Goleta City Council
March 7, 2023

1 Agenda Item C.2

PUBLIC HEARING
Meeting Date: March 7, 2023
TO: City Council
FROM: Peter Imhof, Planning and Environmental Review Director CONTACT: Lisa Prasse, Current Planning Manager
Mary Chang, Supervising Senior Planner
SUBJECT: Certification of Final Environmental Impact Report (SCH 2015041014) and approval of the Heritage Ridge 332 Residential Apartment Project that includes a General Plan (GP) Amendment to remove an Environmental Sensitive Habitat Area designation as shown on GP Figures 3 -5 and 4-1; a Vesting Tentative Map that consolidates 13 lots into 4 lots and a Right -of- Way Exchange; and a Development Plan for 332 units (102 affordable units with two residence manager units, and 228 market rate) with State Density bonus parking concession, a public park on a 17.36 gross acre site located on the northside of Camino Vista Drive between Calle Koral and Aero Camino. Case Nos. 14-049-GPA-VTM-DP-DRB; APNs 073-060-031 to -043.

RECOMMENDATION:

That the City Council open the public hearing and, after consideration of the evidence:

A. Adopt Resolution No. 23-__, entitled “ A Resolution of the City Council of the City of Goleta, California Recommending that the City Council: 1) Adopt Environmental Findings Pursuant to the California Environmental Quality Act, 2) Certify the Heritage Ridge Residential Project Final Environmental Impact Report (Sch No. 2015041014) dated February 2023, 3) Adopt the Mitigation Monitoring and Reporting Program, and 4) Adopt Statement of Overriding Considerations”;
B. Adopt Resolution No. 23-__, entitled “ A Resolution of the City Council of the City of Goleta, California Recommending that the City Council Adopt Amendments to the General Plan/Coastal Land Use Plan Open Space Element Figure 3-5 and Conservation Element Figure 4-1 for APNs 073-060-031 through -043; Case No. 14-049-GPA”; C. Adopt Resolution No. 23-__, entitled “ A Resolution of the City Council of the City of Goleta, California Recommending that the City Council of the City Of Goleta, California Approve the Vesting Tentative Map to Merge and Re -subdivide Thirteen Lots into Four Lots (Three Residential Lots and One Park Lot) for the Heritage Ridg e Residential Project, APNs 073-060-031 through -043; Case No. 14-049 VTM”; and 1 Meeting Date: City Council March 7, 2023

2 D. Adopt Resolution No. 23-__, entitled “ A Resolution of the City Council of the City of Goleta, California Recommending that the City Council of the City of Goleta, California Approve the Development Plan for Three Hundred Thirty -Two Apartment Units , with a State Density Bonus Parking Concession, and a Public Park (Design Option 2/ Original Design) for the Heritage Ridge Residential Project; A PNs 073-060-031 through -043; Case No. 14-049-DP”.

E. Authorize the City Manager, with the approval of the City Attorney, to execute all necessary agreements and associated documents to effectuate the above recommendations and amend the Affordability Control Covenant and Regulatory Agreement and Land Acquisition Loan Agreement with the Housing Authority of the County of Santa Barbara and/or associated partnership entities in substantial compliance with the forms of agreement attached to the staff report and as sociated resolutions and in comportment with federal and state tax credit funding requirements.

APPLICANTS/OWNERS:

Applicants: Red Tail Multifamily Land Development, LLC
Housing Authority of the County of Santa Barbara (HASBARCO)

Owners: FLT Heritage Ridge TG, LLC
GF Frontier, LLC

EXECUTIVE SUMMARY & BACKGROUND:

In 2014, The Towbes Group applied for the proposal to construct 360 residential units, known as Heritage Ridge (“Project”), on the 17.36-gross acre site (16.2 net acres, 14.24 net developable acres), located on the north side of Camino Vista Drive in the City of Goleta.

Heritage Ridge will be the third and final phase of the adjacent Willow Springs Residential development. Since 2014, the applicant/permittee and ownership involvement has changed from the Towbes Group to the entities shown above.

The site in question has a General Plan Land Use designation of Medium -Density Residential and, prior to the adoption of Title 17, the site was zoned Design Residential (DR- 20). The current Title 17 zoning designation is Medium -Residential (RM). In addition, the Project site is designated in the General Plan as an Affordable Housing Opportunity site within the Central Hollister Corridor. The Project is required to provide housing at a density between 20-25 units per acre. As currently designed, the Project is at 23.6 dwelling units per acre.

Given the nature of the Project, an environmental impact report (EIR) has been prepared, which analyzed the anticipated impacts that could result from the Project. The initial Draft EIR was circulated for a 52-day public review period from June 17, 2016, through August 8, 2016, and identified significant and unavoidable impacts in several issue areas, namely, aesthetics/visual, cultural resources, hazar ds, land use policy, noise, and solid waste. In response to the visual impact issues raised within the Draft EIR, in 2017 the applicant chose 2 Meeting Date: City Council March 7, 2023

3 to change Building 1, located along the Los Carneros/Calle Koral intersection, from a three- story design to a two -story design, thereby reducing the number of units from 360 to 353, and reducing the Class I significant and unavoidable aesthetics/visual impact identified in the EIR at the time, to less than significant.

In March 2020, Redtail Multifamily Land Development, LLC (“Redtail”) took over the Project and became the applicant for Project processing with the City . Redtail represented to the City that in December 2020 that they entered into a purchase and sale agreement with the Housing Authority of the County of Santa Barbara (HASBARCO) to provide affordable senior and affordable family housing units on the site. The Project was reduced in total unit count from 353 units to 332 units. The 332 units are broken into a 102-unit affordable-housing development (low-income) plus two manager units, and a 228-unit market rate development.

The Project is using the State Density Bonus parking concession for a reduced parking requirement of 455 spaces. The City’s zoning requirement, not using the concession, is 542 spaces. The Project is providing 494 parking spaces.

On April 29, 2021, a Revised Draft EIR was circulated for a 45 -day public review period. It was determined that additional revisions to the Revised Draft EIR were required and the Revised Draft EIR was recirculated from May 14, 2021 through June 28, 2021.

Subsequently, the grading plan was revised to reduce soil export. In response to public comments received on the Revised Draft EIR, the site plan was revised to reduce total parking, change the type of parking spaces, and increase open space in order to achieve a 100-foot buffer from the Los Carneros Creek Streamside Protection Area (SPA). These revisions are reflected in the Final EIR, which was released on February 17, 2022 in preparation for the Planning Commission meeting planned in late February 2022. The Final EIR identified significant and unavoidable impacts to cumulative cultural resource impacts, construction noise, and solid waste (project level and cumulative).

The applicant is requesting approval of the following actions:

1. Certification of the Final Environmental Impact Report prepared for the Project, adoption of the California Environmental Quality Act (CEQA) Findings and Mitigation Monitoring and Reporting Program, and adoption of Statement of Overriding Considerations (SOC);

2. Adoption of a General Plan Amendment to remove an Environmental Sensitive Habitat Area designation on the property;

3. Approval of Vesting Tentative Map to consolidate the thirteen existing lots from a previous industrial subdivision into four residential lots (one to be a park ) and City vacation of five roadway easements and acceptance of a new roadway easement;

4. Approval of a Development Plan to allow the construction of 332 units (10 2 Affordable units plus two manager units, and 228 Market Rate units) with a parking concession; and

5. Approval of a credit of up to the total Park Fee of $3,041,520 (land value is appraised at $1.6 million and cost of improvements are anticipated to be at least $1,441,520).

The Project is consistent with the density and use envisioned by the General Plan, General Plan policies, and the DR-20 zoning district. This Project has been under review for the past 3 Meeting Date: City Council March 7, 2023

4 8 years and was deemed complete prior to September 1, 2019. This is the date upon which a project had to be deemed complete in order to be processed under the zoning standards that existed prior to the City’s adoption of Title 17, Zoning Ordinance, in 2020, as stated in Goleta Municipal Code Section 17.01.040(E).

Figure 1
Project Location

Figure 2
General Plan Land Use Map

R-MD
4 Meeting Date: City Council March 7, 2023

5 JURISDICTION:

The City is the lead agency for the Project under CEQA and the City Council will be the final decision-maker for the entire Project regarding the adequacy of the Final EIR, Mitigation Monitoring and Reporting Program, and proposed Statement of Overriding Considerations, as well as the merits of the various Project components.

BACKGROUND:

Design Review Board

The original Project of 360 units went before the Design Review Board (DRB) three times between 2013 and 2016. When the revised (current) Project was submitted in 2020, the applicant chose to change the architectural design based on previous DRB comments that the old design looked too “institutional.” The updated architecture became a Craftsman style, which better fit neighborhood compatibility in terms of size, scale, mass, bulk, and overall appearance. The DRB completed conceptual design review on February 9, 2021 , with positive comments on the architecture, the site planning, the park design, and landscaping.

The Project will return to DRB for Preliminary and Final approval upon Project entitlement since the Project is subject to pre-Title 17 process and development standards.

Parks and Recreation Commission

At their February 2, 2022 meeting, the City Parks and Recreation Commission reviewed the original park design and expressed concerns that the proposed 2 -acre neighborhood park may not include sufficient active recreation components to meet the City’s definition of a neighborhood park. On a 4 -3 vote, the Parks and Recreation Commission did not recommend the park design proposed by the applicant as the Commissioners felt the design may not include enough active features.

Planning Commission Hearings

The Planning Commission held public hearing s on March 28, 2022 , April 25, 2022 , and November 14, 2022. The Commission heard from staff, the applicant team, and members of the public at the hearings. Information in the three Planning Commission staff report packets (with more background and Project description), can be accessed here:

https://goleta.legistar.com/LegislationDetail.aspx?ID=5528973&GUID=A247A231-5E7D- 412A-AB2E-FB34E1D7E610 (March 28, 2022)

https://goleta.legistar.com/LegislationDetail.aspx?ID=5561383&GUID=E87695F5-B1B7- 47F9-B9FE-8AF088DB4DDB (April 25, 2022)

https://goleta.legistar.com/LegislationDetail.aspx?ID=5922502&GUID=2C3791DD-199F- 4C2E-932E-92D06405F096 (November 14, 2022)

5 Meeting Date: City Council March 7, 2023

6 On November 14, 2022, the Planning Commission recommended that the City Council:
 Certify the Final EIR, adopt the CEQA Findings, adopt the Mitigation Monitoring Reporting Program (MMRP), and adopt the Statement of Overriding Conditions on a unanimous vote;
 Adopt the requested GPA on a unanimous vote;
 Approve the Vesting Tentative Map on a unanimous vote; and  Approve the Development Plan wi th original park design (Option #2) on a 4 -1 vote.

The negative vote was because Commissioner MacLearn thought Park Option #3 would be better for the community and residents than Option #2. The remaining four commissioners found that the original park de sign (Option #2) struck a balance by providing enough active recreation components, along with respecting the cultural resources on the site.

PROJECT DESCRIPTION:

General Plan Amendment
A General Plan Amendment (GPA) is proposed to revise Figure 3 -5 of the Open Space Element and Figure 4 -1 of the Conservation Element to remove an Environmentally Sensitive Habitat Area (ESHA) designation of Coastal Sage Scrub from the site. A biological survey of the site was prepared, and the results indicate that the Coastal Sage Scrub habitat does not occur on the property. Rincon Consultant (the preparers of the Final EIR) have peer-reviewed the biological survey and conducted independent field work as well, which has confirmed the findings made by the applicant’s biological consultant (Dudek). The Exhibits A and B to Attachment 2 reflect the proposed General Plan changes.

Vesting Tentative Map and Roadway/Slope easement vacations The Vesting Tentative Map proposes to merge 13 existing lots into four lots and proposes that the City vacate three existing road easements (original Los Carneros Road alignment, Via Maya and Via Luisa), and the slope/landscape easement along Calle Koral and Los Carneros Road. Neither Via Maya or Via Luisa were ever constructed and are paper streets (streets shown on a Map but not physically in place). As part of the project, the applicant will be dedicating additional landscape/slope area adjacent to Los Carneros Road near the railroad bridge for a potential future Capital Improvement Plan (CIP) project along Los Carneros Road.

6 Meeting Date: City Council March 7, 2023

7 Figure 3
Vesting Subdivision

Lots 1 and 2 will be for the construction of the affordable units, Lot 3 will be the public park, and Lot 4 will be for the market-rate units. Five street and landscape/slope easements shown in blue and yellow are requested to be vacated with the Vesting Tract Map, as the City does not have a need for these easements. In exchange, the applicant will provide to the City the section shown in green representing a landscape/slope ea sement for future bike lane widening along Los Carneros Road.

Title 16 of the Goleta Municipal Code (GMC) along with California State Government Code Sections 66473.5, 66474 and 66474.6 provide the subdivision findings that must be made by the Planning Commission to approve the Vesting Tentative Map (VTM).

Development Plan
The Development Plan would authorize construction of 332 apartment units (102 Affordable Units with 2 manager units and 228 Market Rate Units) on the Project site. The site is adequate in size, shape and characteristics to accommodate the density and intensity of the Project. The Project complies with every development standard and is consiste nt with General Plan policies, with the use of the Density Bonus parking provisions.

7 Meeting Date: City Council March 7, 2023

8 Figure 4
Site Plan for 332-unit Project

Public Park
As part of the Development Plan, a public park has been proposed since 2014 in accordance with the Open Space Element of the General Plan. The park has been designed with a variety of amenities with the intent to serve the recreational needs of the residents and business employees in the immediate vicinity, which could include individuals (of various ages) and families with young children. The original park design, included a lawn area for ball play, tot lot and picnic area, a walking/jogging path with a ten-station fitness course, and a Chumash interpretive play area. In addition, the park is accessible via sidewalks and bike lanes and includes 13 dedicated off-street parking spaces for users of the park who choose to drive to the site. The size of the park is 2 acres with 1.85 acres for park use and 0.15 acres dedicated to parking use. As a result of the input received at the Parks and Recreation Commission, the applicant has proposed two additional design alternatives which are discussed more fully in the Discussion portion of the report.

8 Meeting Date: City Council March 7, 2023

9 As a reminder, the applicant is proposing a park consistent with the guidance provided in General Plan/Coastal Land Use Plan. Policy OS 6.4 in the City’s General Plan Open Space Element defines a neighborhood park as follows:

Neighborhood parks provide the nearby residential neighborhood with active recreational activities for a variety of age groups. The following standards shall apply to neighborhood parks:

a) The typical service area radius shall be 0.5 mile.
b) The typical size shall be less than 10 acres.
c) Neighborhood parks should be easily accessible to the surrounding neighborhood population through safe pedestrian and bicycle access.

Neighborhood parks do not generally require onsite parking, although a limited amount of parking may be provided.
d) Typical facilities provided in neighborhood parks include playgrounds and associated equipment, picnic tables, open undeveloped areas, lawns or grassy areas for field games, and benches.
e) Neighborhood parks may be developed as a sc hool park or community center park.

Completion of the park will coincide with completion of the last building in the Market Rate (Lot 4) area, approximately three years from the start of construction of the Market Rate units. Upon completion of the park c onstruction, the park will be dedicated to the City and turned over to the City Public Works Department for operation and maintenance. The maintenance, operations, and amenity replacement costs are highest to lowest from most active to the least active as described later in the report in Table 2.

Affordable Units
Because this residential rental development application was vested in 2014, when the City did not have an inclusionary housing requirement for rental residential development, this development is not required to provide any affordable units. The applicant has voluntarily proposed the inclusion of the 102 affordable housing units with 2 manager units at the low and very low-income range for both Seniors and Families (31% of the units). The affordable housing component would be constructed and managed by HASBARCO.

While uncertain until the time of funding, the projected housing mix is listed below but this mix could change, subject to City review and approval, based on the type of funding that is secured. The housing mix as of December 2022 is:

Senior Affordable (41 units)
 1 unit for an onsite resident manager
 10 units for veterans
 10 units for seniors who are unhoused with significant medical needs  10 units for seniors who are unhoused and have mental health and other needs  10 units for lower income seniors in need of affordable housing 9 Meeting Date: City Council March 7, 2023

10 Family Affordable (63 units)
 1 unit for an onsite resident manager
 12 units for households with veterans
 12 units for households in need of housing with a family member with significant medical needs
 14 units for households in need of housing with a family member who has mental health and other needs
 12 units for households currently experiencing, or at risk of, homelessness  12 units for lower income households in need of affordable housing

The timing of construction of the above -described affordable units is not linked to the construction of the market rate units and will occur as funding is secured by the Santa Barbara County Housing Authority. The developer of the site (The Towbes Group and FLT Heritage Ridge TG, LLC) will grade Lots A and B (the site of the Affordable Senior and the Affordable Family housing units, respectively) and extend utilities to the Lots (referred to as “super pads”) so that these Lots will be ready for development once funding is secured.

HASBARCO intends to construct the housing units as soon as funding becomes available but there is not a specific timeframe when these units would be built and operational.

HASBARCO anticipates that most, if not all, of the income -restricted units will have some form of housing voucher (depending on the program funding ultimately obtained), whereby the tenant household will pay 30% of household income for rent. Nevertheless, the City sets a limit for the maximum monthly tenant payment that is permissible. For the low-income units (households with income between 50 -80% Area Median Income (AMI), as published by California HCD), the maximum monthly tenant payment will be limited to the product of 30 percent times 60 percent of AMI adjusted for household size appropriate for the unit (defined as 0.7 is used for a studio unit, 0.8 for a one -bedroom unit, 0.9 for a two-bedroom unit, 1.0 for a three -bedroom unit, and 1.08 for a four -bedroom unit ). Likewise, f or the very low - income units (households with incomes 50% AMI or below, as published by California HCD), the maximum monthly tenant payment will be limited to the product of 30 percent times 50 percent of AMI adjusted for household size appropriate for the unit (defined as 0.7 is used for a studio unit, 0.8 for a one -bedroom unit, 0.9 for a two -bedroom unit, 1.0 for a three - bedroom unit, and 1.08 for a four -bedroom unit). The annual maximum rents established pursuant to these calculations are then divided by 12, less the applicable utility allowance for tenant -paid utilities . Th is method establishes maximum rental rate s according to the number of bedrooms in the unit, and those maximums will be adjusted y early pursuant to annual changes in the State Income Limits published by California HCD.

The Housing Authority has indicated that services (i.e., individual and group counseling, life skill workshops etc.) to support the supportive housing residents would also be provided on site in the indoor space planned as part of the Project located on Lot 1. However, the specifics regarding the operational characteristics (hours of operation, frequency, number of support staff, etc.) for the supportive services have not been developed yet since the Housing Authority does not know the make-up of their future residents.

10 Meeting Date: City Council March 7, 2023

11 Per HASBARCO, in addition to State or federal programs that may be available, the likely potential funding sources include:

 Housing for a Healthy California (HHC)
 No Place Like Home (NPLH)
 Low Income Housing Tax Credits (LIHTC)
 Affordable Housing Program (AHP)
 Multi-family Housing Program (MHP)
 Project Based Vouchers (PBV)
 Veterans Administration Supportive Housing (VASH)
 County of Santa Barbara HOME
 City of Goleta HOME
 City of Goleta In-Lieu Fees

ENVIRONMENTAL REVIEW:

A Notice of Preparation (“NOP”) of an EIR was distributed for a 30-day public-review period on April 6, 2015. The original Draft EIR was circulated for a 52 -day public review period between June 17, 2016, and August 8, 2016. A Revised Draft EIR, which reflected more recent changes since preparation of the original Draft EIR, was circulated for a 45-day public review period from May 14, 2021 to June 28, 2021. A Final EIR was prepared following the close of the 2021 public comment period. A Notice of Availability (NOA) of the Final EIR and notice of the City Planning Commission Hearing was provided on February 17, 2022. Staff presented the initial version of the Final EIR, along with the Project details at the March 28, 2022 Planning Commission hearing.

Several public comments relating to the EIR analysis were submitted at or following the April 25, 2022 Planning Commission hearing, to which staff chose to prepare responses for inclusion in the already prepared and released FEIR. The FEIR has been revised to include a Preface chapter that discusses the CEQA baseline and response to the following comments received by the following organizations after June 28, 2021:

1. A letter from Environment Defense Center (EDC);

2. A letter from the California Department of Fish and Wildlife (CDFW); and

3. A letter from the Sierra Club

The Preface Chapter summarizes the changes that took place since the Final EIR was initially released in February of 2022. The now revised Final EIR also includes responses to the letters from the above three organizations and the revised Final EIR has been available to the public since October 14, 2022 ; the most recent version is dated February 2023 . As part of the Planning Commission’s action, the Planning Commission recommended that the City Council accepts the adequacy of the analysis contained within the revised Final EIR.

The Final EIR, along with the appendices and the Mitigation Monitoring Reporting Program (MMRP), can be accessed in the following link:
https://www.cityofgoleta.org/your-city/planning-and-environmental-review/ceqa- review/heritage-ridge
11 Meeting Date: City Council March 7, 2023

12 The Final EIR analyzed the whole of the Project including the Right -of-Way Exchange and the dedication/construction of the public park. The Final EIR ident ifies and discusses potential impacts, mitigation measures, monitoring requirements, and residual impacts for identified subject areas. Significant and unavoidable impacts are identified in the issue areas of cumulative level Cultural Resources, project-level short term Noise, and project-level Solid Waste. Potentially significant but mitigable effects on the environment are anticipated in the following areas: Aesthetics, Air Quality, Biology, Cultural Resources, Geology and Soils, and Hydrology, and Transportation/Circulation.

To approve the Heritage Ridge project, the City Council would need to adopt a Statement of Overriding Considerations in accordance with applicable law. As part of the actions that the City Council is asked to adopt, Attachment 1 would certify the Final EIR, make the necessary CEQA findings, adopt the MMRP, and adopt a SOC. The Planning Commission unanimously recommended that the Council take this action.

Lastly, following the Planning Commission hearing on November 14, 2022, the City received a letter from the law office of Mitchell Tsai representing Southwest Regional Council of Carpenters (SWRCC) raising issues with adequacy of the Final EIR . The letter is not provided with the report but can be access as part o f the December 12, 2022, Planning Commission report at this link (Attachment 4):

https://goleta.legistar.com/LegislationDetail.aspx?ID=5950593&GUID=A3E4A13B-641E- 40B0-BD60-76B6931373ED

The main points of the 282-page Tsai letter are:

1. The City should require the use of a local workforce to benefit the community’s economic development and environment.

2. The City should impose training requirements for the project’s construction activities to prevent community spread of COVID-19 and other infectious disease.

3. The project would be approved in violation of CEQA based on “segmenting” the environmental review, and violation of the Brown Act and Due process . (This was based on the relationship of the requested General Plan Conformity Determinations (Government Code Section 65402 determinations) on the agenda and the Project.)

The Council is directed to Attachment 6 for a response to Mr. Tsai letter. It is the position of the City that the requested Government Code Section 65402 determinations made on November 14, 2022, by the Planning Commission did not violate the Brown Act. Specifically, the agenda titles expressly recognize that, in addition to making the Section 65402 findings for the Right -of-Way Exchange and Park Dedication associated with the Project, the Planning Commission also considered a finding that those specific a ctions were categorically exempt under CEQA. The Planning Commission adopted Resolutions No. 22- 14 and No. 22-15, which found the Right-of-Way Exchange and Park Dedication associated with the Project, respectively, conforms with the City’s General Plan pursuant to Government 12 Meeting Date: City Council March 7, 2023

13 Code Section 65402, and that those actions are categorically exempt under CEQA. In short, the Planning Commission considered precisely what the agenda identified.

Nonetheless, to avoid negatively impacting the progress of the Project or create further delay, the Planning Commission rescind ed its November 14th actions taken on the associated Government Code Section 65402 determinations on December 12, 2022 (Planning Commission Resolution No. 22 -16). The effect is that the Commission never acted on this matter and, therefore, there are no potential actions to challenge under the Brown Act. The purpose of that action was to avoid potentially wasteful and distracting litigation while allowing the City to focus its att ention on matters of substance and its resources on its priorities. The Government Code section 65402 action can be taken at a later date at the time of final map recordation.

DISCUSSION:

General Plan Amendment

Currently, the General Plan/Coastal Land Use Plan (GP/CLUP) Open Space Element Figure 3-5, Open Space Plan Map and the GP/CLUP Conservation Element Figure 4 -1, Special- Status Species and Environmental Sensitive Habitat Areas depict an Environmentally Sensitive Habitat Are a (ESHA) and Sage Scrub/Dune/Bluff Scrub on the Project site .

Pursuant to General Plan Policy CE 1.5, a biological assessment of the site was done, and the data was confirmed through a peer review. The assessment determined that n o ESHA and Sage Scrub/Dune /Bluff Scrub habitat community exists on the Project site . This assessment has been reviewed and confirmed multiple times by Rincon Consultants during the past six years the EIR has been under preparation and public review as shown in Table 1 below.

Table 1
Biological Surveys

DATE TYPE OF REPORTS PREPARED BY

AND/OR PEER
REVIEW
April 15, 2013, Biological/Wildlife Corridor
Assessment
Dudek (Applicant)
April 10, 2014 Technical Review of Coastal Sage
Scrub ESHA
Dudek (Applicant)
March 18,
2015,
Reconnaissance survey Rincon Consultants
(City)
April 2, 2015 Wildlife (nesting bird habitat
assessment) and botanical survey
Rincon Consultants
(City)
June 10, 2015 Botanical survey Rincon Consultants
(City)
March 26, 2021 Reconnaissance survey Rincon Consultants (City)

13 Meeting Date: City Council March 7, 2023

14 The proposed General Plan Amendment (GPA) would remove the ESHA designation within the GP/CLUP and provide the City with updated GP/CLUP maps of ESHA and Special Species on the Project site. Staff supports the GPA based on the data presented. Further, the City has a duty to ensure that the maps/figures within the General Plan are accurate.

Vesting Parcel Map

One component of the Project is to re-subdivide the property from 13 separate lots into four parcels to accommodate the development. Each of the proposed lots is of adequate size, shape, and dimensions to accommodate the intended development on each parcel. In addition, each lot has appropriate access and utilities to serve the development. Further, drainage/ storm water requirements can be satisfied as required.

The site is physically suitable for the type of development, given the gently sloping topography, its size, and is in close proximity to and has access to existing infrastructure to support the development; namely roads, waters, sewer, gas, electricity and communication utilities and bus routes, etc. The site is located adjacent to existing infrastructure located within the Camino Vista and Calle Koral rights-of-way.

Further, the design of the subdivision and the proposed improvements are unlikely to cause substantial damage or substantially and avoidably injure fish or wildlife or their habitat as borne out in the EIR analysis in conjunction with the implementation of the relevant mitigation measures and con ditions of approval. Additionally, the Project proposes to enhance the north side of Camino Vista with the provision of a public sidewalk to improve pedestrian safety.

