/personal protection

8.1. Control parameters
OSHA Permissible Exposure Limits (PELs): Not established.

ACGIH Threshold Limit Values:

Other Exposure Limits:

8.2. Exposure controls
Engineering Controls:

Personal Protective Equipment
Eye/Face Protection:

Skin Protection
Hand Protection:

Body Protection:

Respiratory Protection:

Thermal Hazards:

General Hygiene Considerations:

Environmental exposure
controls:

Not established.

None specified.

Long-sleeved shirt and long pants, shoes plus socks.

Chemical resistant gloves (such as barrier laminate, butyl rubber, nitrile rubber, neoprene rubber, or poly vinyl chloride) Long-sleeved shirt and long pants, shows plus socks.

None specified.

Avoid contact with skin, eyes, or clothing. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum or using tobacco. Remove and wash
contaminated clothing before reuse.

For terrestrial use only: Do not apply directly to water or to areas where surface water is present, or to inter tidal areas below the mean high water mark. This product is toxic to bees exposed to direct treatment. Do not apply this product while bees are actively visiting the treatment area.

SECTION 9: Physical and chemical properties

9.1. Information on basic physical and chemical properties Appearance:

Odour:

Odour Threshold:
pH: 1% dilution
Brown liquid.

Citrus/garlic.

Not determined.

4.5-6.5.

Page 4 of 9 ends

CE ~IS USA
Safety Data Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
Melting Point/
Freezing Point:

Initial Boiling Point:

Boiling Range:

Flash Point:

Evaporation Rate:

Flammability (solid, gas):

Lower & Upper Flammability
Limits:

Vapour Pressure:

Volatility by weight :

Density:

Solubility:

Partition Coefficient
( n-octan cl/water):

Auto-ignition Temperature:

Decomposition Temperature:

Viscosity:

Explosive Properties:

Oxidising Properties:

9.2. Other information
Not available.
37°F (3°C).
>275 ° F.

Not determined.
70°c.

Not determined.

Not applicable.

Not determined.
25%.

0.86-0.95 g/ml.

Not determined.

None known.

SECTION 10: Stability and reactivity

10.1. Reactivity

10.2. Chemical stability

10.3. Possibility of hazardous reactions
Combustible liquid, no known hazardous reactions when
handled and stored according to stated provisions.

Stable when handled and stored according to stated
provisions.

No known hazardous reactions when handled and
stored according to stated provisions.

10.4. Conditions to avoid Keep aware from flames and hot surfaces. Do not store below 40°F (4°C).

10.5. Incompatible materials None known.

10.6. Hazardous decomposition products None known.

Page 5 of 9 ends

CE ~IS USA
Safety Data Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
SECTION 11: Toxicological information

11.1. Information on toxicological effects
Acute Toxicity
Toxicological information on the substance or mixture:

LDso (oral)
LDso (dermal)
LCso (inhalation)
Skin corrosion /
irritation:

Eye irritation:

Respiratory or skin
sensitization:
> 5000 mg/kg (test with similar product containing higher concentration of the same active ingredient)
> 2000 mg/kg (test with similar product containing higher concentration of the same active ingredient)
> 6.17 ± 1.23 mg/L (test with similar product containing higher concentration of the same active ingredient)
Slightly irritating, Toxicity Category IV (test with similar product containing higher concentration of the same active ingredient)
Minimally irritating, Toxicity Category Ill (test with similar product containing higher concentration of the same active ingredient) Mildly sensitizing (test with similar product containing high concentration of the same Al)
Other information on adverse health effects:

Carcinogenicity
NTP Listed: Not applicable.

IARC Listed: Not applicable.

OSHA: Not applicable.

11.2 Reference to other sections
See Section 4 for symptoms and acute and delayed effects.

SECTION 12: Ecological information
12 1 Toxicitv
Test species Test method Test substance LCso
Bobwhite Quail
14-day
Active Ingredient LDso > 2,150 mg a.i./kg body weight
acute oral
Pimephales promelas 96-hour Active Ingredient NOEC 96-hour: 2,000 mg/L (Fathead Minnow) Oaphnia magna 48-hour Active Ingredient NOEC 48-hour: 2,000 mg/L Apis mellifera L
This product is toxic to bees exposed to direct treatment.

