Goleta City Council
March 7, 2023

City Council Resolution No. 23- __
brush covers the Project site. The Project would include mass grading to prepare the Project site to support the residential development. The Project site is located in an LRA in an area identified by CalFire as a “Non-Very High Fire Hazard Severity Zone” (CalFire 2008). According to Figure 5 -2, Fire, Flood, and Tsunami Hazards Map, in the City of Goleta General Plan/Coastal Land Use Plan, the Project site is not located in an identified Fire Hazard Severity Zone (City of Goleta 2016). The Project site also is surrounded on all sides by roadways, the Union Pacific Railroad, and urban development.

Accordingly, the Project would not occur in a state responsibility area or land classified as a very high fire hazard severity zone, or on steep slopes or in a highly vegetated area, such that development of the site would expose project occupants to significant wildfire risks due to slope, prevailing winds, or other factors. The proposed development also would be required to comply with all applicable SBCFD standards and City Building Code requirements to further avoid and minimize potential fire risks. Direct and indirect impacts related to wildfire risk due to slope, prevailing winds, or other factors would be less than significant. (Final EIR, pp. 4.16-3 through 4.16-4.)

3. Infrastructure Risks
Threshold: Would the Project require the installation or maintenance of associated infrastructure (such a ro ads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Finding: Less than significant. (Final EIR, p. 4.16-4.) Explanation: The Projec t would include mass grading to prepare and level the site to support the proposed residential development. The project would include installation of driveways to provide site access and underground utilities to support the residential development. The Project and associated infrastructure would be located in an urbanized area and outside of high fire hazard areas.

The proposed development would also be required to comply with all applicable SBCFD standards and City Building Code requirements to avoid and m inimize potential wildfire risks. Therefore, exacerbation of fire risk from installation and maintenance of project infrastructure would be less than significant. (Final EIR, p. 4.16-4.)

4. Runoff Risks
Threshold: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post - fire slope instability, or drainage changes?
Finding: Less than significant. (Final EIR, p. 4.16-4.) Explanation: The Project would be located in an urbanized area and outside of high fire hazard areas and flood hazard areas. The Project would include mass grading 109
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to prepare and level the site to support the proposed residential development and would include bioretent ion basins/areas and permeable pavement throughout the site to facilitate stormwater drainage. The proposed development also would be required to comply with all applicable SBCFD standards and City Building Code requirements to further avoid and minimize potential wildfire risks, including downstream flooding and landslides.

Therefore, direct and indirect impacts from exposure of people and structures to wildfire risks, including downslope or downstream flooding or landslides, would be less than significant. (Final EIR, p. 4.16-4.)

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SECTION III.

IMPACTS THAT ARE LESS THAN SIGNIFICANT WITH MITIGATION

INCORPORATED
The City Council hereby finds that Mitigation Measures have been identified in the EIR and in these Findings that will avoid or substantially lessen the follo wing potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:

A. AESTHETICS

1. Light and Glare
Threshold: Would the Project c reate a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Finding: Less than significant with mitigation. (Final EIR, pp. 4.1-21 through 4.1-22.) Explanation: The proposed multi-family housing complex would introduce various sources of lighting and glare to the site. As stated in the Exterior Lighting Concepts for Heritage Ridge, all lighting would consist of light-emitting diodes (LEDs), unless LEDs are not available for any proposed applications. Pole -mounted light fixtures would be installed in proposed parking areas and the on -site neighborhood park; it is anticipated that these fixtures would be 12 to 14 feet in height. Bollard lighting fixtures about 42 inches in height w ould be installed on walkways, pathways, and other areas of pedestrian traffic. The light in bollards would be aimed downward and outward and colored to match surrounding benches and railings. On carports, trash enclosures, mailbox kiosks, and directory si gns, downlighting would be added for security and usability. These lights would be hidden to the extent possible by the structures themselves. On the proposed buildings, a small number of decorative lights would be installed primarily for aesthetic purpose s and would not cast substantial light; in addition, every building entrance would have structurally hidden light fixtures (either downlighting or full cut -off-style wall mounted fixtures) for security. Headlights on cars entering and leaving the Project site and parking on -site would produce glare. The Santa Barbara Airport is 0.5 miles from the project site and would not be affected by the proposed low intensity residential lighting.

Although a proposed masonry wall of approximately eight feet in height along the northern and western site boundaries would reduce the perception of light and glare effects on motorists traveling on U.S. 101 and South Los Carneros Road, the new sources of illumination could have adverse effects on the City’s night sky unless p roperly shielded. Therefore, lighting impacts would be significant but mitigable. (Final EIR, pp. 4.1-20 through 4.1-22.) By minimizing the number of lighting fixtures and intensity of lighting on the Project site, shielding lights to reduce glare, dimming during nighttime hours 111
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where possible, and ensuring the compatibility of lighting with on -site and surrounding architecture, the implementation of Mitigation Measure AES-5 would reduce impacts to less than significant and there would be no residual impacts. (Final EIR, p. 4.1-22.)
AES-5 Lighting Specifications. Any exterior lighting installed on the Project site must be of low intensity, low glare design, and must be hooded to direct light downward onto the Project site and prevent spill -over onto adjacent parcels and must otherwise meet dark night sky requirements. Exterior lighting fixtures must be kept to the minimum number and intensity needed to ensure public safety. These lights must be dimmed after 11 p.m. to the maximum extent practical without com promising public safety as determined by the Planning and Environmental Review Director or designee. Upward directed exterior lighting is prohibited. Lighting fixtures must be appropriate for the architectural style of the structure and surrounding area. T he final lighting plan must be amended to include identification of all types, sizes, and intensities of wall-mounted building lights and landscape accent lighting, and a photometric map must be provided. “Moonlighting” type fixtures that illuminate entire tree canopies should also be avoided.

Plan Requirements and Timing: The locations of all exterior lighting fixtures, complete cut -sheets of all exterior lighting fixtures, and a photometric plan prepared by a registered professional engineer showing the extent of all light and glare emitted by all exterior lighting fixtures must be reviewed and approved by Design Review Board before the City issues a building permit for construction.

Monitoring: Before the City issues a certificate of occupancy, the Planni ng and Environmental Review Director, or designee, must inspect exterior lighting features to ensure that they have been installed consistent with approved plans.

B. BIOLOGICAL RESOURCES

1. Sensitive Species
Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. F ish and Wildlife Service?
Finding: Less than significant with mitigation. (Final EIR, p. 4.3-28.) Explanation: No special status plant species are expected to be impacted by the Project.

Twenty-five special status wildlife species have low potential to occur based on the absence of suitable habitat and ongoing disturbance. No special status terrestrial species are expected to be significantly impacted by the Project and 112
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no further analysis of special status terrestrial species is included within this report. Sensitive avian species may forage at the Project site, but are not expected to reproduce thereon due to a la ck of suitable nesting habitat.

Foraging species are highly mobile could move to other suitable foraging sites; therefore, the proposed Project is not expected to directly impact foraging birds.

There are no historical records or observations of active ra ptor nests or communal roosts at the Project site or within 100 feet. No raptors have potential to nest at the Project site due to lack of suitable nesting habitat, such as tall trees or suitable man-made structures. The Project site also lacks habitat for turkey vulture, white-tailed kite or other species that roosts communally.

Therefore, development of the Project would not substantially reduce or eliminate quantity or quality of raptor nesting or communal roosting areas.

The scrub and non -native grassland likely provides limited low -quality foraging habitat for raptors, including white tailed kites known to roost at Lake Los Carneros located approximately 700 feet north of the Project site.

On an incremental basis, development of the Project would result in the permanent loss of approximately 13.27 acres of suitable foraging habitat for raptors. The foraging habitat at the Project site is not essential for the successful breeding of raptors nesting in the Goleta Valley. The Project site lacks suitable perches and nesting habitat, foraging habitat has been subject to ongoing disturbance, the site is fragmented by existing development and infrastructure, and higher value foraging habitat is available in the Project site vicinity (e.g., Lake Los Carner os). Therefore, development of the Project would not substantially limit reproductive capacity of raptors through loss of foraging habitat.

The undeveloped areas 0.2 -mile north of the Project site including Los Carneros Lake and west -adjacent open space wo uld continue to provide moderate value foraging habitat for raptors, including for the white-tailed kite if this species were to nest at the Los Carneros Wetland. The incremental loss of 13.47 acres of suitable foraging habitat would not have a significant effect on regional raptor populations, as 13.47 acres represents a small percentage of the raptor foraging habitat in the Goleta area when considering the vast amount of open space available for raptor foraging. Also, the Project site is of lower importance to raptors when compared to the larger and more diverse natural habitats in the Goleta area that offer much greater foraging opportunities with a higher diversity of prey. For example, suitable foraging habitat exists at Ellwood Mesa, Bishop Ranch, Los Carneros Lake, Santa Barbara Municipal Airport and Goleta Slough, and UCSB areas, as well as at additional undeveloped private lands throughout the City and unincorporated County. Raptors are mobile species with generally large home ranges that are capable of compensating for the loss of small acreages of foraging habitat in a local area by moving to other suitable foraging habitats. The Fully Protected white-tailed kite, for example, is known to forage up to tens of kilometers from communal roost sites, an d may become nomadic in response to food 113
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shortages. Therefore, development of the Project would not substantially eliminate raptor foraging areas or access of raptors to food resources when considering the amount of available open space in the natural open space areas mentioned above. Impacts to raptors from the loss of marginal foraging habitat are less than significant.

The nests of most native birds and raptors with potential to occur in the area are State and/or federally protected. The Project has pote ntial to result in indirect impacts to nesting birds, including passerine species protected under the MBTA, if they are nesting within the Project site and/or immediate vicinity during construction activities. Nesting birds may potentially occur within shrub vegetation on and adjacent to the Project site, and in trees along Los Carneros Creek. No suitable raptor nesting habitat is present in Project site, however suitable nesting habitat is present in the eucalyptus trees to the north of the Project site Adjacent to U.S. 101. No historical raptor nests have been identified or recorded in the Project vicinity, and no nests were identified during surveys of adjacent eucalyptus woodland habitat at the appropriate time of year. Impacts to nesting birds resulting from implementation of the Project are potentially significant. Implementation of Mitigation Measure BIO-1 would reduce potential new indirect short -term construction impacts to the nesting birds and raptors to a less than significant level by establishing avoidance buffers around nests when construction occurs during the nesting season. (Final EIR, pp. 4.3-28 through 4.3-29.)
Construction and operational direct and indirect Project impacts on sensitive species would be less than significant with Mitigation Measure BIO -1 requiring nesting bird and raptor surveys for ground disturbance during the nesting season. With the implementation of this measure, impacts would be reduced to a less than significant level. (Final EIR, p. 4.3-30.) BIO-1 Nesting Birds and Raptors. To avoid construction impacts to nesting birds and raptors, vegetation removal and initial ground disturbance must occur outside the bird and raptor breeding season, which is typically February 1 through September 1 (January 1 through September 1 for some raptors), but can vary based on local and annual climatic conditions. If construction must begin within the breeding season, then not more than two weeks before ground disturbance and/or vegetation removal commences, a bird and raptor pre-construction survey must be conducted by a City -approved biologist within the disturbance footprint plus a 300 -foot buffer, as feasible. If the Project is phased, a subsequent pre -construction nesting bird and raptor survey is required before each phase of construction within the Project site. If no raptor or other bird nests are observed no further mitigation is required.

Pre-construction nesting bird and raptor surveys must be conducted during the time of day when bird species are active and be of sufficient dura tion to reliably conclude presence/absence of nesting birds and raptors within the 300-foot buffer. A report of the nesting bird and raptor survey results, if applicable, must be submitted to the Planning and Environmental Review 114
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Director, or designee, for review and approval not more than one week before commencing ground disturbances.

If active nest of species protected by CFG Code 3503 or the MBTA Migratory Bird Treaty Act protected bird nests are found within 300 feet of the Project site, their locatio ns must be flagged and then mapped onto an aerial photograph of the Project site at a scale no less than 1”=200’ and/or recorded with the use of a GPS unit. If active raptor nests are detected the map will include topographic lines, parcel boundaries, adjacent roads, known historical nests for protected nesting species, and known roosting or foraging areas, as required by Conservation Element Policy 8.3 of the Goleta Community Plan / Coastal Land Use Plan. If feasible, the buffer must be 300 feet in compliance with Conservation Element Policy CE 8.4 of the Goleta General Plan/Coastal Land Use Plan. If the 300-foot buffer is infeasible, the City approved biologist may reduce the buffer distance as appropriate, dependent upon the species and the proposed work activities. If any active non-raptor bird nests are found, a suitable buffer area (varying from 25 -300 feet), depending on the species, must be established by the City approved biologist. No ground disturbance can occur within the buffer until the City-approved biologist confirms that the breeding/nesting is completed and all the young have fledged. Alternately, a City approved biologist must monitor the active nest full -time during construction activities within the buffer to ensure Project activities are not indirectly impacting protected nesting birds and raptors.

Plan Requirements and Timing : Not more than one week before ground disturbances commence, including exporting of soil, the Planning and Environmental Review Director, or designee, must verify th at construction and grading is occurring outside the nesting season, or that nesting bird and raptor surveys have been conducted, and buffer requirements specified above are in place (if applicable). This measure, and any buffer requirements, must be incorporated into the grading plans for the Project.

Monitoring: The Planning and Environmental Review Director, or designee, must verify compliance not more than one week before ground disturbances commence and conduct periodic site inspections to ensure compl iance throughout the construction period.

2. Riparian Habitat
Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Finding: Less than significant with mitigation. (Final EIR, p. 4.3-30.) Explanation: Vegetation at the Project site consists of coyote brush scrub, quailbush scrub, or ruderal/disturbed areas that consist overwhelmingly of non -native grasses 115
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and forbs. These communities are not considered sensitive nor do they qualify as ESHA. The Project site is outside the County High Fire Hazard Area and the City’s Wildland Fire Hazard Area; t herefore, the Santa Barbara County Fire Protection District is not anticipated to require off-site fuel modification.

Indirect dust impacts to sensitive and riparian communities (i.e., willow thickets) in the Los Carneros Creek SPA would be addressed throu gh adherence to Santa Barbara County Air Pollution Control District requirements.

Invasive plant species are non-native organisms that escape into surrounding ecosystems, where they become established and proliferate. Many invasive species form monocultur es (dense stands of one plant) that push out native species and impair wildlife habitat (Cal -IPC, Invasive Plant Definitions, 2015). Some invasive species also can change fundamental processes in ecosystems including the hydrologic cycle, fire regimes, and soil chemistry.

The planting of nonnative, invasive species reduces the available habitat for native plant and wildlife species within the Project limits and may cause the spread of invasive species to adjacent areas, including the Los Carneros Wetland wh ere Project site stormwater runoff is eventually detained.

Similarly, the use of nonnative, invasive species in erosion control seed mixes on stockpiles during construction would potentially cause the spread of invasive species to adjacent areas along Los Carneros Creek and Los Carneros Wetland.

According to the Project’s Preliminary Landscape Plan, no species proposed are listed as invasive by the California Invasive Plant Council (Cal -IPC).

However, if nonnative, invasive species are sometimes used in seed mixes to control erosion, which could disseminate into adjacent natural areas along Los Carneros Creek and Los Carneros Wetland. Impacts to off -site sensitive communities from the introduction on invasive species would be potentially significant, but mit igable. (Final EIR, pp. 4.3 -30 through 4.3 -31.) Implementation of Mitigation Measure BIO -2 prohibiting invasive and exotic species would reduce indirect invasive species impacts to off -site sensitive communities to a less than significant level. (Final EIR, p. 4.3-31.) BIO-2 Invasive Species Seeding and Landscaping . Nonnative, invasive plant species cannot be included in any erosion control seed mixes and/or landscaping plans associated with the Project. The California Invasive Plant Inventory Database cont ains a list of nonnative, invasive plants (California Invasive Plant Council [Updated 2017] or its successor).

Plan Requirements and Timing: Before the City issues a Zoning Clearance, the applicant secure approval of a final landscape plan from the Design Review Board.

Monitoring: The Planning and Environmental Review Director, or designee, must verify compliance before the City issues a Zoning Clearance. Before the City issues a certificate of occupancy, the Planning and Environmental 116
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Review Director, or designee, must inspect landscape plantings features to ensure that they have been installed consistent with approved plans.

3. Wildlife Movement
Threshold: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Finding: Less than significant with mitigation. (Final EIR, p. 4.3-32.) Explanation: Tecolotito Creek, approximately 0.38 mile west of the Project site, offers the most ideal wildlife access point to the Goleta Slough (Hoagland, 2011; Gallo, 2019). The Project site is separated from the regional corridor by Los Carneros Road and existing d evelopment, and would not result in any significant indirect or direct impacts to resident or migratory wildlife using Tecolotito creek for migration, foraging, or breeding. The Project site provides degraded, low value foraging habitat, and is not expected to function as breeding habitat for terrestrial species, aquatic species, or raptors. As discussed above, ground nesting passerine birds or such species adapted to nesting in man-made structures could nest on or adjacent to the Project site; however, impacts to nesting passerine birds would be less the significant with implementation of Mitigation Measure BIO-1.

A local wildlife linkage is documented on and adjacent to the Project site, which extends between the Santa Ynez Mountain foothills and the Los Carneros Wetlands. The local wildlife linkage is located along the northern and western portions of the Project site to the east and along Los Carneros Road and eventually south (off -site) to the Los Carneros Wetlands (City of Goleta, 2012; Appendix D of F inal EIR). The habitat on -site is generally ruderal and low value; the conversion on 13.26 acres of mostly ruderal habitat would not impact wildlife movement in the vicinity, including those that may use nearby linkages for movement, foraging, breeding, or access to food sources for aquatic species. The Project would not directly affect movement of aquatic species within off -site Los Carneros Creek. Since no impacts are proposed within or adjacent to the creek, and indirect aquatic impacts would be less tha n significant with adherence to existing stormwater regulations discussed in the Final EIR chapter Section 4.8.

The Project will directly impact the width and topography of the on -site terrestrial wildlife linkage from Santa Ynez Mountain foothills and th e Los Carneros Wetlands, through the Project site and across the existing intersection of Calle Koral and Camino Vista. This on-site wildlife linkage is important for many small- (raccoon and stripped skunk) and medium- (coyote and bobcat) sized mammal species that use the habitats found in the wetlands and foothills to hunt, seek shelter, breed, and conduct other normal behaviors important for their survival, especially within the wilderness-urban interface. 117
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Use by small - and medium-sized wildlife in Los C arneros Creek is further substantiated by the CWMP study north of U.S. 101, conducted in more suitable non-native grassland habitat from where wildlife may travel under the freeway culvert to and from to the Project site (Dudek 2014). The Wildlife Corridor Analysis for the Heritage Ridge Project did not find evidence of a linkage between the Los Carneros Wetland and “patch” habitat at the Goleta Slough (Appendix D of the Final EIR). The Preliminary Landscape Plan includes a 25-40-foot wide wildlife connection along a sound wall that would be located along the west perimeter of the site to allow for movement of mammals and other wildlife species between the Santa Ynez Mountain foothills and Los Carneros Wetland to the south. The sound wall would separate park ing lots (north and west side of Project) and condominiums (south side of Project) from the designated wildlife linkage (True Nature, 2021). The wildlife connection would begin at a recently constructed culvert north of the Project site under the UPRR tracks, continuing along the western property line, and ending at the Los Carneros Wetland. A native plant palette would provide vegetative cover that is generally preferred by small and medium sized mammal species for foraging and shelter to support movement.

The wildlife linkage will also be designed to be in compliance with applicable fire codes and resistant to homeless encampments. The proposed wildlife connection would not funnel wildlife movement into new routes that would further endanger their survival , such as onto a road or into fencing hazards.

Rather, wildlife would continue to be funneled through the intersection of Calle Koral and Camino Vista (as mapped in the 2012 Willow Springs EIR) after implementation of the proposed wildlife connection (Cit y of Goleta, 2012; True Nature, 2021).

Project generated traffic at the intersection of Los Carneros Way south of Calle Koral would increase by approximately 16% (Associated Transportation Engineers, 2021). However, a general increase in traffic by 16% is not expected to significantly affect nighttime wildlife movement, since traffic trip increases would generally occur during daytime hours when wildlife is least active. No new roadways are proposed. Based on Project design, which would reroute wildlife movement, and the isolation of the local wildlife linkage from Goleta Slough habitat, direct impacts to wildlife movement would be less than significant.

The Project would not result in significant indirect impacts on remaining undeveloped areas adjacent to the Project by introducing new noise, lighting, and human/domestic pet impacts when considering the current conditions that include traffic along Calle Koral Road and Camino Vista Road and U.S. 101. and train noise from the UPRR located to the north of th e Project site.

Ambient noise levels are not expected to increase significantly by the Project and would be minimized by construction of the sound wall to buffer noises generated from the UPRR and U.S. 101. Short -term noise -related impacts would be less th an significant with incorporation of the Final EIR, Section

4.10, Noise, mitigation measures, and long -term impacts would be nominal with construction of the Project’s sound wall. Mitigation measures restricting 118
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lighting, regulating chemical use, and promoting homeowner pet and wildlife corridor education would mitigate indirect edge -effects to a less than significant level. (Final EIR, pp. 4.3 -32 through 4.3 -34.) Implementation of Mitigation Measures BIO -4(a) regulating lighting, Mitigation Measure BIO-4(b) requiring preparation of a Landscape Chemical and Pest Management Plan, and Mitigation Measure BIO -4(c) mandating resident education will reduce potential indirect edge effect impacts to the local wildlife linkage to less than significant, especially at night, when most mammals were observed moving through the area. (Final EIR, p. 4.3-35.) BIO-4(a) Lighting Plan. In addition to the lighting specifications in Mitigation Measure AES-5, light and glare from new development must be controlled and directed awa y from the wildlife corridors shown on the conceptual landscape plan, Los Carneros Creek SPA ESHA, Los Carneros Wetland ESHA, and the open space areas adjacent to the development. Exterior night lighting must be minimized, restricted to low intensity fixtures, shielded, and directed away from ESHAs, wildlife corridors, and open space.

Plan Requirements and Timing: The locations of all exterior lighting fixtures, complete cut -sheets of all exterior lighting fixtures, and a photometric plan prepared by a registered professional engineer showing the extent of all light and glare emitted by all exterior lighting fixtures must be approved by the Design Review Board before the City issues Zoning Clearance.

Monitoring: Before the City issues a certificate of oc cupancy, the Planning and Environmental Review Director, or designee, must inspect exterior lighting features to ensure that they have been installed consistent with approved plans.

BIO-4(b) Landscape Chemical and Pest Management Plan . All pesticides, herbicides, and fertilizers used at the Project site must be those designated for use near aquatic and wetland habitats, and must be applied with techniques that avoid over -spraying and control application to avoid excessive concentrations. Rodenticides are prohibited. Trash and recycling receptacles shall be wildlife proof.

Plan Requirements and Timing: A Landscape Chemical and Pest Management Plan (Plan) must be developed by the applicant and approved by the Planning and Environmental Review Director, or desi gnee, before a final map is recorded. The requirements must be printed on the final approved landscape plans, each residential unit lease document, the map, and recorded on the property deed. The Plan must provide a prohibition on use of pesticides, herbicides, fertilizers and rodenticides. These prohibitions must be the subject of at least one annual communication by the applicant to the residents in the form of a meeting and/or newsletter or electronic update that is distributed to residents.
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Monitoring: Evidence of this effort must be provided to the Planning and Environmental Review Director, or designee, each year by January 1st. The management must also provide the Planning and Environmental Review Director with an annual monitoring report by January 1st of each year demonstrating the use of aquatic and wetland habitat appropriate fertilizer, herbicides, and pesticides consistent with the Plan on the property. If determined necessary by the City, the City may require the applicant to retain a City appr oved qualified biologist to verify the correct use of appropriate herbicides, pesticides, and fertilizers as part of the annual monitoring report.

BIO-4(c) Domestic Pet Predation, Feline Disease, and Wildlife Corridor Education. The applicant must prepare a public education campaign for future residents of the Project site regarding: 1) the effects of domestic animal predation on wildlife (e.g., domestic cats and protected bird species); 2) promoting indoor cats since bobcats are susceptible to the same dis eases as domestic cats, and disease can be transmitted between domestic cats and bobcats (or vice versa); and 3) the importance of wildlife corridors.

Plan Requirements and Timing: The education materials must be prepared by a City approved qualified biol ogist, approved by the Planning and Environmental Review Director (or designee) and must be recorded with the Final Map. The education materials must be distributed with the unit lease documents, and the subject of at least one annual communication by the applicant to the residents in the form of a meeting and/or newsletter or electronic update that is distributed to all residents.

Monitoring: Evidence of this effort must be provided to the Planning and Environmental Review Director each year by January 1st.

C. CULTURAL RESOURCES

1. Archaeological Resources
Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Less than significant with mitigation. (Final EIR, p. 4.4-12.) Explanation: Proposed grading activities on the Project site have been designed to avoid disturbance of the Northern Midden Area, which includes human remains and is a significant archaeological resource pursuant to CEQA Guidelines Section 15064.5(a)(3). To prevent disturbance of the soil, existing vegetation within the boundary of the Northern Midden Area of CA-SBA-56 is proposed to be removed by hand, remaining root balls and masses would be sprayed with a topical herbicide to ensure no further growth, and the resulting dead masses of vegetation would be left in place. A geotextile tensar fabric (Tensar BX1200 or equivalent) would be placed on top of the existing ground surface 120
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within the Northern Midden Area to reduce the fo rce of compaction from overlying fill soils and redistribute the compaction load force over a wider area, thereby minimizing the disturbance of friable cultural remains such as shellfish and animal bone. No remedial grading, subgrade preparation, or scarification would occur prior to placement of the geotextile fabric. Then the Northern Midden Area and a 50-foot buffer would be covered in a minimum of two feet of protective fill soil to prevent direct impacts to archaeological resources. Fill soils would be spread from the outside in no greater than eight- inch lifts with rubber-tired equipment, such that equipment only operates on top of the fill soils. This protocol would follow the previously approved measures implemented in the protection of CA -SBA-56’s I ntermediate Midden Area resources within the Willow Springs II project.

The Project has also been designed to avoid physical disturbance of the Northern Midden Area. The two-acre park is proposed to be placed above the Northern Midden Area. The park improvements, which include landscaping, irrigation, a decomposed granite trail, a permeable concrete parking area, a picnic area, and a lodgepole perimeter fence, would be placed on top of fill soils and would not require disturbance of the existing ground sur face. All proposed residential buildings and drainage improvements would be placed outside of the Northern Midden Area. Therefore, the Project would not have direct impacts on significant archaeological resources at the Northern Midden Area.