The design of the subdivision or the type of improvements will not conflict with easements, acquired by the public at large, for access through or use of property within the proposed subdivision. Existing easements for roadway purposes along S. Los Carneros Road via Maya and Via Luisa and an existing landscape easement along Calle Koral will be vacated with the map as these easements are no longer needed.

Development Plan

Staff believes that the findings to support approval of the Development Plan can be made as the site is adequate in size, shape, location and physical characteristics to accommodate the density and intensity of development. Further, there are adequate services to serve the development, the adjacent roadways are adequate and properly designed to handle the development, and the Project is consistent with the General Plan designation for the property and meets the development standards of the residential medium -density zone. The rest of this section discusses the Project’s consistency with the General Plan and zoning, traffic/soil export, water availability, Housing Ac countability Act, public park design options , private recreational amenities, Quimby Act credit, Affordable Housing, and density bonus law parking concession.

14 Meeting Date: City Council March 7, 2023

15 General Plan and Zoning Consistency
The Project is consistent with the density and use envisioned by the General Plan land use designation, General Plan policies, and all of the DR-20 zoning district regulations. The site is designated for medium density residential development. As identified in Zoning Consistency Analysis in Attachment 4, Exhibit C, the Project components comply with all development standards (setbacks, building heights, common open space, and building coverage) for the DR-20 zone district.

General Plan Policy LU 8, Central Hollister Residential Development Area (CHRDA), i s specifically applicable to this site. As part of the CHRDA, residential development is required to have a density between 20 to 25 dwelling units/acre. As identified in Table 2 above, the Project density is 23.6 dwelling units/acre. Further, the objective of the CHRDA is:

To promote coordinated planning and development of designated medium - density residential sites in the Central Hollister area in order to create a quality livable environmental with appropriate design and amenities for future residents of this new residential neighborhood.

The applicant believes that the development has been designed in a coordinated manner with the adjacent Willow Springs I and II developments (LU 8.5) and with the performance standards identified in LU 8.6. Further, there is at least 50’ of separation from the closest residential building to both of the adjacent industrial uses and the Union Pacific Railroad Right-of-Way. This buffer is intended to provide separation so that the uses are compatible and will not impac t the viability of the existing uses. Additionally, the required 100’ Streamside Protection Area (SPA) buffer is observed by the project, per Conservation Element Policy CE 2.2. Staff believes that the Project is consistent with both the General Plan and applicable zoning district standards for the reasons outlined in Exhibits B (General Plan Consistency Analysis) and C (Zoning Consistency Analysis) of Attachment 4.

Traffic/Soil Export
A traffic study for the Project was originally prepared for the project, and subsequently updated in February and March of 2021, by Associated Traffic Engineers (ATE). The original traffic study provided a conservative evaluation of the potential traffic impacts of the project.

Actual trip generation and traffi c impacts would be less than presented therein. The traffic study identified existing traffic volumes on area roadways, which would increase at existing area intersections. However, even with these increases , the traffic volumes would remain within acceptable capacity ratings (LOS C or better).

The Project involves the exportation of 92,000 cubic yards of soil from the site at the beginning of construction for up to 27 weeks. The soil export activity would add temporary employee and heavy truck trips to t he area and to adjacent intersections. However, conditions of approval and/or mitigation measures are proposed that offset the impacts created by the development. These include but are not limited to the approval of a construction traffic management contro l plan to regulate hours, haul routes, and size of trucks to be used; repair of the City roadways that are damaged from the heavy truck usage and roadway life degradation, etc.

15 Meeting Date: City Council March 7, 2023

16 Water Availability
Water service to the Project site would be provided by the Goleta Water District (GWD). As the Project is part of the Willow Springs Project (Willow Springs I, Willow Springs II, and Heritage Ridge [formerly North Willow Springs]), the site is considered an existing customer of GWD and meets the criteria for an exemption as outlined in GWD Resolution No. 2014-

32. An updated Preliminary Service Water Letter was provided by the Goleta Water District on December 23, 2020. Recycled water is unavailable to be used as the closest recycled water line is more than 1 mile away at the intersection of Storke Road and Hollister Avenue.

Park Design Options
In response to the issues the applicant heard from both the Parks and Planning Commissions and EDC in the Spring of 2022 , the applicant developed two additional alternatives that were presented to the Planning Commission.

The alternatives along with the original design are summarized in Table 2 below along with the associated figures (Figures 5-7) for the three park designs.

Table 2
Park Design Comparison

Low Active Design
Moderately Active
Design (Original
Design but with larger
grassy field)

Most Active Design
Park Amenities

▪Trail System
▪Picnic Tables and BBQ
area
▪Tot Lot Playground w/
Cultural Theme
▪Chumash Village Play
Area w/ Ethnobotanical
Theme
▪Bike Racks
▪Benches throughout

8,712 SF Grassy Field
▪10 Fitness Stations
▪Trail System
▪Picnic Tables and BBQ
area
▪Tot Lot Playground w/
Cultural Theme
▪Chumash Village Play
Area w/ Ethnobotanical
Theme
▪Bike Racks
▪Benches throughout
8,712 SF Grassy Field
▪1/2 Basketball Court
▪Disc Golf (4 Targets)
▪10 Fitness Stations
▪Trail System
▪Picnic Tables and BBQ area
▪Tot Lot Playground w/ Cultural
Theme
▪Chumash Village Play Area w/
Ethnobotanical Theme
▪Bike Racks
▪Benches throughout
~6,623 SF Grassy Field
Consistency with
General Plan:
-Service area radius within

0.5 miles
-Typical size less than 10
acres
-Easily accessible to
surrounding neighborhood
population
-parking not required but
may be provided
-to include equipment,
picnic tables, lawn or
grassy area and benches

Yes, to all except no
fitness equipment

Yes, to all

Yes, to all
Long Term
Maintenance Cost

$1,014,284

$1,054,602

$1,081,480
16 Meeting Date: City Council March 7, 2023

17 (approximated)

BBCI Input

Supportive Supportive Supportive
EDC Input Supportive Supportive Not Supportive

Figure 5 – Low Active Park Design (Option 1)

17 Meeting Date: City Council March 7, 2023

18 Figure 6– Moderate Active Park Design (Option 2)

18 Meeting Date: City Council March 7, 2023

19 Figure 7 – Most Active Park Design (Option 3)

Although Options 1 and 2 are considered “less active” parks because they do not have the basketball court or disc golf course, it should be noted that both these two options have a larger grassy play field than Option 3, by over 2000 square feet, which could be made available for football games, soccer practices (unofficial sizes) and other field play sports , which is a desirable active recreational element for all ages. EDC does not support Option 3 and the Planning Commission has recommended Option 2, the Original Design for the reasons mentioned above.

19 Meeting Date: City Council March 7, 2023

20 For context, within a 0.5 miles radius of the proposed public park, there will be a total of 1,132 residential units, with the majority of them being attached units with minimal private yard spaces. These units include Willow Springs I (235 units), Willow Springs II (100 units), Village at Los Carneros (465 units) and Heritage Ridge (332 units). At approximately 2.72 persons per household (ref: California Department of Finance), there would be over 3,079 people living near the park site once the Heritage Ridge Project is constructed. In addition, given that the Project site is located in proximity to many businesses, local employees would be able to use the park as well.

Private Open Space/Recreational Amenities on Lots 1,2, and 4 In addition to the public park, there are private amenities for the residents of the affordable units and market-rate units. The private open space/recreational amenities associated with the Affordable Units’ parcels and the Market-Rate Units’ parcel as follows:

Parcels 1 & 2 (Affordable) Parcel 4 (Market Rate)
Senior Recreation Center
 Rose & Herb Garden Pool
 Seating Area Spas (x2)
Family Fire Pits (x2)
 Recreation Center BBQ/Picnic Areas
 Community Vegetable Garden Tot Lot
 Active Turf Area (~3,600sf)
 Tot Lot
 BBQ/Picnic Area (x2)
 Dog Relief Lawn
 Pickleball Court
 Bike Parking (20 spaces)
 Decomposed Granite Pathway

Satisfaction of Quimby Act Requirements (Government Code Section 66477)

The Quimby Act requires subdividers of residential projects to either dedicate land for parks and recreational purposes or pay an equivalent in lieu fee. As part of the Project, the applicant will be dedicating an approximately 2-acre park to the City as specified in the City’s General Plan and has requested that the land value and proposed recreational facilities described above be accepted to satisfy this requirement. The value of these items will likely be at least equal value if not more than the equivalent in -lieu fee, that could be charged if the park dedication and construction was not a part of the project.

The current City adopted Quimby rate (FY 21 -22) for non- single family residential units is $13,340 per residential unit, which for the 228 market rate units would be $3,041,520 (1228 units X $13,340/unit). Based on a City accepted appraisal, the value of the land is $1,610,000. This leaves a remainder balance of $1,431,520 for the cost of the park improvements to not exceed the Quimby In Lieu fee. It is likely that the cost of the

1 Development Impact Fees are waived for the 104 affordable units as Beneficial Project per City Resolution No. 19 -43 20 Meeting Date: City Council March 7, 2023

21 improvements of any of the proposed park designs discussed above will be equal to or exceed t he $1.4 million balance given the range of amenities and current construction estimates. The actual Quimby in-lieu fee rate to be used will be the one in effect at the time of map recordation, and the actual construction costs will not be known until the p ark is constructed.

The park will be constructed as part of the final phase of development of the market rate units which is anticipated to happen 2 -3 years after map recordation. Staff does not have the exact information regarding the actual costs for construction, and if the costs exceed the value of the Quimby in -lieu fee at recordation (less the $1.6 million land value costs), it is possible that the City will need to pay the difference. If the construction costs are less than the value of the Quimby in-lieu fee at recordation (less the $1.6 million land value costs), then the applicant would pay the difference.

Further, the applicant will be depositing the full amount of the required Quimby in-lieu fee as collateral to guarantee the provision of the affordable housing units as discussed below, and the $1.4 million portion of the Quimby in -lieu fees would be reimbursed when certain construction milestones are met and proper documentation is provided after HASBARCO has acquired Lots 1 and 2 as outlined in Condition No. 17 of the Vesting Tentative Map Resolution (Exhibit D of Attachment 3). Condition 17 also describes the list of items that are reimbursable and not reimbursable.

Affordable Housing
In addition to the 228 market rate units, Redtail and Owners (collectively referred to as “Heritage Ridge”) have proposed to provide 102 affordable units plus two manager units .

Heritage Ridge will not construct these units and permits for the 228 market rate units will not be contingent upon the construction of the affordable units. Heritage Ridge proposes to have HASBARCO buy the affordable lots (Lots 1 and 2), construct the affordable units, and operate the units. On July 29, 2021, Heritage Ridge and HASBARCO entered into a Purchase and Sale Agreement and Joint Escrow Instructions for Family Affordable Parcel and Purchase, as amended, and Sale Agreement for Senior Affordable Parcel, as amended (hereinafter referred to as the “PSA”). Under the PSA, HASBARCO will purchase Lots 1 and 2 no later than June 1, 2025, regardless of whether it has received LIHTC funding.

While the PSA provides for certain obligations, they are beyond the City’s control, In order to obtain greater certainty that the affordable units will be constructed, he City’s Development Plan conditions also require sale by Heritage Ridge and purchase by HASBARCO by June 1, 2025 and provide for backup solutions if the purchase and sale does not occur. the City, H eritage Ridge , and HA SBARCO have agreed to the following framework:

A. In all events, H eritage Ridge must sell to H ASBARCO, and H ASBARCO must buy from Heritage Ridge, the affordable housing lots by June 1, 2025. HASBARCO must develop the affordable units in accordance with the Conditions of Approval.

21 Meeting Date: City Council March 7, 2023

22 B. If for any reason H eritage Ridge does not transfer the affordable housing lots to HASBARCO by June 1, 2025, several things may happen, including but not limited to, that at any time thereafter, the City may take action to revoke the D evelopment Plan entitlement, in accordance with the Goleta Municipal Code, for failure to adhere to the conditions of approval. The City may also retain the Quimby Fee Credit, which is the fee Heritage Ridge would have paid to meet the Quimby Fee requirement under the VTM Conditions. Upon the park being completed by Heritage Ridge and delivered to the City, the Quimby Fee Credit will be converted to a security, to be held in the City’s Affordable Housing fund, to ensure the development of the affordable housing units. Heritage Ridge will be entitled to the return of the Quimby Fee Credit either:

(1) Upon Heritage Ridge’s construction of all of the affordable units themselves, or (2) If Heritage Ridge transfers the affordable lots to a replacement affordable housing developer.

C. As to the former option, if HR determines to build the affordable units themselves, they must do so and obtain all related certificates of occupancy within seven years of the failure to convey the affordable lots to HA. If HR also fails to mee t this condition, the Quimby Fee Credit held in the City’s Affordable Housing fund will be forfeited by Heritage Ridge and thereafter available for use by the City in furtherance of its affordable housing efforts, including efforts related to the effects from the loss of not receiving the affordable units for this Project 10 years after entitlement.

D. As to the latter option, if H eritage Ridge attempts to find a replacement affordable housing developer, they must try to do so within one year of the failure to convey the affordable lots to HASBARCO. In that event, the City will have the right to consent to the transfer of the affordable housing developer (the City cannot unreasonably withhold consent ) (“Transferee”). That consent is s ubject to the replacement developer providing a timeline of construction for the affordable units that the City finds reasonable and entering into an agreement with the City relating to the construction of those units, including with respect to the timelin e, as well as any outstanding affordable housing covenants and agreements, including but not limited to those covenants and agreements that Heritage Ridge and HASBARCO are subject to under the Conditions of Approval.

Heritage Ridge and HASBARCO will ente r into an Affordability Control Covenant and Regulatory Agreement that will provide for the affordability of the units for 55 years , which will begin to run only when the units are occupied . In addition, the Agreement will specify that, of the 102 affordable units, at a minimum, 17 units must be reserved for tenants who qualify for the very low-income category under the State Income Limits and 85 must be reserved for tenants who qualify for the low-income category under the State Income Limits (“Minimum Affordability Levels”). A draft of the agreement is provided as Exhibit 3 to Exhibit D of Attachment 3. The agreement will initially be entered into with Heritage Ridge, but the agreement will transfer to HASBARCO in the future once the purchase and sale of Lots 1 and 2 are effectuated. HASBARCO may need certain amendments to the agreement in order to meet certain federal and state tax credit funding requirements. Staff seeks Council direction to authorize the City Manager and City Attorney to am end the agreement 22 Meeting Date: City Council March 7, 2023

23 accordingly to in order to facilitate HASBARCO’s funding requirements as well as preserve the City’s interest in obtaining affordable housing.

In addition, the City will provide two grants, totaling $1 million, to HASBARCO: $500,000 towards the parcel on which the family units will be constructed and $500,000 towards the parcel on which the senior units will be constructed. The amount of these grants represents a majority of the City’s Affordable Housing In Lieu Funds. The grants will be shaped as forgivable loans in order to facilitate HASBARCO’s ability to leverage greater funds for the affordable units. However, Council may direct staff to structure this as a true loan so that the City would be owed residual rents after senior loans are paid back. A form of loan agreement is attached as Attachment 7 for Council’s approval but does not reflect the forgivable nature of the loan and other terms that would comport with federal and state tax credit financing requirements. Staff seeks Council authorization to approve the form of the loan agreement attached to this staff report and authorize the City Manager and City Attorney to amend the agreement as necessary to ensure that the loans are forgivable and comport with federal and tax credit funding requirements.

Density Bonus Law Concession – Reduction in Parking
Lastly, if the Project delivers the affordable housing units, the Project qualifies for a concession under the Density Bonus Law. Heritage Ridge has requested the concession of providing fewer parking spaces than required for the market rate units from 542 to 494 parking spaces. However, as described above, there is risk that the affordable units will not be constructed. If at the time th e market rate units are completed and the affordable units have not commenced construction, the market rate developer will be required to provide the full amount of parking for the market rate units. Heritage Ridge has proposed that the additional 31 parking spaces be constructed on either Lots 1 or 2. An updated site plan would be required to show the additional parking and a Substantial Conformity Determination (SCD) would need to be processed and approved. The Vesting Tentative Map and Development Plan Condition includes language to address this issue.

Public Input

As Council is aware, many comments have been received during the course of review on this project regarding habitat issues, housing needs, and using union labor. The Environmental Defense Center (EDC) has been vocal about the treatment of the streamside protection area, habitat and vegetation on the site . EDC, representing Santa Barbara Audubon Society, Santa Barbara Urban Creeks Council, Citizens Planning Association, Sierra Club, Santa Barbara-Ventura Chapter, The Goodland Coalition, has entered into an agreement with the Applicant for certain native vegetation, to be planted in the 100’ Streamside Protection buffer affecting a small portion of the northeast corner of the site and the Lot 3, the lot that Heritage Ridge will develop as a public park and de dicate to the City. a habitat design/plant palette on the project site, and maintenance provisions regarding then native plant palette for the life of the project on the entire site including Lot 3.

After the Planning Commission’s recommendation of approval of this Project, in December 2022, EDC and Heritage Ridge requested that the City add certain conditions of approval that incorporate their agreement for certain landscaping in the SPA buffer and park. Public 23 Meeting Date: City Council March 7, 2023

24 Works staff pointed out that the establishment and maintenance of these native plants to the specifications requested by Heritage Ridge and EDC would incur costs that are not normally associated with a neighborhood park. In response to staff’s concerns about the cost to the City and the expenditure of public funds to associated with the installation, establishment, and ongoing maintenance of the native vegetation agreed to by EDC and Heritage Ridge, Heritage Ridge has agreed to install the native materials, maintain the park for 90 days after the City accepts title, contribute $25,000 towards plant replacement and monitoring for the first five years, , and contribute $125,000 towards the long term maintenance of the native vegetation. Heritag e Ridge requests that the City also contribute $125,000 into the maintenance fund, which the City can do at its expenditure allocation for parks maintenance during its annual budget process. However, staff has written the Conditions of Approval to reflect the City’s contribution of $125,000 towards this maintenance fund so that after the City accepts title of the park, the maintenance budget for native vegetation will total $250,000.Condition Numbers 4, 26, 47 (b), 49(K) (i), and 50 (J) found in the Develop ment Plan Conditions of Approval (Exhibit D of Attachment 4) reflect these requests.

CONCLUSION

As stated above, the proposed residential Project is consistent with the applicable land use designations (General Plan and Zoning) adopted for the site in terms of use, density, and the development standards (i.e., setbacks, building coverage, open space requirements, building heights, etc.). The Project will provide 10 2 affordable rental units for both seniors and families voluntarily and 228 market -rate re ntal units at a density that is within the designated 20 -25 units per acre for the Affordable Housing Opportunity Site within the Central Hollister Corridor.

Based on the site -specific biological study and the field work/peer review by Rincon Consultants, staff supports the request to revise Figures 3 -5 and 4-1 of the General Plan.

The General Plan Amendment would create maps that would accurately reflect the type of plant community (or lack thereof) on the site.

Currently, the proposed Project site is designated as an Affordable Housing Opportunity site and is included in the City’s Housing Element Technical Appendix list of sites to accommodate the City’s Regional Housing Needs Allocation (RHNA). Affordable housing units are not a requirement of this Project under the previous zoning code, Article III, under which the Project is being processed. The applicant has voluntarily proposed the inclusion of a 102-unit affordable housing development at the low- and very low-income range for both Seniors and Families (31% of the total units) with two manager units . The Heritage Ridge project has been included as a site suitable for residential development in the recent adopted Housing Element 6 th cycle update. Th ese units will also contribute to an increase in local housing stock for which there is a need. Additionally, the Project will complete the third phase of the Willow Springs complex, as planned in the General Plan.

Further, t his Project will complete the Central Hollister Corridor housing plan outlined in General Plan Land Use Policy LU 8 and will provide affordable and market rate housing in keeping with both the Land Use and Housing Element policies. Further, the Project observes 24 Meeting Date: City Council March 7, 2023

25 the 100’ SPA buffer from both the 2015 boundary at the time of the release of the NOP, and also in the 2021 boundary, consistent with Conservation Element Policy CE 2.2. The Project meets all zoning standards and General Plan policies as outlined in the General Plan Consistency Analysis and Zoning Consistency provided as Exhibits to Attachments 3 and 4 noted below . The Project does not requ ire any zoning modifications and meets building height, maximum lot coverage, setbacks, open space, landscaping and parking (with State Density Bonus allowance) requirements.

The EIR prepared for the Project sufficiently analyzes the Project’s potentially significant environmental impacts as well as a range of feasible alternatives to address how those effects can be reduced to a less than significant level. Further, the environmental impacts and the public comments received for this Project have been studied and analyzed in depth, as outlined in the revised Final EIR dated October 2022. While the Project has been found to have significant unavoidable impacts in the areas of cultural resources (cumulative), noise (construction), and solid waste (project level/operational and cumulative), the majority of the issues have either been found to not be significant or can be mitigated to a level of less than significant. The Project would be required to implement 24 mitigation measures: 1 mitigation measure for aesthetics (lighting), 5 mitigation measures for biological resources, 8 mitigation measures for cultural resources and tribal cultural resources, 1 mitigation measure for geology and soils, 1 mitigation measure for hydrology and water quality, 7 mitigation measures for noise, and 1 mitigation measure for utilities and service systems (solid waste).

The DRB has reviewed the Project four times and has worked with the applicant to come to a desirable architectural style and overall design that fits within the surrounding neighborhood. The DRB has found that the current design of all of the units is attractive, has been well-designed, and will add to the design aesthetic of the community.

All of the findings can be made to support approval of the Vesting Tentative Map and the Development Plan. The reasons these findings can be made are outlined in Attachment 3 and 4 and center on Project design; the inclusion of affordable housing; the dedication of a park for public use; and the Project meeting General Plan policies and zoning standards.

Staff has prepared findings and conditions for the Council consideration along with resolutions required for action in Attachments as listed below and recommends approval.

PUBLIC NOTICE

On February 23, 2023, public notice was published in the Santa Barbara Independent and notices were mailed to owners and tenants within a 500-foot radius of the site. In addition, the site was posted on February 20, 2023.

GOLETA STRATEGIC PLAN:

The following Strategic Plan goals and policies are applicable to this project:

2.2 Strategic Goal: Support programs that enhance quality of life in the Goleta community such as recreation, public safety, human services, and cultural arts. 25 Meeting Date: City Council March 7, 2023

26 Objective 2.2.2. Explore opportunities for increasing the amount of active parks and open space, emphasizing underserved areas of the community and areas designated for future new residential development.

Objective 2.2.3. Ensure that new parks and recreational amenities for the public are provided concurrent with new development.

Objective 2.2.7. Collaborate with representatives of the Chumash to assess the development of a Chumash cultural center in Goleta.

4.7 Strategic Goal: Support organizations, programs, and policies that facilitate affordable housing for Goleta workforce.

Objective 4.7.2. Implement inclusionary housing policies for rental housing that meet requirements under state law.

FISCAL IMPACTS:

The case processing costs associated with th is Project are being are being borne by the Applicant.

ALTERNATIVES:

If the City Council does not approve some or all of the Project, the options are:

1. Certify the EIR only; or

2. Certify the EIR and approve the General Plan Amendment; or

3. Not certify the EIR but approve the General Plan Amendment; or

4. Express intent to deny some or all components of the Project (GPA, VTM, and DP), direct staff to prepare findings for denial and continue to item to a date certain for action on the denial Resolutions.