Do not apply when bees are actively visiting the treatment area.

12.2. Persistence and deqradability Neem oil degrades rapidly and does not persist in the environment.

Page 6 of 9 ends

CE
Safety Data Sheet (SOS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019

12.3. Bioaccumulative potential

12.4. Mobility in soil

12.5. Other adverse effects
Neem oil is not intended for use in aquatic environments.

Appropriate cautions are required for use around bodies of water.

No data available.

SECTION 13: Disposal considerations

13.1. Waste treatment methods
Disposal Instructions: Do not contaminate water, food, or feed by storage and disposal.

Pesticide Storage: Keep in original container. Store in a dry place, away from direct sunlight. feed, or foodstuffs. Keep container tightly sealed when not in use. Do not store below 40°F (4°C).

Pesticide Disposal" Wastes resulting from the use of this product must be disposed of on-site or at an approved waste disposal facility.

Contai1er Handling: Non-refillable container. Do not reuse or refill this container. -tor containers equal to or less than 5 gallonsTri pie rinse container (or equivalent) promptly after emptying. Triple rinse as following: Empty the remaining contents into application equipment or a mix tank and drain for 10 seconds after the flow begins to drip. Fill the container 1/4 full with water and recap. Shake for 10 seconds.

Pour rinsate into application equipment or a mix tank or store rinsate for later use or disposal.

Drain for 10 seconds after the flow begins to drip. Repeat this procedure two more times. Then offer for recycling, if available or puncture and dispose of in a sanitary landfill, or by incineration, or if allowed by state and local authorities, by burning. If burned, stay out of smo~. ·
-ior containers greater than 5 gallonsTriple rinse as follows: Empty the remaining contents into application equipment or a mix tank. Fill the container¼ full with water. Replace and tighten closures. Tip container on its side and roll it back and forth, ensuring at least one complete revolution, for 30 seconds. Stand the container on its end and tip back and forth several times. Turn the container over onto its other end and tip it back and forth several times. Empty the rinsate into application equipment or a mix tank or store rinsate for later use or disposal. Repeat this procedure two more times.

Then offer for recycling, if available, or puncture and dispose of in a sanitary landfill, or by incineration, or if allowed by state and local authorities, by burning. If burned, stay out of smoke. -tor 250-gallon refillable containersRefillable container. Refill this container with pesticide only. Do no reuse this container for any other purpose. Cleaning the container before final disposal is the responsibility of the person disposing of the container. Cleaning before refilling is the responsibility of the refiller. To clean the container before final disposal, empty the remaining contents from this container into application equipment or mix tank. Fill the container about 10 percent full with water. Agitate

Page 7 of 9 ends

CE
Safety Data Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
vigorously or recirculate water with pump for 2 minutes. Pour or pump rinsate into application equipment or rinsate collection system. Repeat this rinsing procedure two more times.

SECTION 14: Transportation information

14.1. UN number
Not regulated.

14.3. Transport hazard class(es)
Not regulated.

14.2. UN proper shipping name
Not regulated.

14.4. Packing group
Not regulated.

14.5. Environmental hazards 14.6. Special precautions for user Not regulated. Not regulated.

14.7. Transport in bulk according to Annex II of MARPOL73/78 and the IBC Code Not regulated.

SECTION 15: Regulatory information

15.1. Safety, health and environmental regulations/legislation specific for the substance or mixture
EPA: This product is a pesticide product registered by the United States Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets (SOS), and for workplace labels of non-pesticidal chemicals. The hazard information required on the pesticide label is reproduced below. The pesticide label also includes other important information, including directions for use.

CAUTION, KEEP OUT OF REACH OF CHILDREN
Harmful if absorbed through the skin. Causes moderate eye irritation.