Although the s ite layout proposed and placement of protective fill over the Northern Midden Area would avoid direct impacts to this significant archaeological resource, the preservation of cultural deposits by intentional burial would result in a significant indirect im pact on the research values of the cultural resource. Placement of overlying fill would preclude the opportunity for future investigations to determine the way in which the portions of CA -SBA-56 to be buried are related chronologically and functionally to the Intermediate Midden Areas to the south. This indirect impact can be mitigated through implementation of a limited Phase 3 Data Recovery investigation to obtain a systematic sample of prehistoric remains from the Northern Midden Area. The physical exten t of this investigation would be limited by the lower density of cultural remains in this area, relative to that of the central midden at CA -SBA-56, and by the availability of previous research from the Phase 3 Data Recovery Program for the Willow Springs II project immediately to the south. (Final EIR, p. 4.4-12.) Proposed improvements would result in ground disturbance in the low -lying areas surrounding the elevated knoll. Excavations would extend up to five feet below grade for two bioretention basins an d three feet below grade for two bioswales. Four residential buildings with two -foot-deep foundations would also encroach on the low-lying area soils. In addition, landscaping with ornamental trees, shrubs, and turf, as well as irrigation, would require excavations up to two feet deep. However, the low-lying areas have sparse or no cultural remains, based on the findings of Extended Phase 1 and Phase 2 121
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archaeological investigations. Any cultural remains in the low -lying areas have been determined from the Extended Phase 1 and Phase 2 archaeological investigations to have low potential to contribute to the understanding of CA- SBA-56 occupations and are not significant cultural resources pursuant to the CEQA Guidelines and the City’s Environmental Thresholds and Guidelines Manual. (Final EIR, p. 4.4-19.)
The following measures would address areas of intact CA -SBA-56 deposits where proposed ground disturbances cannot be feasibly avoided. These measures are consistent with conditions of approval for the Willow S prings II project, where relevant.

CR-1(a) Limited Phase 3 Data Recovery. The applicant must provide a Phase 3 Data Recovery Program Plan developed by a City -approved archaeologist for excavations at the Northern Midden Area at CA-SBA-56.

Plan Requirements: The Phase 3 plan must be prepared in accordance with the City of Goleta’s Cultural Resources Guidelines (1993), Open Space Element Policy 8.5, the California Office of Historic Preservation’s (1990) Archaeological Resource Management Reports (ARMR): Re commended Contents and Format , and Public Resources Code § 21083.2 and CEQA Guidelines § 15126.4(b). The plan must include:
 Research design;
 Discussion of relevant research questions that can be addressed by the CA-SBA-56 resources;
 Methods used to gather data, including data from previous studies;  Laboratory methods to analyze the data;
 An assessment of artifacts recovered and any corresponding field notes, graphics, and lab analyses; and
 Results of investigations.

The plan must provide for a systematic sample of the area to be capped, such that the research value of the deposit is adequately characterized.

The Phase 3 must be funded by the applicant and must be prepared by a City- approved archaeologist. The Phase 3 must be documented in a draft and final report and must be reviewed and approved by a City -retained archaeologist.

Pursuant to City Cultural Resource Guidelines, the final report, archaeological collections, field notes, and other standard documentation must be permanently curated at the UCSB Re pository for Archaeological Collections.

The Phase 3 must specify that a local Chumash Native American consultant must be retained by the applicant to observe all excavation activity associated with the Program. The consultant must maintain daily notes and documentation necessary, and provide the observation notes and 122
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documentation to all interested Chumash representatives who request to be informed of the Phase 3 excavation progress.

Timing: A Phase 3 research design prepared pursuant to City of Goleta’s Cultural Resources Guidelines, and a copy of a contract (including a detailed scope of work) between the applicant and a City-approved archaeologist and Chumash Native American consultant for the Phase 3 program, and the subsequent draft and final Phase 3 report, must be reviewed and approved by the City and City -retained archaeologist (funded by the applicant) before recordation of the final map. Upon completion of the Phase 3 study and all contact requirements, the applicant must notify the City in writing of the completed efforts in a bond acceptable to the City. This includes the completion of the curation of items collected during the Phase 3 mitigation.

A summary letter outlining the successful completion of all mitigation excavations must be reviewed a nd approved by the City and City -retained archaeologist prior to issuance of any Land Use Permit for grading within the archaeological resource area, including the placement of fill over the Northern Midden Area. All Phase 3 and curation requirements must be met prior to issuance of occupancy of the first residential building (either Senior or Workforce Housing units).

Monitoring: The Phase 3 Data Recovery Program must be submitted for approval by the City and City -approved archaeologist before the applica nt records a final map. City staff and the City -retained archaeologist must periodically site inspect to verify completion of the Phase 3 field work and review and approve the summary letter outlining the completion of excavations prior to issuance of Land Use Permits for grading within the archaeological resource area. Curation may be completed after the issuance of the LUP, as long as the Phase 3 excavations have been completed and verified by the City and City -retained archaeologist. The City -retained archaeologist must review and approve the draft and final Phase 3 reports prior to issuance of occupancy permit for the first residential building (either Senior or Workforce Housing units). The applicant must provide the City with a letter from the UCSB Repository for Archaeological Collections indicating that all required materials have been accepted for curation prior to the release of the cultural resource bond.

CR-1(b) Surface Preparation and Fill Soils within CA -SBA-56. Preparation of the ground surfac e and the placement of fill soils within the CA -SBA-56 boundary must be low impact and adhere to the following requirements:
 Systematically collect all diagnostic artifacts on the ground surface;  Remove all organic material from the archaeological site Nor thern Midden Area surface by hand (including brushing, raking, or use of power blower);
 Place a layer of Tensar geotextile grid over all archaeological site areas to receive fill;
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 Use fill soils within 1 pH of that identified in the Northern Midden Area soils, as evaluated in the field prior to construction;  Use a contrasting color and/or gradation for the lower six inches of fill soils, signaling to any future sub-surface activity (e.g., landscaping activity) that excavation shall not extend deeper; and
 Place a minimum of 12 inches additional fill material over the contrasting soil;
 Place the fill soils ahead of the loading equipment so that the machine does not have contact with the archaeological site surface.  Moisten fill soils sufficient so that they are cohesive under the weight of the heavy equipment as the material is spread out over the archaeological site and buffer area.

Plan Requirements and Timing: Before the City issues any grading permit, the Planning and Environmental Review Director or designee must approve a Construction Monitoring Plan prepared by the applicant and a City-approved archaeologist. Plan specifications for the monitoring must be printed on all plans submitted for grading, landscaping, and building permits. The applicant must enter into a contract with a City-approved archaeologist and an applicant selected Chumash Native American consultant(s) and must fund the provision of on-site archaeological/cultural resource monitoring during initial grading and excavation activities prior to any LUP issuance for grading. The contract should be executed at least two weeks prior to the LUP issuance for grading.

Monitoring: The Planning and Environmental Review Director, or designee, and a City-retained archaeologist must approve the Construction Monitoring Plan and ensure there is a valid contract with an archaeologist and a Chumash Native American consultant, and must conduct periodic field inspections to verify compliance during ground-disturbing activities.

CR-1(c) Excavations within Northern Midden Area. Excavations for all landscaping and recreational improvements within the Northern Midden Area cannot encroach within the initial six inches of contrasting soil placed above the geotextile grid and existing ground surface.

Plan Requirements and Timing : This requirement must be printed on all plans submitted for any LUP for grading. The area where excavations would not encroach on the Northern Midden Area as specified herein must be clearly marked on the plans.

Monitoring: The Planning and Environmental Review Director, or designee, must conduct periodic field inspections to verify compliance during ground - disturbing activities.

CR-1(d) Monitoring. Before initiating any staging areas, vegetation clearing, or grading activity, the applicant and construction crew must meet on -site with City staff, a City-retained archaeologist, and local Chumash consultant(s) and present the procedures to be followed in the unlikely event that cultural 124
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artifacts are discovered during ground disturbances outs ide of the CA-SBA- 56 Northern Midden Area.

A City-approved archaeologist and local Chumash consultant must monitor all ground -disturbing activities on the Project site, including surface vegetation removal and the Phase 3 Data Recovery Program. The monito r(s) must have the following authority:
1) The archaeological monitor(s) and Chumash consultant(s) must be on - site on a full -time basis during any earthmoving activities, including preparation of the area for capping, grading, trenching, vegetation removal, or other excavation activities. The monitors will continue their duties until it is determined through consultation with the applicant, City Planning and Environmental Review Director or designee, archaeological consultant, and Chumash consultant that monit oring is no longer warranted;
2) The monitor(s) may halt any activities impacting previously unidentified cultural resources and conduct an initial assessment of the resource(s). If cultural resources of potential importance are uncovered during construction, the following must occur per the Goleta General Plan Open Space Policy 8.6
a. The grading or excavation shall cease and the City shall be notified. b. A qualified archeologist shall prepare a report assessing the significance of the find and provide recommendat ions regarding appropriate disposition.
c. Disposition will be determined by the City in conjunction with the appropriate Chumash consultant.
3) If an artifact is identified as an isolated find, the monitor(s) must recover the artifact(s) with the appropriate lo cational data and include the item in the overall inventory for the site;
4) If a feature or concentration of artifacts is identified, the monitor must halt activities in the vicinity of the find, notify the applicant and the Planning and Environmental Review Director or designee, and prepare a proposal for the assessment and treatment of the find(s). This treatment may range from additional study to avoidance, depending on the nature of the find(s);
5) The monitor must prepare a comprehensive archaeological tech nical report documenting the results of the monitoring program and include an inventory of recovered artifacts, features, etc.;
6) The monitor must prepare the artifact assemblage for curation with UCSB and include an inventory with the transfer of the collection; and 125
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7) The monitor must file an updated archaeological site survey record with the UCSB Central Coastal Information Center.

Plan Requirements and Timing : This requirement must be printed on all plans submitted for any land use, building, grading, or dem olition permits.

The applicant must enter into a contract with a City -approved archaeologist and applicant-selected Chumash consultant and must fund the provision of on-site archaeological/cultural resource monitoring during initial grading and excavation activities before issuance of a land use permit. Plan specifications for the monitoring must be printed on all plans submitted for grading, and building permits. The contract should be executed at least two weeks prior to the LUP issuance for grading.

Monitoring: City Planning and Environmental Review Director or designee must conduct periodic field inspections to verify compliance during ground - disturbing activities.

CR-1(e) Continued Chumash Consultation . Previous Chumash consultation with the City of Gol eta and Project applicant resulted in the archaeological site CA-SBA-56 being identified as important to the Chumash community.

Continued Chumash consultation must occur throughout the remainder of the Project including any design changes, alternatives ana lysis, or mitigation measure implementation to ensure that impacts to CA-SBA-56 are mitigated in a manner that would be respectful of the site’s Chumash heritage.

Plan Requirements and Timing: This condition must be printed on all building and grading plans.

Monitoring: The Planning and Environmental Review Director or designee must check plans before the City issues a land use permit and must spot check in the field throughout grading and construction.

CR-1(f) Human Remains. Before initiating any staging areas, vegetation clearing, or grading activity, the applicant and construction crew must meet on -site with City staff, a City-retained archaeologist, and local Chumash consultant(s) and present the procedures to be followed in the unlikely event that human remains are uncovered. These procedures must include those identified by Public Resources Code § 5097.98. If the remains are determined to be of Chumash descent, the County Coroner has 24 hou rs to notify the Native American Heritage Commission (NAHC). The NAHC will then identify the person(s) thought to be the Most Likely Descendent (MLD) of the deceased Chumash. The MLD will then in consultation with the City -approved archaeologist and approp riate local Chumash consultant(s) determine what course of action should be taken in dealing with the remains, so as to limit future disturbance.

Plan Requirements and Timing : Before the City issues permits for any ground disturbance, the applicant must pr ovide the City Planning and 126
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Environmental Review Director or designee the contact information of the Chumash consultant and the agreed upon procedures to be followed. In the event that remains are found and if the remains are found to be of Chumash origin, the County Coroner will notify the Native American Heritage Commission and the Commission will name the Most Likely Descendant (MLD). The MLD, City-retained archaeologist, applicant, and City Planning and Environmental Review staff will consult as to the disposition of the remains. If the remains are identified as non -Chumash, the County Coroner will take possession of the remains and comply with all state and local requirements in the treatment of the remains.

Monitoring: The Planning and Environmental Review Director or designee must confirm that the County Coroner is notified in the event human remains are found, and that the Native American Heritage Commission is contacted if the remains are of Chumash origin.

2. Human Remains
Threshold: Would the Project disturb any human remains, including those interred outside of dedicated cemeteries?
Finding: Less than significant with mitigation. (Final EIR, p. 4.4-12.) Explanation: Proposed grading activities on the Project site hav e been designed to avoid disturbance of the Northern Midden Area, which includes human remains and is a significant archaeological resource pursuant to CEQA Guidelines Section 15064.5(a)(3). To prevent disturbance of the soil, existing vegetation within the boundary of the Northern Midden Area of CA-SBA-56 is proposed to be removed by hand, remaining root balls and masses would be sprayed with a topical herbicide to ensure no further growth, and the resulting dead masses of vegetation would be left in place . A geotextile tensar fabric (Tensar BX1200 or equivalent) would be placed on top of the existing ground surface within the Northern Midden Area to reduce the force of compaction from overlying fill soils and redistribute the compaction load force over a w ider area, thereby minimizing the disturbance of friable cultural remains such as shellfish and animal bone. No remedial grading, subgrade preparation, or scarification would occur prior to placement of the geotextile fabric. Then the Northern Midden Area and a 50-foot buffer would be covered in a minimum of two feet of protective fill soil to prevent direct impacts to archaeological resources. Fill soils would be spread from the outside in no greater than eight- inch lifts with rubber-tired equipment, such that equipment only operates on top of the fill soils. This protocol would follow the previously approved measures implemented in the protection of CA -SBA-56’s Intermediate Midden Area resources within the Willow Springs II project.

The Project has also b een designed to avoid physical disturbance of the Northern Midden Area. The two-acre park is proposed to be placed above the Northern Midden Area. The park improvements, which include landscaping, 127
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irrigation, a decomposed granite trail, a permeable concret e parking area, a picnic area, and a lodgepole perimeter fence, would be placed on top of fill soils and would not require disturbance of the existing ground surface. All proposed residential buildings and drainage improvements would be placed outside of the Northern Midden Area. Therefore, the Project would not have direct impacts on significant archaeological resources at the Northern Midden Area.

Although the site layout proposed and placement of protective fill over the Northern Midden Area would avoid direct impacts to this significant archaeological resource, the preservation of cultural deposits by intentional burial would result in a significant indirect impact on the research values of the cultural resource. Placement of overlying fill would preclud e the opportunity for future investigations to determine the way in which the portions of CA -SBA-56 to be buried are related chronologically and functionally to the Intermediate Midden Areas to the south. This indirect impact can be mitigated through imple mentation of a limited Phase 3 Data Recovery investigation to obtain a systematic sample of prehistoric remains from the Northern Midden Area. The physical extent of this investigation would be limited by the lower density of cultural remains in this area, relative to that of the central midden at CA -SBA-56, and by the availability of previous research from the Phase 3 Data Recovery Program for the Willow Springs II project immediately to the south. (Final EIR, p. 4.4-12.) Mitigation Measures CR -1(a), CR-1(b), CR-1(c), CR-1(d), CR-1(e), and CR-1(f) would address areas of intact CA -SBA-56 deposits where proposed ground disturbances cannot be feasibly avoided. These measures are consistent with conditions of approval for the Willow Springs II project, where relevant. (Final EIR, p. 4.4-12.)
D. GEOLOGY AND SOILS

1. Fault Rupture
Threshold: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic-related ground failure including liquefaction; or landslides? Finding: Less than significant with mitigation. (Final EIR, p. 4.5-5.) Explanation: Soil borings and the results of six cone penetrometer test soundings indicate that there is a potential for liquefaction to occur in some layers of the saturated alluvial soils on the project site. Liquefaction could result in settlement that could cause property damage.
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The combined magnitude of both liquefaction and seismically induced settlement would be less than four inches. The magnitude of differe ntial settlement was estimated to be less than two inches. As described in the Geotechnical Engineering Report (Earth Systems Pacific, 2014), settlement resulting from liquefaction and seismic activity may damage foundations and surface improvements if gra ding of the project site is not completed to the recommendations in the Geotechnical Engineering Report . Therefore, this impact is potentially significant, and mitigation is required to ensure that grading is completed to the recommendations of the Geotechnical Engineering Report. (Final EIR, pp. 4.5-5 through 4.5-6.)

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Mitigation Measure GEO -1 would reduce potential impacts due to liquefaction resulting in settling of soils on the site to a less than significant level by requiring removal of onsite soils, moisture conditioning, and compaction of surfaces before placing appropriate fill soils or a rigid mat foundation system. Mitigation Measure GEO -1 includes special grading techniques to minimize the impact of site develop ment in the archaeological area would reduce impacts related to seismically induced liquefaction to a less than significant le vel. To reduce the potential for settlement within the archaeological area, special grading techniques will need to be implemented to minimize the impact of site development in this area. Accordingly, recommendations from the Geotechnical Engineering Repor t for the archaeological area and buffer zone are included in Mitigation Measure GEO-1. (Final EIR, pp. 4.5-5 through 4.5-8.)
GEO-1 Geotechnical Design Considerations . The recommendations in the Geotechnical Engineering Report (Earth Systems Pacific, 2014) related to soil engineering within and outside of the Archaeological Area must be incorporated into the Project’s grading and building plans, as summarized here:

Areas Outside the Archaeological Area:
 All existing fill soils should be completely removed and replaced as compacted fill. Any existing utilities that will not be serving the site must be removed or properly abandoned
 Voids created by the removal of materials or utilities, and extending below the recommended overexcavation depth, must be immedia tely called to the attention of the geotechnical engineer. No fill may be placed unless the geotechnical engineer has observed the underlying soil
 Following site preparation, soils in the building area should be removed to a level plane at a minimum depth of 3 to 8 feet below the bottom of the deepest footing or 3 to 8 feet below existing grade, whichever is deeper, as recommended by the geotechnical engineer in the field
 Soils in the surface improvement area should be removed to a level plane at a minimum depth of 1 -foot below the proposed subgrade elevation or 2 feet below the existing ground surface, whichever is deeper
 Soils in the fill areas beyond the building and surface improvement areas should be removed to a depth of 2 feet below the existing ground surface
 Stabilization of surface soils by vegetation or other means during and following construction must be implemented, particularly those disturbed during construction
Areas Inside the Archaeological Area, including the 50 -foot Archaeological Buffer Zone:
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 Existing ground surface in the grading area inside of the archaeological area should be prepared for construction by removing the stockpile soils and all other existing fill soils down to the native soil surface
 Before removing vegetation, vegetatio n should be sprayed with topical herbicide per manufacturer's specifications approximately 60 days before implementing grading operations. The herbicide is more effective when applied to plant leaves for better absorption  All vegetation, debris, and other deleterious material should be removed from the native soil surface by hand (can include brushing, raking, or the use of a power blower) to the degree practicable at the ground surface such that no soil disturbance occurs
 Root ball masses must be left in place to die
 Any existing utilities that will not be serving the site must be removed or properly abandoned. The appropriate method of utility abandonment will depend upon the type and depth of the utility  Surface vegetation removal and herbicide applicatio n must be accomplished 60 days prior to the geogrid placement; it is acceptable to place import sand on the native soil surface where uneven areas or undulations exist to create as level a surface as practicable to place the geogrid on as it improves both the constructability and performance of the geogrid system
 The native soil surface must be covered with a tri -axial geogrid such as Tensar TX 7, or an approved equivalent. The geogrid must be anchored and/or overlapped as recommended by the manufacturer prior to placing any fill soil
 The first 6 inches of fill placed on top of the geogrid must be an imported sand material reviewed and approved by the City of Goleta to provide a visual indication to avoid impeding into the native soils  Fill soils must be placed and spread from the outside to the inside of the archeological area with track earthmoving equipment such that the equipment must only be working on top of the fill soils. The fill soils must be placed such that the earthmoving equipment does not come into contact with the archeological area native soils or the geogrid.

Grading (General):
 On-site material and approved import materials may be used as general fill and up to 18 inches below the bottom of the slab-on-grade elevation within the building area where conventional foundations will be used
 A minimum of 18 inches of nonexpansive material when measured from the bottom of the conventional foundation slabs-on-grade should be placed in the building area
 Proposed imported soils should be evaluated by a geotechnical engineer before being used, and on an intermittent basis during 131
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placement on the site
 All materials used as fill should be cleaned of any debris and rocks larger than 6 inches in diameter, and no rocks larger than 3 inches in diameter should be used within the upper 3 feet of finish grade  Fill slopes should be keyed and benched into competent soil  Slopes under normal conditions should be constructed at 2:1(horizontal to vertical) or flatter inclinations. Slopes subject to inundation should be constructed at 3:1 or flatter inclinations  Stabilization of surface soils by vegetation or other means during and following construction must be implemented, particularly those disturbed during construction
If the portions of the site cannot be graded to those recommendations, rigid mat foundations should be used in lieu of conventional foundation systems.

Foundations:
 Foundations must not be constructed within 10 feet of LID drainage improvements. If this is not the case, the geotechnical engineer must review the type of LID drainage improvement planned within 10 feet of a foundation to ascertain if revised and/or supplemental foundation recommendations are needed
 Conventional and Rigid Mat Foundations systems must be engineered in accordance with the rec ommendations contained in the Geotechnical Engineering Report (Earth Systems Pacific, 2014) Plan Requirements and Timing . Grading and building plans must be submitted for review and approval by the Planning and Environmental Review Director or designee bef ore the City issues grading and building permits.

Monitoring. The Project soils engineer must observe all excavations before placement of compacted soil, gravel backfill, or rebar and concrete and report observations to the City. The City will conduct field inspections as needed.

2. Soil Erosion
Threshold: Would the Project result in substantial soil erosion or the loss of topsoil? Finding: Less than significant with mitigation. (Final EIR, p. 4.5-9.) Explanation: The Project would involve construction of 332 dwelling units and associated landscaping and hardscape. Based on information provided in the Project grading plan, the amount of stockpiled dirt on the Project site totals 293,100 cubic yards. Of this 293,100 cubic yards, a total of 92,000 cubic yards of soil would be exported off-site before construction of the Project. Excavation and grading could result in erosion of soils and sedimentation. During grading and soil storage, there is the potential for soil mi gration offsite via wind entrainment and/or water erosion.
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Impacts would be minimized during all phases of Project construction through compliance with a City-issued Grading Permit. To comply with this permit, the applicant would be required to prepare an d implement a Stormwater Pollution Prevention Plan (SWPPP), which must include erosion and sediment control BMPs that would meet or exceed measures required by the City-issued Grading Permit, as well as BMPs that control other potential construction-related pollutants. Erosion control BMPs are designed to prevent erosion, whereas sediment controls are designed to trap sediment once it has been mobilized. Examples of BMPs that may be implemented during construction include the use of geotextiles and mats, te mporary drains and swales, silt fences and sediments traps. Erosion control practices may include the use of drainage controls such as down drains, detention ponds, filter berms, or infiltration pits; removal of any sediment tracked offsite within the same day that it is tracked; containment of polluted runoff onsite; use of plastic covering to minimize erosion from exposed areas; and restrictions on the washing of construction equipment.

A SWPPP would be developed for the Project as required by, and in compliance with, the City -issued Grading Permit and City regulations, including grading regulations. The Construction General Permit requires the SWPPP to include a menu of BMPs to be selected and implemented based on the phase of construction and the weathe r conditions to effectively control erosion and sediment using the Best Available Technology Economically Achievable and Best Conventional Pollutant Control Technology (BAT/BCT). As development implementation of an SWPPP is a standard requirement that would apply to the Project.

Nonetheless, soils on the project site are highly erodible. Implementation and maintenance of proper drainage and the stabilization of surface soils, particularly those disturbed during construction, by vegetation or other means during and following construction are necessary to reduce the potential of erosion damage. Impacts would be potentially significant.

The recommendations in the Geotechnical Engineering Report (Earth Systems Pacific, 2014) related to grading, drainage and landscape maintenance, which are required by Mitigation Measure GEO -1, would reduce impacts related to soil erosion to a less than significant level.

Implementation of Mitigation Measure GEO -1 would reduce potential impacts related to soil erosion to a less than significant level by requiring soils exposed by grading to be stabilized with vegetation or other materials during and following construction. (Final EIR, pp. 4.5-9 through 4.5-10.)

3. Unstable Soils
Threshold: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? 133
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Finding: Less than significant with mitigation. (Final EIR, p. 4.5-5.) Explanation: Soil borings and the results of six cone penetrometer test soundings indicate that there is a potential for liquefaction to occur in some layers of the saturated alluvial soils on the project site. Liquefaction could result in settlement that could cause property damage.

The combined magnitude of both liquefaction and seismically induced settlement would be less than four inches. The magnitude of differential settlement was estimated to be less than two inches. As described in the Geotechnical Engineering Report (Earth Systems Pacific, 2014), settlement resulting from liquefaction and seismic activity may damage foundations and surface improvements if grading of the project site is not completed to the recommendations in the Geotechnical Engineering Report . Therefore, this impact is potentially significant, and mitigation is required to ensure that grading is completed to the recommendations of the Geotechnical Engineering Report. (Final EIR, pp. 4.5-5 through 4.5-6.) Mitigation Measure GEO -1 would reduce impacts related to seismically induced liquefaction to a less than significant level. To reduce the potential for settlement within the archaeological area, special grading techniques will need to be implemented to minimize the impact of site development in this area. Accordingly, recommendations from the Geotechnical Engineering Report for the archaeological area and buffer zone are included in Mitigation Measure GEO-1. (Final EIR, p. 4.5-6.)

4. Expansive Soils
Threshold: Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code, creating substantial risks to life or property? Finding: Less than significant with mitigation. (Final EIR, p. 4.5-8.) Explanation: According to the Earth Systems Pacific Geotechnical Engineering Report , previous expansion index testing of the clay soils on the project site produced values that place these soils in the “medium” expansion category. Expansive soils tend to swell with seasonal increases in soil moisture and shrink during the dry season as soil moisture decreases. The volume changes that the soils undergo in this cyclical pattern can stress and damage slabs and foundations if precautionary measures are not incorporated in design and in the construction procedure. Impacts would be potentially significant. The recommendations in the Geotechnical Engineering Report (Earth Systems Pacific, 2014) related to removal of existing fill, site grading, and foundation design, which are required by Mitigation Measure GEO -1, would reduce impacts related to expansive soils to a less than significant level.

Implementation of Mitigation Measure GEO -1 would reduce potential impacts due to expans ive soils to a less than significant level by requiring 134
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non-expansive materials or a rigid mat foundation system to be placed below all building areas.. (Final EIR, pp. 4.5-8 through 4.5-9.) E. HYDROLOGY AND WATER QUALITY

1. Erosion or Siltation
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site? Finding: Less than significant with mitigation. (Final EIR, p. 4.8-11.) Explanation: The Project would involve a Vesting Tentative Map to merge the existing 13 lots on the Project site into two lots for residential use and one lot for a 2-acre public park, resulting in a substantial increase in impervious surface on the site. The proposed on -site building coverage would total 3.46 acres (representing approximately 24.63 percent of the 14.05 net developable area excluding the public park). Accounting for these buildings as well as the proposed driveways, carports, and parking areas, impervious surfaces would cover approximately 8.0 acres (approximately 56.9 percent of the net developable area excluding the public park) of the Project site. The remainder of site coverage would consist of 0.79-acres of bioretention basins, a two-acre park, and 6.23 acres of common open space. The substantial increase in impervious surface would result in reduced infiltration and increased sheetflow on the site. In addition, grading would aff ect site drainage by reducing the grade differential across the site; however, existing drainage patterns would not be substantially altered because major natural drainage features are not present onsite.