Reviewed By: Legal Review By: Approved By:

___________________ ___________________ _________________ Kristine Schmidt Megan Garibaldi Robert Nisbet
Assistant City Manager City Attorney City Manager

ATTACHMENTS:

1. CEQA Resolution
Exhibit A – Link to EIR, Appendices and MMRP

2. General Plan Amendment (GPA) Resolution
Exhibit A – Amended GP/CLUP Figure 3-5
Exhibit B - Amended GP/CLUP Figure 4-1

26 Meeting Date: City Council March 7, 2023

27 3. Vesting Tentative Map (VTM) Resolution
Exhibit A – Vesting Tentative Map
Exhibit B – General Plan Consistency analysis
Exhibit C – Zoning Consistency Analysis
Exhibit D – Conditions of Approval
Exhibit 1 Reciprocal Easement Agreement
Exhibit 2 Agency Letters
Exhibit 3 Draft Affordable Housing Regulatory Agreement

4. Development Plan (DP) Resolution
Exhibit A – Development Plan - Given the size of the plans, the plans can be accessed at: https://www.cityofgoleta.org/home/showpublisheddocument/27797 Exhibit B – General Plan Consistency Analysis
Exhibit C – Zoning Consistency Analysis
Exhibit D –Conditions of Approval
Exhibit 1 – Agency Letters

5. Project Plans – Given the size of the plans, the plans can be accessed at:
https://www.cityofgoleta.org/home/showpublisheddocument/27797

6. Response to Mr. Tsai’s Planning Commission comment letter

7. Draft Land Acquisition Loan Agreement

8. Staff Power Point Presentation

27 ATTACHMENT 1

Heritage Ridge Residential Project
CEQA Resolution
28 Attachment 1
Heritage Ridge CEQA Resolution No. 23-___

City Council Resolution No. 23- __
RESOLUTION NO. 23-______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GOLETA, CALIFORNIA: 1) ADOPTING ENVIRONMENTAL FINDINGS PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, 2) CERTIFYING

THE HERITAGE RIDGE RESIDENTIAL PROJECT ENVIRONMENTAL
IMPACT REPORT (SCH No. 2015041014), 3) ADOPTING THE
MITIGATION MONITORING AND REPORTING PROGRAM, AND 4)

ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS
WHEREAS, on May 20, 2014, the Towbes Group submitted an application requesting approval of a General Plan/Local Coastal Land Use Plan (GPA/CLUP) amendment (GPA) to the Open Space Element and Conservation Element ; a Vesting Tentative Map ; and a Development Plan with Modification, for th e development of 360 residential apartments and associated improvements on the parcels east of South Los Carneros Road and north of Camino vista Road, APNs 073-060-031 through -043; and WHEREAS, pursuant to Section 21067 of the Public Resources Code, and Section 15367 of the State CEQA Guidelines (Cal. Code Regs., tit. 14, §§ 15000 et seq.), the City of Goleta is the lead agency for the proposed Project; and WHEREAS, in accordance with State CEQA Guidelines Section 15082, on April 6, 2015, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation (“NOP”) stating that an Environmental Impact Report (State Clearinghouse #2015041014) would be prepared; and WHEREAS nine comment letters were received in response to the NOP; and WHEREAS pursuant to Public Resources Code Section 21083.9 and State CEQA Guidelines Sections 15082(c) and 15083, the City held a duly noticed Scoping Meeting on April 29, 2015 to solicit comments on the scope of the environmental review of the proposed Project and four comments were received; and
WHEREAS a Draft Environmental Impact Report (“Draft EIR”) was prepared, incorporating comments received in response to the NOP; and WHEREAS pursuant to State CEQA Guidelines Section 15087(e), the Draft EIR was circulated for at 52-day public review and comment period from June 17, 2016 to August 8, 2016; and
WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines Section 15086, and held an Environmental Hearing Officer meeting on July 20, 2016,to receive verbal public comments on the Draft EIR, where one comment was received; and
WHEREAS the City received fourteen written comment letters on the Draft EIR; and 29 Attachment 1
Heritage Ridge CEQA Resolution No. 23-___

City Council Resolution No. 23- __
WHEREAS in March of 2020, Redtail Multifamily Land Development, LLC became the applicant and took over Project processing, and also entered into a partnership agreement with the Housing Authority of the County of Santa Barbara (HASCARBO); and

WHEREAS the current owners are FLT Heritage Ridge TG, LLC and GF Frontier, LLC, and the applicant/permittees are Red Tail Multifamily Land Development, LLC and HASCARBO; and
WHEREAS in January 2021, the Project was revised to include an affordable housing component; reduce the total number of housing units from 360 to 332 units; provide increased right-of-way along Los Carneros Road, resulting in a building setback shift along this roadway; a request for a Streamside Protection Area (SPA) buffer reduction of up to 33 feet in the northeast corner of the Project site; and address the updated CEQA Guidelines and thresholds; and
WHEREAS the revised Heritage Ridge Residential Project (the “Project”) has been redesigned to develop 332 housing units (10 2 affordable with 2 manager units , and 228 market-rate) in eight buildings as well as two additional recreational buildings and a public park on a 17.36-gross acre site within the Inland Area of the City of Goleta; and WHEREAS the Project is on a currently vacant site north of Camino Vista and east of South Los Carneros Road, comprised of Assessor’s Parcel Numbers 073 -060-031 through -043, in the City of Goleta, in Santa Barbara County; and WHEREAS the Project requires approvals of a General Plan Amendment (14-049- GPA), Development Plan (14-049-DP) with a parking concession as a State Density Bonus project, and Vesting Tentative Map (14-049-VTM); approval from the Design Review Board (14-049-DRB); approval of a road easement vacation and acquisition; a two-acre park acquisition (a 1.85 acre park and a 0.15 acre easement over 13 public parking spaces) , and approval of a Park Fee credit for the Affordable Housing Units; and WHEREAS, on April 29, 2021, to address updated CEQA requirements and the redesign of the Project, a Revised Draft EIR was prepared and initially released for a 45- day public review and comment period; and
WHEREAS, shortly after the initial release of the Revised Draft EIR for public review, it was determined that the public comment period should be restarted due to a noticing error as one of the revised topic areas was not listed in the notice . After correcting the notice, the Revised Draft EIR was recirculated for a 45 -day public review and comment period from May 14, 2021 to June 28, 2021 and the City held an Environmental Hearing Officer meeting on June 16, 2021, where six comments were received; and WHEREAS the City received seven written comment letters o n the Revised Draft EIR; and
WHEREAS the Revised Draft EIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas:
30 Attachment 1
Heritage Ridge CEQA Resolution No. 23-___

City Council Resolution No. 23- __
aesthetics, biological resources, cultural resources, geology and soils, hydrology and water quality, and tribal cultural resources; and
WHEREAS the Revised Draft EIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to cumulative cultural resource impacts, construction noise (short term project level), and solid waste (project level and cumulative); and
WHEREAS, in accordance with State CEQA Guidelines Section 15085, a Notice of Completion was prepared and filed with the Office of Planning and Research on April 29, 2021; and
WHEREAS, as required by State CEQA Guidelines Section 15087(a), the City provided Notice of Availability of the Revised Draft EIR to the public at the same time that the City sent Notice of Completion to the Office of Planning and Research on April 29, 2021; and
WHEREAS, during the public comment period, copies of the Revised Draft EIR and technical appendices were available for review and inspection on the City’s website; and WHEREAS, subsequent to public review of the Revised Draft EIR, the grading plan was revised to reduce soil export, the site plan was revised to reduce total parking, and increase open space in order to achieve a 100 -foot buffer from the Los Carneros Creek Streamside Protection Area; and
WHEREAS, pursuant to Public Resources Code Section 21092.5, the City provided copies of its responses to commenting public agencies at l east ten (10) days prior to the City’s Planning Commission initially planned consideration of the Final EIR on February 28, 2022; and
WHEREAS, at the request of the public in order to allow the public ample time to review the Final EIR, the City chose not to hold the February 28, 2022 Planning Commission hearing and continued the matter to March 28, 2022; and WHEREAS the Planning Commission commenced review of the project and started taking public comments regarding the adequacy of the Final EIR and the m erits of the project on March 28, 2022, and April 25, 2022; and
WHEREAS the Planning Commission continued the review from the April 25, 2022 to allow staff time to respond to the verbal and written comments received; and WHEREAS the City has revised the Final EIR to add a Preface to the beginning of the Final EIR that summarizes the changes and responds to late comments received 10 months after the close of the public comment period; and WHEREAS, on February 15, 2022 and October 14, 2022, the City released the initial and revised Final EIR (“Final EIR”), which consists of the Draft EIR, Revised Draft EIR, all technical appendices prepared in support of the Draft EIR and Revised EIR, all written 31 Attachment 1
Heritage Ridge CEQA Resolution No. 23-___

City Council Resolution No. 23- __
comment letters received on the Draft EIR and Revised Draft EIR, written responses to all written comment letters received on the Draft EIR and Revised Draft EIR, and errata to the Draft EIR, Revised Draft EIR and technical appendices; and WHEREAS the “EIR” consists of the Final EIR and its attachments and appendices, as well as the Draft EIR and its attachments and appendices, and the Revised Draft EIR and its attachments and appendices (as modified by the Final EIR); and WHEREAS all potentially significant adverse environmental impacts were sufficiently analyzed in the EIR; and
WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision on the Project; and
WHEREAS all of the requirements of the Public Resources Code and the State CEQA Guidelines have been satisfied by the City in connection with the preparation of the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and WHEREAS the EIR prepared in connection with the Project sufficiently analyzes the Project’s potentially significant environmental impacts , and the EIR analyzes a range of feasible alternatives to address whether these effects can be reduced to a level of less than significant; and
WHEREAS the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and WHEREAS the City finds that environmental impacts that are identified in the EIR as less than significant and do not require mitigation are described in Section II of Exhibit A; and
WHEREAS the City finds that environmental impacts that are identified in the EIR as less than significant with incorporation of mitigation measures are described in Section III of Exhibit A; and
WHEREAS the City finds that the environmental impacts of the Project that are identified in the EIR as significant and unavoidable are described in Section IV of Exhibit A; and
WHEREAS the cumulative impacts of the Project identified in the EIR, and set forth herein, are described in Section V of Exhibit A; and
WHEREAS the potential significant irreversible environmental changes that would result from the proposed Project identified in the EIR, and set forth herein, are described in Section VI of Exhibit A; and
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WHEREAS the existence of any growth -inducing impacts resulting from the proposed Project identified in the EIR, and set forth herein, are described in Section VII of Exhibit A; and
WHEREAS alternatives to the proposed Project that could potentially reduce the Project’s environmental impacts are described in Section VIII of Exhibit A; and WHEREAS a statement of overriding considerations is set forth in Section IX of Exhibit A; and
WHEREAS all the mitigation measures identified in the EIR that are necessary to reduce the potentially significant impacts of the proposed Project to a level of less than significant are set forth in the Mitiga tion Monitoring and Reporting Program (MMRP) in Exhibit B to this Resolution, attached hereto and incorporated herein; and WHEREAS, on November 14, 2022, the Planning Commission conducted a duly noticed public hearing regarding the adequacy of the Final EIR, at which time all interested parties were given the opportunity to be heard; and
WHEREAS, on November 14, 2022, the Planning Commission on a 5 -0 vote recommended that the City Council adopt environmental findings pursuant to the CEQA, certify the Heritage Ridge Final EIR, adopt the Mitigation Monitoring and Reporting Program, and adopt a Statement of Overriding Considerations; and WHEREAS, on March 7, 2023, the City Council conducted a duly noticed public hearing regarding the adequacy of the Final EIR, at which time all interested parties were given the opportunity to be heard; and
WHEREAS, prior to taking action, the City has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including but not limited to the EIR, and all oral and written evidence presented to it during all meeting s and hearings; and
WHEREAS the EIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and WHEREAS no comments made in the public hearings conducted by the City and no additional information submitted to the City have produced substantial new information requiring recirculation of the EIR or additional environmental review of the Project under Public Resources Code Section 21092.1 and State CEQA Guidelines Section 15088.5; and WHEREAS all other legal prerequisites to the adoption o f this Resolution have occurred.

NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF GOLETA:

SECTION 1. The above recitals are true and correct and incorporated her ein by reference.
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SECTION 2. The City Council hereby finds that it has been presented with the EIR, which it has reviewed and considered, and further finds that the EIR is an accurate and objective statement that has been completed in full compliance with CEQA and the State CEQA Guidelines. The City Council finds that the EIR reflects the independent ju dgment and analysis of the City. The City Council declares that no evidence of new significant impacts or any new information of “substantial importance” as defined by State CEQA Guidelines Section 15088.5, has been received by the City after circulation of the Revised Draft EIR that would require recirculation. Therefore, the City Council hereby recommends City Council certify the EIR based on the entirety of the record of proceedings.

SECTION 3. The City Council hereby adopt the “CEQA Findings of Fact” pursuant to State CEQA Guidelines Section 15091, and the Statement of Overriding Considerations pursuant to State CEQA Guidelines Section 15093, both of which are attached hereto as Exhibit A and incorporated herein by this reference.

SECTION 4. Pursuant to Public Resources Code Section 21081.6, the City Council adopt the Mitigation Monitoring and Reporting Program, attached hereto as Exhibit B and incorporated herein by this reference, and make implementation of the Mitigation Measures contained in the Mitigation Monitoring and Reporting Program a condition of approval of the Project. In the event of any inconsistencies between the Mitigation Measures set forth in the EIR or the Findings of Fact and the Mitigation Mo nitoring and Reporting Program, the Mitigation Monitoring and Reporting Program shall control.

SECTION 5. The documents and materials that constitute the record of proceedings on which this Resolution has been based are in the custody of the City Clerk, City of Goleta, and are located at 130 Cremona Drive, Suite B, Goleta, California 93117. This information is provided pursuant to Public Resources Code Section 21081.6.

SECTION 6. City Council to direct City staff to cause a Notice of Determination to be filed and posted with the County Clerk and the State Clearinghouse within five working days of the adoption of this Resolution.

APPROVED AND ADOPTED this ___ day of _______, 2023.
________________________________

PAULA PEROTTE
MAYOR
ATTEST:

________________________________

DEBORAH LOPEZ

CITY CLERK

APPROVED AS TO FORM:

________________________________

MEGAN GARIBALDI

CITY ATTORNEY

34 Attachment 1
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City Council Resolution No. 23- __

COUNTY OF SANTA BARBARA ) ss.

CITY OF GOLETA )

I, DEBORAH LOPEZ, City Clerk of the City of Goleta, California, DO HEREBY CERTIFY that the foregoing Resolution No. 23- __ was duly adopted by the City Council f the City of Goleta at a regular meeting held on the ___ day of _______, 20 23 by the following vote of the City Council:

AYES:

NOES:

ABSENT:

(SEAL)

_________________________

DEBORAH LOPEZ

CITY CLERK

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EXHIBIT A

CEQA FINDINGS OF FACT
Under the California Environmental Quality Act (Pub. Resources Code, § § 21000 et seq.) (CEQA), public agencies shall not approve or carry out a project for which an environmental impact report (EIR) has been certified that identifies one or more significant adverse environmental effects of a project unless the public agency makes one or more written Findings for each of those significant effects, accompanied by a brief explanation of the rationale for each Finding ( State CEQA Guidelines [Cal. Code Regs., tit. 14, §§ 15000 et seq.], § 15091). This document presents the CEQA Findings of Fact made by the City of Goleta, in its capacity as the CEQA lead agency, regarding the Heritage Ridge Residential Project (Project), evaluated in the Draft Environmental Impact Report (“Draft EIR”) , Revised Draft EIR, and Final Environmental Impact Report ( Final EIR) for the Project.

SECTION I.

INTRODUCTION
Public Resources Code section 21002 states that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” Section 21002 further states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significan t effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.”
Pursuant to section 21081 of the Public Resources Code, a public agency may only approve or car ry out a project for which an EIR has been completed that identifies any significant environmental effects if the agency makes one or more of the following written finding(s) for each of those significant effects accompanied by a brief explanation of the rationale for each finding:

1. Changes or alterations have been required in, or incorporated into, the project which mitigate or avoid the significant effects on the environment.

2. Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency.

3. Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.

As indicated above, section 21002 requires an agency to “avoid or substantially lessen” significant adverse environmental impacts. Thus , mitigation measures that “substantially lessen” significant environmental impacts, even if not completely avoided, satisfy section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 [“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”]; Las Virgenes Homeowners Fed., Inc. v . County of Los Angeles 36 Attachment 1
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(1986) 177 Cal. App. 3d 300, 309 [“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”].)
While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (Pub. Res ources Code, § 21002.1(c) [if “economic, social, or other conditions make it infeasible to mitigate one or more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agency”]; see also State CEQA Guidelines, § 15126.6(a) [an “EIR is not required to consider alternatives which are infeasible”].) CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.” (Pub. Res ources Code, § 21061.1.) The State CEQA Guidelines add “legal” considerations as another indicia of feasibility. (State CEQA Guidelines , § 15364.) Project objectives also inform the determination of “feasibi lity.” (Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828 -829.) “‘[F]easibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technolog ical factors.” ( City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) “Broader considerations of policy thus come into play when the decision-making body is considering actual feasibility[.]” (Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 (“Native Plant”); see also Pub. Resources Code, § 21081(a)(3) [“economic, legal, social, technological, or other considerations” may justify rejecting mitigation and alternatives as infeasible] (emphasis added).) Environmental impacts that are less than significant do not require the imposition of mitigation measures. ( Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal. App.3d 1337, 1347.)
The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their con stituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced.” ( Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project’s environmental alternatives is not required; rather, the requirement is that sufficient information be produced “to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” Outside a gencies (including courts) are not to “impose unreasonable extremes or to interject [themselves] within the area of discretion as to the choice of the action to be taken.” ( Residents Ad Hoc Stadium Com. v. Board of Trustees (1979) 89 Cal.App.3d 274, 287.)
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SECTION II.

FINDINGS REGARDING ENVIRONMENTAL

IMPACTS NOT REQUIRING MITIGATION
The City Council hereby finds that the following potential environmental impacts of the Project are less than significant and therefore do not require the imposition of Mitigation Measures.

A. AESTHETICS

1. Scenic Vistas
Threshold: Would the Project have a substantial adverse effect on a scenic vista? Finding: Less than significant. (Final EIR, pp. 4.1-9 through 4.1-15.) Explanation: The Project would convert a vacant 17.36 -gross acre site into a multi-family housing complex. Three two -story apartment buildings would be located in the northwestern portion of the site. Four three -story apartment buildings would be located in the northeastern portion of the site. Three two - to three- story apartment buildings would be located in the southwest portion of the site. The building closest to Los Carneros Road, which was originally proposed to be three stories in height, was reduced to two stories in height in response to feedback from City staff rega rding potential impacts to scenic views of the Santa Ynez Mountains from South Los Carneros Road. All buildings onsite would have a maximum height of 35 feet. The 35-foot height is consistent with height limits as measured pursuant to the City’s Inland Zoning Ordinance.

Construction on the Project site would affect two designated Los Carneros Road scenic views. Figure 4.1-4 of the Final EIR maps the locations of photo simulations from Los Carneros Road, with respect to the Project site. Figures

4.1-5, 4.1 -6, and 4.1 -7 of the Final EIR present pho to simulations for the Project, at the scenic northward view from South Los Carneros Road near Calle Koral, the scenic southward view from the South Los Carn eros Road overpass of U.S. 101 , and a similar scenic south ward view from South Los Carneros Road just south of the overpass. These figures compare: existing conditions to the proposed conditions with five years of growth in landscaping at each viewpoint.

South Los Carneros Road near Calle Koral currently afford s a view of the foothills and Santa Ynez Mountains, scenic resources that are partially obstructed by scrub vegetation and trees in the UPRR ROW and on the west side of South Los Carneros Road. The two-story buildings in the northwestern portion of the sit e and the two - and three-story buildings in the southwest portion of the site would barely rise above the existing horizon from this perspective, minimally obstructing northward scenic views of the foothills and mountains. The three -story building included in the original project would have obstructed public scenic views of the bulk of mountains to the 38 Attachment 1
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northeast from the perspective of northbound motorists, pedestrians, and bicyclists on South Los Carneros Road approaching Calle Koral Road.

Therefore, the Project as redesigned would have a less than significant impact on the scenic view from South Los Carneros Road at Calle Koral looking northward to the foothills and Santa Ynez Mountains.

Views from the Los Carneros Road overpass to the south and southeast are designated scenic views. The open waters of the Pacific Ocean and Goleta’s shoreline/beaches are designated scenic resources. The southerly descent from the crest of the South Los Carneros Road overpass currently provides scenic views over the Project site toward the Pacific Ocean beyond Goleta Beach. Although the ocean is not visible in these figures’ photographs of current conditions, a slice of the Pacific Ocean is visible in the distance on relatively clear days. The proposed conditions on Figure 4 .1-6 of the Final EIR show the view with the completed roadway project on South Los Carneros Road, showing a low -profile guardrail on the road’s eastern edge.

Both Figures 4.1-6 and 4.1-7 of the Final EIR demonstrate that the proposed buildings on-site would rise nearly to the level of the horizon, but would not obstruct scenic views of the Pacific Ocean. Therefore, the Project would have a less than significant impact on views from the vantage point of the Los Carneros Road overpass.

The Project site is n ot visible from the U.S. 101 mainline, which the Visual and Historic Resources Element of the Goleta General Plan lists as a scenic view corridor which provides scenic views to surrounding areas. The site is briefly visible from the southbound on-ramp from Los Carneros Road to U.S. 101. However, the site is almost 90 degrees out of the line of sight of drivers on the freeway ramp and partially obscured by trees along the UPRR ROW.

Furthermore, the Project would not alter scenic views of the dramatic topography of the Santa Ynez Mountains to the northeast of the on -ramp, which are the primary scenic resource viewable from U.S. 101 in the vicinity of the Project site. Thus, any changes to views from this perspective would not be substantially evident and impac ts to scenic views from the U.S. 101 would be less than significant.

Currently, Hollister Avenue offers a designated scenic view of the Santa Ynez Mountains to the north. From the perspective of motorists driving on Hollister Avenue, the Project site is barely visible due to intervening buildings and landscaping at residential, commercial, and business park properties. With a maximum height of 35 feet, the proposed buildings would not obstruct or otherwise affect existing views of the Santa Ynez Mountains and foothills from Hollister Avenue. Therefore, the Project would have a less than significant impact on scenic views from Hollister Avenue.

The Project would also alter public views of the site from Camino Vista, Calle Koral, and Aero Camino. Currently, the Project site affords partial northward views of the Santa Ynez Mountains, atop existing hills on -site, from the 39 Attachment 1
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perspectives of Calle Koral and Camino Vista. The photo simulations in Figure 4.1-5 of the Final EIR show that the proposed buildings would largely obstruct these northward views of the mountains. Because Aero Camino only offers limited mountainous views to the north and not across the Project site, the Project would not affect views from the local roadway. Although the Project would obstruct views from Camino Vista and Calle Koral, the Visual and Historic Resources Element of the Goleta General Plan does not recognize these roadways as scenic view corridors that provide scenic views.

Therefore, changes to views from these local roadways would be less than significant impacts.

While the UPRR ROW does not provide any City-designated scenic views, it provides brief, unobstructed views across the Project site to the south. Based on information provided in the City of Goleta General Plan Noise Element 2006, daily rail operations include 12 freight trains with 3 occurring at night. A total of nine passenger trains pass the Project site daily on Amtrak’s Pacific Surfliner route (Amtrak, 2021). Because the Willow Springs Apartments to the south of the Project site currently obstruct further views of the coastal plain, the Project would not block any existing scenic vistas from the UPRR ROW. Therefore, the Project would not impair any existing scenic views from the railroad tracks.

The Project could potentially affect private views of the Santa Ynez Mountains, from the Willow Springs II multi -family residences to the south of the site. Currently, north -facing windows on the Willow Springs Apartments site south of Camino Vista offer expansive views of the mountains through the Project site. The proposed two - and three -story buildings and landscaping would almost entirely block these northward views. Policy VH 1.8 of the Visual and Historic Resources Element of the Goleta General Plan requires development to be considerate of private views.

Nevertheless, the City has not designated the view of the mountains from a private property as scenic, and the obstruction of private views from one private property does not constitute a significant impact pursuant t o CEQA, which is primarily concerned with public views. Overall, impacts to scenic views would be less than significant without mitigation. (Final EIR, pp. 4.1- 9 through 4.1-15.)

2. Scenic Resources
Threshold: Would the Project s ubstantially damage scenic res ources, including, but not limited to, trees, rock outcroppings, and historic building s within a state scenic highway?
Finding: Less than significant. (Final EIR, pp. 4.1-15 through 4.1-16.) Explanation: The Project would be located on a vacant property in Goleta’s coastal plain near U.S. 101, between the foothills of the Santa Ynez Mountains to the north and the coastline to the south. The Project site does not include scenic 40 Attachment 1
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resources identified in Policy VH 1.1 of the Visual and Historic Resources Element of the Goleta General Plan, including the open waters of the Pacific Ocean, the shoreline, Goleta and Devereux Sloughs, creeks and riparian vegetation, agricultural areas, Lake Los Carneros and surrounding woodlands, and prominent landforms. Impacts to designated views corridors that contain these scenic resources are discussed above under Impact 1 – Scenic Vistas . The Project would not substantially affect scenic natural landforms, as identified in Policy VH 1.6 in the Goleta General Plan. No mature trees occur on -site, and the stand of eucalyptus trees that overlooks the Project site from the north side of the UPRR tracks would remain in place.

No drainage courses, prominent slopes, or bluffs occur on-site. Native shrubs and ruderal vegetation predominate on-site have low to moderate scenic value from public viewpoints on surrounding roadways. The clearing of existing vegetation to make way for the proposed apartments and park would represent a minor loss of natural landforms. However, the loss of native shrub vegetation would be offset by the planting of several tree species native to California: Cercis occidentalis (western redbud), Lyonothamnus floribundus ssp. asplenifolius (fernleaf Catalina ironwood), Platanus racemosa (California sycamore), Quercus agrifolia (coast live oak), and Quercus tomentella (island live oak). As specimens of taller tree species such as California sycamore, and the oaks mature after construction of the Project, they would become scenic resources on-site. Because implementation of the Project would not impact scenic resources identified in the Goleta General Plan, impacts to scenic resources and scenic natural landforms would be less than significant without mitigation. (Final EIR, pp. 4.1-15 through 4.1-16.)

3. Visual Character
Threshold: In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public view of the site and its surroundings? Finding: Less than significant. (Final EIR, pp. 4.1-16 through 4.1-18.) Explanation: The Project would alter the site’s visual character from open and undeveloped to high-density residential. The proposed development would have a building footprint of 3.46 acres, occupying 24.63 percent of the net developable area (14.05 acres) of the site. Th e proposed two- and three-story buildings would have a peak height of 35 feet and would be clustered on various portions of the site. These proposed buildings would reduce the openness of the site and the depth of views across the site from surrounding roa dways. An approximately two -acre park would retain open space in the south -central portion of the site, with an activity trail, fitness stations, tot lot, benches, barbecue area, picnic tables, bicycle parking, level turf play area, and native landscaping. In total, the 6.23 acres of common open space (excluding the park) would represent 44.3 percent of the net developable area of the site.

Although the Project would alter the site’s existing visual character by introducing a complex of two - and three -story apartment buildings with 41 Attachment 1
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associated on-site parking, the proposed development intensity and height of buildings would be compatible with adjacent residential development at the Willow Springs Apartments to the south as well as the recently constructed Village at Los Carneros residential development to the west. The Village at Los Carneros is a 465 -unit development including two - to three -story townhomes and single-family houses. The combined Willow Springs I and II developments, which together comprise the Willow Springs Apartments, have a building footprint of 181,533 square feet, or 17.9 percent of their collective lot area (Goleta, Willow Springs II Final EIR, 2012). Common open space at these developments also totals 40.6 percent of their lot area.

Similarly, the Project would have a building footprint of approximately 24.63 percent of the net developable area of the Heritage Ridge site and common open space covering 44.3 percent of the net developable area of the site. While the Willow Springs II development has a density of 18.22 dwelling units per acre, the Project would have a higher density of 23.6 units per acre. The proposed two- and three-story buildings, with peak heights of 35 feet, also would be comparable to the two-story buildings at the Village at Los Carneros and Willow Springs Apartments surrounding the Project site. In addition, the proposed layout of apartment buildings surrounding a central open space area would mirror the arrangement of the neighboring apartment complex at Willow Springs II around a central open space.

Furthermore, the massing and architectural style of the proposed apartment buildings would be similar to adjacent developments. The exterior materials and finish of the proposed apartment buildings would match those of the neighboring apartments and townhomes with wood trim, and pitched rooflines.

The maturation of proposed landscaping over five years of growth would incrementally reduce the Project’s visual incompatibility with surrounding urban development. Although the Project would introduce approximately 8.0 acres of structural development and impervious surface to the Project site (approximately 56.9 percent of the net developable area), the maturing landscaping would gradually soften the lines of the proposed buildin gs and obscure surface parking areas from offsite viewpoints. The proposed landscape design is intended to blend with the existing Willow Springs Apartments to the south and the Village at Los Carneros to the west by using similar plant palettes.

Grading activities would reduce the grade differential from existing stockpile soils on the Project site. Moderately steep slopes from stockpile soils occur along the perimeter of the archaeological area and the eastern, western, northern, and southwestern propert y lines. Existing elevations range from about 25 to 43 feet ASL. The Project would level out existing slopes outside the archaeological area for the construction of individual building pads, driveways. Finished grades would range from approximately 18 to 4 0 feet ASL. Although grading activities would change the existing grade differential, this topography is artificial and results from stockpiling of soils 42 Attachment 1
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from previous construction activity in the area. Therefore, the proposed topographic changes would not adversely affect the site’s visual quality.