This product is hazardous to fish and aquatic invertebrates.

This product is highly toxic to bees exposed to direct treatment.

OSHA: N/A
TSCA Status: Exempt
CERCLA Reportable Quantity: N/A
SARA Title Ill:

Section 302: N/A
Section 311/312: N/A
Section 313: N/A
RCRA Status: N/A
SECTION 16: Other information
Disclaimer:

To the best of our knowledge, the information contained herein is accurate. However, neither Certis USA nor any of its subsidiaries assume any liability whatsoever for the accuracy or completeness of the information contained herein. Final determination of suitability of any material is the sole responsibility of

Page 8 of 9 ends

CE TIS USA
Safety [])ata Sheet (SDS)
Product Name: Trilogy®, Triact®, Neem Oil 70%®, Nimbuz® Date of Revision: April 17, 2019
the user. All material may present unknown health hazards and should be used with caution. Although certain hazards are described herein, we cannot guarantee that these are the only hazards which exist.

SDS Authoring Information:

Revision date:

Date of Previous
version:

Reason for Revision:

SDS Prepared by:

April 17, 2019
March 23, 2015
Periodic update.

Certis U.S.A., L.L.C.

Page 9 of 9 ends

LIST OF TRAINED PERSONNEL
City of Carpinteria Position Department
Tiffany Smith Parks and Facilities Supervisor Public Works Contractor Address Contractor License No.

Showscapes, Inc. 1200 Paseo Camarillo, Camarillo, CA 93010 797240

GLYPHOSATE
Fact Sheet
EPA has concluded its regulatory review of glyphosate, the most widely used herbicide in the United States. After a thorough review of the best available science, as required under the Federal Insecticide, Fungicide, and Rodenticide Act, EPA has concluded there are no risks of concern to human health when glyphosate is used according to the label and that it is not a carcinogen. EPA scienttstshad performed an independent evaluation of available data for glyphosate and found:

No risks of concern to human health from proper use of glyphosate. Glyphosate products used according to label directions do not result in risks to children or adults.

No indication of children being more sensitive to glyphosate. After evaluating numerous studies from a variety of sources, EPA found no indication of children being more sensitive to glyphosate from in utero or post-natal exposure. As part of the human health risk assessment, EPA evaluated all populations including infants, children and women of child-bearing age and found no risks of concern from ingesting food with glyphosate residues. EPA also found no risks of concern for children entering or playing on residential areas treated with glyphosate.

No evidence of glyphosate causing cancer in humans. EPA concluded glyphosate is not likely to be carcinogenic to humans. EPA considered a significantly more extensive and relevant data set than the International Agency on the Research for Cancer (IARC).

EPA's database includes studies submitted to support registration of glyphosate and studies EPA identified in the open literature. For instance, IARC only considered eight animal carcinogenicity studies while EPA used fifteen (15) acceptable carcinogenicity studies. EPA does not agree with IARC's conclusion about glyphosate being "probably carcinogenic to humans."
EPA's cancer classification is consistent with other international expert panels and regulatory authorities, including the Canadian Pest Management Regulatory Agency, Australian Pesticide and Veterinary Medicines Authority, European Food Safety Authority, European Chemicals Agency, German Federal Institute for Occupational Safety and Health, New Zealand Environmental Protection Authority, and Food Safety Commission of Japan and the Joint Food and Agriculture Organization/World Health Organization (FAQ/WHO) Meeting on Pesticide Residues (JMPR).

For more information, read the Revised Glyphosate Issue Paper: Evaluation of Carcinogenic Potential.

No indication of glyphosate is an endocrine disruptor. Glyphosate underwent Tier I screening under EPA's Endocrine Disruptor Screening Program. Based on all available information, EPA concluded, using a weight-of-evidence approach, the existing data do not indicate glyphosate has the potential to interact with the estrogen, androgen, or thyroid signaling pathways. The screening program did not indicate the need for additional testing for glyphosat

Carpinteria City CouncilJanuary 22, 2024

Carpinteria City Council
January 22, 2024