To accommodate changes to the onsite movement of w ater during operation of the Project, LID design strategies would be incorporated into the Project.

Uncovered parking stalls throughout the Project would be constructed with permeable pavers set on a gravel base. Some walkways and patio area would also be constructed with permeable pavers. Runoff from roof areas would be directed to landscape areas where possible. In addition, bioretention basins, vegetated swales, permeable pavers set on a gravel reservoir, treatment planter boxes, and a subsurface ADS Sto rmtech Chamber system, would be used as Stormwater Control Measures. The detention system also incorporates components that act as stormwater filtration units at each point of stormwater conveyance into the subsurface system. The bioretention areas and storm drainage storage system are proposed to achieve compliance with the Central Coast RWQCB’s Order R3 -2013-0032 and City of Goleta flood control and water quality requirements.

The City of Goleta has adopted the Santa Barbara County Stormwater Technical Guide for Low Impact Development. The bioretention basins have been designed using the calculation spreadsheet provided by the stormwater 135
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Guide. According to City of Goleta Standard Conditions for Project Plan Approval – Water Quality BMPs, the water qualit y design volume for stormwater detention on the Project site would be 24,508 cf. The volume of the Project’s proposed detention facilities are 30,000 cf, thus exceeding the water quality design volume requirement.

Based on these post -development conditions , the Preliminary Hydraulic Report for North Willow Springs estimates overall runoff volumes from the Project site into the City’s storm drain system. Total post -development peak flows subject to the proposed drainage control infrastructure are estimated at 56 cfs for the 10-year storm event, 69 cfs for the 25-year storm event, 80 cfs for the 50-year storm event, and 90 cfs for the 100-year storm event. Results of the pre - and post-development calculations routed through the retention basin are summarized in Table 4.8-1 of the Final EIR (Preliminary Hydraulic Report for North Willow Springs, refer to Appendix G of the Final EIR).

Post-development peak runoff rates would be equal or less than the expected runoff rates for the same return periods from the pre-development peak runoff rates.

Central Coast RWQCB Order R3 -2013-0032, which took effect in March 2014, creates new Post-Construction Stormwater Management Requirements (Post-Construction Requirements) for development projects in the Central Coast region. These replace the City’s Interim LID Criteria, which had been in effect since 2009. The primary objective of the Post -Construction Requirements is to ensure that Project applicant reduce pollutant discharges to the maximum extent practicable and prevent st ormwater discharges from causing or contributing to a violation of receiving water quality standards.

The Post -Construction Requirements emphasize protecting and, where degraded, restoring key watershed processes to create and sustain linkages between hydrology, channel geomorphology, and biological health necessary for healthy watersheds. The Post-Construction Requirements include specific standards related to:
 Site design and runoff reduction;
 Water quality treatment;
 Runoff retention; and
 Management of peak runoff levels.

The applicant would be required to submit a comprehensive Hydrology and Hydraulic Analysis signed by a registered Civil Engineer that details the pre- and post-development conditions of the Project site. The Project would not result in a reduction in runoff that would result in any hydrological interruption to in Los Carneros Wetland or affect the existing hydrological process. Consistent with the Post -Construction Requirements, this report would identify drainage control improvements th at would be integrated into the Project design. The submitted final Hydrology and Hydraulic Analysis 136
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would be reviewed and approved by City staff before approval of any Land Use Permit for the Project.

The preliminary design of stormwater treatment facilit ies and other stormwater pollution control measures in this plan are in accordance with the current edition of the Santa Barbara County Project Clean Water’s Stormwater Technical Guide. Drainage infrastructure would be constructed as proposed and maintaine d over the life of the Project. Failure to either construct as proposed and/or maintain the system over the life of the Project could result in failure of these facilities and post -development stormwater flows exceeding pre -development flows causing substa ntial increases in bank/channel erosion or siltation at this discharge point in local surface waters.

Without a Stormwater Control Plan, the Project would have a potentially significant impact on site drainage. To reduce impacts to site drainage, Mitigation Measure HWQ -2 would require the Project to submit a Stormwater Control Plan. With preparation of maintenance agreement identified in the Hydrology and Hydraulic Analysis and Storm Water Control Plan, impacts on site drainage would be reduced to a less than significant level. (Final EIR, pp. 4.8-11 through 4.8-14.)
HWQ-2 Maintenance Agreement and Stormwater Control Plan . The applicant must execute a maintenance agreement and Stormwater Control Plan with the City, in a form approved by the City Attorney, that implements maintenance requirements for all improvements associated with all BMPs described in the final approved Hydrology and Hydraulic Analysis and Storm Water Control Plan. The agreement must be executed before the City issues any final certificate of occupancy.

Plan Requirements and Timing: At a minimum, the maintenance agreement and Stormwater Control Plan between the applicant and City must include requirements that all inline storm drain filters must be inspected, repaired, and cleaned per manufacture specifications and at a minimum before September 30th of each year. Additional inspections, repairs, and maintenance must be performed after storm events as needed throughout the rainy season (November 1st to April 15th) and/or per manufacture spe cifications. Any necessary major repairs must be completed before the next rainy season.

Before September 30th of each year, the applicant must submit to Public Works for review and approval a report summarizing all inspections, repairs, and maintenance work done during the prior year.

Monitoring: City Planning and Environmental Review staff must verify compliance before approval of any occupancy permit for the Project. City Planning and Environmental Review staff must verify compliance with the provisions of the agreement periodically and respond to instances of non - compliance with the agreement.
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2. Flooding
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Finding: Less than significant with mitigation. (Final EIR, p. 4.8-11.) Explanation: The Project would involve a Vesting Tentative Map to merge the existing 13 lots on the Project site into two lots for residential use and one lot for a 2-acre public park, resulting in a substantial increase in impervious surface on the site. The proposed on -site b uilding coverage would total 3.46 acres (representing approximately 24.63 percent of the 14.05 net developable area excluding the public park). Accounting for these buildings as well as the proposed driveways, carports, and parking areas, impervious surfac es would cover approximately 8.0 acres (approximately 56.9 percent of the net developable area excluding the public park) of the Project site. The remainder of site coverage would consist of 0.79-acres of bioretention basins, a two-acre park, and 6.23 acre s of common open space. The substantial increase in impervious surface would result in reduced infiltration and increased sheetflow on the site. In addition, grading would affect site drainage by reducing the grade differential across the site; however, ex isting drainage patterns would not be substantially altered because major natural drainage features are not present onsite.

To accommodate changes to the onsite movement of water during operation of the Project, LID design strategies would be incorporated into the Project.

Uncovered parking stalls throughout the Project would be constructed with permeable pavers set on a gravel base. Some walkways and patio area would also be constructed with permeable pavers. Runoff from roof areas would be directed to la ndscape areas where possible. In addition, bioretention basins, vegetated swales, permeable pavers set on a gravel reservoir, treatment planter boxes, and a subsurface ADS Stormtech Chamber system, would be used as Stormwater Control Measures. The detentio n system also incorporates components that act as stormwater filtration units at each point of stormwater conveyance into the subsurface system. The bioretention areas and storm drainage storage system are proposed to achieve compliance with the Central Coast RWQCB’s Order R3 -2013-0032 and City of Goleta flood control and water quality requirements.

The City of Goleta has adopted the Santa Barbara County Stormwater Technical Guide for Low Impact Development. The bioretention basins have been designed using the calculation spreadsheet provided by the stormwater Guide. According to City of Goleta Standard Conditions for Project Plan Approval – Water Quality BMPs, the water quality design volume for stormwater detention on the Project site would be 24,508 cf. The volume of 138
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the Project’s proposed detention facilities are 30,000 cf, thus exceeding the water quality design volume requirement.

Based on these post -development conditions, the Preliminary Hydraulic Report for North Willow Springs (refer to Appendix G) estimates overall runoff volumes from the Project site into the City’s storm drain system. Total post-development peak flows subject to the proposed drainage control infrastructure are estimated at 56 cfs for the 10 -year storm event, 69 cfs for the 25-year storm event, 80 cfs for the 50-year storm event, and 90 cfs for the 100-year storm event. Results of the pre - and post-development calculations routed through the retention basin are summarized in Table 4.8 -1 above (Preliminary Hydraulic Report for North Willow Springs, refer to Appendix G of the Final EIR).

Post-development peak runoff rates would be equal or less than the expected runoff rates for the same return periods from the pre-development peak runoff rates.

Central Coast RWQCB Order R3 -2013-0032, which took effect in March 2014, creates new Post-Construction Stormwater Management Requirements (Post-Construction Requirements) for development projects in the Central Coast region. These replace the City’s Interim LID Criteria, which had been in effec t since 2009. The primary objective of the Post -Construction Requirements is to ensure that Project applicant reduce pollutant discharges to the maximum extent practicable and prevent stormwater discharges from causing or contributing to a violation of rec eiving water quality standards.

The Post -Construction Requirements emphasize protecting and, where degraded, restoring key watershed processes to create and sustain linkages between hydrology, channel geomorphology, and biological health necessary for healthy watersheds. The Post-Construction Requirements include specific standards related to:
 Site design and runoff reduction;
 Water quality treatment;
 Runoff retention; and
 Management of peak runoff levels.

The applicant would be required to submit a comprehensive Hydrology and Hydraulic Analysis signed by a registered Civil Engineer that details the pre- and post-development conditions of the Project site. The Project would not result in a reduction in runoff that would result in any hydrological interruption to in Los Carneros Wetland or affect the existing hydrological process. Consistent with the Post -Construction Requirements, this report would identify drainage control improvements that would be integrated into the Project design. The submitted fi nal Hydrology and Hydraulic Analysis would be reviewed and approved by City staff before approval of any Land Use Permit for the Project.
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The preliminary design of stormwater treatment facilities and other stormwater pollution control measures in this plan are in accordance with the current edition of the Santa Barbara County Project Clean Water’s Stormwater Technical Guide. Drainage infrastructure would be constructed as proposed and maintained over the life of the Project. Failure to either construct as proposed and/or maintain the system over the life of the Project could result in failure of these facilities and post -development stormwater flows exceeding pre -development flows causing substantial increases in bank/channel erosion or siltation at this dis charge point in local surface waters.

Without a Stormwater Control Plan, the Project would have a potentially significant impact on site drainage. To reduce impacts to site drainage, the Project would be required to submit a Stormwater Control Plan. With preparation of maintenance agreement identified in the Hydrology and Hydraulic Analysis and Storm Water Control Plan, impacts on site drainage would be reduced to a less than significant level. (Final EIR, pp. 4.8 -11 through 4.8-14.)
F. TRIBAL CULTURAL RESOURCES

1. Tribal Cultural Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is g eographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: (i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or (ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code section 5024.1? Finding: Less than significant with mitigation. (Final EIR, p. 4.4-18.) Explanation: An intact undisturbed human burial was identified within the Northern Midden Area during Extended Phase I archaeological testing in 1996. The human burial is located within the proposed native plant landscape open space. Protective fill would be placed above the burial to create undulating hummocks and the burial would be at least 25 feet from the nearest designated trail, to preclude future foot traffic over this particularly sensitive location.

The heritage value of a resource is dependent on the values placed on the resource by culturally affiliated descendent communities. These values will vary based on the descendent community but may include the resource’s ability to expand traditional knowledge, contribute to religious practices, or represent a sacred location. Other values placed on a resource may include 140
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aesthetic value, artistic value, or scientific/research value. Burial s ites are often considered sacred to traditional communities, including Native Americans. Descendent communities may view disturbances to a known burial site as diminishing the heritage value of the site.

The provisions of AB 52 requiring tribal consultation are not required for the Project because the NOP for the Project was distributed in April 2015, prior to AB 52 going into effect. However, the provisions of SB 18 are required for the project, and the City conducted consultation with Native American tribal representatives in 2016 and 2017 regarding CA-SBA-56. On March 22, 2021, the City sent letters to the local Native American contacts identified by the NAHC to notify them of the Project design changes. The Coastal Band of the Chumash Nation did not respond to consultation requests sent by the City in 2016 and 2017 for the Project, but did consult on the adjacent Willow Springs II project and stated that CA-SBA-56 was important to their heritage. To date, the City has not received responses to Native Ame rican outreach efforts conducted in 2021. Nevertheless, during 2016 and 2017 consultation, representatives of the Barbareño Band stated that CA-SBA-56 is a significant resource, and that the proposed Mitigation Measures CR-1(a) through CR- 1(f) and CR-2(a) and CR-2(b) would reduce impacts to a Class II, significant but mitigable, level.

Because of the direct impacts to a Native American site with a known human burial, there is a potential to impact the heritage value of this known tribal cultural resource. Representatives of the Barbareño Band have agreed that Mitigation Measures CR-1(a) through CR-1(f) and CR-2(a) and CR-2(b) would reduce impacts. Therefore, with implementation of Mitigation Measures CR -1(a) through CR-1(f) as well as the above mitigation measures, potential impacts to the heritage value of CA -SBA-56 would be reduced to a less than significant level. (Final EIR, p. 4.4 -19.) Therefore, based on these consultation efforts, the Project would result in a signifi cant but mitigable impact to the heritage value of these tribal cultural resources. (Final EIR, p. 4.4-18.)
Mitigation Measures. Mitigation Measures CR-1(a) through CR-1(f) and the measures below would reduce the Project’s impact on the heritage value of this tribal cultural resource.

CR-2(a) Landscape Plan Review . The applicant must demonstrate that the Open Space Landscape Plan has been reviewed and approved by the local Chumash community to ensure appropriate treatment of heritage resources within the Northern Midden Area of CA-SBA-56.

Plan Requirements and Timing . This requirement must be printed on the Final Open Space Landscape Plan and approved by a city approved archaeologist. Confirmation that the local Chumash community was consulted and has appr oved the Final Open Space Landscape Plan must be submitted for any LUP issuance for grading.
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Monitoring. The Planning and Environmental Review Director, or designee, must receive evidence of the local Chumash community’s approval of the Final Open Space Landscape Plan to verify compliance with this measure.

CR-2(b) Chumash Heritage Monument. The applicant must incorporate a monument placed adjacent to the Open Space passive recreational trail to highlight the Chumash heritage of the Project area. A Chumash Heritage Monument Plan must be reviewed and approved by representatives of the local Chumash community.

Plan Requirements and Timing . This requirement must be printed on all plans submitted for any LUP for grading. Confirmation that the local Chumash community was consulted and has approved the Chumash Heritage Monument Plan must be submitted for any LUP for grading. The monument will be installed prior to the condition of occupancy.

Monitoring. The Planning and Environmental Review Director, or designee, must receive evidence of the local Chumash community’s approval of the Chumash Heritage Monument Plan to verify compliance with this measure.

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SECTION IV.

IMPACTS THAN CANNOT BE FULLY MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City Council hereby finds that, despite the incorporation of Mitigation Measures identified in the EIR and in these Findings , the following environmental impacts cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein:

G. NOISE

1. Noise Standards
Threshold: Would the Project r esult in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the loc al general plan or noise ordinance, or applicable standards of other agencies?
Finding: Significant and unavoidable. (Final EIR, p. 4.10-8.) Explanation: The Project would be constructed over a period of approximately 36 months, including the required soi l hauling. Table 4.10 -5 of the Final EIR shows typical noise levels associated with various construction equipment at distances of 50, 100, 200, 400, and 500 feet from the noise source. Typical construction noise levels at 50 feet from the source range from about 76 to 89 dBA. The grading/excavation phase of project construction tends to create the highest construction noise levels because of the operation of heavy earth - moving equipment, although only a limited amount of equipment would operate near a g iven location at a particular time. In the case of the Project, activity requiring the use of heavy earth-moving equipment would include the pre-construction soil removal phase.

The most affected adjacent uses are residential uses (Willow Spring I and II) south of the project site across Camino Vista approximately 50 feet away and residential uses (Village at Los Carneros) west of the project site across South Los Carneros Road approximately 175 feet away. The majority of residences located in the Village a t Los Carneros development, adjacent to South Los Carneros Road, are shielded from the project site due to the elevation of the site relative to the South Los Carneros Road. Adjacent industrial uses to the east could be exposed to temporary noise levels up to 89 dBA range during the loudest periods of construction. However, these types of facilities are not considered noise sensitive receptors. Since construction activities would be located within 50 feet of residential uses and noise at these receptors cou ld exceed 89 dBA for a period of up to 36 months, construction activities would result in a substantial increase in ambient noise levels at adjacent noise - sensitive receptors. Therefore, the impact from construction noise would be potentially significant.
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In addition to these on -site sources of construction noise, the Project would involve approximately 178,000-cubic yards of cut and 15,500-cubic yards of fill with approximately 92,000-cubic yards of export material. Trucks hauling material to and from the site would be a source of construction noise during this phase, which is anticipated to last up to 22 weeks.

Noise from trucks can reach up to 88 dBA Lmax at 50 feet from the source.

The only available haul route from the Project site is Camino Vista to L os Carneros to U.S. 101 which would require trucks to pass by the existing Willow Spring I and II sites south of the project site across Camino Vista. The closest residences are approximately 50 feet from the centerline of Camino Vista. Within Willow Springs I and II up to approximately 360 units could be affected by noise associated with soil excavation and hauling. Because hauling trucks would travel on roads directly adjacent to residential units and past sensitive receptors for a period of up to 22 weeks, resulting in noise levels up to 88 dBA Lmax at the nearest noise-sensitive receptors, soil hauling truck trips would result in a substantial increase in ambient noise levels at adjacent noise-sensitive receptors. Therefore, the noise impact from soil ha uling during construction would be potentially significant. In addition, because on- site construction activities would be up to 89 dBA within 50 feet of the nearest existing residential receptors, overall construction noise impacts would be potentially significant.

Construction activity associated with the Project would occur within 50 feet of sensitive receptors and could therefore generate noise that could result in a significant temporary noise conflict at nearby noise -sensitive receptors.

Project constr uction would represent a temporary but prolonged source of noise to sensitive receptors adjacent to the Project site and along the route used by soil hauling trucks, which would impact existing residential units at the existing Willow Spring I and II sites south of the project site across Camino Vista. Mitigation Measures N -1(a) through N-1(g) require implementation of noise reduction devices and techniques during construction, and would reduce the noise levels associated with construction of the Project to the maximum extent feasible. Construction noise would be intermittent and temporary, and implementation of the maximum feasible construction noise reduction measures would reduce construction -related noise to the extent feasible. However, due to the fact that heavy construction equipment would be located as close to 50 feet from existing residential units, and the pre -construction soil hauling activity would result in heavy trucks passing existing residences along Camino Vista for up to 22 weeks, construction noise impacts would remain significant and unavoidable. (Final EIR, pp. 4.10-8 through 4.10-12.)
N-1(a) Construction Timing. Construction activity and equipment maintenance is limited to the hours between 8 AM and 5 PM, Monday through Friday. No construction can occur on State holidays (e.g., Thanksgiving, Labor Day).

Non-noise generating construction activities such as interior painting are not subject to these restrictions.
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Plan Requirements and Timing : At least one sign near each Project site entrance along Camino Vista stating these restrictions must be posted on the site. Signs must be a minimum size of 24” x 48.” Signs must be in place before the beginning of and throughout grading and construction activities.

Violations may result in suspension of permits.

Monitoring: The Planning and Environmental Review Director or designee must monitor compliance with restrictions on construction hours and must promptly investigate and respond to all complaints.

N-1(b) Electrical Power. Electrical power must be used to run air compressors and similar power tools.

Plan Requirements and Timing : The equipment area with appropriate acoustic shielding must be designated on building and grading plans.

Equipment and shielding must remain in the designated location t hroughout construction activities.

Monitoring: The Planning and Environmental Review Director or designee must periodically inspect the site to ensure compliance with all noise attenuation requirements.

N-1(c) Construction Noise Complaint Line . The applica nt must provide a non - automated telephone number for local residents and employees to call to submit complaints associated with construction noise.

Plan Requirements and Timing: The telephone number must be included in the notice required by Measure N-1(a) and posted on the Project site and must be easily viewed from adjacent public areas. Proof of mailing the notices must be provided to the Planning and Environmental Review Director or designee before the City issues a grading permit. At least one sign ne ar each Project site entrance along Camino Vista with the phone number must be posted on - site. The applicant must inform the Planning and Development Review Director or designee of any complaints within one week of receipt of the complaint. Signs must be in place before beginning of and throughout grading and construction activities. Violations may result in suspension of permits.

Monitoring: Building Inspectors and Permit Compliance staff may periodically inspect and respond to complaints.

N-1(d) Distancing of Vehicles and Equipment . Noise and groundborne vibration construction activities whose specific location on the Project site may be flexible (e.g., operation of compressors and generators, cement mixing, general truck idling) must be conducted as far as possible from the nearest noise- and vibration-sensitive land uses.

Plan Requirements and Timing . The location of vehicles and equipment must be designated on building and grading plans. Equipment and vehicles 145
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must remain in the designated location throughout construction activities.

Monitoring. The Planning and Environmental Review Director must periodically inspect the site to ensure compliance.

N-1(e) Avoid Operating Equipment Simultaneously . Whenever possible, construction activities must be scheduled so as to avoid operating several pieces of equipment simultaneously, which causes high noise levels.

Plan Requirements and Timing . The construction schedule and timing of operation of each piece of equipment must be provided by the applicant.

Monitoring. Planning and Environmental Review Director or designee must periodically inspect the site to ensure compliance.

N-1(f) Sound Control Curtains and Acoustical Blankets . Flexible sound control curtains must be placed around all drilling apparatuses, drill rigs, and jackhammers when in use. Acoustical blankets (or similarly effective temporary noise barriers) must be placed along the southern, western, and eastern Project site boundaries to reduce noise transmission to existing land uses to the south, west, and east, including residential units at the existing Willow Spring I and II sites south of the project site across Camino Vista and residential units at the existing Village at Los Carneros west of the project site across South Los Carneros Road.

Plan Requirements and Timing . The equipment area with appropriate sound control curtains and the locations of acoustical blankets must be designated on building and grading plans. Equipment and shielding must remain in the designated location throughout construction activities.

Monitoring. Planning and Environmental Review Director or designee must monitor compliance with restrictions on construction hours and must promptly investigate and respond to all complaints.

N-1(g) Newest Power Construction Equipment . The Project contractor must use the newest available power construction equipment with standard recommended noise shielding and muffling devices.

Plan Requirements and Timing . The equipment with appropriate noise shielding and muffling must be designated on building and grading plans.

Monitoring. The Planning and Environmental Review Director or designee must inspect the building and grading plans before the City issues permits and periodically inspect the site to ensure compliance.

H. UTILITIES

2. Solid Waste
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Threshold: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Finding: Significant and unavoidable. (Final EIR, p. 4.14-14.) Explanation: Operation
The City’s CEQA thresholds manual includes a formula to estimate solid waste generation from multi -family residential development. Using this formula (2.65 people/market -rate unit x 228 units x 0.95 tons/year) + (2 .58 people/family affordable unit x 63 units x 0.95 tons/year) + (1.36 people/senior affordable unit x 41 units x 0.95 tons/year)], the Project would generate approximately 781 tons of solid waste per year. According to the City’s Environmental Thresholds and Guidelines Manual , the quantity of solid waste to be disposed of at landfills (non-recycled waste) is estimated at 50 percent of the total volume of solid waste generated. Based on a 50 percent diversion rate, the non-recycled waste from the Project would be estimated at 390.5 tons per year. This amount exceeds the City’s Project-specific threshold of 196 tons per year. However, the current diversion rate for Santa Barbara County, including the City of Goleta was most recently identified as 69 percent (County of Santa Barbara Public Works, 2020). Assuming that the Project would divert recyclable waste at a rate consistent with the City’s current average, 31 percent of the Project’s estimated 781 tons of solid waste per year would be disposed of at landfi lls. Thus, based on this assumption, the Project would generate an estimated 242 tons per year of non -recyclable waste. This amount would exceed the City’s project-specific threshold of 196 tons per year. Therefore, impacts on solid waste disposal capacity at the Tajiguas Landfill would be potentially significant.

County waste characterization studies estimate that implementation of the measures included in the required SWMP can reduce the 781 tons per year of waste generation by 50 percent. The actual red uction in waste generation cannot be fully determined until implementation of the SWMP. Therefore, impacts would remain significant and unavoidable . (Final EIR, pp. 4.14 -14 through 4.14-15.)
UTL-4 Solid Waste Management Plan. The Project applicant must develop and implement a Solid Waste Management Plan (SWMP) to be reviewed and approved by Public Works Director, or designee, and include one or more of the following measures:

 Provision of space and/or bins for storage of recyclable materials within the Project site.
 Establishment of a recyclable material pickup area for commercial/industrial projects (i.e., loading docks, etc.).  Implementation of a curbside recycling program to serve the new development.
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 Development of a plan for accessible collection of materials on a regular basis (may require establishment of private pick -up depending on availability of County-sponsored programs).  Implementation of a monitoring program (quarterly, bi - annually) to ensure a 33 percent to 50 percent minimum
participation in recycling efforts.
 Development of Source Reduction measures, indicating method and amount of expected reduction.
 Implementation of a program to purchase recycled materials used in association with the Project (paper, newsprint, etc.).

This should includ e requesting suppliers to show recycled material content.
 Implementation of a backyard composting yard waste
reduction program.

Plan Requirements and Timing: The applicant must coordinate with the Planning and Environmental Review Director, or designee, a nd prepare SWMP as specified in the measure.

Monitoring: The Planning and Environmental Review Director, or designee, must inspect the Project site periodically for the first five (5) years after completion of Project occupancy to verify compliance with the SWMP.

3. Solid Waste Laws
Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Significant and unavoidable. (Final EIR, p. 4.14-14.) Explanation: Operation
The City’s CEQA thresholds manual includes a formula to estimate solid waste generation from multi -family residential development. Using this formula (2.65 people/market -rate unit x 228 units x 0.95 tons/year) + (2.58 people/family affordable unit x 63 unit s x 0.95 tons/year) + (1.36 people/senior affordable unit x 41 units x 0.95 tons/year)], the Project would generate approximately 781 tons of solid waste per year. According to the City’s Environmental Thresholds and Guidelines Manual, the quantity of solid waste to be disposed of at landfills (non-recycled waste) is estimated at 50 percent of the total volume of solid waste generated. Based on a 50 percent diversion rate, the non-recycled waste from the Project would be estimated at 390.5 tons per year. This amount exceeds the City’s Project-specific threshold of 196 tons per year. However, the current diversion rate for Santa Barbara County, including the City of Goleta was most recently identified as 69 percent (County of Santa Barbara Public Works, 2020) . Assuming that the Project would divert recyclable waste at a rate consistent with the City’s 148
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current average, 31 percent of the Project’s estimated 781 tons of solid waste per year would be disposed of at landfills. Thus, based on this assumption, the Project would generate an estimated 242 tons per year of non -recyclable waste. This amount would exceed the City’s project-specific threshold of 196 tons per year. Therefore, impacts on solid waste disposal capacity at the Tajiguas Landfill would be potentially significant.

County waste characterization studies estimate that implementation of the measures included in the required SWMP can reduce the 781 tons per year of waste generation by 50 percent. The actual reduction in waste generation cannot be fully determined until implementation of the SWMP. Therefore, impacts would remain significant and unavoidable . (Final EIR, pp. 4.14 -14 through 4.14-15.)