Utility infrastructure including electrical distribution lines, fiber optic lines, cable television lines, phone lines, gas lines, water lines, and sewer lines would be installed underground and would not affect the visual character of the site. However, components such as backflow preventers, transformers, water meter assemblies, gas meters, power meters, and cable TV pedestals would be installed aboveground. Mechanical equipment would be ground - mounted on concrete pads adjacent to the residential structures and would be screened with landscaping.

Based on the above analysis, impacts to visual character and compatibility with the surrounding neighborhoods would be less than significant without mitigation. (Final EIR, pp. 4.1-16 through 4.1-18.)
B. AGRICULTURE AND FOREST RESOURCES

1. Farmland Conversion
Threshold: Would the Project convert Primate Farmland, Unique Farmland, or Farmland of Statewide significance, as shown on the maps prepared pursuant to the Farmland M apping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: 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 c onsisted 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 resid ential development would not result in the loss 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.)

2. Agricultural Zoning
Threshold: Would the Project c onflict with existing zoning for agricultural use, or a Williamson Act contract?
Finding: No impact. (Final EIR, p. 4.17-1.)
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Explanation: Historically, the Project site was used fo r 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. Consequently, the Project would not conflict with existing zoning for agricultural use, or a Williamson Act contract. Therefore, no impacts related to agriculture and forestry would occur. (Final EIR, p. 4.17-1.)

3. Forestland Zoning
Threshold: Would the Project c onflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)?
Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: 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. Currently, the Project site consists of 13 undeveloped lots. There is no structural development on site; however, there are pieces of construction equipment and c ontainers stored on site, as well as stockpiled soil. The project site has not been identified as timber or forest land, and there is no timber or forest on the site. Consequently, the Project would not conflict with existing zoning for, or cause rezoning of, forest land . Therefore, no impacts related to agriculture and forestry would occur. (Final EIR, p. 4.17 -

1.)

4. Loss of Forest Land
Threshold: Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: 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 includin g industrial, research park and office development, on-site residential development, and significant 44 Attachment 1
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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. 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 project site has not been identified as timber or forest land, and there is no timber or forest on the site. Consequently, the Project would not result in the loss of forest land or conversion of forest land to non -forest use .

Therefore, no impacts related to agriculture and forestry would occur. (Final EIR, p. 4.17-1.)

5. Conversion of Farmland or Forestland
Threshold: Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non- agricultural use or conversion of forest land to non-forest use? Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: 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 n ot result in the loss of significant, viable, local farmland. The project site has not been identified as timber or forest land, and there is no timber or forest on the site. Consequently, the Project would not involve other changes in the existing environ ment which, due to their location or nature, could result in conversion of Farmland, to non- agricultural use or conversion of forest land to non -forest use. Therefore, no impacts related to agriculture and forestry would occur. (Final EIR, p. 4.17 -

1.)
C. AIR QUALITY

1. Air Quality Plans and Air Quality Standards
Threshold: Would the Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Finding: Less than significant. (Final EIR, p. 4.2-9.)
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Explanation: Consistency with the applicable 2019 Ozone Plan is required under CEQA for all projects within the County. In order for a project to be found consistent with the 2019 Ozone Plan, the Project’s direct and indirect emissions must be accounted for in the land use and population growth assumptions of the 2019 Ozone Plan (SBCAPCD, 2021). In addition, all projects involving earthmoving activities must implement SBCAPCD’s standard dust control measures.

The 2019 Ozone Plan is based on countywide population data p rovided by the California Department of Finance. The 2019 Ozone Plan also states that its growth projections are similar to that of the 2019 Santa Barbara County Association of Governments (SBCAG) Regional Growth Forecast 2050, in which assumptions about f uture land development patterns were used to generate future housing forecasts for Santa Barbara County (SBCAG, 2019).

These growth projections for Goleta are shown in Table 4.2 -3 of the Final EIR.

The Project involves developing 332 residential rental uni ts, which would include 104 senior and family affordable units and 228 market-rate apartment units. The current population of Goleta is 32,223 (DOF, 2020). The population for the market -rate housing was determined based on the latest persons-per-household figure from the Department of Finance (2.72 persons per dwelling unit), the population for the family affordable housing was determined based on Housing Authority of the County of Santa Barbara data (2.58 persons per dwelling unit), and the population for the senior affordable housing was determined based on the Heritage Ridge Occupant/Unit Ratio Analysis study conducted by The Towbes Group, Inc. (2014) (1.36 persons per senior dwelling unit). Development of the Project would add an estimated 839 residents ([228 dwelling units x 2.72 people/dwelling unit] + [63 dwelling units x 2.58 people/dwelling unit] + [41 dwelling units x 1.36 people/dwelling unit]), thus increasing the City’s population to 33,062. SBCAG’s 2050 growth forecast projects Goleta’s populati on to be approximately 33,100 in 2030, 33,700 in 2035, and 34,300 in 2040 (SBCAG, 2019). The Project would result in a population of 33,062 in the City (current 32,223 City population plus 839 project residents). This would not exceed SBCAG’s 2030, 2035, o r 2040 growth forecast for the City. The Project is not expected to be fully operational and occupied until 2025 or later. Consequently, the Project was compared to the 2030, 2035, and 2040 forecasts. Population generated by the Project would not cause an exceedance of SBCAG’s 2030 growth forecast of 33,100, 2035 growth forecast of 33,700, or the 2040 growth forecast of 34,300 for the City of Goleta (SBCAG, 2019). Development of the Project would therefore be consistent with the population forecasts contain ed in the 2019 Ozone Plan.

The Project would provide both affordable and market -rate housing, as well as an on-site passive recreational park. The provision of housing along with the Project site’s location near several employment centers in the City, are consistent with efforts by the 2019 Ozone Plan to implement transportation 46 Attachment 1
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performance standards that will provide a substantial reduction in the rate of increase in passenger vehicle trips and vehicle miles traveled (VMT). A reduction in County -wide VMT i s identified by the 2019 Ozone Plan as a major component of an overall strategy to reduce mobile emissions of ozone precursor pollutants (NOX and ROC). Mobile and total emissions from the Project would be less than the ROC and NOX thresholds of significanc e adopted by the SBCAPCD. In addition, the Project would include new sidewalk segments that would enhance pedestrian circulation in the Project area, which is a transportation control measure in the 2019 Ozone Plan.

Therefore, the Project would be consiste nt with planning efforts to reduce County-wide VMT, and Project -related emissions would not substantially interfere with the SBCAPCD’s efforts to maintain attainment of the state one- hour ozone standard. In addition, as discussed in Impact 3 – Sensitive Receptors, the Project would be required to implement SBCAPCD’s standard dust control measures. As a result, the Project would not conflict with or obstruct implementation of the 2019 Ozone Plan. Therefore, impacts from the Project related to 2019 Ozone Plan consistency would not be significant. (Final EIR, pp. 4.2-9 through 4.2-11.)

2. Cumulatively Considerable Pollutant Emissions
Threshold: Would the Project result in cumulatively considerable net increase of any criteria pollutant for which the project regio n is non -attainment under an applicable federal or state ambient air quality standard? Finding: Less than significant. (Final EIR, p. 4.2-11.) Explanation: Operational Air Pollutant Emissions
Regional Air Quality . Long-term regional emissions are generated by area, energy, and mobile sources. Area emissions are generated by the use of architectural coatings, consumer products, and landscaping maintenance equipment. Energy emissions include emissions from the use of natural gas.

Mobile emissions include thos e produced by vehicular traffic generated by residents of the senior and family affordable housing and market-rate housing.

Table 4.2 -4 of the Final EIR summarizes the maximum daily operational emissions resulting from the Project.

The Project would not generate vehicular emissions that would exceed the SBCAPCD mobile significance thresholds for ROC or NOX of 25 pounds per day. Additionally, the Project’s combined area and vehicle emissions would not exceed the SBCAPCD significance thresholds of 240 pounds per day for ROC and NOX or the SBCAPCD significance threshold of 80 pounds per day for PM10. This impact would be less than significant.

CO Hotspots. Based on the Project’s Updated Traffic and Circulation Study, the project is forecast to generate 196 AM peak hour trips, and 196 PM peak hour trips (ATE, 2021). Because the Project would not contribute more than 47 Attachment 1
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800 trips to an existing congested intersection at LOS D or below, a quantitative CO hot spot impact analysis is not warranted, and impacts related to microscale CO concentrations would be less than significant. Furthermore, because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion and very low background concentrations relative to the state and federal standards, the potential for CO hot spots in the SCCAB is steadily decreasing. According to the SBCAPCD, localized CO impacts associated with congested intersections are not expected to exceed the CO health -related air quality standards d ue to the relatively low background ambient CO levels in the County (SBCAPCD 2014). This impact would be less than significant. (Final EIR, pp. 4.2 -11 through 4.2-12.)
Construction Air Pollutant Emissions
The Project involves the development of 332 residential units, parking areas, two recreational buildings, and a two -acre public park on the 17.36 -acre Project site. Construction of the Project is expected to occur over approximately 36 months. Ozone precursors NOX and ROC, as well as CO and diesel exhaus t PM, would be emitted by the operation of construction 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 con struction. As discussed above, the Project would include pre -construction export of stockpiled soil currently on the site (stockpiled in two locations) prior to building construction. The pre -construction soil export would proceed according to one of two potential scenarios – one based on smaller (9 CY) haul trucks and another based on larger (20 CY) haul trucks. Table 4.2 -5 of the Final EIR summarizes estimated annual pre -construction emissions associated with Scenario 1, which includes 25,556 one-way haul truck trips, worker trips, and operation of on-site equipment as well as Scenario 2, which includes 11,500 one-way haul truck trips, worker trips, and operation of on -site equipment.

The updated soil export amount of 92,000 cubic yards would result in few er haul truck trips than what was modeled for both scenarios. Therefore, the estimates of pre -construction emissions in Table 4.2 -5 of the Final EIR are greater than, and thus, more conservative than the actual pre -construction emissions for the Project.

As shown in Table 4.2-5 of the Final EIR, Scenario 1 would result in higher emissions of ozone precursor NOX, with all other emissions of ROC, CO, PM10, and PM2.5 similar to those of Scenario 2.

In addition to emissions generated by pre -construction export of stockpiled soil, annual emissions associated with the Project construction was assumed to occur over approximately 3 years. The building construction phase, which would occur over approximately two years, would be the phase with the highest emissions of NOX, CO, PM10, and PM2.5. The architectural coating phase, which is assumed to occur over the last 12 months of building 48 Attachment 1
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construction, would result in the highest emissions of ROC.

Maximum potential annual construction emissions associated with the Project would not exceed the SBCAPCD’s general rule of 25 tons per year of ROC or NOX used for determining significance of construction exhaust emissions.

Therefore, impacts to air quality during pre -construction export and construction activities would not vi olate any air quality standards or contribute substantially to existing or projected air quality violations.

The Project site is located in Santa Barbara County and the Santa Barbara County portion of the SCCAB is a nonattainment area for the state PM10 standard. Therefore, the SBCAPCD requires construction emissions and dust control measures for all projects involving earthmoving activities regardless of size or duration. In accordance with standard practices, such construction emissions control measures would be shown on grading and building plans and as a note on a separate information sheet to be recorded with map.

According to the SBCAPCD’s Scope and Content of Air Quality Sections in Environmental Documents (June 2017), implementation of required dust control measures results in fugitive dust emissions that are less than significant. The specific measures that would apply to the project in accordance with standard SBCAPCD requirements include the following (SBCAPCD, June 2017):
 During construction, use water trucks or sprinkler systems to keep all areas of vehicle movement damp enough to prevent dust from leaving the site. At a minimum, this should include wetting down such areas in the late morning and after work is completed for the day. Increased watering frequency should be required whenever the wind speed exceeds 15 mph. Reclaimed water should be used whenever possible.

However, reclaimed water should not be used in or around crops for human consumption.
 Minimize amount of disturbed area and reduce on site vehicle speeds to 15 miles per hour or less.
 If importation, exportation and stockpiling of fill material is involved, soil stockpiled for more than two days shall be covered, kept moist, or treated with soil binders to prevent dust generation. Tru cks transporting fill material to and from the site shall be tarped from the point of origin.
 Gravel pads shall be installed at all access points to prevent tracking of mud onto public roads.
 After clearing, grading, earth moving or excavation is completed, treat the disturbed area by watering, or revegetating, or by spreading soil binders until the area is paved or otherwise developed so that dust generation will not occur.
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 The contractor or builder shall designate a person or persons to monitor the dust control program and to order increased watering, as necessary, to prevent transport of dust offsite. Their duties shall include holiday and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the SBCAPCD prior to grading/building permit issuance and/or map clearance.

With implementation of SBCAPCD construction and dust control measures, this impact would be less than significant. (Final EIR, pp. 4.2-12 through 4.2-

15.)

3. Sensitive Receptors
Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than significant. (Final EIR, p. 4.2-15.) Explanation: The California Supreme Court in a December 2015 opinion (California Building Indust ry Assn. v. Bay Area Air Quality Management District) confirmed that CEQA is concerned with the impacts of a project on the environment, not the effects the existing environment may have on a project.

Nevertheless, health risk at the proposed on -site resid ences are presented below for informational purposes and do not constitute a significant impact pursuant to CEQA.

The conclusions of the 2016 HRA are summarized in Table 4.2-8 of the Final EIR. The HRA determined that, without measures to reduce air quali ty pollutants, the proposed residential units on the Project site would be exposed to a high end (95-percentile) 30-year excess cancer risk of between 42 and 59 in one million, which exceeds the SBCAPCD recommended health risk criteria of ten excess cases of cancer in one million individuals (1.0E -05) (SBCAPCD, August 2015). Thirty years is the exposure duration scenario recommended by the SBCAPCD in the Modeling Guidelines for Health Risk Assessments (August 2015). The health effects risk level for the average (50- percentile) residency of 9 years for an adult would be between 12 and 18 in one million, and for that of a child (9 -years) would be between 18 and 26 in one million. Both of which also exceed the SBCAPCD health risk criteria. To provide context for this level of additional risk, the American Cancer Society (2007) reports that in the U.S., men have a one in two chance (0.5 probability) and women about one in three chance (0.3) probability of developing cancer during a lifetime, with nearly one in fo ur deaths (0.23) in the U.S. attributed to cancer.

Diesel exhaust particulates were found to be responsible for about 98% of the calculated cancer risk on -site. The HRA concluded that without air quality pollutant reduction measures, the carcinogenic heal th risk for lifetime 50 Attachment 1
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residency exceeds the SBCAPCD -recommended health risk criteria for a high-end (95-percentile) 30-year residency and average (50-percentile) nine- year residency of ten excess cases of cancer in one million individuals (1.0E- 05).

The HRA also showed that residences on-site would be exposed to chemicals such as 1,3 butadiene and formaldehyde from the exhaust of vehicles on U.S. 101. However, acute and chronic health hazards associated with inhalation of these chemicals would be below the SBCAPCD threshold (a hazard index of

1.0) for proposed residences. A hazard index is the summation of the hazard quotients for all chemicals to which an individual would be exposed. Based on this finding, future residents on -site would experience a less th an significant acute and chronic health risk from freeway, railroad, and permitted sources.

The HRA analysis is based on outdoor air concentrations and conservatively assumes that interior concentrations would be the same as outdoor concentrations. USEPA activity factors show that people in a residential environment spend only approximately 2.3 hours per day on an average basis outdoors. Therefore, the HRA recommends a measure that includes forced air ventilation with filter screens on outside air intake ducts to be provided for all residential units on the Project site. The identified measure is included as a project -specific condition of approval and would reduce the future residents’ exposure to toxic air contaminants associated with U.S. 101 and the UPRR to below the recommended 10 in one million threshold for a 9 -year and 30-year residency, as demonstrated below.

Compliance with the conditions of approval would provide for the removal of particulates before they enter the indoor environment, thereby re ducing the overall exposure of individual residents. With this reduction in exposure to TACs, the combined exposure from time spent both indoors and outdoors would be below SBCAPCD recommended health risk criteria. The reduced carcinogenic health risk valu es only account for the particulate matter reductions from the proposed filtration devices. The MERV 13 rated filter screens would reduce residential cancer risk by approximately 83 percent.

Resulting health risk would be below SBCAPCD recommended health r isk criteria.

Although the analysis of health risks assumes outdoor exposure, the finding related to cancer risk does not mean that using exterior portions of the site would create acute, or short -term, health risks for site residents or visitors.

The excess cancer risk identified in the HRA is based on a 30-year exposure, which is the high -end (95 -percentile) residency, the exposure duration scenario recommended by the SBCAPCD in the Modeling Guidelines for Health Risk Assessments (August 2015); and is greater than the length of time that the majority of residents of the Project would be expected to live on-site.

No significant impacts would occur and no mitigation is required. (Final EIR, 51 Attachment 1
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pp. 4.2-15 through 4.2-18.)

4. Other Adverse Emissions
Threshold: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Finding: Less than significant. (Final EIR, p. 4.17-3.) Explanation: The Project would construct 332 residential units and associated amenities and merge 13 existing lots into 4 lots. This use would not create objectionable odors that would affect a substantial number of people. (Final EIR, p. 4.17 -

3.) No significant impacts would occur.

D. BIOLOGICAL RESOURCES

1. Wetlands
Threshold: Would the Project h ave a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: Less than significant. (Final EIR, p. 4.3-31.) Explanation: No areas defined as wetlands by federal, State or local policies are located on the Project site. The Project would have no direct impacts to off-site riparian vegetation or Los Carneros Creek jurisdictional waters, since development is proposed greater than 100 feet from the edge of vegetation of Los Carneros Creek off-site, and is hydrologically separated by the filled and compacted UPRR track.

Drainage from the Pr oject site would be directed to previously constructed storm drains as part of the Willow Springs I & II development, and ultimately drain to the existing retention basin located along the southwest boundary of Willow Springs I in Los Carneros Wetland, as approved by resource agencies as part of Willow Springs I & II (MAC Design Associates, 2014; USACE, 1995). The post-construction drainage would be less than 7% below existing runoff during a 100 year rainfall event, with no change in post -development runoff during 10 year (or less) rain events. The negligible (less the 7% during a 100 year rainfall event) reduction in runoff during infrequent major rainfall events (i.e., 25 –100 year events) would not result in any hydrological interruption to the Los Carner os Wetland or affect the existing hydrological process. Adherence to existing stormwater regulations would ensure there is no increase to normal water flows before and following construction into Los Carneros Wetland as permitted by the agencies.

Development of the Project would remove existing on -site vegetation and increase the amount of impervious surfaces, which has the potential to affect 52 Attachment 1
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the quality of stormwater runoff reaching downstream waterbodies, including the Los Carneros Wetland and potentially downstream in the Goleta Slough.

Pollutants (e.g. , sediment, hydrocarbons, heavy metals, herbicides, and fertilizers) could be transported in stormwater runoff as a result of temporary construction activities and routine human activities during the oper ational phase of the Project. Pollutant runoff from the Project site has the potential to degrade water and soil quality in sensitive wetland, riparian and aquatic habitats and natural communities (e.g. , the Los Carneros Wetland and the Goleta Slough), as well as indirectly impact sensitive wildlife and vascular plant species dependent upon these habitat areas.

The Project includes the installation of low impact development design strategies intended to retain water on the Project site and encourage groundwater infiltration, including preservation of the 2 -acre park in the center of the Project site, the use of permeable pavements, bioretention basins, vegetated swales, permeable pavements set on a gravel reservoir, and a subsurface Advanced Drainage System (ADS) Stormtech Chamber system (Mac Design, 2014). The bio-swales and bio retention areas would be planted with Carex and other native grasses. The Project includes landscaped bio - filter areas that would help to cleanse surface runoff. Stormwater flows from the Project site must meet appropriate water quality standards through implementation of Best Management Practices to control surface water runoff quality. The City’s Stormwater Management Plan (SWMP), approved through the Central Coast Regional Water Quality Control Board (RWQCB) in compliance with the 1972 Clean Water Act, establishes measures and practices to reduce the discharge of pollutants and to protect downstream water quality. Compliance with the City SWMP with respect to construction period discharges and long -term operational discharges would be required.

As required by the SWMP, water quality measures must be implemented prior to the surface runoff reaching the Los Carneros Wetland. With adherence to existing legal requirements , such as existi ng City SWMP regulations , construction and operational direct and indirect impacts to jurisdictional waters and wetlands would be less than significant. Impacts would be further reduced by Mitigation Measure HWQ-2. (Final EIR, pp. 4.3-31 through 4.3-

32.)

2. Local Policies and Ordinances
Threshold: Would the Project c onflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Finding: Less than significant. (Final EIR, p. 4.3-35.) Explanation: The Goleta General Plan / Coastal Land Use Plan identifies the presence of coastal sage scrub, an Environmentally Sensitive Habitat Area, on the Project site. However, bi ological assessment surveys indicate that no protected habitat ESHAs are present on-site.
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The following paragraphs provide an evaluation of the consistency of the Project with the relevant General Plan Conservation Element policies related to ESHAs and SPAs.

Policy CE 1: Environmental Sensitive Habitats Area Designation and Policy. The off-site willow thickets along Los Carneros Creek are designated as SPA ESHA (CE 2.2), and Los Carneros Wetland is designated as Wetland ESHA (CE 3.1). Therefore, the provisions of Policy CE 1.9 apply, requiring the preservation of wildlife corridors or hab itat networks, limitation of lighting and noise generation adjacent to ESHA, and prohibition of invasive landscaping.

Impacts to wildlife movement corridors are discussed and measures to mitigate indirect impacts recommended under Impact 4-Wildlife Movement.

Policy CE 1.9 specifically limits lighting directed at ESHA. Mitigation Measure BIO-4(a), which limits night lighting, is required under Impact 4- Wildlife Movement.

General Plan CE Policy 1.9 prohibits planting of non-native, invasive species in ESHAs and buffer areas adjacent to ESHAs. The landscape plan includes both ornamental and native plantings, a palette that would improve the Project’s compatibility with ESHA, such as by providing a food source for insects and birds (e.g., coffee berry, coast l ive oak). Mitigation Measure BIO-2 would prohibit invasive species.

Implementation of Mitigation Measures BIO -1, BIO-2, and BIO-4(b) would reduce impacts and ensure consistency with the General Plan. The Project is consistent with CE Policy 1, and no additional mitigation measures are necessary.

Policy CE 2: Protection of Creek and Riparian Areas. Policy CE 2.2 requires a buffer of 100 feet from an SPA, but also allows the City to adjust the 100-foot buffer to 25 feet based on a site-specific assessment at the time of environmental review, if “1) there is no feasible alternative siting for development that will avoid the SPA upland buffer; and 2) the project’s impacts will not have significant adverse effects on streamside vegetation or the biotic quality of the stream.” The Project has been designed to meet the 100-foot setback requirement.

Policy CE 3: Protection of Wetlands . The Project would not conflict with CE 3.3 through CE 3.8, since no fill is proposed and the Project buffer from the edge of wetl and vegetation is greater than 50 feet. The edge of the Project site is approximately 80 feet northwest of the beginning of the wetland, and is separated by Camino Vista. Policy CE 1.4 requires a buffer of 100 feet from any wetland in the coastal zone, whe reas outside the coastal zone Policy CE 3.5 requires “a wetland buffer of a sufficient size to ensure the biological integrity and preservation of the wetland shall be required…buffer shall be no less than 50 feet.” The Los Carneros Wetland is 54 Attachment 1
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directly north of the coastal zone; a 100 -foot buffer is not required by the General Plan. However, since development is proposed within 100 feet from the edge of the wetland, a wetland ESHA buffer recommendation is included in this assessment. The proposed buildings are greater than 100 feet from the beginning of the wetland. Run-off would be conveyed into the existing storm water system that discharges into the Los Carneros Wetland, as permitted by USACE. The portion of the wetland within 100 feet of the Project was required to be created to mitigate for USACE wetland impacts for Willow Springs I, and to serve as a retention basin for Wil low Springs II and the Project. The wetland was once hydrologically connected to Lake Los Carneros and the Goleta Slough; however, the wetland is now fragmented and isolated. Given the urbanized setting and that the area is approved for treating the Project’s stormwater, the existing approximately 80 -foot buffer is adequate. Mitigation Measure BIO -4 regulating the use of fertilizers, pesticides, or herbicide (applied for wildlife protection) would also protect wetland vegetation and the biotic quality of the wetland. Therefore, the proposed development 80 feet from the property line to the edge of wetland vegetation would not have a substantially adverse effect on the functions and values of Los Carneros Wetland. The Project is consistent with CE Policy 3, and no additional mitigation measures are necessary.

Policy CE 9: Protection of Native Woodlands. Three willow trees are present on site and would be replaced at a ratio of 10:1 as required by the Project-specific Conditions of Approval. The off -site trees (e.g. eucalyptus, willow) between the UPRR tracks and U.S. 101, and are located an adequate distance outside the development footpr int and would not be affected by the Project. The Project is consistent with Policy CE 9.

Policy CE 10: Watershed Management and Water Quality . Existing regulations address the requirements of Policy CE 10. The Project is consistent with Policy 10, and no additional mitigation measures are necessary.

As mitigated, the Project is con sistent with the General Plan. No significant impact would occur as a result of a conflict with local policies and ordinances. (Final EIR, pp. 4.3-35 through 4.3-38.)

3. Habitat Conservation Plans
Threshold: Would the Project c onflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: No adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan 55 Attachment 1
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applies to the Project site. Therefore, the Project would not conflict with any such plans. No impact would occur. (Final EIR, p. 4.17-1.) E. CULTURAL RESOURCES

1. Historical Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to State CEQA Guidelines, section 15064.5? Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: The Project site is undeveloped. Consequently, there are no State or locally listed or eligible historic structures or resources on -site, and Project implementation would not result in any impact o n such resources in Goleta.

There are no unique paleontological resources or sites, or unique geologic features on the Project site. No such impacts to these types of resources would occur as a result of Project implementation. (Final EIR, p. 4.17-1.) F. ENERGY

1. Wasteful Use of Energy
Threshold: Would the Project result in potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Finding: Less than significant. (Final EIR, p. 4.15-11.) Explanation: Construction. Project construction would require energy resources primarily in the form of fuel consumption to operate heavy equipment, light -duty vehicles, machinery, and generators. Temporary grid power may also be provided to construction trailers or electric construction equipment. Table

4.16 4 of the Final EIR summarizes the anticipated fuel consumption from construction equipment and vehicles, including construction worker trips to and from the Project site.