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SECTION V.

CUMULATIVE IMPACTS
Regarding the Project’s potential to result in cumulative impacts, t he City hereby f inds as follows:

A. AESTHETICS
Cumulative development in the City of Goleta and the Goleta vicinity (Highway 154 to Gaviota) would add 741 residential units and more than 782,000 square f eet of commercial/retail space in and around Goleta. Additional development would be located on infill sites throughout the community, as well as large tracts of undeveloped open spaces along the area’s urban perimeters.

Although much of the new development would generally be of a type and intensity similar to existing urban uses, a perceptible transformation of the community through increased urbanization would be apparent. In particular, the intensity of land use would increase in the vicinity of the Project site.

Projects in the vicinity of the site that have been recently c ompleted include hotels and various residential and business park developments.

However, the cumulative aesthetic impact from the project would be less than significant given the existing built -up environment around the site. The Project would result in a visual extension of existing residential neighborhoods and commercial areas. The areas in which cumulative development would occur have been predominantly identified in the General Plan as appropriate areas for growth. The Heritage Ridge Residential Project is the last development project to be constructed in the Central Hollister Corridor. The other cumulative projects identified in the 2006 General Plan (Cortona Apartments, The Village at Los Carneros, and Willow Springs II) have all been developed in the last 8 years. The Heritage Ridge Residential Project would complete the residential neighborhood envisioned by the General Plan. Therefore, cumulative development would not pose a significant change to the overal l visual character of the City , and the Pro ject would not have a considerable contribution to significant cumulative impacts.

Cumulative development on vacant and underutilized land in the Goleta area also could obstruct scenic views from U.S. 101, State Route 217, and public viewing areas within t he City.

However, implementation of policies to protect scenic views in the City’s Visual and Historic Resources Element would reduce cumulative impacts to scenic views and key viewpoints to a less - than-significant level. Therefore, the Project would not have a significant contribution to cumulative impacts.

Furthermore, the Project’s contribution to cumulative impacts related to the visual character of the site and the introduction of new sources of light and glare would not be cumulatively significant, as the infill Project’s design and height would be compatible with surrounding development. Offsite spillover of lighting would be minimized with implementation of the lighting specifications in Mitigation Measure AES -5. Cumulative aesthetic impacts would be less than significant. (Draft EIR, pp. 4.1-22 through 4.1-23.)

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B. AGRICULTURE AND FORESTRY RESOURCES
Historically, the Project site was used for grazing and agriculture (including row crops and orchards). Since that time the site has been substantially altered by grading, surrounding urban development including industrial, research park and office development, on -site residential development, and significant stockpiling of fill soils. Initial grading on-site consisted of clearing and grubbing of orchard trees and root structures. Surface material was scraped and placed in windrows.

The site is no longer designated for agricultural uses, and is not zoned for agricultural use. Currently, the Project site consists of 13 undeveloped lots. There is no structural development on site; however, there are pieces of construction equipment and containers stored on site, as well as stockpiled soil.

The site is not actively farmed, and conversion of the Project site to residential development would not result in the lo ss of significant, viable, local farmland. Consequently, the Project would not interfere with or convert existing farmlands to urban uses. Therefore, no impacts related to agriculture and forestry would occur. (Final EIR, p. 4.17-1.) C. AIR QUALITY
Cumulative development in the City of Goleta and the Goleta vicinity (Highway 154 to Gaviota) would contribute to the cumulative degradation of regional air quality. 741 residential units and more than 782,000 square feet of non-residential development are currently planned and pending in and around Goleta. Because Santa Barbara County is in non -attainment the state standard for PM10, there is currently an existing cumulative impact associated with PM10 emissions. As stated in the SBCAPCD’s Environmental Review Guid elines, “Unless otherwise specified in published/adopted thresholds of significance and guidelines, a project’s potential contribution to cumulative impacts is assessed utilizing the same significance criteria as those for project specific impacts” (SBCAPCD, 2021). The Project would not exceed any of the SBCAPCD -recommended thresholds and therefore, the Project’s contribution to cumulative air quality impacts would be less than significant.

In addition, pursuant to Goleta thresholds, the Project would have a significant cumulative impact if it were inconsistent with the adopted federal and state air quality plans of Santa Barbara County. The Project would not conflict with or obstruct implementation of the 2019 Ozone Plan.

Therefore, the project’s impact on air quality would not be cumulatively considerable. (Final EIR, p. 4.2-20.)
D. BIOLOGICAL RESOURCES
Section 15130 of the CEQA Guidelines provides guidance on the discussion of cumulative impacts. Two conditions apply to determine the cumulative effect of a Project: first, the overall effect on biological resources caused by existing and known or forecasted Projects must be considered significant under the significance thresholds discussed above; and second, the Project must have a “cumulatively considerable” contribution to that effect. The analysis includes a discussion of the adopted Programmatic General Plan FEIR analysis, and an updated Project-specific cumulative analysis of the loss sensitive species and habitat and raptor foraging habitat.

Cumulative Programmatic General Plan Biological Resource Impacts . The Programmatic 151
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General Plan FEIR (City of Goleta, 2006; SCH # 2005031151), inc orporated herein by reference, evaluated direct and indirect impacts from the conversion of existing vacant sites to the land uses designated for those areas in the General Plan. This analysis included the Project site build-out. The Project build -out is c onsistent with the General Plan land use designation. No significant unavoidable (Class I) impacts to biological resources were identified as a result of General Plan build-out. Biological resource impacts associated with build -out of vacant sites under th e General Plan EIR were identified as less than significant (Class II), with adherence to Policies CE 1 –10, Policies OS 1 –7, and Policies LU 1,6, and 9. Development of the Project would not change the existing General Plan land use designation (Medium Dens ity R -MD and Affordable Housing Opportunity Site) that was evaluated in the Programmatic General Plan FEIR. The Project impacts would be mitigated consistent with the General Plan policy requirements. The Statement of Overriding Consideration and FEIR adopted by the Goleta City Council is specific to Class II long- term impacts from the development of vacant land to specific special status species (Impact 3.4 -5), native species (Impact 3.4 -6,7), special status habitats (Impacts 3.4 -2,3,4), and wildlife corri dors (Impact 3.4-8). Cumulative impacts to biological resources, including the “loss of foraging habitat (grassland) for resident and migratory raptors” attributable to Projects in the City, were found to be less than significant (Class III) with adherence to General Plan policies and applicable federal and state regulations (Impact 3.4 -14). Cumulative impacts to biological resources would not be cumulatively considerable, as identified under the Programmatic General Plan FEIR. The Project is consistent with the General Plan biological resource protection policies. Therefore, as identified in the Programmatic General Plan FEIR, cumulative biological resources impacts would be less than significant with implementation of the General Plan policies.

Cumulative Loss of Sensitive Species and Habitat and Wildlife Connectivity . Cumulative development in the Central Hollister area of Goleta consists of previous infill of undeveloped parcels (e.g., Village at Los Carneros, Cortona Apartments) within an urbanized area. Previous development in this area permanently eliminated extensive tracts of native plant communities, some of them now classified as rare or threatened. Native habitats support native wildlife species, many of which cannot survive in, or do not adapt to , the noise and disturbance associated with residential and urban developments. Species that do tolerate developed, landscaped, and disturbed sites include aggressive, non-native species that further displace native plants and wildlife, or may prey upon native species.

Vegetation on the majority of the Project site consists of non-native grasses and disturbance- following native shrubs. The proposed conversion from existing conditions to residential development would not be a cumulatively considerable contri bution to a cumulatively significant effect, as the reduction and fragmentation of native habitats (including sensitive habitats), loss of native plant species diversity and populations, and reduction in native wildlife diversity and populations has alread y occurred in the past and was evaluated under the Programmatic General Plan FEIR. Moreover, mitigation measures would protect existing biological resources on and adjacent to the Project, such as nesting birds and wildlife connectivity. Cumulative impacts sensitive species and habitats would be less than significant.

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Cumulative Loss of Raptor Habitat . The 16.29-acre Project site is not a significant nesting or roosting habitat for raptors and the Project’s conversion to urban development, when considered with other cumulative development in the area, would not result in significant loss of suitable nesting or roosting habitat for raptors.

The Project and several related Projects in the Goleta area would result in the loss of foraging habitat for raptors i ncluding, without limitation, non -native grassland, open scrubland, and disturbed/ruderal fields. The Project would not result in a cumulative impact to raptor foraging areas or access to food resources, as the foraging habitat at the Project site is of lesser importance to raptors at a regional scale due to its small size, fragmented condition, and proximity to existing development; the foraging habitat at the site is not essential to successful nesting of raptors in the Goleta area; suitable foraging habitat exists at several other locations in the area, such as Ellwood Mesa, Bishop Ranch, Los Carneros Lake, Santa Barbara Municipal Airport and Goleta Slough, and UCSB areas, as well as additional undeveloped private lands; and, raptors are mobile species ca pable of compensating for the loss of small acreages of suitable foraging habitat in a local area by finding and utilizing other suitable habitats. Approximately four acres of the Project site itself was recently inaccessible to raptors for foraging for at least two years when stockpiled soils were present in the native hydro-seed area. The Project’s contribution (13.47 acres) to the loss of raptor habitat would not result in a significant cumulative effect at a regional -level, nor would it cause a region -wide raptor population to drop below self-sustaining levels when considering the few other infill Projects in the City, therefore cumulative impacts are less than significant. (Draft EIR, pp. 4.3 -39 through

4.3-40.)
E. CULTURAL RESOURCES
Cumulative development in the Goleta Valley would continue to disturb areas that may potentially contain cultural resources, including archaeological resources. Two approved/constructed projects, the Marriott Residence Inn and Cortona Apartments, are known to involve impacts to cultural resources. However, all potential development sites in the City are considered sensitive for archaeological resources due to their location adjacent to the Goleta Slough.

Existing City policies and regulations would protect any unknown resources that might be uncovered in the course of project development. City policies require protection of cultural resources through, among other techniques, appropriate site design, monitoring of grading activities in archaeologically sensitive areas, avoidance or/or capping of identified resources, and coordination with the Chumash consultant(s). While there is the potential for significant cumulative impacts to cultural resources within the Goleta Slough area, it is anticipated that potential impacts associated with individual development projects will be addressed on a case -by-case basis in accordance with City requirements.

CA-SBA-56 has been subject to previous impacts resulting from the development of the Willow Springs I and Willow Springs II projects. Whil e environmental review of these previous projects determined that impacts to this resource were reduced to a less than significance level through mitigation, the cumulative impact to CA -SBA-56 as a whole is potentially significant.

Pursuant to CEQA Guidelines § 15355, cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. The Project’s impacts to tribal cultural resources related to CA -SB-56 would be reduced to less than significant wi th implementation of Mitigation Measures CR -1(a) through CR-1(f). Nevertheless, the project’s contribution to cumulative cultural resource impacts would remain significant and unavoidable. 153
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(Final EIR, p. 4.4-20.)
F. ENERGY
A project’s environmental impacts ar e “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The geographic scope for energy consumption is Santa Barbara County. This geographic scope is appropriate because the smallest scale at which energy consumption information is readily available is the county level.

Cumulative de velopment in Santa Barbara County would increase demand for energy resources. However, new iterations of the California Building Energy Efficiency Standards and CALGreen would require increasingly more efficient appliances and building materials that reduce energy consumption in new development. In addition, vehicle fuel efficiency is anticipated to continue improving through implementation of the existing Pavley regulations under AB 1493, and implementation of the Santa Barbara County Association of Governments (SBCAG) 2040 Regional Transportation Plan and Sustainable Communities Strategy (2040 RTP -SCS) would reduce per capita VMT in Santa Barbara County. Cumulative development in Santa Barbara County will also be required to be consistent with applicable provisions of the SBCAG 2040 RTP-SCS and with the County of Santa Barbara Energy and Climate Action Plan, which identifies the County’s GHG emissions reduction goals and strategies to achieve these goals.

Project development would be constructed in accorda nce with the City’s CAP and General Plan/Coastal Land Use Plan policies; California Building Energy Efficiency Standards; and CALGreen. This would include energy-saving features that would reduce the potential for wasteful, inefficient, and unnecessary con sumption of energy resources. As a result, the Project would not have a cumulatively considerable contribution to a significant cumulative impact related to the wasteful, inefficient, and unnecessary consumption of energy resources. (Final EIR, pp. 4.15 -14 through 4.15-15.)
G. GEOLOGY AND SOILS
Cumulative projects proposed in and around Goleta would expose additional people and property to seismic and geologic hazards that are present in the region. The magnitude of geologic hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. Any specific geologic hazards associated with each individual site would be limited to that site without affecting other areas. In additio n, existing regulations, including compliance with CBC requirements, would reduce seismic and geologic hazards to acceptable levels. Seismic and geologic hazards would be addressed on a case -by-case basis and would not result in cumulatively considerable i mpacts. Cumulative geologic hazard impacts would be less than significant and the Project’s contribution would not be cumulatively considerable. (Final EIR, p. 4.5-10.)

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H. GREENHOUSE GAS EMISSIONS
Analysis of GHG-related impacts is cumulative in nature as climate change is related to the accumulation of GHGs in the global atmosphere. 741 residential units and more than 782,000 square feet of non -residential development are approved or pending in and around Goleta. Such development would increase overall GHG emissions generated within Goleta. Similar to the Project, planned and pending projects in the City would be required to comply with applicable strategies contained in the Goleta CAP. As indicated in Impact 1 – Emissions Generation, GHG emissions associated with the Project were found to be less than significant. Although cumulative increases in atmospheric GHGs may be significant, the Project’s contribution to cumulative levels of GHGs is not cumulatively considerable because emissions associated with the Project would not exceed the quantitative locally -applicable, project -specific threshold and the Project is consistent with all applicable plans and policies pertaining to GHG reduction. (Final EIR, p. 4.6-20.) I. HAZARDS AND HAZARDOUS MATERIALS
The General Plan Final EIR identifies a significant and unavoidable cumulative hazards and hazardous materials risk of upset/exposure impact resulting from the inherent risk associated with the transport of hazardous materials along major transportation routes (includ ing U.S. 101, and the Union Pacific railroad tracks). Significant hazards identified in the General Plan Final EIR include the risk of a trucking or rail accident and subsequent release of hazardous materials.

The overall risk associated with the handling, storage, and transport of hazardous materials would be expected to increase following build-out of the General Plan as additional development is introduced in close proximity to major transportation routes and hazardous material users. The potential for exposure to hazards and hazardous materials as a result of an accidental release would be statistically low or very low. Therefore, while the cumulative risk of such exposure associated with the introduction of additional population in close proximity to U. S. 101, the UPRR railroad tracks, and businesses that store and use hazardous materials, has been found to be significant and unavoidable in the General Plan FEIR, the Project’s contribution to this impact would be less than significant (Class III).

Cumulative projects proposed in and around Goleta would have the potential to expose future area residents, employees, and visitors to hazards by developing and redeveloping areas that may have previously been contaminated. The magnitude of hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. If lead-based paint and/or asbestos containing materials are found to be present in buildings planned for demolition or ren ovation, or in the case that soil and groundwater contamination are found to be present on sites of planned and future development, these conditions would be required to comply with existing applicable local, state and federal regulations. Hazard evaluations would be completed on a case-by-case basis for future development. Compliance with applicable regulations and implementation of appropriate mitigation measures, including remedial action on contaminated sites, would address impacts related to these hazards and hazardous materials associated with future development in the City. Cumulative impacts related to soil and/or groundwater contamination would be less than significant and the Project’s contribution would not be considerable. Given the scope of planned and pending projects as listed on Table 3-1 in Section 3.0, Related Projects of the Final EIR, the majority of which are residential properties that do not utilize hazardous materials, significant cumulative public health or safety hazards are not anticipated with regard to contaminated 155
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sites. (Draft EIR, p. 4.7-19.)
J. HYDROLOGY AND WATER QUALITY
Cumulative projects in the Goleta area, including those that are pending, approved, or under construction, would add 741 residential units and more than 782,000 square feet of commercial and retail space. Collectively, these projects would add new sources of water pollution and would increase the amount of impervious surface in the Goleta area, contributing to existing i mpairments of waterways such as Tecolotito Creek, Los Carneros Creek, and the Goleta Slough. In particular, the Project could contribute to cumulative stormwater flows; sedimentation and siltation of surface water bodies; and water pollution from bacteria, metals and other sources. Given that Tecolotito Creek, Los Carneros Creek, and the Goleta Slough are currently impacted, cumulative impacts to water quality would be potentially significant.

Nevertheless, the Project would be subject to implementation of appropriate Best Management Practices in accordance with City, State, and Federal requirements. Furthermore, all qualifying projects are subject to the requirements of the NPDES Permit, which is specifically designed to develop, achieve, and implement a t imely, comprehensive, and cost -effective storm water pollution control program. As with the Project, cumulative projects that disturb more than one acre of soil would be required to compile and implement a SWPPP, which would include appropriate BMPs. Moreover, the Project would be expected to meet the applicable water quality standards and sufficiently reduce its incremental contribution to cumulative water quality impacts to a less than significant level. The Project, with incorporation of the proposed on -site detention systems, implementation of storm water standards/regulations, and implementation of mitigation measures included in this EIR would meet requirements for stormwater discharge during construction and operation of the Project. Therefore, the Pr oject would not contribute significantly to cumulative impacts to regional water quality and hydrology. (Final EIR, pp. 4.8-15 through 4.8-16.) K. LAND USE AND PLANNING
Planned, pending and recently approved development in and around Goleta consists of 741 residential units and approximately 782,223 square feet of non -residential development. Conflicts regarding land use compatibility between the Project and surrounding uses have been found to be less than significant. These impacts are localized to the Projec t site and its surrounding area and as such would not involve any significant cumulative impacts. Potential land use conflicts for cumulative development would be addressed on a case -by-case basis and potential impacts would be reduced through Project design review. The Project’s contribution to cumulative land use impacts would be less than significant. (Draft EIR, p. 4.9-41.) L. MINERAL RESOURCES
No known mineral resources are located within the Project site. Therefore, development of the Project site would not result in the loss of availability of known mineral resources or locally important mineral resource recovery sites . (Final EIR, p. 4.17 -2.) No cumulative impact would occur.

M. NOISE
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Table 4.10-7 of the Final EIR shows cumulative noise increases along roa dways near the Project site due to cumulative traffic growth. Noise level increases along the traffic and circulation study roadway segments near sensitive receptors due to cumulative traffic would range between 0.1 and 1.1 dBA. This increase would not be significant based on the applicable FTA significance thresholds for each roadway/receptor (refer to Table 4.10 -4 of the Final EIR). Therefore, the Project’s contribution would not be cumulatively considerable or significant.

Construction and operation of other projects in the vicinity of the Project site would likely generate noise levels in excess of existing measured noise levels and may affect sensitive receptors.

There is a residential development with 465 residential units west of S. Los Carneros Road and this development may be exposed to construction noise from the Project. However, construction noise would be localized and short-term in nature and would not contribute to cumulative noise impacts.

With implementation of Mitigation Measures N -1(a) through N-1(g), cumulative noise impacts would be reduced to a less than significant level. (Final EIR, p. 4.10-20.) N. POPULATION AND HOUSING
The addition of 332 new residential units as a result of the Project would result in approximately 839 additional residents, which would increase the City’s population to 33,062. The population generated by the Project would not exceed the Santa Barbara County Association of Government’s (SBCAG) 2040 population forecast of 34,400 for Goleta (SBCAG, January 2019).

Thus, the Project would not have significant unplanned population growth. (Final EIR, p. 5 -1.) Moreover, development of the Project would occur on a vacant site, and as such there would be no loss of housing or necessitate the construction of replacement housing el sewhere. Therefore, the Project’s contribution would not be cumulatively considerable or significant.

O. PUBLIC SERVICES
Cumulative development in the City of Goleta would add 516 residential units and approximately 726,444 square feet of commercial and retai l space . In addition, cumulative development in non-City areas in the Goleta vicinity would add 225 housing units and approximately 55,779 square feet of commercial and industrial space. Cumulative development in the City and the vicinity, which is under v arious stages of construction and approval, would increase demand for public services.

Fire Protection. Development of the planned Fire Station 10, as identified in General Plan Policies PF 3.2 and PF 3.3, is intended to address deficiencies in fire service and facilities within the City, which could result from cumulative development. A Final Environmental Impact Report (Final EIR) was prepared and certified for Fire Station 10 by the City Council in December 2018. The planned Fire Station 10 project would ensure that cumulative development in the western end of the City would be served efficiently and service to existing customers would continue to be provided within current standards. Furthermore, development of the Project would not cause fire protectio n service ratios or response times to reach unacceptable levels and SBCFD requirements would be incorporated into the Project to ensure adequate access to the Project site. Therefore, the Project would not require new or altered fire facilities, and would not contribute to a significant cumulative impact.

Police Protection . According to the Santa Barbara County Sheriff’s Office, cumulative 157
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development throughout the City is placing increased pressure on the Office’s current personnel and facilities. Increasing the service demand of the Sheriff’s Office may result in increased response times that would require additional staff, and which eventually may result in the need for new or expanded facilities (Santa Barbara County Sheriff’s Office 2021). Any new or e xpanded police facilities would be subject to project -specific CEQA environmental review. As part of the environmental review, mitigation measures would be identified to avoid, minimize, or reduce any identified environmental effects of new or expanded facilities.

The Project would add an estimated 839 new city resident’s dependent on police protection service from the Santa Barbara County Sheriff’s Office. While the increase in demand may require one additional deputy, this increase in demand and one staff person would not result in the need for new or expanded facilities. The Project developer also would be required to comply with Policy PF

10.2, which requires new development to pay a proportionate share of the costs of new or upgraded capital facilities attributable to new development, including sufficient funding for environmental compliance and permitting. Therefore, the Project’s contribution to cumulative impacts to police protection services would be less than significant.

Public Schools. Residential development in the area under cumulative conditions would add 516 residential units to the city. Using student generation factors of 0.2 students per unit for GUSD schools, 0.1 students per for GVJHS, and 0.2 students per for DPHS, cumulative development could generate 103 new students dependent on GUSD schools, 103 new students dependent on GVJHS schools, and 155 new students dependent on SBUSD schools. The additional students generated by cumulative development in combination with students generated by the Project could be served within the existing capacity of these schools. Therefore, cumulative impacts to schools would be less than significant. (Final EIR, pp. 4.11-7 through 4.11-8.) Parks. Residential growth throughout the City would result in increa sed demand for recreational facilities. According to the City’s January 2021 list of cumulative projects, a total increase of 741 residential units are pending review, have been approved, or are under construction in Goleta. As required by Chapter 16.14 of the Goleta Municipal Code, new residential developments within the City must dedicate 0.0128 acres per dwelling unit to parks and recreation, or else pay in -lieu fees toward the future development of such facilities. Thus, cumulative development in the Ci ty would generate demand for approximately 9.5 acres of recreational facilities.

The Goleta General Plan identifies approximately 90 acres of existing active recreation, which translates to approximately 2.8 acres per 1,000 residents. Several planned and recently completed park facilities, as shown in Table 4.12-1, also provide space for active recreation. These planned and recently completed parks provide an additional 11 acres, bringing the total active recreation area to 101 acres. With the addition of approximately 2,016 City of Goleta residents upon development of cumulative projects (74 residences x 2.72 persons per residence), the available active recreation ratio would be approximately 3 acres per 1,000 residents. This would be slightly greater than the current 2.8 acres per 1,000 residents, but falls short of the City’s adopted goal of providing

4.7 acres of parkland per thousand residents. The Project’s population would contribute to this existing cumulative impact. However, the proposed onsite facilities and required payment of park and recreation fees required by Goleta Municipal Code Chapter 16.14 would be used to fund public park facilities that would meet the incremental demand for recreational facilities created by the Project. With the required payment of in -lieu parks and recreation fees, the Project’s incremental 158
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contribution to this cumulative impact would be less than significant. (Final EIR, pp. 4.12-4 through

4.12-5.)
Library Facilities. Cumulative development planned for the City includes 516 new residential units which would increase the population within the City a nd increase demand on public library services which may require new or expanded facilities. New or expanded library facilities would be subject to project -specific CEQA environmental review. As part of the environmental review, mitigation measures would be identified to avoid, minimize, or reduce any identified environmental effects of the new or expanded facilities. The Project would generate 839 new residents within the City which would increase the use of the Goleta Valley Library. However, existing facilities would be sufficient to accommodate the increased use and annual circulation as a result of the Project. The Project developer also would be required to pay DIFs, as described in Policy PF 10.2 of the General Plan, which would provide funding for exp anded library facilities to accommodate new residents, including environmental compliance and permitting for new facilities. Therefore, the Project’s to cumulative impacts to library facilities would be less than significant. (Final EIR, pp. 4.11-7 through

4.11-8.)
P. RECREATION
Residential growth throughout the City would result in increased demand for recreational facilities. According to the City’s January 2021 list of cumulative projects, a total increase of 741 residential units are pending review, have b een approved, or are under construction in Goleta. As required by Chapter 16.14 of the Goleta Municipal Code, new residential developments within the City must dedicate 0.0128 acres per dwelling unit to parks and recreation, or else pay in -lieu fees toward the future development of such facilities. Thus, cumulative development in the City would generate demand for approximately 9.5 acres of recreational facilities.

The Goleta General Plan identifies approximately 90 acres of existing active recreation, which translates to approximately 2.8 acres per 1,000 residents. Several planned and recently completed park faci lities also provide space for active recreation. These planned and recently completed parks provide an additional 11 acres, bringing the total active recreation area to 101 acres.

With the addition of approximately 2,016 City of Goleta residents upon development of cumulative projects (74 residences x 2.72 persons per residence), the available active recreation ratio would be approximately 3 acres per 1,000 residents. This would be slightly greater than the current 2.8 acres per 1,000 residents, but falls short of the City’s adopted goal of providing 4.7 acres of parkland per thousand residents. The Project’s population would contribute to this ex isting cumulative impact.

However, the proposed onsite facilities and required payment of park and recreation fees required by Goleta Municipal Code Chapter 16.14 would be used to fund public park facilities that would meet the incremental demand for recre ational facilities created by the Project. With the required payment of in -lieu parks and recreation fees, the Project’s incremental contribution to this cumulative impact would be less than significant. (Final EIR, pp. 4.12-4 through 4.12-5.) Q. TRANSPORTATION
Based on technical guidance from the Governor’s Office of Planning and Research, if a project has a less than significant impact on VMT using an efficiency -based threshold (e.g., VMT per resident), the project would not contribute to a cumulative VMT im pact (OPR 2018). The Project’s VMT impact would be presumed to be less than significant based on the City’s screening 159
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criteria because the Project includes affordable housing which generally improves the City’s jobs - housing balance, shortens commutes, and reduces vehicle trips. The City’s screening criteria is analogous to an efficiency -based threshold and the Project’s contribution to cumulative VMT impacts would be less than significant.