Construction of the Project would require approximately 92,426 gallons of gasoline and 178,317 gallons of diesel fuel. Energy use during construction activities would be temporary in nature, and construction equipment used would be typical of similar -sized construct ion projects in the region. In addition, construction contractors would be required to comply with the provisions of 13 California Code of Regulations Sections 2449 and 2485, which prohibit diesel -fueled commercial motor vehicles and off -road diesel vehicles from idling for more than five minutes, which would minimize unnecessary fuel consumption. Construction equipment would be subject to the U.S. EPA Construction Equipment Fuel Efficiency Standard (40 Code of Federal Regulations Parts 1039, 1065, and 1068 ), which would minimize inefficient fuel consumption. Electrical power would be consumed during 56 Attachment 1
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construction activities, and the demand, to the extent required, would be supplied from existing electrical infrastructure in the area.

Overall, construction a ctivities would utilize fuel -efficient equipment consistent with state and federal regulations and would comply with state measures to reduce the inefficient, wasteful, or unnecessary consumption of energy. Construction contractors would not be anticipated to utilize fuel in a manner that is wasteful or unnecessary as a business practice to ensure cost efficiency. Moreover, the use of energy to construct new development on the Project site would not be unnecessary because the intention of the Project is to provide additional market -rate, affordable, and senior housing as well as park space in Goleta. Therefore, Project construction would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption o f energy, and impacts would be less than significant.

Operation. Energy demand from operation of Project development would include fuel consumed by passenger vehicles; natural gas consumed for heating and cooking in residential buildings; and electricity consumed by new residences including, but not limited to lighting, water conveyance, and air conditioning.

Vehicle Trips . Vehicle trips generated by the Project would require approximately 202,506 gallons of gasoline and 43,403 gallons of diesel fuel, or a total of 27,764 MMBtu of energy annually. Gasoline and diesel fuel demands would be met by existing gasoline stations i n the vicinity of the Project site. The Project would facilitate bicycle riding among site residents by providing a bicycle parking area at each residential building and the park with a total of 120 bicycle parking spaces. In addition, the Project would include new sidewalk segments and walkways with connections to adjacent pedestrian and bicycle networks identified in the City’s Bicycle and Pedestrian Master Plan that would enhance non -vehicular circulation in the Project area. The proposed bicycle and pedestrian facilities would encourage the use of alternative transportation modes, which would reduce VMT and associated fuel consumption. Vehicles driven by future residents and visitors of the proposed uses on the Project site also would be subject to increasingly stringent federal and state fuel efficiency standards, minimizing the potential for the inefficient consumption of vehicle fuels. As a result, vehicle fuel consumption resulting from the Project would not be wasteful, inefficient, or unnecessary.

Built Environment . The Project would consume approximately 1,418,923 kWh per year of electricity for lighting and large appliances, and approximately 3,960 MMBtu per year of natural gas for heating and cooking.

Electricity would be supplied by SCE and natu ral gas would be provided by SoCal Gas.

The Project would require permanent grid connections for electricity and 57 Attachment 1
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natural gas. All new residential buildings must comply with Goleta Municipal Code Chapter 15.13 entitled “Energy Efficiency Standards,” which require energy savings measures that exceed 2008 State of California Title 24 Energy Requirements by 15 percent, and with the 2019 California Green Building Code, as adopted by Goleta Municipal Code Chapter 15.12. Construction of the proposed residential buildings also would comply with all applicable 2019 California Building Energy Efficiency Standards for Residential and Non - residential Buildings and CALGreen (California Code of Regulations Title 24, Parts 6 and 11) or later versions, which are anticipated to be more stringent than the 2019 codes. This includes the provision of electric vehicle supply equipment, water-efficient plumbing fixtures and fittings, recycling services, solar on low -rise residential development, and other energy -efficient measures that would reduce the potential for the inefficient use of energy. As a result, energy consumption resulting from the proposed built environment would not be wasteful, inefficient, or unnecessary, and this impact would be less than significant. (Final EIR, pp. 4.15-11 through 4.15-14.)

2. Energy Efficiency Plans
Threshold: Would the Project conflict with or obstruct a state of local plan for renewable energy or energy efficiency?
Finding: Less than significant. (Final EIR, p. 4.15-14.) Explanation: The City’s CAP, Strategic Energy Plan, General Plan/Coastal Land Use Plan, and Municipal Code contain measures intended to increase energy efficiency and expand the use of renewable energy in the City. The Project would include energy efficiency measures to achie ve energy requirements in the City’s Municipal Code. The Project would facilitate bicycle riding among site residents by providing a bicycle parking area at each residential building and the park with a total of 120 bicycle parking spaces. In addition, the Project would include new sidewalk segments and walkways with connections to adjacent pedestrian and bicycle networks identified in the City’s Bicycle and Pedestrian Master Plan that would enhance non -vehicular circulation in the Project area. The proposed bicycle and pedestrian facilities and access would encourage the use of alternative transportation modes, which would reduce VMT and associated fuel consumption. With incorporation of energy efficiency measures in the proposed buildings and decreased fue l consumption through facilitation of reduced and alternative travel, the Project would not conflict with or obstruct implementation of the City’s CAP, Strategic Energy Plan, or any other applicable plans for renewable energy or energy efficiency. This impact would be less than significant. (Final EIR, p.

4.15-14.)
G. GEOLOGY AND SOILS

1. Septic Tanks
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Threshold: Would the Project h ave soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Finding: No impact. (Final EIR, pp. 4.17-1 through 4.17-2.) Explanation: The Project would connect to the existing municipal waste disposal system and would not require the use of septic tanks or alternative waste water disposal systems. Therefore, impacts related to soils incapable of adequately supporting the use of septic tanks w ould not occur. (Final EIR, pp. 4.17 -1 through 4.17-2.)

2. Paleontological Resources
Threshold: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Finding: No impact. (Final EIR, p. 4.17-1.)
Explanation: The Project site is undeveloped. Consequently, there are no State or locally listed or eligible historic structures or resources on -site, and Project implementation would not result in any impact on such resources in Goleta.

There are no un ique paleontological resources or sites, or unique geologic features on the Project site. No such impacts to these types of resources would occur as a result of Project implementation. (Final EIR, p. 4.17-1.) H. GREENHOUSE GAS EMISSIONS

1. Emissions Generation
Threshold: Would the Project g enerate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Finding: Less than significant. (Final EIR, p. 4.6-14.) Explanation: Construction Emissions. For the purpose of this analysis, construction activity is assumed to occur over a period of approximately 36 months. The construction analysis also includes a discussion of pre -construction soil export activity, which would occur prior to the main construction phase, to remove excess stockpiled soil and prepare the site for construction of the Project. Pre -construction export is outlined in two separate Scenarios (Scenario 1 and 2) as described in the Final EIR, Section 4.2, Air Quality.

Modeled Scenario 1 assumes tha t the existing stockpiled material would be removed using 9-CY trucks, which would require a total of 25,556 one -way haul truck trips; Modeled Scenario 2 assumes that 20 -CY trucks would be used to haul the material, resulting in approximately 11,500 one -way haul truck trips.
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Construction activity for the Project would generate an estimated 3,197 MT CO2e under Scenario 1 or 2,648 MT CO2e under Scenario 2. Following the SLOAPCD’s recommended methodology to amortize emissions over a 50 - year period (the assumed life of the Project), construction of the Project would generate an estimated 64 MT of CO2e per year under Scenario 1 or 88 MT of CO2e per year under Scenario 2. The updated soil export amount of 92,000 cubic yards would result in fewer haul truck trips than what was modeled for both scenarios. Therefore, the estimates of construction emissions in Table

4.6-3 of the Final EIR are greater than, and thus, more conservative than the actual construction emissions for the Project.

Operational Emissions. Long-term emissions relate to area sources, energy use, solid waste, water use, and transportation. Each of these sources are discussed below, and associated GHG emissions were estimated using CalEEMod. Project sustainable design features described in Appendix B of the Final EIR based on applicant -provided information, would reduce GHG emissions associated with operational emissions. The sustainable design features associated with this project that have quantifiable reductions include:
 Increased density of dwelling units to 19.1 units per acre;  Increased transit accessibility, with the nearest station located 0.4 mile from the site;
 Integration of below market rate (affordable) housing, of 31 percent of proposed dwelling units;
 Improved pedestrian network by connecting the Project and surrounding neighborhoods with pedestrian facilities contiguous with the Project site; and
 Limited parking supply with a 2.2 percent reduction in total required spaces per the City zoning code.

Area Source Emissions. Direct sources of air emissions located at the Project site include consumer product use and landscape maintenance equipment.

Area source emissions would be approximately 4 MT of CO2e per year.

Energy Use . Operation of on -site development would consume both electricity and natural gas. The generation of electricity through combustion of fossil fuels typically yields CO2, and to a smaller extent, N2O and CH4.

Electricity consumption associated with the Project would generate approximately 0 MT of CO2e per year due to the 1 00 percent solar requirement, and natural gas use would generate approxi mately 213 MT of CO2e per year . Thus, overall energy use at the Project site would generate approximately 213 MT of CO2e per year.

Solid Waste Emissions. In accordance with AB 939, the CalEEMod emissions estimate assumes by default that the Project would achieve at least a 50 percent diversion rate of recyclable materials. Based on this estimate, solid waste associated with the Project would generate approximately 71 MT of CO2e per year.
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Water Use Emissions. Based on the amount of electricity used to supply and convey water for the Project, the Project would generate approximately 35 MT of CO2e per year.

Transportation Emissions . Mobile source GHG emissions were estimated using the avera ge daily trips for the Project according to the Project traffic and circula tion study and VMT calculations . The Project would generate approximately 4,675,285 annual VMT. As noted above, CalEEMod does not calculate N2O emissions related to mobile sources. Rincon estimated N2O emissions and included these in the overall emissions total, based on the Project’s VMT using calculation methods provided by CARB (CARB, 2018).

The Project would generate a total of approximately 1,262 MT CO2e, associated with mobile emissions.

Combined Construction, Operation, and Mobile Source Emissions. Table 4.6- 4 of the Final EIR shows the combined construction and operational GHG emissions associated with development of the Project. The maximum estimated annual operational indire ct and direct emissions, would be approximately 1,661 MT CO2e per year. The service population for the Project is 839 persons. This equates to approximately 2.0 MT CO2e/resident/year. GHG emissions associated with the Project would not exceed the 2.7 MT CO 2e/resident/year threshold of significance. Therefore, this impact would be less than significant. (Final EIR, pp. 4.6-14 through 4.6-

16.)

2. Emission Reduction Plans
Threshold: Would the Project c onflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases? Finding: Less than significant. (Final EIR, p. 4.6-17.) Explanation: In July 2014, the City of Goleta adopted a CAP. The CAP outlines a programmatic approach to review the potential from GHG -related impacts associated with new development. As indicated in Table 4.6-5 of the Final EIR, the Project would be consistent with applicable CAP Strategies.

Consistency with SBCAG’s 2040 RTP/SCS . SBCAG’s 2040 RTP -SCS provides land use and transportatio n strategies to reduce regional GHG emissions. The project’s consistency with applicable goals and objectives from the 2040 RTP -SCS is discussed in Table 4.6 -6 of the Final EIR. The project would be consistent with the applicable goals and objectives from the SBCAG 2040 RTP -SCS. Therefore, the project would not conflict with or obstruct implementation of the SBCAG 2040 RTP-SCS.

Consistency with 2017 Scoping Plan . The principal state plans and policies are AB 32, the California Global Warming Solutions Act o f 2006, and the subsequent legislation, SB 32. The quantitative goal of AB 32 is to reduce 61 Attachment 1
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GHG emissions to 1990 levels by 2020 and the goal of SB 32 is to reduce GHG emissions to 40 percent below 1990 levels by 2030. Pursuant to the SB 32 goal, the 2017 Scoping Plan was created to outline goals and measures for the state to achieve the reductions. The 2017 Scoping Plan’s strategies that are applicable to the proposed project include reducing fossil fuel use, energy demand, and VMT; maximizing recycling and diversion from landfills; and increasing water conservation. The project would be consistent with these goals through project design, which includes complying with the 2019 Building Energy Efficiency Standards, requiring the installation of solar panels on all new residential buildings, and water-use reductions required by CALGreen (Part 11 of Title 24). The project would be served by Southern California Edison, which is required to increase its renewable energy procurement in accordance with SB 100 targets. The project would be located in an area well -served by transit and within walking and biking distance of several commercial and recreational destinations, which would reduce future residents’ VMT and associated fossil fuel usage. Therefore, the project would be consistent with the 2017 Scoping Plan.

Conclusion. The Project would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs and would therefore be consistent with the objectives of AB 32, SB 32, SB 375, and the City’s CAP. This impact would be less than significant. (Final EIR, pp. 4.6-17 through 4.6-20.)
I. HAZARDS AND HAZARDOUS MATERIALS

1. Hazardous Materials
Threshold: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Finding: Less than significant. (Final EIR, p. 4.7-9.)
Explanation: As part of the Phase I ESA conducted for the Project site, a database search of public lists of sites that generate, store, treat, or dispose of hazardous materials or sites for which a release or incident has occurred was conducted for the Project site and included data from surrounding sites within a one-mile radius of the property. The Project site and adjoining properties were not listed in any of the databases searched by EDR. Based on standard sources reviewed and site observations, releases of chemic als of concern may have occurred on the Project site and has occurred on adjacent properties.

However, contaminated soils are at a depth that eliminates potential impacts (Property Solutions Inc., 2014). In addition, the location of contaminated soils has been identified and these soils are proposed to be exported prior to Project construction.

The documentation reviewed as part of the Phase I ESA concluded that various areas of the Project site have experienced the delivery and removal of 62 Attachment 1
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contaminated soils over a period of years. The following provides a summary of documentation reviewed and action taken for imported fill on the Project Site:
 In its Phase I Environmental Site Assessment report dated April 2, 1999, Dames & Moore noted the presence of large piles of fill soil on the Project site. The source of the fill was not identified and no discolored soil was noted. Dames & Moore did not identify the fill as a recognized environmental condition, and made no recommendations for further action.
 In its Report of Soil Removal dated August 12, 2004, Earth Systems Pacific documented the removal of approximately 130 cubic yards of hydrocarbon-contaminated soil (diesel fuel or fuel oil) that had mistakenly been deposited on the Project site. The removal actio n included the collection and analysis of post -excavation soil samples in order to evaluate the adequacy of the remedial action. A total of 400 cubic yards of soil was transported for off -property disposal. Earth Systems Pacific concluded that the remedial action was adequate.
 In its Soils Material Report dated July 20, 2010, Earth Systems Pacific noted a “slight hydrocarbon odor” in the logs for all five soil borings advanced on the southwestern arm of the Project site for geotechnical engineering purposes. Earth Systems Pacific’s A-A’ cross section, which extends for more than 600 feet from northeast to southwest across the investigated area, identifies a “slight hydrocarbon odor” from an upper depth of 10 to 15 feet below ground extending to a lower depth of 16 to 25 feet below ground surface. Earth Systems Pacific’s B-B’ cross section, which extends for more than 800 feet from north to south across the investigated area, also identifies a “slight hydrocarbon odor” from an upper depth of 10 to 15 feet belo w ground extending to a lower depth of 16 to 25 feet below ground surface. As described above, this was determined to be a de minimis finding (negligible impact) in the Phase I ESA (September 2014).
 In its Geotechnical Engineering Report dated July 8, 2014, Earth Systems Pacific noted that groundwater on the subject property occurred at depths as shallow as 22.5 feet below ground surface.
 In its Results of Soil Analysis, Northwest Stockpile dated August 1, 2014, Earth Systems Pacific noted the presence of s tained and odorous soils, which, in their estimation, might render this soil (proposed to be exported) undesirable for use at a property that is to be developed as a school, hospital, or residence. Earth Systems Pacific reported that laboratory analysis did not identify concentrations of target compounds that would preclude the use of the soils for fill at properties proposed for other uses less sensitive than uses such as a school, hospital, or residence.

On the basis of the documentation reviewed, Proper ty Solutions Inc. concluded that because of its depth, the soil that was noted with a “slight 63 Attachment 1
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hydrocarbon odor,” appears to be de minimis (negligible) in its potential impact. This soil generally does not present a threat to human health or the environment and typically would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. In addition, the location of contaminated soils has been identified and these soils are proposed to be exported prior to Project construction. The management of the imported soils documented on the Project site is ongoing and would be subject to regulatory requirements of the City of Goleta (grading permits) and the Regional Water Quality Control Board (RWQCB), including the preparation of an associated Soil Management Plan that includes controls on the use and placement of the exported soils to reduce potential risks from exposure to potential contaminants in the soil. Compliance with these regulatory requirements (grading permi t and RWQCB permit including a Soil Management Plan) would ensure that potential impacts related to contaminated soils would remain less than significant. (Final EIR, pp. 4.7 -9 through 4.7-10.)

2. Accident or Upset
Threshold: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Finding: Less than significant. (Final EIR, p. 4.7-11.) Explanation: Proposed residential structures and future residents on the project site would be located in proximity to several types of facilities in which hazardous materials are used, stored, or transported: nearby businesses, the UPRR railroad tracks, and the U.S. 101 freeway. The Project would not result in an increase in the use, store, and transport hazardous chemicals associated with the nearby businesses, or in the transport of hazardous materials on the existing UPRR railroad tracks or U.S. 101. Therefore, the Project wo uld not result in increased risk associated with accident release from these facilities.

However, the Project may be exposed to increased risk from these existing activities near the Project site. Although not considered an impact under CEQA pursuant to the CBIA v. BAAQMD ruling, each type of facility, and the potential increase in risk associated with these facilities, is discussed below for informational purposes.

Nearby Businesses
A mix of commercial and industrial businesses is located directly east of the Project site in the General Industrial zone district. Specific types of businesses in this area include software development, electric parts supplier, hardware store, property management, and automotive repair. Types of hazardous materials stored and u sed in these facilities consist mainly of oils and other lubricants, as identified in the Phase I report for the project site by Property Solutions, Inc.
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The Santa Barbara County HMU regulates businesses that handle hazardous materials, generate or treat hazardous waste, or operate storage tanks with hazardous materials. As the County CUPA, the HMU promotes compliance with applicable hazardous material laws and regulations.

The HMU’s Business Plan Program requires businesses handling hazardous materials in quantities in excess of specified amounts to submit inventories of those materials and to develop appropriate employee training and emergency procedures. For such businesses, including those in close proximity to the Project site, the HMU requires preparation and filing of a Business Plan and Emergency Response Plan that ensures that all nearby hazardous materials are handled appropriately to minimize potential health and environmental effects. The HMU also maintains the inventory and emergency contact information submitted from businesses in a computerized data management system and, in turn, provides this information to emergency response agencies.

In April 2016, the HMU provided an updated list of businesses located within 1/4-mile of the project site that use potentially hazardous chemicals. A number of light-industrial and commercial uses in the vicinity of the project site use hazardous chemicals in the course of operation.

The requirement that businesses prepare and submit Business Plans to Santa Barbara County means that the HMU and the Fire Department is aware of the hazardous materials that are stored at these businesses, where they are stored, and in what quantities. Fire Department personnel periodically visit the facilities to become more famil iar with them. All businesses submitting Business Plans are also required to prepare and submit
emergency/contingency response plans. Hence, all businesses are required to be prepared to take immediate action in the event of an incident. Fire Department personnel are required to also be prepared to take action based on the Business Plan. Businesses are required to update their Business Plans whenever major changes occur such as the addition of another hazardous material. In addition, a business would be req uired to apply for permits if a storage tank is to be added. Such an application would be reviewed by the building and fire departments before a permit would be issued. This would ensure that all codes are met and that additional mitigation measures are implemented as deemed necessary.

The laws and regulations in place mitigate the potential to the maximum extent feasible. In addition, in the event of an accident, the requirement for pre-planning and emergency response plans reduces the potential consequences of the accident. Therefore, while it is not possible to completely eliminate the potential for accidents, the probability for a future hazardous material release at any of the nearby facilities that store and use hazardous materials would be low; therefore, this impact would be less than significant.

UPRR Rail Line
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A unit train transporting crude oil travels along the UPRR adjacent to the project site one to two times per week. In addition, local trains deliver freight, including hazardous materials to businesses located in the area. These trains operate in the Goleta area approximately four times per week. Trains hauling empty auto cars and container cars travel south along the route approximately once per day and a train hauling empty oil tank cars tr avels north one to two times per week (Cuesta Pass Rails, 2015). However, it is possible that additional through trains transporting freight, including hazardous materials, could run in the future as they have in the past. Nothing prevents additional through trains carrying hazardous materials from using the rail lines, and no additional agency approvals would be required for this to occur. The public health risk posed by an accidental release would depend upon the materials involved, their toxicity, and th e wind direction that could carry emissions from the release. The prevailing weather pattern at the time of release would affect the rate of dilution and the direction of transport of any gaseous or volatilized materials.

Upset may also result from the ex plosion of highly volatile materials within the train cars or during a derailment. Because the project site is adjacent to the rail line, explosion and fire could pose a health risk in addition to that which could result from inhalation of volatile chemicals and fumes.

The potential impact can be evaluated only in terms of probabilities. The possibility of impact is determined by a combination of the probability of an accident, the probability that the released cargo is hazardous, and the probability that winds are blowing from the spill or release into the air toward occupied receptor sites. An analysis of the potential for a rail accident resulting in the release of hazardous material was recently completed on two projects located adjacent to the UPRR and approximately ¾ and 1 ½ miles west of the project site (Envicom, 2012a and 2012b). The methodology used in these reports has been used to estimate the potential risk of local freight train accidents to the Project. Statistical data contained in two oil transportation studies, Washington State 2014 Marine and Rail Transportation Study (State of Washington, 2015) and U.S. Rail Transportation of Crude Oil: Background and Issues for Congress (Frittelli, et. al. 2014) were used to estimate the potential risk fro m the crude oil train to the Project.

Approximately six percent of total freight movement by rail in the United States in 2007 (the most current data available from the Office of Freight Management and Operations) consisted of hazardous materials (Office o f Freight Management and Operations, 2012). The probability of a freight train accident over the 9-year period 2006 through 2014 was 1.6 x 10-5 (16 in one million) per mile of travel (Federal Railroad Administration Office of Safety Analysis, 2015). The pr obability of a hazardous materials release given an accident during this time period was 2.0 x 10 -3 (two in one thousand).

Approximately four local freight trains per day operate on the tracks adjacent to the Project site. The risk of a rail accident with release of hazardous 66 Attachment 1
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material within this one-mile segment is calculated as follows:
 4 trains per week x 52 weeks x 1 mile traveled near the Project site x 1.6 x 10 -5 (probability of accident per mile) x 2.0 x 10 -3 (probability of a hazardous materials release given an accident) = 6.6 x 10-6 (once every 150,000 years)
Injuries or fatalities may be somewhat less than the calculated probability of an accident. People located inside their apartments may be shielded from the impacts of a fire. Buildings and walls may also provide protection from the radiant heat from a fire (Orange County, 2013).

The probability of a crude oil unit train accident is estimated to be between

0.81 and 2.08 accidents per billion ton -miles transported (State of Washington, 2015). A typical unit train carries approximately three million gallons. Assuming 1.5 -unit trains per week, this equates to 234 million gallons of crude oil transported past the Project site annually. The weight of crude oil varies depending on the type, but crud e oil generally weighs less than water. Assuming a conservative average weight of 7.5 pounds per gallon means that approximately 880,000 tons of oil are transported past the Project site annually. Assuming an accident rate of 2 accidents per billion ton -miles transported results in an annual probability of crude oil unit train accident with release within a half mile of the Project site (one mile segment) of 3.6 x 10-6 or once every 275,000 years. Such an accident could result in a spill, a fire, and/or an explosion. A fire or explosion could impact the health and safety of people at the Project.

Based on this analysis, the risk of derailment with or without hazardous material release is statistically low. The Goleta General Plan FEIR (3.7 -2 Transport) identifies this potential impact as significant with respect to rail traffic along the UPRR ROW, where the project site is located. The FEIR states that the potential impact “remains significant” and no feasible mitigation measures are available to reduce the level of significance. The City Council adopted a statement of overriding considerations with respect to this impact as part of its action in certifying the FEIR for the General Plan.

However, the project site is designated for residential use under the ado pted General Plan, and the Project would be consistent with the existing General Plan land use designation and zoning. Therefore, the Project would not increase exposure of residents to risk from transport of hazardous materials on the existing UPRR railro ad tracks beyond levels already identified in the General Plan FEIR. As such, this impact would be less than significant.

U.S. 101 Freeway
The annual average daily truck traffic (AADT) on U.S 101 at Los Carneros Road in 2014 was 5,922 (Caltrans, 2015). This represented 9.0 percent of the total AADT. About half of these (49 percent) were trucks with five or more axles. In 2007, trucks transported the largest volume of hazardous materials 67 Attachment 1
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through the nation’s transportation system, moving 1.2 out of 2.2 billion tons of hazardous materials. Approximately 13.7 percent of materials transported by truck were classified as hazardous (Bureau of Transportation Statistics, 2011). Table 4.7 -3 shows the breakdown of hazardous materials shipped in trucks by hazard class.

The accident rate for trucks transporting hazardous materials is estimated to be 3.2 x 10-7 per mile (0.32 in one million) (Battelle, 2001). The vast majority of incidents involving truck releases will not impact resources located more than a few thousand feet from the place of the accident (see discussion below on the potential hazards from the various types of hazardous materials. To be conservative, the analysis has assumed that accidents that occur with a half mile of the project site (one mile segment ) have the potential to impact the site. Thus, the probability of an accident involving a truck on U.S. 101 within a one-mile segment adjacent to the Project is calculated as follows:
 5,922 (truck AADT) x 365 (days per year) x 0.077 (percent trucks with ha zardous materials) x 3.2 x 10 -7 (accident rate per mile assumed for U.S 101) = 0.053 or one accident every 19 years It should be noted than an accident involving a truck carrying hazardous material does not always result in the release of the material. The Federal Emergency Management Agency’s (FEMA) Handbook of Chemical Hazard Analysis Procedures (1989) estimates that approximately half of accidents result in a release, including very minor valve and fitting leaks. Omitting minor release accidents, a spill may result from an accident about 15 percent to 20 percent of the time (FEMA, 1989). After applying the more conservative assumption of 20 percent, the probability of a truck accident releasing hazardous material on U.S 101 within one half mile of the pro ject is 0.053 x

0.2 = 0.01, or once every 100 years.

The Project site is approximately 250 feet and 300 feet south of the southbound lane of the freeway at the eastern and western sides of the site, respectively. The potential impact from a truck accident with release would be dependent of the type and amount of material released. Table 4.7 -3 of the Final EIR presents the probability of release by cargo type. The sum of the probabilities of the individual hazard classes presented below is 0.01 or once every 100 years. The consequence of each type is discussed below.