The related projects include construction of 741 residential units, which equates to a population increase of 2,016 people. Assuming 51.2 percent of the population are part of the workforce (DOF 2020; EDD 2020), 5% of commuters in the Goleta area utilize public transportation, and 6% of commuters travel to work on bicycles , the cumulative projects would add 52 additional transit users and 62 new bicyclists to the Goleta area. The Project would add less than 1 rider per bus that serve the Project site which would not be a considerable contribution to the cumulative impacts to transit facilities. Additionally, the Project would result in approximately 14 new bicycle riders that would commute during the peak hour periods. Given the distance of the project site to the other related projects (Figure 3-1), it is unlikely that bicycle commuters from the Project site would commute via the same routes and the majority of the bicyclists from the related projects. As such, the bicycle riders would not be anticipated to measurably impact operations of the bicycle routes within the Goleta area. Therefore, cumulative impacts to transit and bicycle facilities would be less than significant.

Potential impacts associated with emergency access and transportation hazards would be site-specific and would not have corresponding cumulative effects . (Final EIR, pp. 4.13 -7 through

4.13-8.)
R. TRIBAL CULTURAL RESOURCES
CA-SBA-56 has been subject to previous impacts resulting from the development of the Willow Springs I and Willow Springs II projects. While environmental review of these previous projects determined that impacts to this resource were reduced to a less than significance level through mitigation, the cumulative impact to CA -SBA-56 as a whole is potentially significant.

Pursuant to CEQA Guidelines § 15355, cumulative impacts can result from in dividually minor but collectively significant projects taking place over a period of time. The Project’s impacts to tribal cultural resources related to CA -SB-56 would be reduced to less than significant with implementation of Mitigation Measures CR -1(a) through CR-1(f). Nevertheless, the project’s contribution to cumulative cultural resource impacts would remain significant and unavoidable. (Final EIR, p. 4.4-19.)

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S. UTILITIES AND SERVICE SYSTEMS
Water Supply. Cumulative development in the City would add 516 residential units and approximately 726,444 square feet of commercial and industrial space (City of Goleta, Cumulative Project List, January 2021). Using conservative water demand rates for single-family residences, multi-family residences, and non-residential development, as identified in the City’s Environmental Thresholds and Guidelines Manual, the total additional water demanded (should all pending projects in the City of Goleta be approved) is estimated at 530 AFY.

The total estimated water demand of 530 AFY would exceed GWD’s current surplus of 346 AFY. In accordance with GWD’s Water Conservation Plan from 2010, cumulative development would be required to incorporate feasible BMPs into water system design and be subject to the City’s conditions o f approval for outdoor and indoor water conservation. The Project would also be required to incorporate these measures and conditions of approval to reduce water demand. The Project also would be within GWD’s current water surplus and water allocation of 100.89 AFY for Willow Springs I, Willow Springs II, and the Project. Because sufficient water has been allocated for the Project, the Project would not result in a considerable contribution to a cumulative water supply impact associated with planned and pe nding development in Goleta would be less than significant.

Wastewater. Cumulative development within the City of Goleta would add 516 residential units and approximately 726,444 square feet of commercial and industrial space, resulting in increased generation of wastewater. Assuming that wastewater generation is 90 percent of water demand, cumulative development would generate about 477 AFY or 425,838 of wastewater per day.

This is about 44.8 percent of the 0.95 mgd of the remaining GWSD wastewater treatme nt capacity.

Wastewater generated by cumulative development would therefore be within GWSD’s available capacity. In addition, ongoing upgrades to wastewater treatment facilities would improve treatment capacity. In September of 2013, the GSD completed a major up-grade of its treatment facility and is now a Full Secondary Treatment Plant. NPDES permit extensions have been granted to GWSD given satisfactory progress made in completing the design and construction of the wastewater treatment facility upgrades to full secondary treatment standards. These upgrades were designed to eliminate constraints on the growing wastewater treatment demand of the City. In order for the Project and other related developments to connect to the wastewater system, payment of fees to reserve capacity and contribute to costs of plant upgrades would be required. With the payment of fees toward the construction of improvements to wastewater inf rastructure, the Project would not contribute to a cumulative impact on wastewater infrastru cture. Therefore, cumulative impacts would be less than significant.

Solid Waste. Solid waste generation from Project construction is estimated to be 85 tons per year. The Project’s operational solid waste generation, assuming 69 percent waste diversion is estimated at 242 tons/year. According to the City’s Environmental Thresholds and Guidelines Manual, projects with a project-specific impact identified in relation to the threshold of 196 tons/year are also considered cumulatively significant because the p roject-specific threshold is based on a cumulative growth scenario. The City’s Environmental Thresholds and Guidelines Manual also states that if solid waste generation exceeds 40 tons/year, it is considered an adverse contribution to cumulative impacts to solid waste facilities. Despite implementation of a SWMP for the potentially significant operational solid waste impact and required by Mitigation Measure UTL -4, Project construction and operations would result in waste in excess of 40 tons per year, resu lting in a 161
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significant and unavoidable contribution to cumulative solid waste impacts. (Final EIR, pp. 4.14-15 through 4.14-17.)
T. WILDFIRE
Cumulative projects proposed at the periphery of and just beyond the Goleta city limits would have the potential to expose people and structure to wildfire hazards by developing and redeveloping in areas near state responsibility areas and lands classified as very high fire hazard severity zones.

The magnitude of hazards for individual projects would depend upon the location, type, and size of development and the proximity of those individual sites to specific fire hazard zones. Wildfire hazard evaluations would be completed on a case -by-case basis for future development. Compliance with applicable SBCFD standards and stat e and local regulations pertaining to fire management would address impacts related to these wildfire hazards associated with future development in and around the city. The Project would not exacerbate or expose people or structures to risks associated wit h wildfire and would not impair emergency access or evacuation in the Project area. Therefore, the Project would not contribute to cumulative impacts due to wildfire, and cumulative impacts related to wildfire would be less than significant. (Final EIR, p. 4.16-5.) 162
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SECTION VI.

FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

CHANGES
Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the project be implemented.

Generally, a project would result in significant irreversible envir onmental changes if any of the following would occur:
 The project would involve a large commitment of non-renewable resources;  The primary and secondary impacts of the project would generally commit future generations to similar uses;
 The project involves uses in which irreversible damage could result from any potential environmental accidents; or
 The proposed consumption of resources is not justified.

CEQA Guidelines § 15126.2(b) requires EIRs to identify those significant impacts that cannot be reduced to a less than significant level with the application of mitigation measures. The implications and reasons why the Project is being proposed, notwithstanding, must be described.

Because the Project includes a General Plan Amendment (14-049-GPA), CEQA Guidelines § 15126.2(c) requires a discussion of any significant irreversible environmental changes which would be caused by the Project should it be implemented. Such significant irreversible environmental changes may include the following:
 Use of non-renewable resources during the initial and continued phases of the Project which would be irreversible because a large commitment of such resources makes removal or non-use unlikely.
 Primary impacts and, particularly secondary impacts (such as highway improvement which provides access to a previously inaccessible area) which generally commit future generations to similar uses.
 Irreversible damage which may result from environmental accidents associated with the Project.

Construction of the Project would require building materials and energy, some of which are non renewable resources. Consumption of these resources would occur with any development in the region and are not unique to the Project. The addition of new residential units would irreversibly increase local demand for non renewable energy resources such as petroleum and natural gas. Additional vehicle trips associated with the Project would incrementally increase local traffic and regional air pollutant and greenhouse gas emissions. As discussed in Section 4.13, Transportation/Circulation, Section 4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions of the Final EIR, impacts resulting from traffic generated by future development would be less than significant or could be mitigated to a less than significant level. 163
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Growth accommodated under the Project would require an irreversible commitment of law enforcement, fire protection, water supply, wastewater treatment, and solid waste disposal services. However, these impacts would be less than significant or would be reduced to a less than significant level with mitigation. (Final EIR, pp. 5-2 through 5-3.) SECTION VII.

GROWTH-INDUCING IMPACTS
Section 15126.2(e) of the State CEQA Guidelines requires a Draft EIR to discuss the ways the Project could foster economic or popul ation growth or the construction of additional housing, directly or indirectly, in the surrounding environment. In accordance with State CEQA Guidelines Section 15126.2(e), a Project would be considered to have a growth-inducing effect if it would:
 Directly or indirectly foster economic or population growth, or the construction of additional housing in the surrounding environment;
 Remove obstacles to population growth (e.g., construction of an infrastructure expansion to allow for more construction in service areas);  Tax existing community service facilities, requiring the construction of new facilities that could cause significant environmental effects; or
 Encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.

In addition, CEQA Guidelines provide that growth inducement must not be assumed.

Population and Economic Growth
The Project would add 332 new residential units to Goleta’s housing stock. The current population of Goleta is 32,223. Based on an average household size of 2.72 persons for market-rate housing (228 units proposed), 2.58 persons for family affordable housing (63 units proposed) and

1.36 persons for senior affordable housing (41 units proposed), the Project’s estimated po pulation would be approximately 839 persons (Department of Finance, 2020; Towbes, 2014; HACSB, 2020).

Therefore, the Project would be expected to increase the City’s population to 33,062. Consequently, the population generated by the Project would not exceed the Santa Barbara County Association of Government’s (SBCAG) 2040 population forecast of 34,300 for Goleta (SBCAG, January 2019).

The Project is not expected to induce any additional population growth beyond that associated with the Project itself.

Cumulative development in Goleta involves 741 residential units. Assuming 2.76 persons per household, this amount of residential development would add 2,045 residents (741 dwelling units x 2.76 people/dwelling unit). Cumulative development and the Project woul d increase the City’s population to 35,107 (current population of 32,223 + 839 + 2,045), which would exceed the SBCAG 2040 population forecast by 807. The physical environmental effects of cumulative development are addressed in Section 4.0 of the Final EIR as well as in the environmental documents prepared for each individual project.
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The Project includes residential development rather than commercial development. As such, the Project would not directly contribute to economic growth by providing additional space for business. Under the Project, 332 new residential units could be developed, which may indirectly contribute to economic growth. The additional population associated with the Project would likely contribute to the local economy as demand for gener al goods increases, which in turn could result in economic growth for various sectors. Project residents would increase the City population by about 2.5% and would be expected to primarily use existing City commercial services, creating only a minor need f or expanded services. The Project would not be expected to induce economic expansion to the extent that significant environmental impacts directly associated with the Project’s contribution would occur.

Removal of Obstacles to Growth
The Project would facilitate residential development on an undeveloped property historically used for agriculture and soil stockpiling in Goleta. The Project is surrounded by existing urban development and would rely upon existing roadways (primarily Camino Vista, Los Carne ros Way, and S. Los Carneros Road) for site access. No new roads would be required. The existing Camino Vista that fronts on the south side of the Project site will be widened to 43-feet curb to curb allowing on-street parking on the north side of the road. Access to the Project site would be provided via three driveway connections providing ingress and egress to Camino Vista. However, neither of these changes would result in new roadways, or would open any new areas to potential development. In addition, the Project would utilize existing water, wastewater and solid waste facilities that serve the urban areas of Goleta . Service would be provided through minor extensions of existing utility infrastructure. No additional infrastructure or facilities beyond those necessary to accommodate the Project would be required. No other undeveloped land in the vicinity of the Project would benefit in terms of growth from the extension/provision of urban services to the Project site. Because the Project constitutes infill development within an urbanized area and does not require the extension of new infrastructure that would open up additional undeveloped areas to potential future development, Project implementation would not remove an obstacle to growth. (Final EIR, pp. 5-1 through 5-2.) SECTION VIII.

ALTERNATIVES
A. BACKGROUND
The EIR analyzed five alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Project’s significant environmental effects while also meeting the majority of the Project’s objectives. The City finds that it has consider ed and rejected as infeasible the alternatives identified in the EIR and described below. This section sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light of the Project objectives, as required by CEQA.

Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:
(a) An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of 165
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the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Subsection 15126.6(b) states the purpose of the alternatives analysis:
(b) Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determinati on. Additional information explaining the choice of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic p roject objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reas oned choice. The EIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project.

B. PROJECT OBJECTIVES
The following objectives have been established for the Project (Final EIR, p. 6-1):

1. Complete development of residential units in the Central Hollister Residential Development area on Affordable Housing Opportunity Site. 166
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2. Assist City in providing affordable housing and complying with Regional Housing Needs Allocation (RHNA) requirements.

3. Construct senior affordable apartment units, family affordable apartment units, and market-rate apartment units up to the maximum density allowed by the General Plan and in keeping with the Housing Element.

4. Create an infill housing development project that meets the density range of 20 to 25 dwelling units per acre as envisioned for the site in the City’s General Plan.

5. Fully utilize the existing public infrastructure (Camino Vista and all utilities) provided by Willow Springs and Willow Springs II.

6. Promote City planning goals by developing a medium density residential project located conveniently close to a major transportation corridor and to employment and recreational areas.

7. Provide a public neighborhood park in the location shown in General Plan Figure 3- 2 (Park and Recreation Plan Map).

8. Protect, and preserve on-site cultural resources.

9. Develop multifamily residential housing while maintaining visual resources.

C. ALTERNATIVES CONSIDERED BUT REJECTED FROM DETAILED

ANALYSIS
Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts.

The following alternative was considered but rejected as part of the environmental analysis for the Project:
 Alternative Sites
Finding: The City Council rejects the Alternative Sites alternative, on the following ground, which provides sufficient justification for rejection of this alternative: (1) the alternative is technically, financially, and legally infeasible given that none of the alternative sites are controlled by the Project applicant and therefore cannot be developed by the applicant. Some of the undeveloped sites are too small in area (e.g., Kenwood Village Site, 7300 Calle Real) or too constrained by creeks and Environmentally Sensitive Habitat Areas (ESHA) (e.g., Girsh/Western Site at 7100 block of Hollister Avenue). Of the remaining vacant sites within the City that could accommodate development of similar scale to the Project, some are currently designated as Agriculture in the General Plan and others have a non-residential land 167
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use designation. Development on vacant sites with an Agricultural designation (e.g., Bishop Ranch) would result in losses of agricultural lands, creating a new impact for the residential project and requiring a General Plan amendment and zone change. The Bishop Ranch site is subject to Chapter 2.0 of the Goleta General Plan Land Use Element as amended by Measure G. Chapter 2.0 of the Land Use Element prohibits conversion of most land designated as agriculture on Figure 2-1 (Land Use Plan Map) of the General Plan without voter approval. There are limited vacant non- residential sites in the City, which are primarily located in the overflight areas of the Santa Barbara Airport. In addition, to the Airpor t constraint, changing the designation to residential would entail a General Plan amendment and a zone change. Many of the remaining vacant sites have pending or approved applications for development with the City. (Final EIR, pp. 6-21 through 6-22.) Therefore, this alternative is eliminated from further consideration.

D. EVALUATION OF ALTERNATIVES SELECTED FOR ANALYSIS
The alternatives selected for further detailed review within the EIR focus on alternatives that could reduce the Project’s significant environmental impacts, while still meeting most of the basic Project objectives. Those alternatives include:
 Alternative 1: No Project/No Development Alternative (Final EIR, p. 6-1.)  Alternative 2: Avoid CA-SBA-56 and Buffer (Final EIR, p.6-2.)  Alternative 3: Increased Railroad/Freeway Buffer and Higher Sound Barrier (Final EIR, p. 6-7.)
 Alternative 4: Reduced Building Height (Final EIR, p. 6-12.)  Alternative 5: Mixed Use Development (Final EIR, p. 6-16.)

1. Alternative 1: No Project/No Development Alternative Description: Alternative 1, the “No Project/No Development” alternative, assumes that no residential development would occur on the Project site and that environmental conditions would not change. The Project site would remain vacant. This a lternative would not add residents to the City’s population. Absent additional housing, population growth in the City would be accommodated through other proposed residential development projects within the City. (Final EIR, p. 6-1.)
Impacts: Implementation of this alternative would not result in any physical changes to the Project site since it would not accommodate any new development. This alternat ive would remove the unavoidable significant impacts with respect to cumulative cultural resource imp acts, construction noise, and solid waste . This alternative would also remove other significant, but mitigable impacts with res pect to visual character, light and glare , special status plant a nd animal species and habitats , intact CA -SBA-56 deposits and the known undisturbed human burial site, geotechnical impacts, and site drainage. However, the site would retain the existing Medium Density Residential (R-MD) zoning and the Affordable Housing Opportunity Site designation pursuant to 168
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the City’s General Plan, which would accommodate future residential development on the site. (Final EIR, p. 6-2.)
Attainment of Project Objectives : This alternative would not meet any of the Project objectives, including those related to the development of affordable rental housing to meet the City’s Regional Housing Needs Assessment (RHNA) requirements. (Final EIR, p. 6-2.) Finding: The City Council rejects Alternative 1: No Project/No Development Alternative, on the following ground , which provides sufficient justification for rejecti on of this alternative: the alternative fails to provide for the development of affordable housing as contemplated in the Project , and therefore does not meet some of the Project objectives . To the extent that the Project does not include an affordable housing component that would meet the Project objectives, the No Project/No Development Alternative is identified as the Environmentally Superior Alternative because it would not result in significant cumulative cultural resource impacts, construction noise impacts, and solid waste impacts. Under the No Project/No Development Alternative, an affordable housing project may still be proposed on the Project site at a later point in time because the site is designated as an Affordable Housing Opportunity Site un der the Goleta General Plan.

2. Alternative 2: Avoid CA-SBA-56 and Buffer
Description: In contrast to the developable area for the Project, which only excludes the 3.31 acres within the archaeological constraint area (CA -SBA-56), Alternative 2, the “Avoid CA-SBA- 56 and Buffer” alternative would eliminate the portion of the proposed development that lies within the boundary of the CA-SBA-56 archaeological site as well as the 50 -foot buffer surrounding CA- SBA-56, which includes Buildings 4, 5, 6, and 7 and o n-site parking. In order to avoid impacting CA-SBA-56 and the 50 -foot buffer, some or all of four proposed residential buildings in Area B (Buildings 4, 5, 6, and 7) as well as several uncovered and carport parking spaces would be eliminated from the plan.

Under this alternative, the total number of proposed units on the Project site would be reduced by 120 to 212 units, compared to the Project’s 332 units. The elimination of development within the 50 -foot buffer surrounding CA -SBA-56 would reduce the net developable area of the Project site from 14.05 acres to approximately 12.23 acres. Based on the minimum density of 20 units/acres associated with the Affordable Housing Opportunity Site designation, a minimum of 245 units would need to be provided on the 12.23-acre site. The reduction of residential units would be to market-rate units, resulting in 108 market -rate units, 63 family affordable units, and 41 senior affordable units under this alternative. Based on an average household size of 2.72 persons for market-rate housing (108 units proposed), 2.58 persons for family affordable housing (63 units proposed), and 1.36 persons for senior affordable housing (41 units proposed), this alternative would add an estimated 513 new residents (Department of Finance, 2020; Towbes, 2014; and HACSB, 2020). The site plan for this alternative would require reconfiguration of the residential structures, site access, and parking, on the remainder of the Project site to accommodate 212 units. This may require most if not all of the residential buildings to be three stories in height. Depending on the design, this change may affect the bedroom mix. The park in the central portion of the site would remain and would be expanded to cap the remainder of CA -SBA-56 and the 50 -foot buffer. (Final EIR, p. 6-2.)
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Impacts:
a. Aesthetics. Under this alternative, the Project site would be developed with structures that would alter views of and through the Project site. Eliminating all or part of Buildings 4, 5, 6, and 7 would result in a smaller footprint of development than the Project. This alternative would not affect the affordable housing components of the Project and, thus, would not require additional units or height to provide affordable housing options. Therefore, this alternative wou ld not involve alteration of buildings to a height that would substantially affect public views of the Santa Ynez Mountains from S. Los Carneros Road at Calle Koral looking northward, which is a City-designated view corridor. Views from the Los Carneros Ro ad overpass to the south and southeast are also designated view corridors. Structures would rise nearly to the level of the horizon, but would not obstruct scenic views of the Pacific Ocean. Thus, similar to the Project, Alternative 2 would result in a less than significant impact to the designated scenic view corridor looking northward from S.

Los Carneros Road at Calle Koral.

This alternative would still result in the removal of native shrub vegetation on most of the site. However, as with the Project, this impact would be less than significant. This alternative would have a smaller footprint of development compared to the Project; nevertheless, it would permanently alter the existing visual character of the Project site. This alternative involves replaci ng open and undeveloped land with residential development. However, as for the Project, this alternative would be generally compatible with adjacent development and landscaping would incrementally reduce changes to the character and quality of the site and surroundings.

New sources of light and glare on and around the Project site due to the introduction of new structures, hardscape and associated lighting would be similar to the Project. Therefore, this impact would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with new sources of light and glare ( Mitigation Measure AES-5).
b. Air Quality. As with the Project, this alternative would include construction of new residential units which would generate temporary increases in localized air pollutant emissions.

Ozone precursors NOX and ROG, as well as carbon monoxide (CO), would be still emitted by construction equipment such as graders, backhoes, and generators, while fugitive dust (PM10) would still be emitted by activities that disturb the soil, such as grading and excavation, road construction and building construction. Impacts would be incrementally lower due to the reduction in overall building footprint and required grading. By reducing the number of residential units by 120 to 212 units, this alternative would incrementally reduce the duration and amount of construction activity.

Nevertheless, standard emission control measures as required by the SBCAPCD would still apply.

This impact would remain less than significant.

This alternative involves 120 fewer residential units compared to the Project (a reduction of approximately 36%), and would therefore result in reduced energy demand and fewer motor vehicle trips. Therefore, operational emissions would be commensurately lower than those of the Project.

Emissions would be below SPCAPCD thresholds and this impact would remain less than significant.

Because this alternative involves fewer residential units than the Project, it would remain consistent with the applicable Clean Air Plan, which is the SBCAPCD 2019 Ozone Plan. This would be a less than significant impact.
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As with the Project, this alternative would expose residents on the Project site to a health risk (e.g., respiratory p roblems, lung damage, cancer) that would exceed SBCAPCD’s recommended health risk criteria. Because this alternative involves fewer residential units, fewer people would be exposed to health risks. Similar to the proposed project, forced air ventilation wi th filter screens on outside air intake ducts to be provided for all residential units on the Project site, which are included as a project -specific condition of approval. These measures would reduce the future residents’ exposure to toxic air contaminants to below the recommended health risk criteria. As with the Project, this impact would be less than significant.
c. Biological Resources. This alternative would reduce the overall building footprint, but would not avoid impacts related to the removal of habit at that could support nesting and/ or foraging birds protected under State and federal law. As with the Project, landscaping for this alternative could introduce invasive plant species that may escape into natural areas. This alternative, like the Project, would be located within a local wildlife linkage area, which could result in indirect impacts to wildlife movement. These impacts would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with nesting birds and raptors, invasive species, and wildlife movement ( Mitigation Measures BIO-1, BIO-2, BIO-4[a], BIO-4[b], and BIO-4[c]) to reduce these impacts to a less than significant level. Similar to the Project, this alternative would not impact wetlands or sensitive habitat. As with the Project, these impacts would be less than significant.
d. Cultural Resources. This alternative is designed to reduce impacts related to CA - SBA-56, which is an area of prehistoric archaeological significance that is eligible for listing on the National Register of Historic Places (NRHP), and is therefore considered a significant archaeological resource pursuant to CEQA Guidelines Section 15064.5(a)(3). Elimination of development within the area of CA -SBA-56 and the 50 -foot buffer would reduce the potential for disturbance to the resource by eliminating components of the project that would overlie the resource and buffer. In order to avoid impacting CA -SBA-56 and the 50 -foot buffer, some or all of four of the proposed residential buildings in Area B (Buildings 4, 5, 6, and 7) and several uncovered and carport parking spaces would be eliminated from the plan. This alternative would eliminate the need for mitigation related to excavation within CA-SBA-56 (Mitigation Measure CR-1[a]). Due to the proposed plan to cap the remainder of CA -SBA-56 and the 50 -foot buffer, this alternative would continue to require mitigation related to potential impacts to surface resources within CA -SBA-56 (Mitigation Measures CR-1[b], and CR -1[c]). Additionally, this alternative would continue to require mitigation related to potential impacts to previously undiscovered resources ( Mitigation Measures CR-1[d], CR-1[e], and CR -1[f]) to reduce this impact to a less than significan t level, especially in light of the work that would be required in close proximity to the known resources CA- SBA-56. Finally, Alternative 2 would not reduce the potentially significant impact associated with the identified human burial site within CA -SBA-56, and Mitigation Measures CR-2(a) and CR- 2(b) would continue to apply. Overall, impacts to cultural resources would be less than the Project. e. Geology. This alternative would reduce the overall building footprint and would incrementally reduce the amount o f grading required compared to the Project; nevertheless, the Project site would remain subject to the same potential geological impacts as the Project. Therefore, the potential for adverse effects caused by seismic settlement, liquefaction, erosion, and e xpansive soils would be fundamentally the same under this alternative as the Project. This alternative would continue to require mitigation related to potential geologic impacts (Mitigation Measure GEO-1). 171
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Therefore, this alternative would result in geological impacts that would be less than significant with mitigation, and similar to the Project.
f. Greenhouse Gas Emissions . This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 36%. Thus, the Project’s long-term GHG emissions from transportation and non -transportation sources would be reduced commensurately. As with the Project, GHG-related impacts would be less than significant. g. Hazardous Materials/Risk of Upset . Like the Project, th is alternative includes housing units near the U.S. 101 and UPRR corridors, a high-pressure natural gas line, and businesses that store and use hazardous materials. However, like the Project, this alternative would not increase risk of upset conditions ass ociated with those facilities. As with the Project, compliance with applicable federal, state, and local regulations pertaining to hazardous materials use, storage, and transport would minimize the potential risk of upset associated with hazardous materials use during project construction and operation. Therefore, risk of upset impacts would remain less than significant under this alternative.
h. Hydrology and Water Quality. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 36%. Therefore, there would be less overall impervious surface area under this alternative and surface water runoff and the erosion/sedimentation potential would be incrementally reduced. Nonetheless, as with the Project, this alternative would increase impermeable surfaces compared to existing conditions. Mitigation Measure HWQ-2 would be required to reduce impacts to site drainage. Implementation of required mitigation measure would reduce impacts to a less than significant level. Under this alternative, as with the Project, compliance with NPDES requirements and implementation of Best Management Practices (BMPs) would be required and would ensure that hydrologic impacts from construction and water pollutants would remain less than significant. i. Land Use. This alternative would maintain the minimum density of 20-25 units/acre associated with the Affordable Housing Opportunity Site designation. Similar to the Project, this alternative would be consistent with appli cable General Plan policies with mitigation as described in the Land Use section, and the resulting impact to land use would be less than significant. As for the Project, this alternative would result in development within the City’s Central Hollister Residential Development Area and development of the Project site would contribute to the objectives established for this area. As with the Project, this alternative would not divide an established community.
j. Noise. The overall footprint of development and are a of required grading would be incrementally reduced under this alternative. Therefore, overall construction noise would be slightly reduced. Nevertheless, as with the Project, construction activities would occur within 50 feet of sensitive receptors. This alternative would continue to require a similar scale of pre-construction soil hauling to prepare the site for construction. Therefore, this alternative would continue to require Mitigation Measures N-1(a) through N-1(g) for construction impacts. However, as with the Project, temporary construction noise impacts would remain significant and unavoidable.