Class 1, Explosives . An event involving explosives could cause property damage on the Project site as well as injury and or death. The probability of a release of explosive material is 1.4 x 1 0-5 or once every 71,400 years.

Class 2, Gases. The probability of a release of a gas is 1.1 x 10 -3, or once every 890 years. For a gas release to impact the Project, the wind would have to be blowing from the north. In addition, the gas would either have to be flammable or toxic and enough material would have to be released to 68 Attachment 1
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generate a hazardous cloud that could reach the site. If a flammable cloud were to be ignited immediately at the source of the release, then there would be no impact to the Project site. FEMA (1989) estimates that 63 percent of the gases transported are flammable. Assuming a probability of the wind blowing from the north at 50 percent, the probability of a release possibly reaching the Project site is 3.5 x 10 -4 or once in 2,890 year s. Even if a gas cloud were to reach the property, a person would not necessarily be impacted.

A non-toxic flammable gas would not pose a hazard unless it becomes ignited.

The impact from a toxic gas cloud would depend on the type of material, concentration, and sensitivity of the person to that material. One effective way of responding to a release of a toxic gas is to shelter in place. Buildings provide shelter against contaminants by three methods: condensation of vapors on exterior walls, passive filter ing by the building material and structure, and providing a physical barrier to vapor/gas intrusion. In addition to providing a physical barrier and causing vapors to condense, building exteriors provide a “filter” for contaminants as surfaces, cracks and pores absorb the contaminants before they enter the building. Once those vapors/gases enter the building they are diluted by the uncontaminated air already in the building. In addition, since a structure slows the rate of vapor/gas infiltration the effects of fluctuations in concentration are reduced.

This reduces the indoor concentration relative to the outdoor concentration (Governor’s Office of Emergency Services, 2014).

Class 3, Flammable liquids. The majority of materials transported by trucks are classified as flammable liquids. This class includes materials that are either flammable or combustible. The probability of a release of a Class 3 liquid is estimated to be 7.9 x 10-3 or once every 130 years . There are two potential hazards from a release of a flammable liquid: a fire at the release point creating radiant heat that can produce burns and, if not ignited, a flammable gas cloud that can move with the wind and become ignited someplace else. A pool fire at the point of the accident produces radiant heat that can cause burns. The intensity of the heat is dependent on the material on fire and the size of the area on fire. The intensity of the radiant heat decreases as a function of distance. The California Department of Education (CDE, 2007) estimates that the hazard zone that could begin causing second degree burns on exposed skin after 30 seconds exposure from a gasoline fire with a diameter of 100 feet (7,800 square feet) would extend to 200 feet. People located indoors or behind structures would be afforded some protection from the heat. People outdoors would feel the heat and naturally move away from it. Based on CDE estimates (2007) for a flammable gas cloud from a gasoline release to reach the Project site, the diameter of the release would have to be greater than 460 feet (166,200 square feet). A combustible material does not produce a flammable gas cloud because it does not produce enough flammable vapors at ambient temperature to become ignited (e.g., its flash point is high).

Class 4, Flammab le Solids . The probability of a release of a flammable solid is 9.1 x 1 0-5 or once every 11,000 years . Flammable solids 69 Attachment 1
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are normally more difficult to ignite than flammable liquids. In addition, because flammable solids do not spread like a liquid when rel eased, if they become ignited the surface area on fire is relatively contained. Therefore, the radiant heat produced is normally lower than that of a flammable liquid and the area potentially impacted is lower.

Class 5, Oxidizers and Organic Peroxides . An oxidizer is a liquid or solid material that may, generally by yielding oxygen, cause or enhance the combustion of other materials. An organic peroxide is any organic compound containing oxygen (O) in the bivalent -O-O- structure. If an oxidizer or organic peroxide is also explosive, flammable, or a gas it is classified as such and not as an oxidizer or organic peroxide. Thus, a release of such material can exacerbate the consequences of an accident involving other hazardous materials but a release without an explosive, flammable, or gas classification would not pose a hazard to the Project site. The probability of a release of a Class 5 material is 6.7 x 10-5 or once every 14,500 years.

Class 6, Toxic (poison). These are poisonous materials other than gases. The probability of a release of a Class 6 material is 5.1 x 1 0-5 or once every 19,500 years. Because these materials are not gases, they would only be a hazard if someone comes in contact with them or is very near them. A release of a Class 6 material should not impact the Project site.

Class 7, Radioactive Materials . Very little radioactive material is transported by truck. The probability of a release of a Class 7 material is 1.0 x 10-6 or once every 500,000 years. Therefore, the probability of an even t involving radioactive materials would be one in one million.

Class 8, Corrosive Materials . These materials are considered to be hazardous because they corrode other materials that they may come in contact with. Because the freeway is located over 250 fee t north of the Project site, on the far side of the railroad ROW, it is unlikely that the Project site would come into contact with corrosive materials in the event of a truck accident, and such materials do not present a hazard to the Project site.

Class 9, Miscellaneous Dangerous Materials . These are hazardous substances that do not fall into the other categories and include materials such as asbestos, air -bag inflators, self -inflating life rafts, and dry ice. The probability of a release of a Class 9 material is 2.8 x 10-4 or once every 3,500 years. Based on the type of materials in this class, a release is unlikely to impact the project site.

Based on this analysis, the risk of exposure to upset conditions from U.S. 101 is statistically low. Neverthele ss, an accident involving hazardous materials on U.S. 101 could impact the surrounding population. The General Plan FEIR (3.7-2 Transport) identifies this potential impact as significant with respect to trucking, particularly along the U.S. 101 corridor, w here the project site is located. The FEIR states that the potential impact “remains significant” and 70 Attachment 1
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no feasible mitigation measures are available to reduce the level of significance. The City Council adopted a statement of overriding consideration with respect to this impact as part of its action in certifying the FEIR for the General Plan. However, the Project site is designated for residential use under the adopted General Plan, and the Project would be consistent with the existing General Plan land use designation and zoning.

Therefore, the Project would not increase exposure of residents to risk from transport of hazardous materials on U.S. 101 beyond levels already identified in the General Plan FEIR. Consequently, this impact would be less than significant.

Risk of Upset Impact Summary
Based on the above discussion, the potential for a hazardous material release from area businesses, U.S. 101, and the UPRR is low. The potential consequences of such a release could be catastrophic, resulting in injury or death to project site residents. However, the Project would not increase exposure of residents to risks associated with chemical leaks and fire from nearby businesses, derailed trains, and truck accidents beyond levels already anticipated in the General Plan FEIR. The Project also would be subject to conditions of approval, such as the following:
 Developing a plan for evacuation procedures in the event of accident/release of hazardous materials for approval by the Director of Planning and Environmental Review or designee before of the City issues a building permit.
 Developing and providing leases for apartment units that provide notification of hazards associated with the Project’s location, including UPRR, US 101, and nearby businesses for approval by the City Attorney and by the Director of Planning and
Environmental Review, or designee, before the City issues a building permit.
 Developing a notice to future property owners regarding the potential risks of upset to be reviewed and approved by the Director of Planning and Environmental Review and the City Attorney, and then recorded either as part of the Final Map or before of the City issues a building permit.

These conditions would further avoid risk of upset in the Project vicinity.

Therefore, this impact would be less than significant. Mitigation would not be required because no significant Project -specific impacts have been identified. (Final EIR, pp. 4.7-11 through 4.7-18.)

3. Hazards Near Schools
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Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school?
Finding: No impact. (Final EIR, pp. 4.2-15 through 4.2-16.) Explanation: The Project site vicinity is primarily occupied by residential and light industrial development. Sensitive receptors near the Project site include residential uses (Willow Springs I and II) to the south of the project site across Camino Vista. There is no existing or proposed school within one -quarter mile of the Project site. New sensitive receptors on the Project site would be exposed to hazardous air pollutants at levels that may cause health risks. With implementation of the conditions of approval, whic h require forced air ventilation with filter screens on outside air intake ducts, the proposed residences closest to U.S. 101 and the Union Pacific Railroad would not be exposed to hazardous air pollutants that exceed significance thresholds. (Final EIR, pp. 4.2-15 through 4.2-16.) No impact would occur.

4. Waste Sites
Threshold: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it creat e a significant hazard to the public or the environment?
Finding: Less than significant. (Final EIR, p. 4.7-9.)
Explanation: As part of the Phase I ESA conducted for the Project site, a database search of public lists of sites that generate, store, treat, or dispose of hazardous materials or sites for which a release or incident has occurred was conducted for the Project site and included data from surrounding sites within a one-mile radius of the property. The Project site and adjoining properties were no t listed in any of the databases searched by EDR. Based on standard sources reviewed and site observations, releases of chemicals of concern may have occurred on the Project site and has occurred on adjacent properties.

However, contaminated soils are at a depth that eliminates potential impacts (Property Solutions Inc., 2014). In addition, the location of contaminated soils has been identified and these soils are proposed to be exported prior to Project construction.

The documentation reviewed as part of the Phase I ESA concluded that various areas of the Project site have experienced the delivery and removal of contaminated soils over a period of years. The following provides a summary of documentation reviewed and action taken for imported fill on the Pr oject Site:
 In its Phase I Environmental Site Assessment report dated April 2, 1999, Dames & Moore noted the presence of large piles of fill soil on the Project 72 Attachment 1
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site. The source of the fill was not identified and no discolored soil was noted. Dames & Moore did not identify the fill as a recognized environmental condition, and made no recommendations for further action.
 In its Report of Soil Removal dated August 12, 2004, Earth Systems Pacific documented the removal of approximately 130 cubic yards of hydrocarbon-contaminated soil (diesel fuel or fuel oil) that had mistakenly been deposited on the Project site. The removal action included the collection and analysis of post -excavation soil samples in order to evaluate the adequacy of the remedial action. A to tal of 400 cubic yards of soil was transported for off -property disposal. Earth Systems Pacific concluded that the remedial action was adequate.
 In its Soils Material Report dated July 20, 2010, Earth Systems Pacific noted a “slight hydrocarbon odor” in th e logs for all five soil borings advanced on the southwestern arm of the Project site for geotechnical engineering purposes. Earth Systems Pacific’s A-A’ cross section, which extends for more than 600 feet from northeast to southwest across the investigated area, identifies a “slight hydrocarbon odor” from an upper depth of 10 to 15 feet below ground extending to a lower depth of 16 to 25 feet below ground surface. Earth Systems Pacific’s B-B’ cross section, which extends for more than 800 feet from north t o south across the investigated area, also identifies a “slight hydrocarbon odor” from an upper depth of 10 to 15 feet below ground extending to a lower depth of 16 to 25 feet below ground surface. As described above, this was determined to be a de minimis finding (negligible impact) in the Phase I ESA (September 2014).
 In its Geotechnical Engineering Report dated July 8, 2014, Earth Systems Pacific noted that groundwater on the subject property occurred at depths as shallow as 22.5 feet below ground surface.
 In its Results of Soil Analysis, Northwest Stockpile dated August 1, 2014, Earth Systems Pacific noted the presence of stained and odorous soils, which, in their estimation, might render this soil (proposed to be exported) undesirable for use at a prope rty that is to be developed as a school, hospital, or residence. Earth Systems Pacific reported that laboratory analysis did not identify concentrations of target compounds that would preclude the use of the soils for fill at properties proposed for other uses less sensitive than uses such as a school, hospital, or residence.

On the basis of the documentation reviewed, Property Solutions Inc. concluded that because of its depth, the soil that was noted with a “slight hydrocarbon odor,” appears to be de min imis (negligible) in its potential impact. This soil generally does not present a threat to human health or the environment and typically would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. In addition, the location of contaminated soils has been identified and these soils are proposed to be exported prior to Project construction. The management of the 73 Attachment 1
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imported soils documented on the Project site is ongoing and would be subject to regulatory r equirements of the City of Goleta (grading permits) and the Regional Water Quality Control Board (RWQCB), including the preparation of an associated Soil Management Plan that includes controls on the use and placement of the exported soils to reduce potent ial risks from exposure to potential contaminants in the soil. Compliance with these regulatory requirements (grading permit and RWQCB permit including a Soil Management Plan) would ensure that potential impacts related to contaminated soils would remain l ess than significant. (Final EIR, pp. 4.7 -9 through 4.7-10.)

5. Public Airports
Threshold: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
Finding: Less than significant impact. (Final EIR, p. 4.17-2.) Explanation: The Project site is not located near a private airstrip, but is located within two miles of the Santa Barbara Municipal Airport. However, the property is not located within any of the airport’s approach or clear zones and is not subject to review by the Airport Land Use Commission. Therefore, the Project would not be exposed to significant airpo rt safety hazards. (Final EIR, p. 4.17 -2.) Impacts would remain less than significant.

6. Emergency Plans
Threshold: Would the Project i mpair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Finding: No impact. (Final EIR, p. 4.17-2.)
Explanation: Given the Project’s location within an urbanized area and outside of the tsunami run-up area or any flood hazard area, the Project site is not within any adopted emergency response or evacuation plan. (Final EIR, p. 4.17 -2.) Impacts would remain less than significant.

7. Wildland Fires
Threshold: Would the Project e xpose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
Finding: Less than significant. (Final EIR, p. 4.16-3.) 74 Attachment 1
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Explanation: Currently, there is no structural development on the Project site. Construction equipment and containers as well as a substantial amount of stockpiled soil are stored onsite. The topography of the Project site is relatively flat to gently sloping with the exception of the moderately steep slopes that define the boundary of the stockpile soils. A sparse to moderate g rowth of weeds and 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). Th e 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 not 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, p. 4.16-3.)
J. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
Threshold: Would the Project v iolate any water quality standards or waste discharge requirements?
Finding: Less than significant. (Final EIR, p. 4.8-10.) Explanation: The Project would involve construction of 332 residential units and associated landscaping and hardscape. Estimated preliminary Project grading would include approximately 178,000-cubic yards of cut and 15,500-cubic yards of fill with approximately 92,000-cubic yards of export material. Excavation and grading could result in erosion of soils and sedimentation, which could cause temporary impacts to surface water quality and therefore violate water quality standards or contribute additional sources of polluted runoff. Project development would likely require temporary on -site storage of excavated soils (stockpiling). During grading and soil storage, there is the potential for soil migration offsite via wind entrainment and/or water erosion. In addition, there is potential for e rosion caused by the tires of vehicles and equipment throughout the construction period.

Impacts would be minimized during all phases of Project construction through compliance with the Construction General Permit and with City grading regulations. To com ply with these regulations, the applicant would 75 Attachment 1
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be required to prepare and implement a SWPPP, which must include erosion and sediment control BMPs that would meet or exceed measures required by the Construction General 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, temporary 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.

The Construction General Permit r equires the SWPPP to include a menu of BMPs to be selected and implemented based on the phase of construction and the weather conditions to effectively control erosion and sediment using the Best Available Technology Economically Achievable and Best Conventional Pollutant Control Technology (BAT/BCT) and to protect water quality. These construction site management BMPs would be implemented for the Project during the dry season and wet season as necessary depending upon the phase of construction and weather conditions. These BMPs would help ensure effective control of not only sediment discharge, but also of pollutants associated with sediments, including but not limited to nutrients, heavy metals, and certain pesticides or herbicides. Because the development and implementation of a SWPPP is a standard requirement that would apply to this Project, hydrologic impacts from construction would be less than significant. (Final EIR, pp. 4.8-10 through 4.8-11.)

2. Groundwater Supplies
Threshold: Would the Project s ubstantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
Finding: Less than significant. (Final EIR, pp. 4.14-1 through 4.14-12.) Explanation: The Goleta Water District (GWD) is the water purveyor for the City of Goleta.

The GWD service area is located in the South Coast portion of Santa Barbara County with its western border adjacent to El Capitan State Park, its northern border along the foothills of the Santa Ynez Mountains and the Los Padres National Forest, the City of Santa Barbara to the east, and the Pacific Ocean to the south. The service area encompasses approximately 29,000 acres and includes approximately 87,000 residents. GWD includes the City of Goleta, the University of California Santa Barbara, and Santa Barbara Municipal Airport as well as nearby unincorporated areas of Santa Barbara County. 76 Attachment 1
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In June 2017, the GWD adopted its most recent Urban Water Management Plan (UWMP). As discussed in the UWMP, the GWD draws its existing water supplies from four primary sources: Lake Cachuma surface water, the State Water Project, the Goleta Groundwater Basin, and recycled water from wastewater treatment.

GWD’s rights to groundwater drawn from the Goleta Groundwater Basin (Basin) were adjudicated through a court case in 1985 entitled Wright v.

Goleta Water District [Wright v. Goleta Water Dist. (1985) 174 Cal.

App.3d74]. The Wright Judgment gave GWD the right to pump up to 2,000 AFY from the Basin in addition to the right to surplus waters, injected water, return flows, and rights transferred from private pumpers, identified as Exchange Service and Augmented Service. Based on the GWD’s reported amounts of these Exchange and Augmented S ervices, it has conservatively reported an entitlement of 2,350 AFY from the Basin. The Wright Judgment also gave GWD the right to inject excess surface water supplies into the Basin to recharge the Basin and replenish groundwater supplies (GWD, 2010).

In addition to its fixed adjudicated allotment, GWD safeguards for less-than- normal rainfall years by storing excess water runoff during high rainfall years.

This helps to maintain supplies during drought conditions. Excess surface water (e.g., from Cachuma P roject “spill”) during high rainfall years is injected into the Basin as “recharge” through GWD maintained injection wells. The injected recharge volumes are then available to GWD in the future, providing a variable increase in the annual allotment that ca n be tapped, as needed. This is also known as “banking.” Unexercised groundwater rights at the end of a year revert to a stored water right in the Basin. As of December 2015, the GWD Groundwater Management Plan (2016 Update) reported that GWD storage balance in the Basin was 45,959 acre-feet. (Final EIR, pp. 4.14- 1 through 4.14-2.)
At present, the 17.36-gross acre Project site is vacant and generates no water demand. However, Willow Springs I, Willow Springs II, and the Project are entitled to a combined 100.89 AFY in accordance with the Court judgement described above. Water service to the Project site would be provided by the GWD.

In July 2015, MAC Design Associates prepared an Annual Demand Water Report for Willow Springs I, Willow Springs II, and the Project, as proposed at that time. The calculations for water usage were derived from the actual water use data from 2007 to 2015 for Willow Springs I and Willow Springs II, provided by GWD. For the most current Project domestic water use, a 24 month period (January 2012 through December 2013) was used as the base period. The water me ters were categorized as either domestic, landscape, or commercial meters. As domestic water use varies substantially based on the type of unit, the domestic meters were further separated by the following unit types: 1BR/1BA, 2BR/1BA, 2BR/2BA, and 3BR/2BA. To determine the average water consumption rate by unit type, the water usage for each month 77 Attachment 1
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of the base period was totaled and then converted to a monthly average based on the data for the 24 month period. The monthly average was then converted to AFY per month. The total AFY was divided by the number of a single unit type. This method was then replicated for all unit types in the development.

There was insufficient water use history to utilize actual figures for the Project. Therefore, the actual water u sage for Willow Springs I was utilized to project water usage at the Project site. The Project units are smaller than Willow Springs I, so actual water usage would be expected to be lower. The GWD has reviewed and approved the MAC Design Associates water demand for the Project. The Project’s estimated water service demand has since been updated utilizing the rates in the 2015 Annual Water Demand Report, but to account for a reduction in the proposed total unit count since 2015. The proportion (i.e., percent age) of each unit type for the overall reduced unit count is the same as for the previously proposed project. The proposed studios are included with the 1BR/1BA unit types.

Based on the water use study, the Project’s domestic water demand, landscaping water demand, and commercial water demand are estimated at

31.6 AFY, 6.2 AFY, and 1.6 AFY, respectively. The calculations for Project- generated water demand are shown in Table 4.14 -2. The total water demand generated by the Project would be 39.4 AFY (not acco unting for recycling and other water savings). This represents approximately 0.2 percent of the 16,737 AFY of water available from GWD (not accounting for unused recycled water). As the Project is part of the Willow Springs project (Willow Springs I, Willo w Springs II, and Heritage Ridge [formerly North Willow Springs]), it is considered an existing customer of GWD and would meet the criteria for an exemption as outlined in Resolution No. 2014-32.

Water for domestic uses and landscaping on the Project site could potentially be supplied by different sources. However, the recycled water system is not in the vicinity of the Project site. The nearest water main for recycled water, located at the corner of Storke Road and Hollister Avenue approximately 1 mile to the west and south of the site, will extend to Cortona Drive and Hollister Avenue in the future, but will remain out of vicinity for use at the Project site (Jim Heaton, Senior Water Resource Analyst, Goleta Water District, personal communication, June 4, 2015).

The 39.4 AFY of water demand generated by the Project represents 11.4 percent of GWD’s projected surplus of 346 AFY in water supply above current demand levels (GWD UWMP, 2017). Accordingly, the GWD currently has sufficient water supply to provide potable water to the Project and Project impacts to water supply would be less than significant. Based on the total allocation of 100.89 AFY for Willow Springs I, Willow Springs II, and the Project, and water use by the Willow Springs properties of 55.983 AFY, there is 44.907 AFY available to serve the Project. Therefore, the Projects use of 39.4 AFY would be within the allocated water supply. 78 Attachment 1
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In accordance with GWD’s Water Conservation Plan from 2010, the Project also would be required to incorporate feas ible Best Management Practices (BMPs) into its water system design. Such practices include the use of water conserving fixtures and water efficient landscape and irrigation. Impacts would be less than significant without mitigation since the Project’s wate r demand is within the current GWD surplus. Nevertheless, the City recommends the following conditions of approval to further reduce impacts on water supplies.
 Outdoor Water Conservation. Minimize outdoor water use through the following:
a. Use of native and/ or drought tolerant species in the final landscaping;
b. Installation of drip irrigation or other water-conserving irrigation; c. Grouping of plant material by water needs;
d. Limiting turf to less than 20% of the total landscaped area if proposed under the final landscape plan or use of artificial turf in place of living grass (this may exceed the 20% maximum); e. No turf is allowed on slopes of over 4%;
f. Use of extensive mulching (2" minimum) in all landscaped areas to improve the water holding capacity of the soil b y reducing evaporation and soil compaction;
g. Installation of soil moisture sensing devices to prevent unnecessary irrigation;
h. Use of only recycled water for landscape irrigation if the Project site is connected to a recycled water line;
i. Use of plant materi als that can withstand high salinity levels, if recycled water is used for irrigation; and
j. Use of plant materials that are compatible with the Goleta climate pursuant to Sunset Western Garden Book’s Zone 24, published by Sunset Books, Inc., Revised and Updated 2001 edition.
 Indoor Water Conservation . Minimize indoor water use through the following:
a. Insulation of all hot water lines;
b. Installation of re -circulating, point -of-use, or on -demand water heaters;
c. Prohibition of self-regenerating water softening in all structures; d. Use of lavatories and drinking fountains with self-closing valves; and e. Installation of water sense specification toilets in each unit. (Final EIR, pp. 4.14-9 through 4.14-12.)

3. Runoff
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 create or contribute runoff water which would exceed the capacity of existing or planned stor mwater drainage systems or provide 79 Attachment 1
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substantially additional sources of polluted runoff or impede or redirect flood flows?
Finding: Less than significant. (Final EIR, p. 4.8-14.) Explanation: The new residential units associated with the Project would intr oduce a variety of pollutants typical of residential development to a site that is currently vacant and undeveloped. Waste in the form of leftover paints, solvents, cleaning and automotive products, or pool chemicals associated with recreational facilities, could be spilled or dumped into the storm drain system.

Nutrients from fertilizers and animal waste along walking trails, including nitrogen and phosphorous, can result in excessive or accelerated growth of vegetation or algae, resulting in oxygen deplet ion and additional impaired uses of water. Heavy metals such as lead, cadmium, and copper are the most common metals found in urban storm water runoff. These metals can be toxic to aquatic organisms, and have the potential to contaminate drinking water supplies. Furthermore, impermeable surfaces such as driveways would accumulate deposits of oil, grease, and other vehicle fluids and hydrocarbons (which can be toxic to aquatic organisms at low concentrations), while preventing infiltration of polluted runoff during storm events and facilitating the off-site transport of pollutants.

Residential development on the Project site would incrementally increase the amount of pollutants that could be contained in the first flush of runoff from the area associated with residents and associated uses (car washing, chemical cleaners, pets, trash, etc.). The increase in impervious surface of approximately 8.0 acres would incrementally increase peak flows from the site to offsite drainages. Stormwater runoff from the Projec t site would generally flow to detention basins before being discharged and eventually flowing into Tecolotito Creek, Los Carneros Creek, and the Goleta Slough.

Project features such as landscaping and permeable paving would mitigate the discharge of polluted runoff. In addition, installation of mutt -mitt dispensers and refuse receptacles along walking paths, and in park or open areas would reduce pollution from animal waste. As discussed in the preliminary drainage analysis for the Project, the proposed d rainage infrastructure would provide infiltratable features onsite to remove stormwater pollutants prior to discharge off-site. As downspouts on the proposed buildings convey runoff from rooftops, it would be discharged to landscaped common areas. A portio n of runoff on the site would infiltrate the pervious surface in landscaped areas and percolate through the soil, reducing the transport of pollutants off -site. In addition, the proposed use of permeable pavers within the parking areas onsite, would enable infiltration of surface water during storm events.

Nevertheless, the potential remains for pollutants from operation of the project to be discharged into Tecolotito Creek, Los Carneros Creek, and the Goleta Slough, all of which are listed as impaired waterways based on Central Coast RWQCB criteria. To address the potential for pollutant discharges into these impaired water bodies, the Project would be required to comply with 80 Attachment 1
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the Post-Construction Stormwater Management Requirements of Order R3 - 2013-0032.

By increasing the amount of impervious surface onsite by approximately 8.0 acres, the Project would be subject to the most stringent criteria under Post - Construction Requirements. Based on the proposed site design, the Project would meet the performance mea sure for water quality (treatment of stormwater runoff up to the 95th percentile).

The applicant would be required to apply for a National Pollutant Discharge Elimination System (NPDES) Storm Water Permit from the California RWQCB. Implementation of the NPDES-required Storm Water Permit would ensure that 100 percent of rainfall from the site would flow either into/onto the source control BMPs or onto areas of undisturbed natural vegetation, and would reduce impacts that could occur from pollutants on -site or increase in storm flows on or off -site. Furthermore, the applicant would be required to incorporate BMPs for stormwater quality into the Project’s design, consistent with the requirements of the Central Coast RWQCB’s Post -Construction Requirements.

With compliance with the Post-Construction Requirements, the Project would have a less than significant impact on water quality. (Final EIR, pp. 4.8 -14 through 4.8-15.)