The potential long-term noise increase resulting from development of this alternative would be less than the Project since this alternative would result in 120 fewer residential units (a reduction 172
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of approximately 36%), with a commensurate reduction in overall traffic generation. As with the Project, the potential long-term noise increase would remain less than significant.

As with the Project, this alternative would place residential uses near the U.S. 101 and UPRR rights-of-way. By eliminating Buildings 5 and 6, fewer residential units would be located adjacent to the U.S. 101 and UPRR. Nevertheless, this alternative would be subject to the same conditions as the Project to provide noise barriers as well as a rail line real-estate disclosure to potential occupants, providing notice of the site’s proximity to the UPRR and that associated noise and vibration may be perceptible. These measures would avoid the potential on-site noise exposure impact associated with this alternative.

Similar to the Project, activity during the construction period would not result in vibration levels that would exceed 80 VdB, and would not be expected to result in vibration levels that would be perceptible at nearby residences in excess of 30 vibration events of the same kind per day.

Therefore, impacts associated with groundborne vibration would be less than significant. k. Public Services. This alternative would have a smaller build ing footprint than the Project and would result in fewer residential units and amenities on the Project site as compared to the Project. As a result, the demand for impacts associated with the potential need for new public service infrastructure would be l ower under this alternative than the Project. As with the Project, impacts to public services would remain less than significant. l. Recreation. This alternative would result in fewer residential units and, therefore, fewer new residents than the Project. As a result, this alternative would result in a lower demand for public parks than the Project. As with the Project, this alternative would provide private recreational facilities for residents. In addition, the two -acre public park in the central portion of the property would be expanded to cover a greater extent of the CA -SBA-56 archaeological resource under this alternative. As with the Project, payment of parks development impact fees would be required and impacts to recreation would be less than significant.
m. Transportation/Circulation. This alternative would reduce the building footprint and the number of residential units on the Project site by approximately 36%. The reduced number of residential units would result in commensurately lower vehicle miles traveled (VMT) annually than the Project. As with the Project, impacts related to conflict or inconsistency with CEQA Guidelines Section 15063.3, subdivision (b) would remain less than significant. With fewer residents generated under this alternative than the Project, this alternative would not substantially overburden transit services or impact the operations of bicycle facilities in the Project site vicinity. Impacts related to conflict with alternative transportation program plan, ordinances or policies would remain less than significant.
n. Utilities and Service Systems. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 36%. As a result, the demand for utilities and services (water demand, wastewater generation, and solid waste generation) on the Project site would be commensurately lower under this alternative than the Project. Demand for water under this alternative would decrease from approximately 39.4 acre feet per year (AFY) to approximately 25.2 AFY. Wastewater generation under this alternative would decrease from approximately 0.06 million gallons per day (mgd) to approximately 0.04 mgd. Non-recyclable solid waste generation under this alternative would decrease from appr oximately 242 tons per year to 173
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approximately 158 tons per year. Therefore, this alternative would have a reduced overall impact with respect to utilities and service systems. The amount of non -recyclable solid waste generated under this alternative would n ot exceed the City’s project -specific threshold of 196 tons per year, and Mitigation Measure UTL-4 (Solid Waste Management Plan) would no longer be required.

As with the Project, impacts associated with water and wastewater generation would remain less than significant, and impacts associated with solid waste generation would be reduced to a less than significant level. (Final EIR, pp. 6-3 through 6-7.)
Attainment of Project Objectives: Under this alternative, Objective 3 would not be met to the same extent as the proposed Project and Objective 4 would not be met due to the reduced number of residential units on th e Project site. Objectives 1, 5, and 6, which relate to providing residential development on the site that completes the development of the Centra l Hollister Residential Development area, would continue to be met at the minimum density anticipated by the Affordable Housing Overlay. Objectives 7 and 8 to provide a public park consistent with the General Plan for the Project site and to protect on-site cultural resources would continue to be met. (Final EIR, pp. 6- 2 through 6-3.)
Finding: The City Council rejects Alternative 2: Avoid CA -SB-56 and Buffer , on the following grounds, each of which individually provides sufficient justification for reject ion of this alternative: (1) the alternative fails to meet some of the Project objectives to the same extent as the proposed Project ; and (2) the alternative fails to avoid or reduce the Project’s significant and unavoidable impacts relating to construction noise.

3. Alternative 3: Increased Railway/Freeway Buffer and Higher Sound Barrier Description: Alternative 3, the “Increased Railway/Freeway Buffer and Higher Sound Barrier” alternative, would reconfigure the development to provide a larger buffer between the railroad and the U.S. 101, and increase the height of the masonry wall to reduce noise impa cts.

Buildings 5, 6, 8 and 9 are as close as 120 feet from the railroad tracks and 300 feet from the centerline of U.S. 101. The combined noise exposure from U.S. 101 and the UPRR was determined to be as high as 72 dBA at the most affected residence on the third floor of Building 9, and would also be above the City’s 65 dBA CNEL standard at the second floor of Buildings 4, 5, 6, 8, and 9, and the first floors of Buildings 5, 6, 8 and 9 (Dudek, May 2014).

In this alternative, the height of the proposed noise barrier would be increased to 12 feet and would consist of a six -foot tall masonry wall on top of a six -foot tall berm. With the sound attenuation expected from a 12 -foot high barrier, the residential units would need to be approximately 200 feet from th e UPRR alignment to reduce the exterior noise level at affected residences to under 65 dBA CNEL, which is the maximum “acceptable” noise exposure for multi - family housing according to the Goleta General Plan. Therefore, in this alternative the Project would be reconfigured so that buildings are set back a minimum of 200 feet from the railroad. To achieve this setback, Buildings 5, 6, and 8 would be removed, and Building 9 would be reduced in size. This would result in the loss of up to 120 of the proposed units.

Because the Project site is designated as an Affordable Housing Opportunity Site, the minimum allowable density is 20 units/acre. Therefore, this alternative also assumes that Building 4 would increase to three stories and the bedroom mix would shift toward 1-bedroom and 2-bedroom units, rather than the 3-bedroom units included in the Project, in order to accommodate 69 additional 174
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units in the remaining buildings. This would result in a total of 281 units (approximately 15.4% reduction from the propo sed 332 units), which would meet the minimum allowable density of 20 units/acre associated with the site’s Affordable Housing Opportunity Site designation.

The additional space between the residential units and UPRR could be used for parking and/or open space. Site access and the approximately two-acre park would be the same as under the Project. (Final EIR, p. 6-7.)
Impacts:
a. Aesthetics. This alternative would involve developing the Project site with new structures that would alter views of and through the Project site. This alternative would involve construction of buildings at a height that would substantially affect public views of the Santa Ynez Mountains from S. Los Carneros Road at Calle Koral looking northward, which is a City-designated view corridor. Elimination of the buildings in the northern portion of the site may incrementally reduce view blockage from S. Los Carneros Road looking northward. However, increasing the height of Building 4 from two to three stories would incrementally increase view blockage of the Santa Ynez Mountains from S. Los Carneros Drive looking northward. Views from the Los Carneros Road overpass to the south and southeast are also designated view corridors. Structures would rise nearly to the level of the horizon, but would not obstruct scenic views of the Pacific Ocean. This alternative would increase the height of the proposed masonry wall along the western and northern property boundary from eight feet to 12 feet. However, the proposed structures would continue to dominate the visual changes caused by the Project. The increased height of the masonry wall would not result in further blocking of views, beyond that which would be caused by the proposed on -site structures. Thus, Alternative 3 would result in a less than significant impact to the designated scenic view corridor looking northward from S. Los Carneros Road at Calle Koral, similar to the project.

However, as this alternative may require additional buildings to be 3 -story, rather than 2 -story as with the Project, Objective 9 to maintain visual resources may not be met.

This alternative would still result in the removal of native shrub vegetation on most of the site. However, as with the Project, this impact would be less than significant. This alternative would have a smaller footprint of development compared to the Project; nevertheless, it would permanently alter the existing visual character of the Project site. This alternative involves replacing open and undeveloped land with a residential development. However, s imilar to the Project, this alternative would be generally compatible with adjacent development and landscaping would incrementally reduce changes to the character and quality of the site and surroundings.

New sources of light and glare on and around the Project site due to the introduction of new structures, hardscape and associated lighting would be similar to the Project. Therefore, this impact would remain potentially significant, and this alternative would continue to require mitigation related to pote ntial impacts associated with new sources of light and glare ( Mitigation Measure AES-5).
b. Air Quality. As with the Project, this alternative would include construction of new residential units, which would generate temporary increases in localized air pollu tant emissions.

Ozone precursors NOX and ROG, as well as carbon monoxide (CO), would be still emitted by construction equipment such as graders, backhoes, and generators, while fugitive dust (PM10) would still be emitted by activities that disturb the soil , such as grading and excavation, road construction 175
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and building construction. By reducing the number of residential units by 51, this alternative would incrementally reduce the duration and amount of construction activity. Nevertheless, standard SBCAPCD e mission control requirements would apply. This impact would remain less than significant.

This alternative involves 51 fewer residential units compared to the Project (a reduction of approximately 15.4%) and would, therefore, result in reduced energy deman d and fewer motor vehicle trips. Therefore, operational emissions would be commensurately lower than those of the Project. This impact would remain less than significant.

Because this alternative involves fewer residential units than the Project, it would remain consistent with the 2019 Ozone Plan. This would be a less than significant impact.

Under this alternative, residential units would be set back approximately 200 feet from the railroad compared to 120 feet under the Project. However, without air qua lity pollutant reduction measures, this alternative would still expose residential units on the Project site to a carcinogenic health risk that would exceed SBCAPCD’s recommended health risk criteria. Because this alternative involves fewer residential units, fewer people would be exposed to health risks. Similar to the proposed project, forced air ventilation with filter screens on outside air intake ducts to be provided for all residential units on the Project site, which are included as a project-specific condition of approval. These measures would reduce the future residents’ exposure to toxic air contaminants to below the recommended health risk criteria. As with the Project, health risk impacts would be less than significant.
c. Biological Resources. This alternative would reduce the overall building footprint but would not avoid impacts related to removal of habitat that could support nesting and/or foraging birds protected under State and federal law. As with the Project, landscaping for this alternative could introduce invasive plant species that may escape into natural areas. This alternative, like the Project, would be located within a local wildlife linkage area, which could result in indirect impacts to wildlife movement. These impacts would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with nesting birds and raptors, invasive species, and wildlife movement ( Mitigation Measures BIO -1, BIO-2, BIO-4[a], BIO- 4[b], and BIO-4[c]) to reduce these impacts to a less than significant level. Similar to the Project, this alternative would not impact wetlands, or sensitive habitat and these impacts would remain less than significant.
d. Cultural Resources. Under Alternative 3, Buildings 5, 6, and 8 would be eliminated and Building 9 would be reduced in size to provide a larger buffer between the railroad and the U.S. 101. However, this revision to the Project footprint would not result in a reduction in the potential for ground disturbing activity within the area of CA-SBA-56 and the 50-foot buffer. Impacts would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts to known resources within CA -SBA-56 and previously undis covered resources (Mitigation Measures CR -1[a], CR -1[b], CR -1[c], CR -1[d], CR -1[e], and CR-1[f]). Overall, impacts to cultural resources would be similar to the Project, and cumulative cultural resource impacts would remain significant and unavoidable.
e. Geology. This alternative would reduce the overall building area and would incrementally reduce the amount of grading required compared to the Project; nevertheless, the 176
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Project site would remain subject to the same potential geological impacts as the Project. Therefore, the potential for adverse effects caused by seismic settlement, liquefaction, erosion, and expansive soils would be fundamentally the same under this alternative as under the Project. This alternative would continue to require mitigation rela ted to potential geologic impacts ( Mitigation Measure GEO-1). Therefore, this alternative would result in geological impacts that would be less than significant with mitigation, and similar to the Project. f. Greenhouse Gas Emissions . This alternative would r educe the building footprint and the number of new residential units on the Project site by approximately 15.4%. Thus, the Project’s long-term GHG emissions from transportation and non -transportation sources would be commensurately reduced. As with the Project, GHG-related impacts would be less than significant. g. Hazardous Materials/Risk of Upset . Like the Project, this alternative includes housing units near the U.S. 101 and UPRR corridors, a high -pressure natural gas pipeline, and businesses that store and use hazardous materials. However, like the Project, this alternative would not increase risk of upset conditions associated with those facilities. As with the Project, compliance with applicable federal, state, and local regulations pertaining to hazardo us materials use, storage, and transport would minimize the potential risk of upset associated with hazardous materials use during project construction and operation. Therefore, risk of upset impacts would remain less than significant .
h. Hydrology and Water Quality. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 15.4%. Therefore, there would be less impervious surface area under this alternative and overall surface water runof f and erosion/sedimentation potential would be incrementally reduced. Nonetheless, as with the Project, this alternative would increase impermeable surfaces compared to existing conditions. This alternative would be required to implement mitigation measure HWQ-2 to reduce impacts to site drainage. Implementation of required mitigation measure would reduce impacts to a less than significant level. Under this alternative, as with the Project, compliance with NPDES requirements and implementation of Best Manag ement Practices (BMPs) would be required and would ensure that hydrologic impacts from construction and water pollutants would remain less than significant.

i. Land Use. This alternative would have 51 fewer residential units and would result in fewer new vehicle trips than the Project, resulting in a smaller increase in roadway noise and traffic.

Therefore, this alternative may pose slightly fewer compatibility conflicts with surrounding uses than would the Project. This alternative would maintain the minimu m density of 20 units/acre associated with the Affordable Housing Opportunity Site designation. As described above, Alternative 3 would potentially result in a significant and unavoidable impact to the designated scenic view corridor looking northward from S. Los Carneros Road at Calle Koral. Therefore, Alternative 3 would be inconsistent with several policies related to preservation of views, including VH 1.1, VH 1.4, VH 2.2, VH 2.3, and VH 4.15. In addition, this alternative would continue to require mitigation related to a temporary noise incompatibility impact ( Mitigation Measure N-1). Effects related to compatibility with adjacent businesses may be incrementally greater than those of the Project due to the increased number of three -story buildings, but would continue to be significant but mitigable.
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j. Noise. The overall footprint of d evelopment and area of required grading would be incrementally reduced under this alternative. Therefore, overall construction noise would be slightly reduced. Nevertheless, as with the Project, construction activities would occur within 50 feet of sensitive receptors. This alternative would continue to require a similar scale of pre-construction soil hauling to prepare the site for construction. Therefore, this alternative would continue to require Mitigation Measures N-1(a) through N-1(g) for construction impacts. However, as with the Project, temporary construction noise impacts would remain significant and unavoidable.

The potential long-term operational noise increase resulting from this alternative would be less than those of the Project since this alt ernative would involve 51 fewer new residential units (a reduction of approximately 15.4%), with a commensurate reduction in overall traffic generation. As with the Project, the potential long-term noise increase would remain less than significant.

Similar to the Project, activity during the construction period would not result in vibration levels that would exceed 80 VdB, and would not be expected to result in vibration levels that would be perceptible at nearby residences in excess of 30 vibration events of the same kind per day.

Therefore, impacts associated with groundborne vibration would be less than significant. k. Public Services. This alternative would have a smaller building footprint than the Project, and would result in fewer residential units and amenities on the Project site as compared to the Project. As a result, the demand for impacts associated with the potential need for new public service infrastructure would be lower under this alternative than the Project. As with the Project, impacts to public services would remain less than significant. l. Recreation. This alternative would result in fewer residential units, and therefore fewer new residents than the Project. However, this alternative would retain the proposed approximately two-acre park on the Project site. As noted above, the additional space between the residential units and UPRR under Alternative 3 could be used for additional open space. As a result, this alternative would result in a lower demand for public parks than the Project. As with the Project, payment of parks development impact fees would be required, and impacts to recreation would be less than significant.
m. Transportation/Circulation. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 15.4%, and therefore would result in commensurately lower VMT annually than the Project. As with the Project, impacts related to conflict or inconsistency with CEQA Guidelines Section 15063.3, subdivision (b) would remain less than significant. With fewer residents generated under this alternative than the Project, this alternative would not overburden transit services or impact the operations of bicycle facilities in the Project site vicinity. Impacts to related to conf lict with alternative transportation program plan, ordinances or policies would remain less than significant. n. Utilities and Service Systems. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 15.4%. As a result, the demand for utilities and services (water demand, wastewater generation, and solid waste generation) on the Project site would be commensurately lower under this alternative than the Project. Demand for water under this alternative would decrease from approximately 39.4 acre feet per year (AFY) to approximately 33.3 AFY. Wastewater generation under this alternative would decrease from approximately 0.06 mgd to approximately 0.05 mgd. Non -recyclable solid waste generatio n under 178
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this alternative would decrease from approximately 242 tons per year to approximately 205 tons per year. Therefore, this alternative would have reduced overall impacts with respect to utilities and service systems. However, the amount of non-recyclable solid waste generated under this alternative would exceed the City’s project -specific threshold of 196 tons per year, and Mitigation Measure UTL-4 (Solid Waste Management Plan) would be required. As with the Project, impacts associated with water and wastewater generation would remain less than significant, and impacts associated with solid waste generation would be significant and unavoidable. (Final EIR, pp. 6 -7 through 6-12.)
Attainment of Project Objectives: Under this alternative, Objective 3 would not be met to the same extent as the proposed Project due to the reduced number of residential units on the Project site. Objectives 1, 4, 5, and 6, which relate to providing residential development on the site that completes the development of the Central Hollister Residential Development Area, is accessible to nearby transportation corridors, and utilizes existing public infrastructure would continue to be generally met, although at a slightly reduced density when compared to the Project. Objectives 7 and 8 to provide a public park consistent with the General Plan for the Project site and to protect on- site cultural resources would continue to be met. As this alternative may require additional buildings to be 3-story, rather than 2-story as with the Proj ect, Objective 9 to maintain visual resources may not be met. (Final EIR, pp. 6-7 through 6-8.)
Finding: The City Council rejects Alternative 3 Increased Railway/Freeway Buffer and Higher Sound Barrier , on the following ground s, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative fails to meet some of the Project objectives to the same extent as the proposed Project ; and (2) the alternative fails to avoid the Project’s significant and unavoi dable impacts relating to cumulative cultural resource impacts, construction noise, and solid waste.

4. Alternative 4: Reduced Building Height
Description: Alternative 4, the “Reduced Building Height” alternative, would involve changing the six three-story buildings to two-story buildings and modifying the bedroom mix of the remaining units in order to meet the minimum density of 20 units/acre. Under this alternative, there would be 51 fewer residential units or 281 units provided (approximately a 15.4% decrease). The bedroom mix would shift towards 1-bedroom and 2-bedroom units, rather than the 3-bedroom units included in the Project. Site access and the con figuration of buildings, the approximately two -acre park, parking areas, and roadways would be the same as under the Project. (Final EIR, p. 6-12.) Impacts:
a. Aesthetics. Similar to the Project, under this alternative the Project site would be developed with new structures that would alter views of the Project site and through the Project site.

However, with this alternative, all structures would be two stories instead of three. By limiting the heights of all residential buildings to two stories (approximate ly 20 feet), this alternative would incrementally reduce the Project’s aesthetic impacts with respect to scenic vistas, visual character, and scenic resources. As a result of reduced scale and building mass, impacts to public and private views from surroun ding areas and roadways, in particular S. Los Carneros Road at Calle Koral looking both northward and southward, would be reduced. As this alternative would require buildings to be limited to two stories, Objective 9 to maintain visual resources would be met. 179
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This alternative would still result in the removal of native shrub vegetation on most of the site. However, as with the Project, this impact would be less than significant. This alternative would have the same footprint of development as the Project an d would permanently alter the existing visual character of the Project site. This alternative involves replacing open and undeveloped land with a residential development. However, similar to the Project, this alternative would be generally compatible with adjacent development and landscaping would incrementally reduce changes to the character and quality of the site and surroundings.

By reducing the height of the structures compared to the Project, this alternative would incrementally reduce new sources of light and glare on and around the Project site due to introduction of new structures, hardscape and associated lighting. Nevertheless, this impact would remain potentially significant, and this alternative would continue to require mitigation related to po tential impacts associated with new sources of light and glare (Mitigation Measure AES-5). b. Air Quality. As with the Project, this alternative would include construction of new residential units, which would generate temporary increases in localized air pol lutant emissions.

Ozone precursors NOX and ROG, as well as carbon monoxide (CO), would be still emitted by construction equipment such as graders, backhoes, and generators, while fugitive dust (PM10) would still be emitted by activities that disturb the so il, such as grading and excavation, road construction and building construction. By reducing the number of residential units by 51, this alternative would incrementally reduce the duration and amount of construction activity. Nevertheless, standard emission control measures as required by the SBCAPCD would apply. This impact would remain less than significant.

This alternative involves 51 fewer residential units compared to the Project (a reduction of approximately 15.4%), and would therefore result in redu ced energy demand and fewer vehicles trips. Therefore, operational emissions would be commensurately lower than those of the Project.

This impact would remain less than significant.

Because this alternative involves fewer residential units than the Project , it would remain consistent with the 2019 Ozone Plan. This would be a less than significant impact.

As with the Project, without air quality pollutant reduction measures, this alternative would expose new residential units on the Project site to a carcino genic health risk that would exceed SBCAPCD’s recommended health risk criteria. Because this alternative involves fewer residential units, fewer people would be exposed to health risks. Similar to the proposed project, forced air ventilation with filter sc reens on outside air intake ducts to be provided for all residential units on the Project site, which are included as a project -specific condition of approval. These measures would reduce the future residents’ exposure to toxic air contaminants to below th e recommended health risk criteria. As with the Project, this impact would be less than significant. c. Biological Resources. This alternative would reduce the overall building height, but would not avoid impacts related to removal of habitat that could suppo rt nesting and/ or foraging birds protected under State and federal law. As with the Project, landscaping for this alternative could introduce invasive plant species that may escape into natural areas. This alternative, like the Project, would be located within a local wildlife linkage area, which could result in indirect impacts to wildlife movement. These impacts would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with nesting birds and raptors, 180
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invasive species, and wildlife movement ( Mitigation Measures BIO -1, BIO-2, BIO-4[a], BIO- 4[b], and BIO-4[c]) to reduce these impacts to a less than significant level. Similar to the Project, this alternative would not impact wetlands, or sensitive habitat and these impacts would remain less than significant.
d. Cultural Resources . Although the number of units would be reduced with this alternative, the configuration and footprint of buildings on the Project site would remain the same, and the potential for ground disturbing activity within the area of CA-SBA-56 and the 50-foot buffer would be similar. Therefore, cultural resource impacts would be similar to those of the Project and this alternative would continue to require mitigation related to potential impacts to known resources within CA-SBA-56 and previously undiscovered resources ( Mitigation Measures CR -1[a], CR- 1[b], CR-1[c], CR-1[d], CR-1[e], and CR-1[f]). Overall, impacts to cultural resources would be similar to the Project, an d cumulative cultural resource impacts would remain significant and unavoidable.
e. Geology. This alternative would reduce the overall building height and involve fewer units; nevertheless, the Project site would remain subject to the same potential geological impacts as the Project. Therefore, the potential for adverse effects caused by seismic settlement, liquefaction, erosion, and expansive soils would be fundamentally the same under this alternative as the Project.

This alternative would continue to requir e mitigation related to potential geologic impacts (Mitigation Measure GEO -1). Therefore, this alternative would result in geological impacts that would be less than significant with mitigation, and similar to the Project. f. Greenhouse Gas Emissions . This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 15.4%. Thus, the Project’s long-term GHG emissions from transportation and non -transportation sources would be commensurately reduced. As with the Project, GHG-related impacts would be less than significant. g. Hazardous Materials/Risk of Upset . Like the Project, this alternative involves housing units near the U.S. 101 and UPRR corridors, a high -pressure natural gas pipeline, an d businesses that store and use hazardous materials. However, like the Project, this alternative would not increase risk of upset conditions associated with those facilities. As with the Project, compliance with applicable federal, state, and local regulat ions pertaining to hazardous materials use, storage, and transport would minimize the potential risk of upset associated with hazardous materials use during project construction and operation. Impacts associated with the risk of upset would remain less than significant.
h. Hydrology and Water Quality. This alternative would include 51 fewer units than the Project, but the building footprint would be identical. Therefore, the total area of impervious surfaces under this alternative, and resulting surface water runoff and erosion/ sedimentation potential would be substantially similar to the Project. As with the Project, this alternative would increase impermeable surfaces compared to existing conditions and would be required to implement mitigation measures HWQ -2 to reduce impacts to site drainage. Implementation of required mitigation measure would reduce impacts to a less than significant level. Under this alternative, as with the Project, compliance with NPDES requirements and implementation of Best Management Practices (BMPs) would be required and would ensure that hydrologic impacts from construction and water pollutants would remain less than significant. 181
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i. Land Use . This alternative would have 51 fewer residential units, would limit building height to two stories, and would result in fewer new vehicle trips than the Project, resulting in a smaller increase in roadway noise and traffic and less obstructed view of scenic resources.

Therefore, this alternative may pose slightly fewer compatibility conflicts with surrounding uses than would the Project. This alternative would maintain the minimum density of 20 units/acre associated with the Affordable Housing Opportunity Site designation. As described above, Alternative 4 would not result in a significant impact to the designated scenic view corridor looking northward from S. Los Carneros Road at Calle Koral. Therefore, this alternative would be consistent with the City’s General Plan. However, this alternative would continue to require mitigation related to a tempo rary noise incompatibility impact ( Mitigation Measure N -1). This alternative would result in site access and the configuration of buildings, the approximately two -acre park, parking areas, and roadways which would be the same as under the Project. Effects related to privacy for adjacent businesses would remain significant but mitigable, similar to the Project. j. Noise. The number of units would be reduced by 51 (15.4%) under this alternative.

Therefore, overall construction noise would be slightly reduced. Ne vertheless, as with the Project, construction activities would occur within 50 feet of sensitive receptors. This alternative would continue to require a similar scale of pre-construction soil hauling to prepare the site for construction.

Therefore, this alternative would continue to require Mitigation Measures N-1(a) through N-1(g) for construction impacts. However, as with the Project, temporary construction noise impacts would remain significant and unavoidable.

The potential long-term operational noise i ncrease resulting from this alternative would be less than those of the Project since this alternative would involve 51 fewer new residential units (a reduction of approximately 15.4%), with a commensurate reduction in overall traffic generation. As with the Project, the potential long-term noise increase would remain less than significant.

Similar to the Project, activity during the construction period would not result in vibration levels that would exceed 80 VdB, and would not be expected to result in vibration levels that would be perceptible at nearby residences in excess of 30 vibration events of the same kind per day.

Therefore, impacts associated with groundborne vibration would be less than significant. k. Public Services. This alternative would reduce the number of residential units as compared to the Project. As a result, the demand for impacts associated with the potential need for new public service infrastructure would be lower under this alternative than the Project. As with the Project, impacts to public services would remain less than significant. l. Recreation. This alternative would result in fewer residential units, and therefore fewer new residents than the Project. As a result, this alternative would result in a lower demand for public parks tha n the Project. Like the Project, this alternative would provide private recreational facilities for residents, as well as a two -acre public park. As with the Project, payment of parks development impact fees would be required, and impacts to recreation would be less than significant. m. Transportation/Circulation. This alternative would reduce the building height and the number of new residential units on the Project site by approximately 15.4%, and therefore would result in commensurately lower VMT annually than the Project. As with the Project, impacts related to conflict or inconsistency with CEQA Guidelines Section 15063.3, subdivision (b) would remain less than significant. With fewer residents generated under this alternative than the Project, this 182
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alternative would not overburden transit services or impact the operations of bicycle facilities in the Project site vicinity. Impacts to related to conflict with alternative transportation program plan, ordinances or policies would remain less than significant. n. Utilities and Service Systems. This alternative would reduce the building footprint and the number of new residential units on the Project site by approximately 15.4%. As a result, the demand for utilities and services (water demand, wastewater generation, and solid waste generation) on the Project site would be commensurately lower under this alternative than the Project. Demand for water under this alternative would decrease from approximately 39.4 acre feet per year (AFY) to approximately 33.3 AFY. Wast ewater generation under this alternative would decrease from approximately 0.06 mgd to approximately 0.05 mgd. Non -recyclable solid waste generation under this alternative would decrease from approximately 242 tons per year to approximately 205 tons per year. Therefore, this alternative would have reduced overall impacts with respect to utilities and service systems. However, the amount of non-recyclable solid waste generated under this alternative would exceed the City’s project -specific threshold of 196 t ons per year, and Mitigation Measure UTL-4 (Solid Waste Management Plan) would be required. As with the Project, impacts associated with water and wastewater generation would remain less than significant, and impacts associated with solid waste generation would be significant and unavoidable. (Final EIR, pp. 6 -12 through 6-16.)
Attainment of Project Objectives: Under this alternative, Objective 3 would not be fully met to the same extent as the proposed Project due to the reduced number of residential units on the Project site. Objectives 1, 2, 4, 5, and 6, which relate to prov iding residential development on the site that completes the development of the Central Hollister Residential Development area, is accessible to nearby transportation corridors, and utilizes existing public infrastructure would continue to be met, although at a slightly reduced density when compared to the Project. Objectives 7 and 8 to provide a public park consistent with the General Plan for the Project site and to protect on-site cultural resources would continue to be met. Objective 9 to maintain visual resources would be met. (Final EIR, p. 6-12.)
Finding: The City Council rejects Alternative 4 Reduced Building Height, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the al ternative fails to meet most of the Project objectives to the same extent as the proposed Project.; and (2) the alternative fails to avoid the Project’s significant and unavoidable impacts relating to cumulative cultural resource impacts, construction noise, and solid waste.

5. Alternative 5: Mixed Use Development
Description: Alternative 5, the “Mixed Use Development” alternative, would involve residential as well as business park development in place of the Project’s proposed residential development along the eastern and northern portions of the site. Business park development (under the City’s MRP zone) is proposed as a transition from industrial uses on Aero Camino and a buffer from U.S. 101 and the UPRR. This alternative assumes that buildout of the Project site would be the maximum amount allowed by the Goleta General Plan and Goleta Municipal Code if assessor’s parcel numbers (APN) 073-060-039 through -043 were re-zoned to MRP and designated for General Plan Business Park uses, similar to business park properties in the vicinity. It also assumes that the business park development would encompass 35% of the site and be two stories in height. This alternative is intended to address compatibility with industrial uses on Aero Camino to the east, and 183
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U.S. 101 and UPRR to the north, and would also reduce impacts associated with noise and risk of upset on the residential units.

The development assumptions for this alternative assume the maximum residential build-out that could be accommodated on the Project site under a combination of Design Residential, Affordable Housing Opportunity Site (25 units/acre) and Business Park designation. Since the eastern and northern parcels have 5.72 net developable acres, the maximum size of the business park structures would be approximately 179,400 square feet (89,700 square foot footprint and two stories tall) based on build-out of 35% of the business park site. The remaining 8.33 acres of net developable area on the Project site would be developed with residential uses. At th e maximum density of 25 units/ acre, the residential component of this alternative would be designed to accommodate 208 units within two- and three-story buildings.

A smaller business park development could also be constructed, which would reduce the overall impact of this alternative. For example, a one-story alternative with the same overall building footprint in the Business Park parcels as described above would involve 89,700 square feet of development. The site plan for this alternative would require that the residential structures, business park use, site access, and parking, be reconfigured on the remainder of the Project site to accommodate required residential density. In order to maintain the minimum density of 20 units/acre associated with the Affordable Housing Opportunity Site designation, the residential component of this alternative would be designed to accommodate 167 units, which this configuration assumes would be accommodated in two -story buildings. This alternative also assumes that the approximately two-acre park would be the same as proposed in the Project. This alternative also assumes that adequate parking would be provided to meeting parking regulations. Table 6 -1 of the Final EIR compares Alternative 5 to the Project. (Final EIR, p. 6-16.) Impacts:
a. Aesthetics. Under this alternative, the Project site would be developed with mixed uses, including residential and business park uses. The Project site would be developed with new structures that alter views of and through the Project site . However, by limiting the heights of the residential buildings to two stories, Alternative 5b would incrementally reduce the project’s aesthetic impacts with respect to scenic vistas, visual character, and scenic resources. Because there would be reduced scale and building mass, impacts to public and private views from surrounding areas and roadways, in particular S. Los Carneros Road at Calle Koral looking both northward and southward, would be reduced. Views of the scenic Santa Ynez Mountains under Alter native 5b would be less than significant. Under Alternative 5a, residential buildings would be built to 3 stories and impacts to views of the Santa Ynez Mountains would be potentially significant. In addition, as Alternative 5a may require additional buildings to be 3-story, rather than 2-story as with the Project, Objective 9 to maintain visual resources may not be met. Alternative 5b would require buildings to be limited to two stories, so Objective 9 to maintain visual resources would be met.

This alternative would still result in the removal of native shrub vegetation on most of the site. However, as with the Project, this impact would be less than significant. This alternative would permanently alter the existing visual character of the Project site. This alternative involves replacing open and undeveloped land with residential and business park development. However, similar to the Project, this alternative would be generally compatible with adjacent development and landscaping would incrementally reduce changes to the character and quality of the site and surroundings. 184
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This alternative involves mixed use development which would create new sources of light and glare on and around the Project site due to introduction of new structures, hardscape and associated lighting. Nevertheless, this impact would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with new sources of light and glare (Mitigation Measure AES-5).
b. Air Quali ty. This alternative would involve construction of a business park and residential development, which would generate temporary increases in localized air pollutant emissions. Ozone precursors NOX and ROG, as well as carbon monoxide (CO), would be emitted by equipment such as graders, backhoes, and generators, while fugitive dust (PM10) would be emitted by activities that disturb the soil, such as grading and excavation, road construction and building construction. Similar to the Project, it is assumed that construction would occur over approximately 2.5 years and standard emission control measure as required by the SBCAPCD would still apply. This impact would remain less than significant.

This alternative would involve fewer residential units compared to the Project (either 124 fewer units under Alternative 5a or 165 fewer units under Alternative 5b). Additionally, this alternative would include business park uses. The mixed -use of the site would result in decreased vehicle trips due to internal capture of tr ips and therefore less energy use compared to the Project.

Therefore, operational emissions would be commensurately lower than those of the Project.

Emissions would be below SPCAPCD thresholds and this impact would remain less than significant.

Because a lternative involves fewer residential units than the Project, it would remain consistent with the 2019 Ozone Plan. This would be a less than significant impact.

As with the Project, without air quality pollutant reduction measures, this alternative would expose residents on the Project site to a carcinogenic health risk that would exceed SBCAPCD’s recommended health risk criteria. Because this alternative involves fewer residential units, fewer people would be exposed to health risks. Similar to the proposed project, forced air ventilation with filter screens on outside air intake ducts to be provided for all residential units on the Project site, which are included as a project -specific condition of approval. These measures would reduce the future residents’ exposure to toxic air contaminants to below the recommended health risk criteria.

As with the Project, this impact would be less than significant. c. Biological Resources . Depending on the configuration of the business park and residential development, this alternative could avoid impacts related to removal of habitat that could support nesting and/ or foraging birds protected under State and federal law. However, it is likely that at least some sensitive habitat would be affected. As with the Project, land scaping for this alternative could introduce invasive plant species which may escape into natural areas. This alternative, like the Project, would be located within a local wildlife linkage area, which could result in indirect impacts to wildlife movement. These impacts would remain potentially significant, and this alternative would continue to require mitigation related to potential impacts associated with nesting birds and raptors, invasive species, and wildlife movement ( Mitigation Measures BIO-1, BIO-2, BIO-4[a], BIO-4[b], and BIO-4[c]) to reduce these impacts to a less than significant level.

Similar to the Project, this alternative would not impact wetlands, or sensitive habitat and these impacts would remain less than significant.
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d. Cultural Resources . Depending on the configuration of the business park and parking area, this alternative could potentially avoid the significant, but mitigable impact related to CA-SBA-56, which is an area of prehistoric archaeological significance. However, it is assumed that, at a minimum, parking lot and landscaped areas would overlie the resource, similar to the Project. Thus, impacts would be similar to those of the Project. This alternative would continue to require mitigation related to potential impacts to known re sources within CA -SBA-56 and previously undiscovered resources ( Mitigation Measures CR -1[a], CR-1[b], CR-1[c], CR-1[d], CR-1[e], and CR-1[f]). Overall, impacts to cultural resources would be similar to the Project, and cumulative cultural resource impacts would remain significant and unavoidable. e. Geology. This alternative would involve business park uses and residential uses, but the Project site would remain subject to the same potential geological impacts as the Project.

Therefore, the potential for adverse effects caused by seismic settlement, liquefaction, erosion, and expansive soils would be similar to the Project under this alternative. This alternative would continue to require mitigation related to potential geologic impacts (Mitigation Measure GEO-1). Therefore, this alternative would result in geological impacts that would be less than significant with mitigation, and similar to the Project.
f. Greenhouse Gas Emissions. This alternative would reduce the size of the Project by at least 124 units. However, this alternative would involve business park development on a portion of the Project site. Business park development would result in increased GHG emissions from transportation and non -transportation sources. GHG emissions may exceed the annual efficie ncy threshold of 4.9 MT CO2e per service population. Therefore, in contrast to the Project, this alternative may generate emissions exceeding applicable thresholds. This impact would be potentially significant and would require mitigation.
g. Hazardous Materi als/Risk of Upset . Like the Project, this alternative involves housing units and businesses park development near the U.S. 101 and UPRR corridors, a high - pressure natural gas pipeline, and businesses that store and use hazardous materials. However, like the Project, this alternative would not increase risk of upset conditions associated with those facilities. As with the Project, compliance with applicable federal, state, and local regulations pertaining to hazardous materials use, storage, and transport wo uld minimize the potential risk of upset associated with hazardous materials use during project construction and operation. Impacts associated with the risk of upset would remain less than significant . h. Hydrology and Water Quality. As with the Project, thi s alternative would involve structural development and paved area on the majority of the Project site. Therefore, there would similar impervious surface area and associated surface water runoff and the potential for erosion and sedimentation under this alt ernative. As with the Project, this alternative would be required to implement mitigation measure HWQ -2 to reduce impacts to site drainage. Implementation of required mitigation measure would reduce impacts to a less than significant level. Under this alternative, as with the Project, compliance with NPDES requirements and implementation of Best Management Practices (BMPs) would be required and would ensure that hydrologic impacts from construction and water pollutants would remain less than significant. i. Land Use. This alternative involves development of a business park and reduced number of residential units on the Project site (either 124 fewer units under Alternative 5a or 165 fewer units under Alternative 5b). The Project site has a General Plan land use designation of 186
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Medium-Density Residential (R-MD) and is designated as an Affordable Housing Opportunity Site.

The Project site is zoned Medium Density Residential (R-MD). Therefore, the business park portion of this alternative would be inconsistent with the City’s General Plan and the Goleta Municipal Code’s zoning regulations, and would require a General Plan amendment and zone change.

However, this alternative would maintain the minimum density of 20 units/acre associated with the Affordable Housing Opp ortunity Site designation. This alternative would continue to require mitigation related to a temporary noise incompatibility impact ( Mitigation Measure N-1). Effects related to privacy for adjacent businesses would remain significant but mitigable, simila r to the Project.
j. Noise. Because this alternative would involve full development of the Project site with a different mix of uses than the Project, the anticipated duration of construction activity under this alternative would be generally similar to that of the Project. As with the Project, construction activities would occur within 50 feet of sensitive receptors. This alternative would continue to require a similar scale of pre-construction soil hauling to prepare the site for construction. Therefore, this alternative would continue to require Mitigation Measures N -1(a) through N-1(g) for construction impacts. However, as with the Project, temporary construction noise impacts would remain significant and unavoidable.

Operational noise associated with this alternative would include typical noise associated with business park development such as vehicular movement, conversations, HVAC systems, loading, unloading, forklifts, and other equipment. These sources of operational noise would be comparable to surrounding business park uses and would not result in a significant noise impact. This alternative would generate more vehicle trips than the Project. Therefore, traffic -related noise would increase in comparison to the Project and may require mitigation.

Similar to the Project, activity during the construction period would not result in vibration levels that would exceed 80 VdB, and would not be expected to result in vibration levels that would be perceptible at nearby residences in excess of 30 vibration eve nts of the same kind per day.

Therefore, impacts associated with groundborne vibration would be less than significant. k. Public Services. This alternative would involve development of a business park and residential uses on the Project site. This alternative would result in fewer residential units than the Project; however, the same Santa Barbara County Fire Protection District requirements pertaining to defensible space, serviceable access, fire hydrants, and sprinkler systems would apply. Therefore, this alternative would have the same overall impacts to public services as the Project. As with the Project, impacts to public services would be less than significant. l. Recreation. This alternative would result in fewer residential units, and therefore fewer new residents than the Project. As a result, this alternative would result in a lower demand for public parks than the Project. Like the Project, this alternative would provide private recreational facilities for residents, as well as a two -acre public park. A s with the Project, payment of parks development impact fees would be required, and impacts to recreation would be less than significant. m. Transportation/Circulation. This alternative includes a mix of uses, which would include in fewer residential units th an the Project, but would include business park development.

The mix of uses proposed under this alternative may result in internal trips within the Project site, which would somewhat reduce off -site VMT compared to the Project. Like the Project, impacts 187
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related to conflict or inconsistency with CEQA Guidelines Section 15063.3, subdivision (b) would remain less than significant. With fewer residents generated under this alternative than the Project, this alternative would not overburden transit services or impact the operations of bicycle facilities in the Project site vicinity. Impacts to related to conflict with alternative transportation program plan, ordinances or policies would remain less than significant. n. Utilities and Service Systems . This alternativ e would involve development of a business park and residential uses on the Project site. This alternative would result in 124 (Alternative 5a) to 165 (Alternative 5b) fewer residential units than the Project. However, business park uses that would replace residential units on the Project site would result in increased reliance on utilities and services systems which serve the site. Estimated water demand, wastewater generation, and solid waste generation associated with Alternative 5a and Alternative 5b, ba sed on factors from the City’s Environmental Thresholds and Guidelines Manual, and assumptions used in Section 4.14, Utilities and Service Systems, are shown in Table 6-2 of the Final EIR. (Final EIR, pp. 6-17 through 6-21.)
Attainment of Project Objectives: This alternative would be consistent with the General Plan land use designation and zoning on the residential portion of the site (8.52 acres), but inconsistent with existing General Plan and zoning designations on the remaining portion (5.72 acres). As this alternative may require additional buildings to be 3 -story, rather than 2 -story as with the Project, Objective 8 to maintain visual resources may not be met. (Final EIR, p. 6-17.) Finding: The City Council rejects Alternative 5: Mixed Use Development, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the alternative fails to meet some of the Project objectives; (2) the alternative fails to avoid or reduce the Project ’s significant and unavoidable impacts relating to cumulative cultural resource impacts and construction noise; and (3) the alternative would result in increased impacts relating to greenhouse gas emissions.

E. ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of alternatives to a proposed Project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR. Based on the alternatives analysis conta ined within the Draft EIR, the No Project alternative is identified as the Environmentally Superior Alternative since it avoid s all impacts associated with development of the Project site. However, the No Project Alternative would not achieve the basic objectives of the Project, including providing affordable housing. To the extent that the Project does not include an affordable housing component, however, under the No Project/No Development Alternative, an affordable housing project may still be propos ed on the Project site at a later point in time because the site is designated as an Affordable Housing Opportunity Site under the Goleta General Plan.

Among the development options, Alternatives 2 through 5 would all reduce one or more significant Project impacts, as discussed below:
 Alternative 2 would somewhat reduce the potentially significant impact to cultural resources. Alternative 2 would incrementally reduce, but not eliminate impacts in several other issue areas, including air quality, greenhouse gas emissions, 188
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hydrology, noise, public services, and transportation due to a reduced number of residences proposed for development on the project site. Alternative 2 would eliminate the significant and unavoidable impact associated with solid waste generation.
 Alternative 3 would reduce residential exposure to noise and health risk from U.S. 101 and the UPRR. This alternative would reduce vehicle miles traveled and associated impacts related to air quality, greenhouse gases, and noise.  Alternative 4 would reduce the Project’s environmental effects to scenic resources, including views of the Santa Ynez Mountains; however, impacts to these views have been found less than significant. Alternative 4 would incrementally reduce impacts in several issue areas, including air quality, greenhouse gas emissions, noise, public services, and transportation due to the reduction in building height and number of units.
 Alternative 5 would reduce residential exposure to noise and health risk from U.S. 101 and the UPRR. This alternative would increase traffic generation and associated impacts related to air quality, greenhouse gases, and noise. Alternative 5b would eliminate the significant and unavoidable impact associated with solid waste generation.

In addition, Alternat ives 2 through 5 would all fail to meet one or more of the Project objectives, as noted below:
 Alternative 2 may not meet Objective 3 to the same extent as the proposed Project and would not meet Objective 4 due to the reduced number of residential units on the Project site.
 Alternative 3 may not meet Objective 3 to the same extent as the proposed Project due to the reduced number of residential units on the Project site. Because this alternative may require additional buildings to be 3-story, rather than 2-story as with the Project, Objective 9 to maintain visual resources may not be met.  Alternative 4 may not meet Objective 3 to the same extent as the proposed Project due to the reduced number of residential units on the Project site. Objective 9 regarding the maintenance of visual resources would be met and improved under this alternative when compared to the Project.
 Alternative 5 may not meet Objective 3 to the same extent as the proposed Project due to the reduced number of residential units on the Project site. Because Alternative 5a may require buildings to be 3-story, Objective 9 to maintain visual resources may not be met.

Alternatives 2 and 5b would each eliminate the Class I impact of the Project, related to solid waste generation. However, Alt ernative 5a would not eliminate this Class I impact. Alternative 3 would require additional buildings to be three -story rather than two -story, which could result in a potential significant impacts to scenic resources. All other project impacts would be reduced below 189
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identified thresholds of significance through implementation of the mitigation measures described in this EIR. Although some alternatives would reduce impacts in such areas as cultural resources and noise, these reductions would be incremental in nature and adoption of an alternative rather than the Project would not be necessary to avoid significant environmental effects. Therefore, based on the reduction of impacts and ability to meet most of the objectives of the Project, Alternative 2 “Avoid CA-SBA-56 and Buffer” would be the environmentally superior alternative of those described above. (Final EIR, pp. 6-22 through 6-23.)

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SECTION IX.

ADOPTION OF STATEMENT OF OVERRIDING CONSIDERATIONS
Under State CEQA Guidelines section 15093(a), the City Council must balance, as applicable, the economic, legal, social, t echnological, or other benefits of the Project against its unavoidable environmental risks in determining whether to approve the Project. If the specific benefits of the Project outweigh its unavoidable adverse environmental effects, those environmental effects may be considered acceptable under State CEQA Guidelines section 15093.

Having reduced the adverse significant environmental effects of the Project to the extent feasible by adopting the mitigatio n measures identified in the EIR and the Mitigation Monitoring and Reporting Program, and having considered the entire administrative record for the Project, the City Council has weighed the benefits of the Project against its unavoidable adverse impacts as identified in the EIR, including cumulative cultural resource impacts, construction noise impacts, and solid waste impacts. While recognizing that the unavoidable adverse impacts are significant under CEQA thresholds, the City Council nonetheless finds that the unavoidable adverse impacts that will result from the Project are outweighed by specific social, econ omic and other benefits of the Project and are therefore acceptable under State CEQA Guidelines section 15093.

In making this determinatio n, the factors and public benefits specified below were considered. Any one of these reasons is sufficient to justify approval of the Project. Accordingly, even if a court were to conclude that a particular benefit is not supported by substantial evidence, the City Council would be able to stand by its determination that the other benefits are sufficient overriding considerations . The substantial evidence supporting the various benefits enumerated below can be found in the preceding findings, which are incorporated by reference herein, and in the documents found in the record of proceeding.

The City Council therefore finds that each of the following social, economic, and environmental benefits of the Project outweigh the Project’s unavoidable adverse impacts and render acceptable each of the Project’s unavoidable adverse environmental impacts under State CEQA Guidelines section 15093:

1. The Project provides much needed senior income-restricted affordable housing and family income-restricted affordable housing. This project would provide 27% of the City’s Regional Housing Needs Assessment allocation for the low/very low category during the 2015-2023 Housing Element period.

2. The Project provides a significant number of additional housing units in the City.

3. The Project addresses a long-term economic goal of the City by providing housing that addresses the needs of workers and that helps achieve a more equal balance between the provision of jobs and housing in the City.

4. The Project provides housing within two miles of UCSB, which is the County’s largest employer, and within one mile of major job centers in the City.

5. The Project implements the goals and completes the Central Hollister Residential Development Area as stated in General Plan Policy Land Use 8. 191
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6. The Project will create an open space area that is available to the public while fostering awareness and protection of Goleta’s cultural resources.

7. The Project provides substantial new public facilities (e.g., a neighborhood park).

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EXHIBIT B

MITIGATION MONITORING AND REPORTING PROGRAM

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Heritage Ridge Residential Project

Mitigation Monitoring and Reporting
Program
SCH # 2015041014

Prepared by:

City of Goleta
130 Cremona Drive,
Suite B Goleta, CA 93117
Contact: Mary Chang, Supervising Senior Planner
(805) 961-7567

Prepared with the assistance of:

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Rincon Consultants,
Inc. 180 N. Ashwood
Avenue Ventura,
California 93003

January 2022
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This report is printed on 50% recycled paper with 30% post-consumer content.
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Heritage Ridge Residential Project
Mitigation Monitoring and Reporting Program

MITIGATION MONITORING AND REPORTING PROGRAM

The Final Environmental Impact Report (EIR) for the Heritage Ridge Residential Project identifies mitigation measures that will be implemented to reduce the environmental impacts associated with the Project. The California Environmental Quality Act (CEQA) was amended in 1989 to add Section 21081.6, which requires a public agency to adopt a monitoring and reporting program for assessing and ensuring compliance with any required mitigation measures applied to proposed development. As stated in Section 21081.6 of the Public Resources Code:

... the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment.

Section 21081.6 also provides general guidelines for implementing mitigation monitoring programs and indicates that specific reporting and/or monitoring requirements, to be enforced during Project implementation, shall be defined as part of adopting a mitigated negative declaration.

The mitigation monitoring table lists those mitigation measures that may be included as conditions of approval fo r the Project. To ensure that the mitigation measures are properly implemented, a monitoring program has been devised which identifies the timing and responsibility for monitoring each measure. The Project applicant will have the responsibility for implementing the measures, and the various City of Goleta departments will have the primary responsibility for monitoring and reporting the implementation of the mitigation measures.

City of
Goleta
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Mitigation Measure

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By

When Implemented

Monitoring or
Reporting Action
Verification of
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Initial Date
AESTHETICS – IMPACTS
AES-5 Lighting Specifications. Any exterior lighting installed on the Project site must be of low intensity, low glare design, and must be hooded to direct light downward onto the
Project site and prevent spill-over onto adjacent parcels and must otherwise meet dark night sky requirements.

Exterior lighting fixtures must be kept to the minimum
number and intensity needed to ensure public safety.

These lights must be dimmed after 11 p.m. to the
maximum extent practical without compromising public
safety as determined by the Planning and Environmental
Review Director or designee. Upward directed exterior
lighting is prohibited. Lighting fixtures must be
appropriate for the architectural style of the structure and surrounding area. The final lighting plan must be
amended to include identification of all types, sizes, and intensities of wall-mounted building lights and landscape accent lighting, and a photometric map must be provided. “Moonlighting” type fixtures that illuminate entire tree canopies should also be avoided.

Permittee The locations of all exterior
lighting fixtures, complete cut-
sheets of all exterior lighting
fixtures, and a photometric plan
prepared by a registered
professional engineer showing the
extent of all light and glare
emitted by all exterior lighting
fixtures must be reviewed and
approved by Design Review Board
before the City issues a building
permit for construction.

Before the City issues a
certificate of occupancy,
the Planning and
Environmental Review
Director, or designee,
must inspect exterior
lighting features to
ensure that they have
been installed
consistent with
approved plans.

BIOLOGICAL RESOURCES – IMPACTS
BIO-1 Nesting Birds and Raptors. To avoid construction impacts to nesting birds and raptors, vegetation removal and
initial ground disturbance must occur outside the bird and raptor breeding season, which is typically February 1
through September 1 (January 1 through September 1 for
some raptors), but can vary based on local and annual
climatic conditions. If construction must begin within the breeding season, then not more than two weeks before
ground disturbance and/or vegetation removal
commences, a bird and raptor pre-construction survey
must be conducted by a City-approved biologist within
the disturbance footprint plus a 300-foot buffer, as
Permittee,
City-
approved
biologist
Not more than one week before
ground disturbances commence,
the Planning and Environmental
Review Director, or designee,
must verify that construction and
grading is occurring outside the
nesting season, or that nesting
bird and raptor surveys have been
conducted, and buffer
requirements specified above are
in place (if applicable). This
measure, and any buffer
The Planning and
Environmental Review
Director, or designee,
must verify compliance
not more than one week
before ground
disturbances commence
and conduct periodic
site inspections to
ensure compliance
throughout the
construction period.

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feasible. If the Project is phased, a subsequent pre-
construction nesting bird and raptor survey is required before each phase of construction within the Project site.

If no raptor or other bird nests are observed no further mitigation is required.

Pre-construction nesting bird and raptor surveys must be conducted during the time of day when bird species are
active and be of sufficient duration to reliably conclude presence/absence of nesting birds and raptors within the 300-foot buffer. A report of the nesting bird and raptor survey results, if applicable, must be submitted to the Planning and Environmental Review Director, or designee, for review and approval not more than one week before
commencing ground disturbances.

If active nest of species protected by CFG Code 3503 or the MBTA Migratory Bird Treaty Act protected bird nests are found within 300 feet of the Project site, their
locations must be flagged and then mapped onto an aerial photograph of the Project site at a scale no less than
1”=200’ and/or recorded with the use of a GPS unit. If
active raptor nests are detected the map will include
topographic lines, parcel boundaries, adjacent roads,
known historical nests for protected nesting species, and known roosting or foraging areas, as required by
Conservation Element Policy 8.3 of the Goleta Community Plan/Coastal Land Use Plan. If feasible, the buffer must be 300 feet in compliance with Conservation Element Policy CE 8.4 of the Goleta General Plan/Coastal Land Use Plan.