4. Flood Hazard
Threshold: In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to project inundation?
Finding: No impact. (Final EIR, p. 4.17-2.)
Explanation: No portion of the Project site is within or adjacent to a local 100 -year flood hazard area. The Project site is not within a levee, dam inundation area and is not otherwise at risk of inundation. Therefore, no impacts related to redirection of flood flows or risk of release of pollutants due to inundation would occur. (Final EIR, p. 4.17-2.)

5. Water Quality Control Plan
Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant. (Final EIR, p. 4.8-14.) Explanation: The new residential units associated with the Project would introduce a variety of pollutants typical of residential development to a site that is currently vacant and undeveloped. Waste in the form of leftover paints, solvents, cleaning and automotive products, or pool chemicals associated with recreational facilities, could be spilled or dumped into the storm drain system. 81 Attachment 1
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Nutrients from fertilizers and animal waste along walking trails, including nitrogen and phosphorous, can result in excessive or accelerated growth of vegetation or algae, resulting in oxygen depletion a nd additional impaired uses of water. Heavy metals such as lead, cadmium, and copper are the most common metals found in urban storm water runoff. These metals can be toxic to aquatic organisms, and have the potential to contaminate drinking water supplies. Furthermore, impermeable surfaces such as driveways would accumulate deposits of oil, grease, and other vehicle fluids and hydrocarbons (which can be toxic to aquatic organisms at low concentrations), while preventing infiltration of polluted runoff during storm events and facilitating the off-site transport of pollutants.

Residential development on the Project site would incrementally increase the amount of pollutants that could be contained in the first flush of runoff from the area associated with residents and associated uses (car washing, chemical cleaners, pets, trash, etc.). The increase in impervious surface of approximately 8.0 acres would incrementally increase peak flows from the site to offsite drainages. Stormwater runoff from the Project sit e would generally flow to detention basins before being discharged and eventually flowing into Tecolotito Creek, Los Carneros Creek, and the Goleta Slough.

Project features such as landscaping and permeable paving would mitigate the discharge of polluted runoff. In addition, installation of mutt -mitt dispensers and refuse receptacles along walking paths, and in park or open areas would reduce pollution from animal waste. As discussed in the preliminary drainage analysis for the Project, the proposed draina ge infrastructure would provide infiltratable features onsite to remove stormwater pollutants prior to discharge off-site. As downspouts on the proposed buildings convey runoff from rooftops, it would be discharged to landscaped common areas. A portion of runoff on the site would infiltrate the pervious surface in landscaped areas and percolate through the soil, reducing the transport of pollutants off -site. In addition, the proposed use of permeable pavers within the parking areas onsite, would enable infi ltration of surface water during storm events.

Nevertheless, the potential remains for pollutants from operation of the project to be discharged into Tecolotito Creek, Los Carneros Creek, and the Goleta Slough, all of which are listed as impaired waterways based on Central Coast RWQCB criteria. To address the potential for pollutant discharges into these impaired water bodies, the Project would be required to comply with the Post-Construction Stormwater Management Requirements of Order R3 - 2013-0032.

By increasing the amount of impervious surface onsite by approximately 8.0 acres, the Project would be subject to the most stringent criteria under Post - Construction Requirements. Based on the proposed site design, the Project would meet the performance measure for water quality (treatment of stormwater runoff up to the 95th percentile).
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The applicant would be required to apply for a National Pollutant Discharge Elimination System (NPDES) Storm Water Permit from the California RWQCB. Implementation of the NPDES-required Storm Water Permit would ensure that 100 percent of rainfall from the site would flow either into/onto the source control BMPs or onto areas of undisturbed natural vegetation, and would reduce impacts that could occur from pollutants on -site or increase in storm flows on or off -site. Furthermore, the applicant would be required to incorporate BMPs for stormwater quality into the Project’s design, consistent with the requirements of the Central Coast RWQCB’s Post -Construction Requirements.

With compliance with the Post-Construction Requirements, the Project would have a less than significant impact on water quality. (Final EIR, pp. 4.8 -14 through 4.8-15.)
K. LAND USE AND PLANNING

1. Established Communities
Threshold: Would the Project physically divide an established community? Finding: No impact. (Final EIR, p. 4.17-2.)
Explanation: The Project is in an infill area and would not divide an established community.

No impacts would occur. (Final EIR, p. 4.17-2.)

2. Conflicts With Plans
Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Finding: Less than significant. (Final EIR, p. 4.9-3.)
Explanation: General Plan Policies
When the General Plan was adopted in 2006, the City Council considered the land use and zoning designations for all vacant parcels in the City and determined that residential land use/zoning designations with an Affordable Housing Opportunity designation was appropriate for the Project site. The Project site has a General Plan land use designation of Med ium-Density Residential (R-MD). The R-MD land use designation allows a maximum of 20 units per acre and a minimum of 15 units per a cre. The site is also designated as Affordable Housing Opportunity Site within General Plan Housing Element, which allows for a maximum of 25 units per acre and a minimum of 20 units per acre.

The developable lot area is used to calculate residential dens ity. The net developable acreage is defined pursuant to Land Use Element Policy LU 2.2 83 Attachment 1
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as gross acreage minus all acreage containing the following development constraints:
 Environmentally sensitive habitat areas;
 Areas prone to flooding and geologic, slope instability, or other natural hazards;
 Areas with stormwater drainage problems;
 Presence of other significant hazards or hazardous materials;  Protection of significant public and private views;
 Exposure to exterior noise levels that exceed a Community Noi se Exposure Level (CNEL) of 60 dBA (see related NE 1.2);
 Areas with archaeological or cultural resources;
 Deficiencies in the type or level of services necessary for urban development, such as transportation facilities (roadway and pedestrian), sewer and water service, and emergency service response time; and
 Prevailing densities of adjacent developed residential areas.

After removing the development constraints area of 3.31 acres from the

17.36-acre Project site pursuant to LU 2.2, the net developable acr eage is

14.05 acres. With the proposed 332 housing units, the density would be 23.63 units per acre (net developable). At the 25 units per acre maximum specified by the General Plan for this Central Hollister Housing Opportunity Site, the site is restricted to 356 units and, therefore, the Project would not exceed the density limit.

The Project site is located within the City of Goleta’s Central Hollister Residential Development Area. According to the General Plan, the objective of this area is to “promote coordinated planning and development of designated medium-density residential uses in the Central Hollister area in order to create quality, livable environment with appropriate design and amenities for future residents of this new residential neighborhoo d.” The Project involves medium density residential uses consistent with the General Plan vision for the Central Hollister Residential Development Area. This area is close to such amenities as public transit, local and regional circulation routes, major em ployment centers, major shopping areas, restaurants, and other commercial services. The applicant’s objectives for the Project include providing affordable and market -rate housing and complying with the Regional Housing Needs Allocation (RHNA) requirements as well as utilizing the existing public infrastructure (Camino Vista and all utilities) provided by Willow Springs I and II.

Land Use Policies LU 8.5 and LU 8.6 guide development in the Central Hollister area. Consistency with applicable policies in the General Plan for the Central Hollister area and for residential development in general is shown in Table 4.9-1 of the Final EIR.
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The Project also proposes an amendment to the General Plan that would revise Figure 3-5 of the Open Space Element and Figure 4-1 of the Conservation Element to remove an ESHA designation of Coastal Sage Scrub that does not occur on the property. Specifically, although the Project site contains a City of Goleta mapped ESHA, the habitat was not found within the Project boundary or immediately adjacent areas during the biological resources analysis and therefore Project includes an amendment to the General Plan to remove the ESHA designation of Coastal Sage Scrub.

The Project would be consistent with the front and rear yard setbacks, parking design, distance between buildings, building coverage, height limit, open space and landscaping requirements of the City’s zoning regulations. The total amount of required parking for the residential portion of the Project per the zoning code would be 542 spaces with 494 spaces provided. This results in a 48 -space deficit for the residential uses. A Modification from parking requirements will not be required due to State Density Bonus Law parking reduction allowances which reduces the required par king for the residential uses to 455 spaces. As detailed in the Project Description, because the Project will provide approximately 31% of the total units for lower income residents, the Project qualifies for prescriptive parking rights under the State Den sity Bonus Law. Under the State Density Bonus Law, the zoning required parking for the Project is one space for studio units and two spaces for two- and three- bedroom units. By applying these parking rights to the proposed development, the Project would have a total surplus of 39 parking spaces for the residential uses. (Final EIR, pp. 4.9 -3 through 4.9-4.) The Project would be consistent with applicable City land use policies, with incorporation of mitigation included throughout the Final EIR. This impact would be less than significant. (Final EIR, pp. 4.9-3 through 4.9-39.)
Inland Zoning Ordinance
The Project site is zoned Design Residential in the Inland Zoning Ordinance (Article III, Chapter 35 of the Goleta Municipal Code). Pursuant to the zoning regulations (Section 35 -222.1), the purpose of the DR zone district is to “provide standards for traditional multiple residences as well as allowing flexibility and encouraging innovation and diversity in the design of residential developments by allowing a wi de range of densities and housing types while requiring the provision of a substantial amount of open space within new residential developments. The intent is to ensure comprehensively planned, well designed projects.” Permitted uses in this zone include m ulti- family dwelling units, including community apartment projects. Accessory use buildings that are incidental to the permitted uses are also allowed. The Project involves multi -family housing that would be permitted in the DR zone.

The Design Residential zoning designation allows for a maximum of 20 units per acre. As stated in Impact LU-1, the Project site is an Affordable Housing Opportunity Site within the General Plan, which requires a minimum density 85 Attachment 1
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of 20 units/acre and a maximum density of 25 unit s/acre. The Project would have a density of 23.63 units/acre.

Table 4.9 -2 of the Final EIR shows consistency with other DR zone and General Regulation requirements in the City’s zone code, based on the proposed site plan shown on Figure 2-5 in Section 2.0, Project Description of the Final EIR. T he Project would be consistent with the Inland Zoning Ordinance, as adopted by the Goleta Municipal Code. This impact would be less than significant. (Final EIR, pp. 4.9-39 through 4.9-41.) L. MINERAL RESOURCES

1. Regional and Statewide Mineral Resources
Threshold: Would the Project r esult in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? Finding: No impact. (Final EIR, p. 4.17-2.)
Explanation: No known mineral resources are located within the Project site. Therefore, no impacts related to mineral resources would occur. (Final EIR, p. 4.17-2.)

2. Locally-Important Mineral Resource
Threshold: Would the Project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Finding: No impact. (Final EIR, p. 4.17-2.)
Explanation: No known mineral resources are located within the Project site. Therefore, no impacts related to mineral resources would occur. (Final EIR, p. 4.17-2.) M. 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 proj ect in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Finding: Less than significant. (Final EIR, p. 4.10-13.) Explanation: Traffic Noise
The Project would generate an estimated 2,205 average daily vehicle trips to and from the site, including 196 AM peak hour trips and 196 PM peak hour trips. These trips would incrementally increase traffic noise on study area 86 Attachment 1
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roadways. The Project could therefore incrementally increase noise at neighboring uses, particularly uses located along Los Carneros Road, Camino Vista, Los Carneros Way, and U.S. 101.

Estimated peak hour traffic values from the traffic and circulation study were used to model the change in noise levels resulting from increase d traffic on eight traffic intersections. Table 4.10 -7 indicates noise levels at the adjacent existing Willow Springs I and II residences to the south, a location at the Project site nearest Los Carneros Road, UPRR, and U.S. 101, and the location of the no ise measurement performed by Dudek for this EIR. The noise measurement location was modeled to calibrate the model and ensure accuracy. The peak -hour noise measurement taken was 62 dBA Leq, while the Traffic Noise Model (TNM) for the same location (Roadway 3 in Table

4.10-7 of the Final EIR) produced a noise level of 62.8 dBA Leq.

The highest noise level increase due to the Project would be 1.7 dBA under existing plus Project conditions at the existing Willow Springs I and II residential development to the south, which would be primarily affected by increased traffic on Camino Vista. Roadway noise increases associated with new traffic on South Los Carneros Road and U.S. 101 would be less than 1 dBA.

The increase in noise of 1.7 dBA under existing conditions and 1.1 dBA under cumulative conditions would be less than the applicable noise increase threshold of 2.0 dBA. The 0.2 dBA noise increase under existing conditions and 0.1 noise increase under cumulative conditions on the Project site would be less than the applicable noise increase threshold of 1.0 dBA at this location.

Therefore, impacts related to Project -generated traffic noise would be less than significant. (Final EIR, pp. 4.10-13 through 4.10-14.) Operation
The new parking areas on the Project site would bring vehicular activity and associated parking lot noise to the site. These uses would result in increased noise at the industrial uses immediately adjacent to the Project site, and potential on -site noise conflicts between vehicular/parking activit y and proposed residential units. Sources of noise would include general vehicular movement, periodic instantaneous sounds such as car honking and car alarms, and conversations. Table 4.10-8 of the Final EIR shows exterior noise levels typically associated with parking lots. Noise levels at parking areas on -site could reach 72 dBA at 50 feet from the parking areas when street sweeping occurs, and 69 dBA when car alarms and car horns sound. However, these noise sources are sporadic and not usually anticipate d as part of normal parking lot activity in a residential area. Noise levels from normal daily parking lot activity would not exceed 64 dBA.

The Project would require maintenance associated with typical residential uses, such as lawn mowers, leaf blowers, and other landscaping equipment. 87 Attachment 1
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Use of this outdoor equipment would generally be of short duration, and would not occur on a daily basis (landscaping activities would generally occur weekly or bi-weekly), and would occur during the daytime, when residential land uses are the least noise -sensitive; therefore these activities would not contribute substantially to the overall outdoor noise environment and would not be expected to cause noise levels to exceed 65 dBA CNEL.

The Goleta General Plan Noise Element requires that habitable rooms do not exceed interior noise levels of 45 dBA CNEL. Standard construction materials and techniques used for residential developments in Southern California normally result in a minimum exterior-to-interior noise attenuation of 15 dBA with windows open and 20 dBA with windows closed. Factoring in this reduction for parking area noise, interior noise levels for residences would not exceed 45 dBA CNEL as long as the City’s outdoor 65 dBA CNEL standard is not exceeded. Therefore, this impact would be less than significant. (Final EIR, p. 4.10-15.)

2. Vibration
Threshold: Would the Project r esult in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Finding: Less than significant. (Final EIR, p. 4.10-12.) Explanation: Construction activities that would occur at the Project site have the potential to generate low levels of groundborne vibration. Table 4.10-6 of the Final EIR identifies various vibration velocity levels for the type s of construction equipment that would operate at the Project site during construction activities.

Vibration levels could reach approximately 78 VdB at 50 feet from the Project site boundary. The Project would be adjacent to several general industrial uses, which are located approximately 50 feet east of the Project site.

However, these structures do not include uses that would be sensitive to vibration, and vibration levels would not exceed 100 VdB, which is the FTA threshold at which groundborne vibration levels may damage buildings.

The nearest residential uses are located 50 feet south of the Project site. As described above, the FTA groundborne vibration threshold for “infrequent events” (defined as fewer than 30 vibration events of the same kind per day), for residences and buildings where people normally sleep (e.g., the future on- site residences and the residences 50 feet south of the Project site) is 80 VdB.

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. (Final EIR, pp. 4.10-12 through 4.10-13.)
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3. Airport Noise
Threshold: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? Finding: Less than significant. (Final EIR, p. 4.17-2.)) Explanation: Pursuant to the Goleta General Plan, the Project site is located outsi de of the current and the anticipated 2030 60 dBA noise contour of the Santa Barbara Municipal Airport. Therefore, airport noise impacts on the Project, either in the near or foreseeable future, would be less than significant. No private airport impacts on the Project would occur since there are no private airports within the vicinity of the City. (Final EIR, p. 4.17-.2) N. POPULATION AND HOUSING

1. Population Growth
Threshold: Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure? Finding: Less than significant. (Final EIR, p. 5-1.)
Explanation: 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 housi ng (63 units proposed) and 1.36 persons for senior affordable housing (41 units proposed), the Project’s estimated population 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 Pr oject is not expected to induce any additional population growth beyond that associated with the Project itself. (Final EIR, p. 5-1.) Thus, impacts would be less than significant.

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2. Displacement of Housing
Threshold: Would the Project d isplace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
Finding: No impact. (Final EIR, p. 4.17-3.)
Explanation: The Project site is currently undeveloped. The Project would not displace any existing housing units or cause the displacement of any people. Therefore, no impacts related to displacement would occur. (Final EIR, p. 4.17-3.) O. PUBLIC SERVICES

1. Fire Protection
Threshold: Would the Project r esult in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the constructi on of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection?
Finding: Less than significant. (Final EIR, p. 4.11-5.) Explanation: The Project involves construction of ten residential buildings with 332 units, two recreational buildings, a maintenance building, and a maintenance/storage building. Based on the 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 would add an estimated 839 new residents (Department of Finance, 2020). According to the 2019 Statistical Summary, SBCFD had 271 personnel on staff, including 68 firefighters, in 2019. The addition of 839 new residents to the existing population of 32,223 would not result in failure of SBCFD to meet the City’s minimum service ratio of one firefighter per 2,000 reside nts. Because the Project would not exceed the City’s minimum service ratio, there is no evidence that the Project would result in response times in excess of the five minute response time goal.

Fire response times in the City are expected to remain adequat e due to the proximity of Station 14 and other fire stations in the southern coastal portion of Santa Barbara County, as well as utilization of the dynamic response system discussed in Section 4.11.1(a) (SBCFD 2021). In the event that Fire Station 14 would require back-up, other available engine companies would respond via static and/or dynamic deployment. In addition, 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 and is likely to be operational by the time the Project is ready for 90 Attachment 1
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occupancy. This further supports a conclusion that development of the Project would be served efficiently, and fire service would continue to be provided within current standards. The Project would not result in the need of new or expanded facilities to maintain acceptable fire protection service ratios or response times. Therefore, this impact would be less than significant. (Final EIR, p. 4.11-5.)

2. Police Protection
Threshold: Would the Project r esult in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the constru ction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for Sheriff Law Enforcement Services?
Finding: Less than significant. (Final EIR, p. 4.11-6.) Explanation: Based on the City of Goleta General Plan Environmental Impact Report (EIR) prepared in September 2006, the Santa Barbara County Sheriff’s Office recommends that additional deputies be assigned to the City at a range of 1:750 to 1:1,070 new res idents. The Project would generate approximately 839 new residents within the City. Given the recommended service level for the City, the Project may result in the need for one additional officer.

However, the Project would not be expected to result in the need to expand or construct new facilities police facilities that would result in physical impacts on the environment. Therefore, impacts to police protection facilities resulting from the Project would be less than significant. (Final EIR, p. 4.11-

6.)

3. Schools
Threshold: Would the Project r esult in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools?
Finding: Less than significant. (Final EIR, p. 4.11-6.) Explanation: The Project would develop 291 multi-family (228 market-rate and 63 family affordable) and 4 1 senior affordable residential units within the City of Goleta. Using student generation factors of 0.2 students per multi-family unit for GUSD schools, 0.1 students per multi -family unit for GVJHS, and 0.2 students per multi -family unit for DPHS, the Pro ject would generate approximately 145 additional students. The 41 senior residential units are not anticipated to house school -aged children and, thus, would not generate any 91 Attachment 1
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students. Table 4.11 -2 shows projected enrollment increases attributable to the development of the proposed project.

The proposed residential development would add 58 students to GUSD and 87 students to the SBUSD schools. The schools which serve the Project site would be able to accommodate the additional students generated by the Project within their existing capacities. Therefore, the Project would not result in the need for new or expanded public school facilities. Payment of the required school impact fees would ensure that impacts to public schools would remain less than significant. (Final EIR, pp. 4.11-6 through 4.11-7.)

4. Parks
Threshold: Would the Project r esult in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for parks?
Finding: Less than significant. (Final EIR, p. 4.12-3.) Explanation: 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 housing (41 units proposed), the Project would add an estimated 839 new residents (Department of Finance, 2020; Towbe s Group, 2014; Housing Authority of the County of Santa Barbara, 2020). This would represent a 2.6 percent increase in the City’s population, which would result in a corresponding increase in demand for recreational facilities and open space. Absent development of new active park space, the anticipated 839 new residents would reduce the per person park space level in the City to 2.7 acres per 1,000 residents.

For new developments and subdivisions that increase recreational demand, Chapter 16.14 of the Goleta Municipal Code requires a dedication of 0.0128 acres per dwelling unit to neighborhood and community park and recreation purposes. Based on this ratio, the Project must devote 4.25 acres to park and recreation purposes. Alternatively, when filing a tentative map application for approvals, the applicant may choose to pay the City an in-lieu fee.

The Project includes a two -acre public park that would be developed onsite and would include an activity trail, benches, barbecue area, picnic tables bicycle parking, level turf play area, and native landscaping. This park would not create any significant environmental impacts and would partially offset impacts of the population increase generated from the Project. In addition to the proposed park, private recreational facilities would be provided as part of the Project for residents of the development and would consist of a clubhouse and pool for each development area. As these private recreational facilities would not be available for public use, they do not count toward the required 92 Attachment 1
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dedication of park and recreational facilities for neighborhood or community use. However, pursuant to Chapter 16.14 of the Goleta Municipal Code, the provision of private developed parkland within common open space can be credited towards offsetting public parkland impacts in the form of reduced in- lieu fees. The credit toward in-lieu fees may not exceed 50 percent.

The City has an abundance of passive open space opportunities. The Project would increase demands on the capacity of exis ting regional and neighborhood open space areas with passive recreational opportunities, such as the Ellwood/Sperling Preserve and Lake Los Carneros Natural and Historic Preserve which collectively account for 363 acres of the City’s total open space acreage. With the Project’s additional 839 new residents in the City, there would be approximately 11.5 acres of these open space areas per 1,000 residents. Therefore, the City’s supply of such areas is sufficient to meet the demand generated by the Project. Therefore, the Project’s impacts on passive open space recreation would be less than significant.

The increase in demand for active recreational facilities from future residents on the Project site would exacerbate the City’s existing deficiency in parkland with active recreational amenities. Thus, the Project could further contribute to deterioration, or accelerate deterioration, of the City’s existing inventory of active recreational facilities. Nevertheless, Chapter 16.14 of the Goleta Municipal Code would require the applicant to pay in -lieu parks and recreation fees upon the approval of the final subdivision map and development project and prior to the issuance of land use permits, which would be used to fund public park and recreational facilities. The a mount of fee required in lieu of land dedication is based on the fee schedule in effect when the applicant applies for land use clearance for the subdivision. With payment of these fees, the Project would comply with City requirements related to provision of park facilities. The Project would not cause the physical deterioration of existing parks or create the need for new parks or recreational facilities beyond those proposed onsite and currently planned by the City. Therefore, the Project’s impact on recr eational facilities would be less than significant. (Final EIR, pp. 4.12-3 through 4.12-4.)

5. Other Public Facilities
Threshold: Would the Project r esult in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, respo nse times, or other performance objectives for other public facilities?
Finding: Less than significant. (Final EIR, p. 4.11-7.) Explanation: The Project includes 332 new residential units which would generate approximately 839 new residents within the City and could result in increased use of the Goleta Valley Library. The addition of 839 new residents to the 93 Attachment 1
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existing City population of 32,223 (Department of Finance, 2020) would result in a total population of approximately 33,062 persons. This increase is not expected to inhibit the City’s goals for the library described in Section

4.11.2(a). The existing library facilities would be sufficient to accommodate increased use and circulation needs that may result from the Project.

Therefore, this impact would be less than significant. (Final EIR, p. 4.11-7.) P. RECREATION

1. Increased Use
Threshold: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Finding: Less than significant. (Final EIR, p. 4.12-3.) Explanation: 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 un its proposed), and 1.36 persons for senior housing (41 units proposed), the Project would add an estimated 839 new residents (Department of Finance, 2020; Towbes Group, 2014; Housing Authority of the County of Santa Barbara, 2020). This would represent a 2 .6 percent increase in the City’s population, which would result in a corresponding increase in demand for recreational facilities and open space. Absent development of new active park space, the anticipated 839 new residents would reduce the per person pa rk space level in the City to 2.7 acres per 1,000 residents.

For new developments and subdivisions that increase recreational demand, Chapter 16.14 of the Goleta Municipal Code requires a dedication of 0.0128 acres per dwelling unit to neighborhood and com munity park and recreation purposes. Based on this ratio, the Project must devote 4.25 acres to park and recreation purposes. Alternatively, when filing a tentative map application for approvals, the applicant may choose to pay the City an in-lieu fee.

The Project includes a two -acre public park that would be developed onsite and would include an activity trail, benches, barbecue area, picnic tables bicycle parking, level turf play area, and native landscaping. This park would not create any significant env ironmental impacts and would partially offset impacts of the population increase generated from the Project. In addition to the proposed park, private recreational facilities would be provided as part of the Project for residents of the development and would consist of a clubhouse and pool for each development area. As these private recreational facilities would not be available for public use, they do not count toward the required dedication of park and recreational facilities for neighborhood or community use. However, pursuant to Chapter 16.14 of the Goleta Municipal Code, the provision of private developed parkland within common open space can be 94 Attachment 1
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credited towards offsetting public parkland impacts in the form of reduced in- lieu fees. The credit toward in-lieu fees may not exceed 50 percent.

The City has an abundance of passive open space opportunities. The Project would increase demands on the capacity of existing regional and neighborhood open space areas with passive recreational opportunities, such as the Ellwood/Sperling Preserve and Lake Los Carneros Natural and Historic Preserve which collectively account for 363 acres of the City’s total open space acreage. With the Project’s additional 839 new residents in the City, there would be approximately 11.5 acres of these open space areas per 1,000 residents. Therefore, the City’s supply of such areas is sufficient to meet the demand generated by the Project. Therefore, the Project’s impacts on passive open space recreation would be less than significant.

The increase in demand for active recreational facilities from future residents on the Project site would exacerbate the City’s existing deficiency in parkland with active recreational amenities. Thus, the Project could further contribute to deterioration, or accelerate deterioration, of the City’s existing inventory of active recreational facilities. Nevertheless, Chapter 16.14 of the Goleta Municipal Code would require the applicant to pay in -lieu parks and recreation fees upon the approval of the final s ubdivision map and development project and prior to the issuance of land use permits, which would be used to fund public park and recreational facilities. The amount of fee required in lieu of land dedication is based on the fee schedule in effect when the applicant applies for land use clearance for the subdivision. With payment of these fees, the Project would comply with City requirements related to provision of park facilities. The Project would not cause the physical deterioration of existing parks or create the need for new parks or recreational facilities beyond those proposed onsite and currently planned by the City. Therefore, the Project’s impact on recreational facilities would be less than significant. (Final EIR, pp. 4.12-3 through 4.12-4.)