If the 300-foot buffer is infeasible, the City approved biologist may reduce the buffer distance as appropriate, dependent upon the species and the proposed work
activities. If any active non-raptor bird nests are found, a requirements, must be
incorporated into the grading
plans for the Project.

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suitable buffer area (varying from 25-300 feet), depending on the species, must be established by the City approved biologist. No ground disturbance can occur within the
buffer until the City-approved biologist confirms that the breeding/nesting is completed and all the young have
fledged. Alternately, a City approved biologist must
monitor the active nest full-time during construction
activities within the buffer to ensure Project activities are not indirectly impacting protected nesting birds and
raptors.

BIO-2 Invasive Species Seeding and Landscaping. Nonnative, invasive plant species cannot be included in any erosion control seed mixes and/or landscaping plans associated
with the Project. The California Invasive Plant Inventory Database contains a list of nonnative, invasive plants
(California Invasive Plant Council [Updated 2017] or its successor).

Permittee Before the City issues a Zoning
Clearance, the applicant shall
secure approval of a final
landscape plan from the Design
Review Board.

The Planning and
Environmental Review
Director, or designee,
must verify compliance
before the City issues a
Zoning Clearance.

Before the City issues a
certificate of occupancy,
the Planning and
Environmental Review
Director, or designee,
must inspect landscape
plantings features to
ensure that they have
been installed
consistent with
approved plans.

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When Implemented

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BIO-4(a) Lighting Plan. In addition to the lighting specifications in Mitigation Measure AES-5, light and glare from new
development must be controlled and directed away from
the wildlife corridors shown on the conceptual landscape plan, Los Carneros Creek SPA ESHA, Los Carneros Wetland ESHA, and the open space areas adjacent to the
development. Exterior night lighting must be minimized, restricted to low intensity fixtures, shielded, and directed away from ESHAs, wildlife corridors, and open space.

Permittee The locations of all exterior
lighting fixtures, complete cut-
sheets of all exterior lighting
fixtures, and a photometric plan
prepared by a registered
professional engineer showing the
extent of all light and glare
emitted by all exterior lighting
fixtures must be approved by the
Design Review Board before the
City issues Zoning Clearance.

Before the City issues a
certificate of occupancy,
the Planning and
Environmental Review
Director, or designee,
must inspect exterior
lighting features to
ensure that they have
been installed
consistent with
approved plans.

BIO-4(b) Landscape Chemical and Pest Management Plan. All pesticides, herbicides, and fertilizers used at the Project site must be those designated for use near aquatic and
wetland habitats, and must be applied with techniques
that avoid over-spraying and control application to avoid excessive concentrations. Rodenticides are prohibited.

Trash and recycling receptacles shall be wildlife proof.

Permittee A Landscape Chemical and Pest
Management Plan (Plan) must be
developed by the applicant and
approved by the Planning and
Environmental Review Director, or
designee, before a final map is
recorded. The requirements must
be printed on the final approved
landscape plans, each residential
unit lease document, the map, and
recorded on the property deed.

The Plan must provide a
prohibition on use of pesticides,
herbicides, fertilizers and
rodenticides. These prohibitions
must be the subject of at least one
annual communication by the
applicant to the residents in the
form of a meeting and/or
newsletter or electronic update
that is distributed to residents.

Evidence of this effort
must be provided to the
Planning and
Environmental Review
Director, or designee,
each year by January
1st. The management
must also provide the
Planning and
Environmental Review
Director with an annual
monitoring report by
January 1 of each year
demonstrating the use
of aquatic and wetland
habitat appropriate
fertilizer, herbicides,
and pesticides
consistent with the Plan
on the property. If
determined necessary
by the City, the City may
require the applicant to

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retain a City approved
qualified biologist to
verify the correct use of
appropriate herbicides,
pesticides, and
fertilizers as part of the
annual monitoring
report.

BIO-4(c) Domestic Pet Predation, Feline Disease, and Wildlife Corridor Education. The applicant must prepare a public education campaign for future residents of the Project site regarding: 1) the effects of domestic animal predation on wildlife (e.g., domestic cats and protected bird species); 2) promoting indoor cats since bobcats are susceptible to the same diseases as domestic cats, and disease can be
transmitted between domestic cats and bobcats (or vice
versa); and 3) the importance of wildlife corridors.

Permittee The education materials must be
prepared by a City approved
qualified biologist, approved by
the Planning and Environmental
Review Director (or designee) and
must be recorded with the Final
Map. The education materials
must be distributed with the unit
lease documents, and the subject
of at least one annual
communication by the applicant to
the residents in the form of a
meeting and/or newsletter or
electronic update that is
distributed to all residents.

Evidence of this effort
must be provided to the
Planning and
Environmental Review
Director each year by
January 1st.

CULTURAL RESOURCES – IMPACTS
CR-1(a) Limited Phase 3 Data Recovery. The applicant must provide a Phase 3 Data Recovery Program Plan developed
by a City-approved archaeologist for excavations at the Northern Midden Area at CA-SBA-56.

Plan Requirements: The Phase 3 plan must be prepared in accordance with the City of Goleta’s Cultural Resources Guidelines (1993), Open Space Element Policy 8.5, the
California Office of Historic Preservation’s (1990)
Permittee A Phase 3 research design
prepared pursuant to City of
Goleta’s Cultural Resources
Guidelines, and a copy of a
contract (including a detailed
scope of work) between the
applicant and a City-approved
archaeologist and Chumash
Native American consultant for
The Phase 3 Data
Recovery Program must
be submitted for
approval by the City and
City-approved
archaeologist before the
applicant records a final
map. City staff and the
City-retained

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Archaeological Resource Management Reports (ARMR):

Recommended Contents and Format, and Public Resources
Code § 21083.2 and CEQA Guidelines § 15126.4(b). The
plan must include:

 Research design;
 Discussion of relevant research questions that
can be addressed by the CA-SBA-56 resources;
 Methods used to gather data, including data
from previous studies;
 Laboratory methods to analyze the data;
 An assessment of artifacts recovered and any
corresponding field notes, graphics, and lab
analyses; and
 Results of investigations.

The plan must provide for a systematic sample of the area to be capped, such that the research value of the deposit is adequately characterized.

The Phase 3 must be funded by the applicant and must be prepared by a City-approved archaeologist. The Phase 3
must be documented in a draft and final report and must be reviewed and approved by a City-retained
archaeologist. Pursuant to City Cultural Resource
Guidelines, the final report, archaeological collections, field notes, and other standard documentation must be
permanently curated at the UCSB Repository for
Archaeological Collections.

The Phase 3 must specify that a local Chumash Native
American consultant must be retained by the applicant to observe all excavation activity associated with the
Program. The consultant must maintain daily notes and
the Phase 3 program, and the
subsequent draft and final Phase
3 report, must be reviewed and
approved by the City and City-
retained archaeologist (funded by
the applicant) before recordation
of the final map. Upon
completion of the Phase 3 study
and all contact requirements, the
applicant must notify the City in
writing of the completed efforts
in a bond acceptable to the City.

This includes the completion of
the curation of items collected
during the Phase 3 mitigation. A
summary letter outlining the
successful completion of all
mitigation excavations must be
reviewed and approved by the
City and City-retained
archaeologist prior to issuance of
any Land Use Permit for grading
within the archaeological
resource area, including the
placement of fill over the
Northern Midden Area. All Phase
3 and curation requirements must
be met prior to issuance of
occupancy of the first residential
building (either Affordable or
Market rate Housing units).
archaeologist must
periodically site inspect
to verify completion of
the Phase 3 field work
and review and approve
the summary letter
outlining the completion
of excavations prior to
issuance of Zoning
Clearance for grading
within the
archaeological resource
area. Curation may be
completed after the
issuance of the Zoning
Clearance, as long as the
Phase 3 excavations
have been completed
and verified by the City
and City-retained
archaeologist. The City-
retained archaeologist
must review and
approve the draft and
final Phase 3 reports
prior to issuance of
occupancy permit for
the first residential
building (either Senior
or Workforce Housing
units). The applicant
must provide the City
with a letter from the
UCSB Repository for

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documentation necessary, and provide the observation
notes and documentation to all interested Chumash
representatives who request to be informed of the Phase 3 excavation progress.

Archaeological
Collections indicating
that all required
materials have been
accepted for curation
prior to the release of
the cultural resource
bond.

CR-1(b) Surface Preparation and Fill Soils within CA-SBA-56.

Preparation of the ground surface and the placement of
fill soils within the CA-SBA-56 boundary must be low
impact and adhere to the following requirements:

 Systematically collect all diagnostic artifacts on
the ground surface;
 Remove all organic material from the Northern
Midden Area surface by hand (including
brushing, raking, or use of power blower);
 Place a layer of Tensar geotextile grid over all
archaeological site areas to receive fill;
 Use fill soils within 1 pH of that identified in the
Northern Midden Area soils, as evaluated in the
field prior to construction;
 Use a contrasting color and/or gradation for the
lower six inches of fill soils, signaling to any
future sub-surface activity (e.g., landscaping
activity) that excavation shall not extend deeper;
and
 Place a minimum of 12 inches additional fill
material over the contrasting soil;
 Place the fill soils ahead of the loading
equipment so that the machine does not have
contact with the archaeological site surface.

Permittee Before the City issues any grading
permit, the Planning and
Environmental Review Director or
designee must approve a
Construction Monitoring Plan
prepared by the applicant and a
City-approved archaeologist. Plan
specifications for the monitoring
must be printed on all plans
submitted for grading,
landscaping, and building permits.

The applicant must enter into a
contract with a City-approved
archaeologist and an applicant
selected Chumash Native
American consultant(s) and must
fund the provision of on-site
archaeological/cultural resource
monitoring during initial grading
and excavation activities prior to
Zoning Clearance issuance for
grading. The contract should be
executed at least two weeks prior
to the Zoning Clearance issuance
for grading.

The Planning and
Environmental Review
Director, or designee,
and a City-retained
archaeologist must
approve the
Construction Monitoring
Plan and ensure there is
a valid contract with an
archaeologist and a
Chumash Native
American consultant,
and must conduct
periodic field
inspections to verify
compliance during
ground-disturbing
activities.

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 Moisten fill soils sufficient so that they are
cohesive under the weight of the heavy
equipment as the material is spread out over the
archaeological site and buffer area.

CR-1(c) Excavations within Northern Midden Area. Excavations for all landscaping and recreational improvements within the Northern Midden Area cannot encroach within the
initial six inches of contrasting soil placed above the geotextile grid and existing ground surface.

Permittee This requirement must be printed
on all plans submitted for any
Zoning Clearance for grading. The
area where excavations would not
encroach on the Northern Midden
Area as specified herein must be
clearly marked on the plans.

The Planning and
Environmental Review
Director, or designee,
must conduct periodic
field inspections to
verify compliance during
ground-disturbing
activities.

CR-1(d) Monitoring. Before initiating any staging areas, vegetation clearing, or grading activity, the applicant and
construction crew must meet on-site with City staff, a City- retained archaeologist, and local Chumash consultant(s) and present the procedures to be followed in the unlikely event that cultural artifacts are discovered during ground disturbances outside of the CA-SBA-56 Northern Midden
Area.

A City-approved archaeologist and local Chumash
consultant must monitor all ground-disturbing activities on the Project site, including surface vegetation removal and the Phase 3 Data Recovery Program. The monitor(s)
must have the following authority:

1) The archaeological monitor(s) and Chumash
consultant(s) must be on-site on a full-time basis
during any earthmoving activities, including
preparation of the area for capping, grading,
trenching, vegetation removal, or other
excavation activities. The monitors will continue
their duties until it is determined through
Permittee This requirement must be printed
on all plans submitted for any
Zoning Clearance, building,
grading, or demolition permits.

The applicant must enter into a
contract with a City-approved
archaeologist and applicant-
selected Chumash consultant and
must fund the provision of on-site
archaeological/ cultural resource
monitoring during initial grading
and excavation activities before
issuance of Zoning Clearance. Plan
specifications for the monitoring
must be printed on all plans
submitted for grading, and
building permits. The contract
should be executed at least two
weeks prior to a Zoning Clearance
for grading.

City Planning and
Environmental Review
Director or designee
must conduct periodic
field inspections to
verify compliance during
ground-disturbing
activities.

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consultation with the applicant, City Planning
and Environmental Review Director or designee,
archaeological consultant, and Chumash
consultant that monitoring is no longer
warranted;
2) The monitor(s) may halt any activities impacting
previously unidentified cultural resources and
conduct an initial assessment of the resource(s).

If cultural resources of potential importance are
uncovered during construction, the following
must occur per the Goleta General Plan Open
Space Policy 8.6
a) The grading or excavation shall cease and
the City shall be notified.
b) A qualified archeologist shall prepare a
report assessing the significance of the find
and provide recommendations regarding
appropriate disposition.
c) Disposition will be determined by the City
in conjunction with the appropriate
Chumash consultant.
3) If an artifact is identified as an isolated find, the monitor(s) must recover the artifact(s) with the
appropriate locational data and include the item
in the overall inventory for the site;
4) If a feature or concentration of artifacts is
identified, the monitor must halt activities in the
vicinity of the find, notify the applicant and the
Planning and Environmental Review Director or
designee, and prepare a proposal for the
assessment and treatment of the find(s). This
treatment may range from additional study to
avoidance, depending on the nature of the
find(s);

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5) The monitor must prepare a comprehensive
archaeological technical report documenting the
results of the monitoring program and include
an inventory of recovered artifacts, features,
etc.;
6) The monitor must prepare the artifact
assemblage for curation with UCSB and include
an inventory with the transfer of the collection;
and
7) The monitor must file an updated archaeological
site survey record with the UCSB Central Coastal
Information Center.

CR-1(e) Continued Chumash Consultation. Previous Chumash consultation with the City of Goleta and Project applicant resulted in the archaeological site CA-SBA-56 being
identified as important to the Chumash community.

Continued Chumash consultation must occur throughout
the remainder of the Project including any design changes, alternatives analysis, or mitigation measure
implementation to ensure that impacts to CA-SBA-56 are
mitigated in a manner that would be respectful of the
site’s Chumash heritage.

Permittee This condition must be printed on
all building and grading plans.

The Planning and
Environmental Review
Director or designee
must check plans before
the City issues a Zoning
Clearance and must spot
check in the field
throughout grading and
construction.

CR-1(f) Human Remains. Before initiating any staging
areas, vegetation clearing, or grading activity,
the applicant and construction crew must meet
on-site with City staff, a City-retained
archaeologist, and local Chumash consultant(s)
and present the procedures to be followed in
the unlikely event that human remains are
uncovered. These procedures must include
those identified by Public Resources Code §
5097.98. If the remains are determined to be of
Chumash descent, the County Coroner has 24
hours to notify the Native American Heritage
Permittee Before the City issues permits for
any ground disturbance, the
applicant must provide the City
Planning and Environmental
Review Director or designee the
contact information of the
Chumash consultant and the
agreed upon procedures to be
followed. In the event that
remains are found and if the
remains are found to be of
Chumash origin, the County
The Planning and
Environmental Review
Director or designee
must confirm that the
County Coroner is
notified in the event
human remains are
found, and that the
Native American
Heritage Commission is
contacted if the remains
are of Chumash origin.

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Commission (NAHC). The NAHC will then identify
the person(s) thought to be the Most Likely
Descendent (MLD) of the deceased Chumash. The
MLD will then in consultation with the City-
approved archaeologist and appropriate local
Chumash consultant(s) determine what course of
action should be taken in dealing with the
remains, so as to limit future disturbance.

Coroner will notify the Native
American Heritage Commission
and the Commission will name the
Most Likely Descendant (MLD).

The MLD, City-retained
archaeologist, applicant, and City
Planning and Environmental
Review staff will consult as to the
disposition of the remains. If the
remains are identified as non-
Chumash, the County Coroner will
take possession of the remains
and comply with all state and local
requirements in the treatment of
the remains.

CR-2(a) Landscape Plan Review. The applicant must demonstrate that the Open Space Landscape Plan has been reviewed
and approved by the local Chumash community to ensure
appropriate treatment of heritage resources within the
Northern Midden Area of CA-SBA-56.

Permittee This requirement must be printed
on the Final Open Space
Landscape Plan and approved by a
city approved archaeologist.

Confirmation that the local
Chumash community was
consulted and has approved the
Final Open Space Landscape Plan
must be submitted for any Zoning
Clearance issued for grading.

The Planning and
Environmental Review
Director, or designee,
must receive evidence
of the local Chumash
community’s approval
of the Final Open Space
Landscape Plan to verify
compliance with this
measure.

CR-2(b) Chumash Heritage Monument. The applicant must
incorporate a monument placed adjacent to the Open
Space passive recreational trail to highlight the Chumash heritage of the Project area. A Chumash Heritage
Monument Plan must be reviewed and approved by
representatives of the local Chumash community.

Permittee This requirement must be printed
on all plans submitted for any
Zoning Clearance issued for
grading. Confirmation that the
local Chumash community was
consulted and has approved the
Chumash Heritage Monument
Plan must be submitted for any
Zoning Clearance for grading. The
The Planning and
Environmental Review
Director, or designee,
must receive evidence
of the local Chumash
community’s approval
of the Chumash
Heritage Monument
Plan to verify

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monument will be installed prior
to the condition of occupancy.
compliance with this
measure.

GEOLOGY AND SOILS – IMPACTS
GEO-1 Geotechnical Design Considerations. The
recommendations in the Geotechnical Engineering Report
(Earth Systems Pacific, 2014) related to soil engineering within and outside of the Archaeological Area must be
incorporated into the Project’s grading and building plans, as summarized here:

Areas Outside the Archaeological Area:
 All existing fill soils should be completely
removed and replaced as compacted fill Any
existing utilities that will not be serving the site
must be removed or properly abandoned
 Voids created by the removal of materials or
utilities, and extending below the recommended
overexcavation depth, must be immediately
called to the attention of the geotechnical
engineer. No fill may be placed unless the
geotechnical engineer has observed the
underlying soil
 Following site preparation, soils in the building
area should be removed to a level plane at a
minimum depth of 3 to 8 feet below the bottom
of the deepest footing or 3 to 8 feet below
existing grade, whichever is deeper, as
recommended by the geotechnical engineer in
the field
 Soils in the surface improvement area should be
removed to a level plane at a minimum depth of
1-foot below the proposed subgrade elevation
or 2 feet below the existing ground surface,
Permittee Grading and building plans must
be submitted for review and
approval by the Planning and
Environmental Review Director or
designee before the City issues
grading and building permits.

The Project soils
engineer must observe
all excavations before
placement of
compacted soil, gravel
backfill, or rebar and
concrete and report
observations to the City.

The City will conduct
field inspections as
needed.

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whichever is deeper
 Soils in the fill areas beyond the building and
surface improvement areas should be removed
to a depth of 2 feet below the existing ground
surface
 Stabilization of surface soils by vegetation or
other means during and following construction
must be implemented, particularly those
disturbed during construction

Areas Inside the Archaeological Area, including the 50- foot Archaeological Buffer Zone:
 Existing ground surface in the grading area
inside of the archaeological area should be
prepared for construction by removing the
stockpile soils and all other existing fill soils
down to the native soil surface
 Before removing vegetation, vegetation should
be sprayed with topical herbicide per
manufacturer's specifications approximately 60
days before implementing grading operations.

The herbicide is more effective when applied to
plant leaves for better absorption
 All vegetation, debris, and other deleterious
material should be removed from the native soil
surface by hand (can include brushing, raking, or
the use of a power blower) to the degree
practicable at the ground surface such that no
soil disturbance occurs
 Root ball masses must be left in place to die
 Any existing utilities that will not be serving the
site must be removed or properly abandoned.

The appropriate method of utility abandonment
will depend upon the type and depth of the

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utility
 Surface vegetation removal and herbicide
application must be accomplished 60 days prior
to the geogrid placement; it is acceptable to
place import sand on the native soil surface
where uneven areas or undulations exist to
create as level a surface as practicable to place
the geogrid on as it improves both the
constructability and performance of the geogrid
system
 The native soil surface must be covered with a
tri-axial geogrid such as Tensar TX 7, or an
approved equivalent. The geogrid must be
anchored and/or overlapped as recommended
by the manufacturer prior to placing any fill soil
 The first 6 inches of fill placed on top of the
geogrid must be an imported sand material
reviewed and approved by the City of Goleta to
provide a visual indication to avoid impeding
into the native soils
 Fill soils must be placed and spread from the
outside to the inside of the archeological area
with track earthmoving equipment such that the
equipment must only be working on top of the
fill soils. The fill soils must be placed such that
the earthmoving equipment does not come into
contact with the archeological area native soils
or the geogrid

Grading (General):
 On-site material and approved import materials
may be used as general fill and up to 18 inches
below the bottom of the slab-on-grade elevation
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foundations will be used
 A minimum of 18 inches of nonexpansive
material when measured from the bottom of the
conventional foundation slabs-on-grade should
be placed in the building area
 Proposed imported soils should be evaluated by
a geotechnical engineer before being used, and
on an intermittent basis during placement on
the site
 All materials used as fill should be cleaned of
any debris and rocks larger than 6 inches in
diameter, and no rocks larger than 3 inches in
diameter should be used within the upper 3 feet
of finish grade
 Fill slopes should be keyed and benched into
competent soil
 Slopes under normal conditions should be
constructed at 2:1(horizontal to vertical) or
flatter inclinations. Slopes subject to inundation
should be constructed at 3:1 or flatter
inclinations
 Stabilization of surface soils by vegetation or
other means during and following construction
must be implemented, particularly those
disturbed during construction

If the portions of the site cannot be graded to those
recommendations, rigid mat foundations should be used
in lieu of conventional foundation systems.

Foundations:
 Foundations must not be constructed within 10
feet of LID drainage improvements. If this is not
the case, the geotechnical engineer must review

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the type of LID drainage improvement planned
within 10 feet of a foundation to ascertain if
revised and/or supplemental foundation
recommendations are needed
 Conventional and Rigid Mat Foundations
systems must be engineered in accordance with
the recommendations contained in the
Geotechnical Engineering Report (Earth Systems
Pacific, 2014)

HYDROLOGY AND WATER QUALITY – IMPACTS
HWQ-2 Maintenance Agreement and Stormwater Control Plan.

The applicant must execute a maintenance agreement
and Stormwater Control Plan with the City, in a form
approved by the City Attorney, that implements
maintenance requirements for all improvements
associated with all BMPs described in the final approved Hydrology and Hydraulic Analysis and Storm Water
Control Plan. The agreement must be executed before the City issues any final certificate of occupancy.

Permittee At a minimum, the maintenance
agreement and Stormwater
Control Plan between the
applicant and City must include
requirements that all inline storm
drain filters must be inspected,
repaired, and cleaned per
manufacture specifications and at
a minimum before September 30
of each year. Additional
inspections, repairs, and
maintenance must be performed
after storm events as needed
throughout the rainy season
(November 1 to April 15) and/or
per manufacture specifications.

Any necessary major repairs must
be completed before the next
rainy season. Before September
30 of each year, the applicant
must submit to Public Works for
review and approval a report
summarizing all inspections,
City Planning and
Environmental Review
staff must verify
compliance before
approval of any
occupancy permit for
the Project. City
Planning and
Environmental Review
staff must verify
compliance with the
provisions of the
agreement periodically
and respond to
instances of non-
compliance with the
agreement.

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repairs, and maintenance work
done during the prior year.

NOISE - IMPACTS
N-1(a) Construction Timing. Construction activity and
equipment maintenance is limited to the hours between
8 AM and 5 PM, Monday through Friday. No construction
can occur on State holidays (e.g., Thanksgiving, Labor
Day). Non-noise generating construction activities such as interior painting are not subject to these restrictions.

Permittee At least one sign near each Project
site entrance along Camino Vista
stating these restrictions must be
posted on the site. Signs must be a
minimum size of 24” x 48.” Signs
must be in place before the
beginning of and throughout
grading and construction
activities. Violations may result in
suspension of permits.

The Planning and
Environmental Review
Director or designee
must monitor
compliance with
restrictions on
construction hours and
must promptly
investigate and respond
to all complaints.

N-1(b) Electrical Power. Electrical power must be used to run air compressors and similar power tools.

Permittee The equipment area with
appropriate acoustic shielding
must be designated on building
and grading plans.

Equipment and shielding must
remain in the designated location
throughout construction activities.

The Planning and
Environmental Review
Director or designee
must periodically
inspect the site to
ensure compliance with
all noise attenuation
requirements.

N-1(c) Construction Noise Complaint Line. The applicant must provide a non-automated telephone number for local
residents and employees to call to submit complaints
associated with construction noise.

Permittee The telephone number must be
included in the notice required by
Measure N-1(a) and posted on the
Project site and must be easily
viewed from adjacent public areas.

Proof of mailing the notices must
be provided to the Planning and
Environmental Review Director or
designee before the City issues a
grading permit. At least one sign
near each Project site entrance
Building Inspectors and
Permit Compliance staff
may periodically inspect
and respond to
complaints.

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 Heritage Ridge Residential Project
Mitigation Monitoring and Reporting Program

 City of Goleta
 1
9 Heritage Ridge Residential Project Environmental Impact Report Mitigation Monitoring and Reporting Plan

Mitigation Measure

Implemented
By

When Implemented

Monitoring or
Reporting Action
Verification of
Completion
Initial Date
along Camino Vista with the phone
number must be posted onsite.

The applicant must inform the
Planning and Development Review
Director or designee of any
complaints within one week of
receipt of the complaint. Signs
must be in place before beginning
of and throughout grading and
construction activities. Violations
may result in suspension of
permits.

N-1(d) Distancing of Vehicles and Equipment. Noise and
groundborne vibration construction activities whose
specific location on the Project site may be flexible (e.g., operation of compressors and generators, cement
mixing, general truck idling) must be conducted as far as possible from the nearest noise- and vibration-sensitive land uses.

Permittee The location of vehicles and
equipment must be designated on
building and grading plans.

Equipment and vehicles must
remain in the designated location
throughout construction
activities.

The Planning and
Environmental Review
Director must
periodically inspect the
site to ensure
compliance.

N-1(e) Avoid Operating Equipment Simultaneously. Whenever possible, construction activities must be scheduled so as to avoid operating several pieces of equipment
simultaneously, which causes high noise levels.

Permittee The construction schedule and
timing of operation of each piece
of equipment must be provided
by the applicant.

Planning and
Environmental Review
Director or designee
must periodically
inspect the site to
ensure compliance.

N-1(f) Sound Control Curtains and Acoustical Blankets. Flexible sound control curtains must be placed around all drilling apparatuses, drill rigs, and jackhammers when in use.

Acoustical blankets (or similarly effective temporary noise barriers) must be placed along the southern, western, and eastern Project site boundaries to reduce noise
transmission to existing land uses to the south, west, and east, including residential units at the existing Willow Spring I and II sites south of the project site across Camino Permittee The equipment area with
appropriate sound control curtains
and the locations of acoustical
blankets must be designated on
building and grading plans.

Equipment and shielding must
remain in the designated location
throughout construction activities.

Planning and
Environmental Review
Director or designee
must monitor
compliance with
restrictions on
construction hours and
must promptly
investigate and respond

215