2. Construction and Expansion
Threshold: Does the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Finding: Less than significant. (Final EIR, p. 4.12-3.) Explanation: 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 housing (41 units proposed), the Project would add an estimated 839 new residents (Department of Finance, 2020; Towbes Group, 2014; Housing Authority of the County of Santa Barbara, 2020). This would represent a 2.6 percent increase in the City’s population, which would result in a correspon ding increase in demand for recreational facilities and open space. Absent development of new active park 95 Attachment 1
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space, the anticipated 839 new residents would reduce the per person park space level in the City to 2.7 acres per 1,000 residents.

For new developmen ts and subdivisions that increase recreational demand, Chapter 16.14 of the Goleta Municipal Code requires a dedication of 0.0128 acres per dwelling unit to neighborhood and community park and recreation purposes. Based on this ratio, the Project must devo te 4.25 acres to park and recreation purposes. Alternatively, when filing a tentative map application for approvals, the applicant may choose to pay the City an in-lieu fee.

The Project includes a two -acre public park that would be developed onsite and wou ld include an activity trail, benches, barbecue area, picnic tables bicycle parking, level turf play area, and native landscaping. This park would not create any significant environmental impacts and would partially offset impacts of the population increase generated from the Project. In addition to the proposed park, private recreational facilities would be provided as part of the Project for residents of the development and would consist of a clubhouse and pool for each development area. As these private recreational facilities would not be available for public use, they do not count toward the required dedication of park and recreational facilities for neighborhood or community use. However, pursuant to Chapter 16.14 of the Goleta Municipal Code, the provision of private developed parkland within common open space can be credited towards offsetting public parkland impacts in the form of reduced in- lieu fees. The credit toward in-lieu fees may not exceed 50 percent.

The City has an abundance of passive ope n space opportunities. The Project would increase demands on the capacity of existing regional and neighborhood open space areas with passive recreational opportunities, such as the Ellwood/Sperling Preserve and Lake Los Carneros Natural and Historic Preserve which collectively account for 363 acres of the City’s total open space acreage. With the Project’s additional 839 new residents in the City, there would be approximately 11.5 acres of these open space areas per 1,000 residents. Therefore, the City’s supply of such areas is sufficient to meet the demand generated by the Project. Therefore, the Project’s impacts on passive open space recreation would be less than significant.

The increase in demand for active recreational facilities from future residents on the Project site would exacerbate the City’s existing deficiency in parkland with active recreational amenities. Thus, the Project could further contribute to deterioration, or accelerate deterioration, of the City’s existing inventory of active recrea tional facilities. Nevertheless, Chapter 16.14 of the Goleta Municipal Code would require the applicant to pay in -lieu parks and recreation fees upon the approval of the final subdivision map and development project and prior to the issuance of land use pe rmits, which would be used to fund public park and recreational facilities. The amount of fee required in lieu of land dedication is based on the fee schedule in effect when the applicant applies for land use clearance for the subdivision. With payment of these fees, the Project would comply with City requirements 96 Attachment 1
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related to provision of park facilities. The Project would not cause the physical deterioration of existing parks or create the need for new parks or recreational facilities beyond those proposed onsite and currently planned by the City. Therefore, the Project’s impact on recreational facilities would be less than significant. (Final EIR, pp. 4.12-3 through 4.12-4.) Q. TRANSPORTATION / TRAFFIC

1. Plans, Policies, and Ordinances
Threshold: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Finding: Less than significant. (Final EIR, p. 4.13-6.) Explanation: The Project would generate an estimated 839 residents, which would increase demand for alternative transportation facilities.

Transit. Census data collected in 2010 show that 5% of commuters in the Goleta area utilize public transportation. Therefore, the Project would result in approximately 11 new transit users during the peak periods (7:00 to 9:00 A.M. and 4:00 to 6:00 P.M.). There are currently 22 busses that serve the site during the weekday peak hour periods; thus, the Project would add less than 1 rider per bus. The new bus riders generated by the Project would not measurably impact the operations of the transit routes that serve the site.

Therefore, impacts related to transit would be less than significant.

Bicycling. The Project would result in approximately 14 new bicycle riders that would commute during the peak hour periods. The Project would facilitate bicycle riding among site residents by providing a bicycle parking area at each residential building and the recreational building with a total of approximately 120 bicycle parking spaces. The increase in bicycle ridership generated by the Project would not measurably impact the operations of the bicycle facilities in the vicinity of the Project site. Therefore, impacts related to bicycling and bicycling infrastructure would be less than significant. (Final EIR, pp. 4.13-6 through 4.13-7.)

2. VMT
Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines sections 15064.3, subdivision (b)?
Finding: Less than significant. (Final EIR, p. 4.13-7.) Explanation: The Project would generate 12,809 VMT daily and 4,675,285 VMT annually.

This equates to a per capita daily VMT of 15.27. The City’s Guidelines for the Implementation of Vehicle Miles Traveled, including Vehicle Miles Traveled Thresholds of Significance (Resolution 20-44) includes screening 97 Attachment 1
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criteria for land use projects that are presumed to have a less than significant impact on VMT. As discussed in the Guidelines for the Implementation of Vehicle Miles Traveled, including Vehicle Miles Traveled Thresholds of Significance, affordable housing in infill locations generally improves the City’s jobs -housing balance, shortening commutes and reducing VMT.

Affordable housing has a higher composition of non -workforce residents, which generates fewer trips. As such, the City has adopted the following affordable housing VMT screening criteria threshold:
 Housing projects with a minimum of 20% low and/or very low affordable deed-restricted housing units are presumed to be less than significant
The proposed Project includ es 41 affordable senior units and 63 affordable apartment units, which is 31.3% of the total apartment units. Therefore, the Project meets the City’s VMT screening criteria threshold for affordable housing and VMT impacts would be less than significant. In addition, the Project’s per capita VMT is 15.27, which is 22.9 percent below the City’s average per capita VMT of 19.8 for residential uses. For these reasons, potential VMT impacts would be less than significant. (Final EIR, p. 4.13-7.)

3. Design Hazards
Threshold: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Finding: No impact. (Final EIR, p. 4.17-3.)
Explanation: The Project would be required to be designed in accordance with applicable Santa Barbara County Fire Department standards, including those that address minimum driveway width, roadway naming, building height, signage and addressing, fire hydrants, fire sprinklers, an d emergency access.

Compliance with applicable development standards would ensure that the Project would not result in significance design hazards, and that it would have no impact on the provision of emergency access to either the project site or surrounding development. (Final EIR, p. 4.17-3.)

4. Emergency Access
Threshold: Would the Project result in inadequate emergency access? Finding: No impact. (Final EIR, p. 4.17-3.)
Explanation: The Project would be required to be designed in accordance with appl icable Santa Barbara County Fire Department standards, including those that address minimum driveway width, roadway naming, building height, signage and addressing, fire hydrants, fire sprinklers, and emergency access. 98 Attachment 1
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Compliance with applicable developmen t standards would ensure that the Project would not result in significance design hazards, and that it would have no impact on the provision of emergency access to either the project site or surrounding development. (Final EIR, p. 4.17-3.)
R. UTILITIES AND SERVICE SYSTEMS

1. Wastewater Treatment Requirements
Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications f acilities, the construction or relocation of which could cause significant environmental effects? Finding: No impact. (Final EIR, pp. 4.14-9 through 4.14-10.) Explanation: Water Supply
At present, the 17.36-gross acre Project site is vacant and generates no water demand. However, Willow Springs I, Willow Springs II, and the Project are entitled to a combined 100.89 AFY in accordance with the Court judgement described above. Water service to the Project site would be provided by the GWD.

In July 2015, MAC Design Associates prepared an Annual Demand Water Report for Willow Springs I, Willow Springs II, and the Project, as proposed at that time. The calculations for water usage were derived from the actual water use data from 2007 to 2015 for Willow Springs I and Willow Springs II, provided by GWD. For the most current Project domestic water use, a 24 month period (January 2012 through December 2013) was used as the base period. The water me ters were categorized as either domestic, landscape, or commercial meters. As domestic water use varies substantially based on the type of unit, the domestic meters were further separated by the following unit types: 1BR/1BA, 2BR/1BA, 2BR/2BA, and 3BR/2BA. To determine the average water consumption rate by unit type, the water usage for each month of the base period was totaled and then converted to a monthly average based on the data for the 24 month period. The monthly average was then converted to AFY per month. The total AFY was divided by the number of a single unit type. This method was then replicated for all unit types in the development.

There was insufficient water use history to utilize actual figures for the Project. Therefore, the actual water u sage for Willow Springs I was utilized to project water usage at the Project site. The Project units are smaller than Willow Springs I, so actual water usage would be expected to be lower. The GWD has reviewed and approved the MAC Design Associates water demand for the Project (Appendix J). The Project’s estimated water service demand has since been updated utilizing the rates in the 2015 Annual Water Demand Report, but to account for a reduction in the proposed total unit count since 2015. The proportion ( i.e., percentage) of each unit type for the overall 99 Attachment 1
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reduced unit count is the same as for the previously proposed project. The proposed studios are included with the 1BR/1BA unit types.

Based on the water use study, the Project’s domestic water demand, landscaping water demand, and commercial water demand are estimated at

31.6 AFY, 6.2 AFY, and 1.6 AFY, respectively. The calculations for Project- generated water demand are shown in Table 4.14 -2. The total water demand generated by the Project would be 39.4 AFY (not accounting for recycling and other water savings). This represents approximately 0.2 percent of the 16,737 AFY of water available from GWD (not accounting for unused recycled water). As the Project is part of the Willow Springs project (Willow Springs I, Willow Springs II, and Heritage Ridge [formerly North Willow Springs]), it is considered an existing customer of GWD and would meet the criteria for an exemption as outlined in Resolution No. 2014-32.

Water for domestic uses and landscaping on the Project site could potentially be supplied by different sources. However, the recycled water system is not in the vicinity of the Project site. The nearest water main for recycled water, located at the corner of Storke Road and Hollister Avenue approximat ely 1 mile to the west and south of the site, will extend to Cortona Drive and Hollister Avenue in the future, but will remain out of vicinity for use at the Project site (Jim Heaton, Senior Water Resource Analyst, Goleta Water District, personal communication, June 4, 2015).

The 39.4 AFY of water demand generated by the Project represents 11.4 percent of GWD’s projected surplus of 346 AFY in water supply above current demand levels (GWD UWMP, 2017). Accordingly, the GWD currently has sufficient water suppl y to provide potable water to the Project and Project impacts to water supply would be less than significant. Based on the total allocation of 100.89 AFY for Willow Springs I, Willow Springs II, and the Project, and water use by the Willow Springs properti es of 55.983 AFY, there is 44.907 AFY available to serve the Project. Therefore, the Projects use of 39.4 AFY would be within the allocated water supply.

In accordance with GWD’s Water Conservation Plan from 2010, the Project also would be required to inc orporate feasible Best Management Practices (BMPs) into its water system design. Such practices include the use of water conserving fixtures and water efficient landscape and irrigation.

Impacts would be less than significant without mitigation since the P roject’s water demand is within the current GWD surplus. Nevertheless, the City Council imposes the following conditions of approval to further reduce impacts on water supplies.
 Outdoor Water Conservation. Minimize outdoor water use through the following:
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a. Use of native and/or drought tolerant species in the final landscaping;
b. Installation of drip irrigation or other water -conserving irrigation;
c. Grouping of plant material by water needs;
d. Limiting turf to less than 20% of the total landscaped area if proposed under the final landscape plan or use of artificial turf in place of living grass (this may exceed the 20% maximum); e. No turf is allowed on slopes of over 4%;
f. Use of extensive mulching (2" minimum) in all landscaped areas to improve the water holding capa city of the soil by reducing evaporation and soil compaction;
g. Installation of soil moisture sensing devices to prevent unnecessary irrigation;
h. Use of only recycled water for landscape irrigation if the Project site is connected to a recycled water line;
i. Use of plant materials that can withstand high salinity levels, if recycled water is used for irrigation; and
j. Use of plant materials that are compatible with the Goleta climate pursuant to Sunset Western Garden Book’s Zone 24, published by Sunset Books, Inc ., Revised and Updated 2001 edition.
 Indoor Water Conservation. Minimize indoor water use through the following:
a. Insulation of all hot water lines;
b. Installation of re -circulating, point -of-use, or on -demand water heaters;
c. Prohibition of self -regenerating w ater softening in all structures;
d. Use of lavatories and drinking fountains with self -closing valves; and
e. Installation of water sense specification toilets in each unit. (Final EIR, pp. 4.14-10 through 4.14-12.)
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Wastewater
Future Project site residents would generate wastewater that would feed into GWSD’s conveyance system and ultimately flow to GSD’s treatment plant.

As discussed in Section 4.14.1(b), GWSD owns 40.78 percent of the capacity rights at the GSD treatment plant, which gives GWSD an allotmen t of 3.11 mgd of treatment capacity. GWSD currently collects approximately 1.8 mgd of sewage. However, prior to the start of the COVID -19 pandemic in early 2020, GWSD was generating approximately 2.1 mgd of sewage, leaving a remaining allocated capacity of approximately 1 mgd pursuant to its contract with GSD. The pre -COVID-19 wastewater generation rate is used in this analysis as it represents a more conservative analysis and may more closely reflect the post -pandemic conditions. Applying GWSD’s wastewat er generation rate of 184 gpd per equivalent residential unit (ERU), the proposed 332 housing units would generate 61,088 gpd of wastewater. Project - generated wastewater represents approximately 1.96 percent of the GWSD’s allocated capacity of 3.11 mgd. As shown in Table 4.14 -3, the combination of existing wastewater flow in GWSD’s service area and Project -generated flow would represent 69.5 percent of total allocated capacity. Thus, GWSD’s treatment plant would have sufficient capacity to treat Project -generated wastewater. The Project would have a less than significant impact with respect to wastewater service.

In order for the Project to connect to the wastewater system, payment of fees to reserve capacity and contribute to costs of plant upgrades would b e required. A Sewer Service Connection Permit from the GWSD also would be necessary to ensure that the District’s excess capacity can be utilized to serve this Project (Nation, 2015). The Project would be required to obtain a District Sewer Service Connect ion Permit from GWSD and pay applicable fees.

Impacts would be less than significant, and no mitigation is required. (Final EIR, pp. 4.14-12 through 4.14-13.)
Electric Power, Natural Gas, and Telecommunications Facilities Electric power, natural gas, and telecommunications would be provided to the Project site through the extension of existing off -site electric power, natural gas, and telecommunications facilities. The Project would not require or result in the construction of new facilities or expansion of existing facilities beyond those designed specifically for the Project. The physical impacts of on -site development, which includes electric power, natural gas, and telecommunications facilities, are evaluated throughout this EIR for each issue area that may be affected by development of the project site. (Final EIR, p. 4.14-9.) The Project would have no impact.

2. Water Supplies
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Threshold: Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future deve lopment during normal, dry and multiple dry years?
Finding: Less than significant. (Final EIR, p. 4.14-10.) Explanation: At present, the 17.36-gross acre Project site is vacant and generates no water demand. However, Willow Springs I, Willow Springs II, a nd the Project are entitled to a combined 100.89 AFY in accordance with the Court judgement described above. Water service to the Project site would be provided by the GWD.

In July 2015, MAC Design Associates prepared an Annual Demand Water Report for Willow Springs I, Willow Springs II, and the Project, as proposed at that time. The calculations for water usage were derived from the actual water use data from 2007 to 2015 for Willow Springs I and Willow Springs II, provided by GWD. For the most current Pr oject domestic water use, a 24 month period (January 2012 through December 2013) was used as the base period. The water meters were categorized as either domestic, landscape, or commercial meters. As domestic water use varies substantially based on the type of unit, the domestic meters were further separated by the following unit types: 1BR/1BA, 2BR/1BA, 2BR/2BA, and 3BR/2BA. To determine the average water consumption rate by unit type, the water usage for each month of the base period was totaled and then converted to a monthly average based on the data for the 24 month period. The monthly average was then converted to AFY per month. The total AFY was divided by the number of a single unit type. This method was then replicated for all unit types in the deve lopment.

There was insufficient water use history to utilize actual figures for the Project. Therefore, the actual water usage for Willow Springs I was utilized to project water usage at the Project site. The Project units are smaller than Willow Springs I, so actual water usage would be expected to be lower. The GWD has reviewed and approved the MAC Design Associates water demand for the Project (Appendix J). The Project’s estimated water service demand has since been updated utilizing the rates in the 2015 Annual Water Demand Report, but to account for a reduction in the proposed total unit count since 2015. The proportion (i.e., percentage) of each unit type for the overall reduced unit count is the same as for the previously proposed project. The proposed studios are included with the 1BR/1BA unit types.

Based on the water use study, the Project’s domestic water demand, landscaping water demand, and commercial water demand are estimated at

31.6 AFY, 6.2 AFY, and 1.6 AFY, respectively. The calculations for Project- generated water demand are shown in Table 4.14 -2. The total water demand generated by the Project would be 39.4 AFY (not accounting for recycling and other water savings). This represents approximately 0.2 percent of the 16,737 AFY of water avail able from GWD (not accounting for unused recycled water). As the Project is part of the Willow Springs project (Willow Springs I, Willow Springs II, and Heritage Ridge [formerly North Willow 103
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Springs]), it is considered an existing customer of GWD and would meet the criteria for an exemption as outlined in Resolution No. 2014-32.

Water for domestic uses and landscaping on the Project site could potentially be supplied by different sources. However, the recycled water system is not in the vicinity of the Project site. The nearest water main for recycled water, located at the corner of Storke Road and Hollister Avenue approximately 1 mile to the west and south of the site, will extend to Cortona Drive and Hollister Avenue in the future, but will remain out of vicinity for use at the Project site (Jim Heaton, Senior Water Resource Analyst, Goleta Water District, personal communication, June 4, 2015).

The 39.4 AFY of water demand generated by the Project represents 11.4 percent of GWD’s projected surplus of 346 A FY in water supply above current demand levels (GWD UWMP, 2017). Accordingly, the GWD currently has sufficient water supply to provide potable water to the Project and Project impacts to water supply would be less than significant. Based on the total allocation of 100.89 AFY for Willow Springs I, Willow Springs II, and the Project, and water use by the Willow Springs properties of 55.983 AFY, there is 44.907 AFY available to serve the Project. Therefore, the Projects use of 39.4 AFY would be within the allocated water supply.

In accordance with GWD’s Water Conservation Plan from 2010, the Project also would be required to incorporate feasible Best Management Practices (BMPs) into its water system design. Such practices include the use of water conserving fixtures and water efficient landscape and irrigation.

Impacts would be less than significant without mitigation since the Project’s water demand is within the current GWD surplus. Nevertheless, the City Council imposes the following conditions of approval t o further reduce impacts on water supplies.
 Outdoor Water Conservation. Minimize outdoor water use through the following:
a. Use of native and/or drought tolerant species in the final landscaping;
b. Installation of drip irrigation or other water -conserving irrigation;
c. Grouping of plant material by water needs;
d. Limiting turf to less than 20% of the total landscaped area if proposed under the final landscape plan or use of artificial turf in place of living grass (this may exceed the 20% maximum); e. No turf is allowed on slopes of over 4%;
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f. Use of extensive mulching (2" minimum) in all landscaped areas to improve the water holding capacity of the soil by reducing evaporation and soil compaction;
g. Installation of soil moisture sensing devices to prevent unnecessary irrigation;
h. Use of only recycled water for landscape irrigation if the Project site is connected to a recycled water line;
i. Use of plant materials that can withstand high salinity levels, if recycled water is used for irrigation; and
j. Use of plant material s that are compatible with the Goleta climate pursuant to Sunset Western Garden Book’s Zone 24, published by Sunset Books, Inc., Revised and Updated 2001 edition.
 Indoor Water Conservation. Minimize indoor water use through the following:
a. Insulation of all hot water lines;
b. Installation of re -circulating, point -of-use, or on -demand water heaters;
c. Prohibition of self -regenerating water softening in all structures;
d. Use of lavatories and drinking fountains with self -closing valves; and
e. Installation of water sense specification toilets in each unit. (Final EIR, pp. 4.14-10 through 4.14-12.)

3. Wastewater Capacity
Threshold: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate ca pacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Finding: Less than significant. (Final EIR, p. 4.14-12.) Explanation: Future Project site residents would generate wastewater that would feed into GWSD’s conveyance system and ultimately flow to GSD’s treatment plant.

As discussed in Section 4.14.1(b), GWSD owns 40.78 percent of the capacity rights at the GSD treatment plant , which gives GWSD an allotment of 3.11 105
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mgd of treatment capacity. GWSD currently collects approximately 1.8 mgd of sewage. However, prior to the start of the COVID -19 pandemic in early 2020, GWSD was generating approximately 2.1 mgd of sewage, leaving a remaining allocated capacity of approximately 1 mgd pursuant to its contract with GSD. The pre -COVID-19 wastewater generation rate is used in this analysis as it represents a more conservative analysis and may more closely reflect the post -pandemic conditi ons. Applying GWSD’s wastewater generation rate of 184 gpd per equivalent residential unit (ERU), the proposed 332 housing units would generate 61,088 gpd of wastewater. Project - generated wastewater represents approximately 1.96 percent of the GWSD’s allocated capacity of 3.11 mgd. As shown in Table 4.14 -3, the combination of existing wastewater flow in GWSD’s service area and Project -generated flow would represent 69.5 percent of total allocated capacity. Thus, GWSD’s treatment plant would have sufficient capacity to treat Project -generated wastewater. The Project would have a less than significant impact with respect to wastewater service.

In order for the Project to connect to the wastewater system, payment of fees to reserve capacity and contribute to c osts of plant upgrades would be required. A Sewer Service Connection Permit from the GWSD also would be necessary to ensure that the District’s excess capacity can be utilized to serve this Project (Nation, 2015). The Project would be required to obtain a District Sewer Service Connection Permit from GWSD and pay applicable fees.

Impacts would be less than significant, and no mitigation is required. (Final EIR, pp. 4.14-12 through 4.14-13.)

4. Solid Waste
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: Less than significant. (Final EIR, p. 4.14-13.) Explanation: Construction
During the construction phase of development, a project can generate solid waste from the demolition of existing structures and the erection of new buildings. The Project would not involve demolition, but construction of new residential structures would generate solid waste. The proposed structures on- site, including 332 residential units in ten buildings, two recreational facilities, a maintenance building, and a maintenance/storage building, would total 277,919 gross square feet. According to the U.S. EPA report Characterization of Building-Related Construction and Demolition Debris in the United States, residential construction has a solid waste generation factor of 4.38 pounds per square foot (U.S. EPA, 1998). Based on this estimate, Project construction would generate a total of about 1.22 million pounds of debris (approximately 609 tons). The construction period (excluding pre - 106
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construction soil hauling, which is not expected to generate substantial waste) is estimated at 30 months. Therefore, construction activity would result in an average waste generation rate of approximately 244 tons/year.

As described under the Regulatory Framework, the Goleta Municipal Code was updated in March 2013 to increase the required diversion rate for construction and demol ition waste. Pursuant to Chapter 8.10 of the Goleta Municipal Code, any project involving the construction of new structures must divert from disposal at least 65 percent of all construction and demolition waste by weight. To attain this diversion rate, the applicant would be required to submit a Pre -Construction Waste Reduction and Recycling Plan as part of the application for a building permit. By complying with the City’s requirement for diversion of solid waste, construction of the Project would generate an estimated 213 tons of non-recyclable waste during the 30- month construction period, or approximately 85 tons/year. This amount of non-recyclable construction waste would not exceed the City’s Project - specific threshold of 196 tons per year. Therefore, with compliance with the City’s construction waste reduction and recycling requirements, impacts would be less than significant. (Final EIR, pp. 4.14-13 through 4.14-14.)

5. Solid Waste Laws
Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Less than significant. (Final EIR, p. 4.14-13.) Explanation: Construction
During the construction phase of development, a project can generate solid waste from the demolition of existing structure s and the erection of new buildings. The Project would not involve demolition, but construction of new residential structures would generate solid waste. The proposed structures on- site, including 332 residential units in ten buildings, two recreational facilities, a maintenance building, and a maintenance/storage building, would total 277,919 gross square feet. According to the U.S. EPA report Characterization of Building-Related Construction and Demolition Debris in the United States, residential construction has a solid waste generation factor of 4.38 pounds per square foot (U.S. EPA, 1998). Based on this estimate, Project construction would generate a total of about 1.22 million pounds of debris (approximately 609 tons). The construction period (excludin g pre - construction soil hauling, which is not expected to generate substantial waste) is estimated at 30 months. Therefore, construction activity would result in an average waste generation rate of approximately 244 tons/year.

As described under the Regula tory Framework, the Goleta Municipal Code was updated in March 2013 to increase the required diversion rate for construction and demolition waste. Pursuant to Chapter 8.10 of the Goleta 107
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Municipal Code, any project involving the construction of new structur es must divert from disposal at least 65 percent of all construction and demolition waste by weight. To attain this diversion rate, the applicant would be required to submit a Pre -Construction Waste Reduction and Recycling Plan as part of the application f or a building permit. By complying with the City’s requirement for diversion of solid waste, construction of the Project would generate an estimated 213 tons of non-recyclable waste during the 30- month construction period, or approximately 85 tons/year. Th is amount of non-recyclable construction waste would not exceed the City’s Project - specific threshold of 196 tons per year. Therefore, with compliance with the City’s construction waste reduction and recycling requirements, impacts would be less than significant. (Final EIR, pp. 4.14-13 through 4.14-14.) S. WILDFIRE

1. Response Plans
Threshold: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
Finding: Less than significant. (Final EIR, p. 4.16-3.) Explanation: Given the Project’s location within an urbanized area and outside of high fire hazard areas, the tsunami run -up area, and other flood ha zard areas, the Project site is not within any adopted emergency response or evacuation plan area. The Project also would be required to be designed in accordance with applicable Santa Barbara County Fire Department standards, including those that address minimum driveway width, roadway naming, building height, signage and addressing, fire hydrants, fire sprinklers, and emergency access.

Compliance with applicable development standards would ensure that the Project would not impair provision of access to ei ther the Project site or surrounding development in the event of an emergency or evacuation.

Therefore, this impact would be less than significant. (Final EIR, p. 4.16-3.)

2. Pollutant Concentrations
Threshold: Due to slope, prevailing winds, and other fact ors, would the Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of wildfire? Finding: Less than significant. (Final EIR, p. 4.16-3.) Explanation: Currently, there is no structural development on the Project site. Construction equipment and containers as well as a substantial amount of stockpiled soil are stored onsite. The topography of the Project site is relatively flat to gently sloping with the exception of th e moderately steep slopes that define the boundary of the stockpile soils. A sparse to moderate growth of weeds and 108
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